I. Name and Information

Scott Dodson

6810 High Country Trail

Arlington, Texas 76016

214-683-1948

scott.dodson@tx.rr.com

Owner, Vid Flight

(a subsidiary of Live It Again Productions, LLC)

All mentions of my name "Scott Dodson" are inclusive of "Vid Flight"

II. The Specific Sections of Title 14 of the Code of

Federal Regulations From Which Scott Dodson Requests

Exemption are:

14 CFR 21;§14 C.F.R. 45.23(b);§14 CFR 61.113 (a) & (b); 14

C.F.R. 91, et seq.;§14 CFR 407 (a) (1);§14 CFR 409 (a) (2);

and, 14 CFR 417 (a) & (b).

III. The Extent of relief Scott Dodson seeks and the Reason He Seeks Such 

Relief:

I, Scott Dodson, submit this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating 

to prevent me, Scott Dodson, contemplated commercial cinematic, academic and

other flight operations within the national airspace system. The Reform Act in 

Section 332 provides for such integration of civil unmanned aircraft systems into 

our national airspace system as it is in the public’s interest to do so. 

My, Scott Dodson's, ultra light weight UAS meets the definition of “small

unmanned aircraft” as defined in Section 331 and therefore the integration of my 

ultra light weight UAS is expressly contemplated by the Reform Act. I would like 

to operate my ultra light weight UAS prior to the time period by which the

Reform Act requires the FAA to promulgate rules governing such craft. Thereby, 

providing direct experience and valuable information for formal regulation that 

can be administered uniformly to all UAS aerial video and photography. 

The Reform Act guides the Secretary in determining the types of UAS's that may

operate safely in our national airspace system. Considerations include: The 

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will 

be operated near airports or heavily populated areas; and, Whether the

UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items 

reflect in favor of an exemption for me, Scott Dodson. 

My UAS utilizes four (4) counter-rotating propellers for balance, control and 

stability. My UAS is equipped with GPS and auto return safety technology.

Weighing less than five (5) pounds (far below the maximum 55 pound limit); 

including camera with gimbal.
I, Scott Dodson, consider safety as foremost with each flight. My small, 

unmanned aircraft is designed to hover in place via GPS and operate in less than 

a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly 

in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode 

that allows my UAS to hover in place when radio controls are released. With 

three modes to choose from, I utilize the GPS Mode for aerial 

videography/photography. This is the safest, most reliable and stable mode to 

prevent accident and hazard. When pilot communication is lost UAS is designed 

slowly descend to point of take off. I do not operate my UAS near airports, 

Hospitals nor Police heliports, and do not operate near areas where general

public is within fifty to one hundred (50-100) yards depending on location,

conditions and weather. I am constantly on alert for any manned aircraft 

(Police/Medical helicopters, etc.) and prepared to land/abort immediately to the 

nearest and safest ground point should a manned aircraft approach my location

or I suspect manned aircraft may approach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within 

my line of sight of me, as the remote control pilot, or with my licensed PIC. 

Utilizing battery power rather than combustible fuels, flights generally last 

between three (3) to twelve (12) minutes, with an altitude under two hundred 

(200) feet. I, Scott Dodson, utilize a fresh fully charged battery with each flight as 

a safety precaution; full flight time limit for each battery is twelve (12) to twentytwo (22) minutes as tested. I do not operate my UAS at or below manufacture 

recommend minimum charge levels for operation; preferring to remain well within 

a safe operating range to insure adequate communication between radio control 

and UAS to eliminate potential for crash, loss of control or hazard. Reserve

batteries are at hand with each exercise to insure replacement for sufficient safe 

level of operation. I do not believe in taking risk that may cause a crash, that 

could create hazard to the public/property/manned aircraft, and have no desire to 

lose an investment. I have clocked numerous practice flights in remote areas as 

a hobbyist simulating flights for future commercial use to gain familiarization with 

the characteristics of this specific UAS's performance under different temperature 

and weather conditions. I also practice computerized simulated flights to maintain 

adequate skills and response reflex time, all for the sake of safety.

I, Scott Dodson, am extremely cautious when operating of my UAS/ultra light 

weight unmanned aircraft and will not “create a hazard to users of the national 

airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and

weight of my UAS it falls well within Congress’s contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to integrate UAS's 

into the national airspace system. Scott Dodson’s UAS, used in hobby flight, has 

a demonstrable safety record and does not pose any threat to the general public 

or national security.
IV. How Scott Dodson’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness and for real estate marketing has 

been around for a long time through manned fixed wing aircraft and helicopters. 

For small budget real estate companies and average homeowners the expense 

of such aerial videography is cost prohibitive. The same is also true for 

construction sites, land surveying, and even location historical documentation. 

Only large companies and high end Realtors or luxury homeowners can afford to 

absorb such expense. Depriving non-luxury homeowners and lower budget 

Realtors and other such companies with needs from a valuable marketing and 

analysis tool. Manned aircraft pose a threat to the public through potential 

catastrophic crash in the North Texas community, each resulting in loss of life, 

and with combustible fuel that exploded and burned on impact. Police, TV and 

radio helicopters have made emergency hard landings within city limits. 

My, Scott Dodson’s, UAS pose no such threat since size and lack of combustible 

fuel alleviates any potential threat to the public. Congress has already proclaimed 

that it is in the public’s interest to integrate commercially flown UAS's into the

national airspace system, hence the passing of the Reform Act. Granting my, 

Scott Dodson’s, exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits in and around the North 

Texas area. My ultra lightweight UAS is battery powered and creates no

emissions that can harm the environment. The consequence of my ultra light 

weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; 

which are heavy, contain combustible fuel and can cause catastrophic

devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by 

permitting aerial video/photo capture through my battery operated ultra light 

weight UAS's. Permitting me, Scott Dodson, to immediately fly within national air 

space furthers economic growth. Granting my exemption request substantially 

furthers the economic impact for the North Texas community for companies 

looking to relocate or build in the North Texas area as well as individuals looking 

to relocate for career advancement through academic and geographical 

awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Scott Dodson’s Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal 

To Existing Rule:

My, Scott Dodson’s, exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting me, Scott Dodson, to log more flight 

time in FAA controlled airspace, with communication with the FAA, will allow me 

to contribute to the innovation and implementation of new and novel, as of yet 

undiscovered safety protocols for Realtors, construction sites, land surveying, 

location historical documentation, and infrastructure inspections that can be 
embraced by the NAR, AAR, and TAR for development in cooperation with the 

FAA. In addition I, Scott Dodson, submit the following representations of

enhancements to current aerial videography and photography for real estate, 

construction sites, land surveying, location historical documentation, 

infrastructure inspections, athletic field marketing and maintenance:

My UAS, a Phantom 2 manufactured by DJI weighs less than 5 pounds complete 

with a small ultra light weight high quality GoPro 3+ Black camera;

§I only operate my UAS below 200 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only 

operates for 12-16 minutes per flight;

§I land my UAS prior to manufacturer recommended minimum level of battery 

power;

§I pilot my UAS through remote control only by line of sight;

§My UAS has GPS a flight safety feature whereby it hovers and then slowly lands 

if communication with the remote control pilot is lost;

§I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols;

§I only operate in reasonably safe environment that are strictly controlled, are 

away from power lines, elevated lights, airports and actively populated areas;

§I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance;

§I always obtains all necessary permissions prior to operation; and,

§I have procedures in place to abort flights in the event of safety breaches or 

potential danger.

My, Scott Dodson’s, safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of 

commercial UAS into our national airspace system, helicopters are the primary 

means of aerial video and photography for community awareness and 

application. While the safety record of such helicopters is remarkably astounding, 

there have been local incidents involving loss of life as well as extensive property 

damage; it is far safer to operate a battery powered ultra light weight UAS.

§First, the potential loss of life is diminished because UAS's carry no people on 

board and I only operate my UAS in specific areas away from mass populations. 

§Second, there is no fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished.

§Third, the small size and extreme maneuverability of my UAS allow me to 

remotely pilot away from and avoid hazards quickly and safely.

§Lastly, given its small size and weight, even when close enough to capture 

amazing images, my UAS need not be so close to the objects they are focused 

on through the technology and use of post editing software allowing pan and 

zoom. Accordingly, my UAS has been experimentally operated for

familiarization/competency and will continue to operate at and above current 

safety levels.
VI. A Summary The FAA May Publish in the Federal

Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The 

Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation 

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, 

Scott Dodson's, UAS permits exemption from Part 21 because my

UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 

of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness certificate requirement in consideration of 

the weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. My, Scott Dodson, current and projected UAS's meet or 

exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no on board pilots or passengers, and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining a safety/flight manual delineating areas of where safety can be 

defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS 

utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same reasons 

described above. The equivalent level of safety will be achieved by maintaining 

any such required certifications and registrations by me, Scott Dodson.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal 

Regulation require aircraft to be marked according to certain specifications. My 

UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or 

pilot station on which to mark certain words or phrases. Further, two-inch lettering 

is difficult to place on such small aircraft with dimensions smaller that minimal 

lettering requirement. Regardless, I will mark its UASs in the largest possible 
lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 

C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the 

UAV will see the markings. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. I, Scott Dodson, can achieve an equivalent level of safety 

as achieved by current regulations because my UAS does not carry any pilots or 

passengers. Further, while helpful, a pilot license will not ensure remote control 

piloting skills. The risks attended to the operation of my UAS is far less than the 

risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

Thus, allowing me, Scott Dodson, to operate my UAS meet and exceed current 

safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. My UAS 

will never operate at an altitude greater than 200 AGL; safely below the standard 

of 400 AGL. I, Scott Dodson, will however operate my UAS in safe areas away 

from public and traffic, providing a level of safety at least equivalent to or below 

those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of my UAS, an equivalent or higher level of safety will 

be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b):

Maintenance Inspections.

The above-cited Regulations require, amongst other things,

aircraft owners and operators to “have [the] aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided 

in paragraph (c) of this section, have discrepancies repaired as prescribed in part 

43 of this chapter. . . .” These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to my, Scott Dodson's, 

UAS. However, as a safety precaution I carefully and thoroughly inspect my UAS 

before and after each flight.

In summary, Scott Dodson seeks an exemption from the

following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§

61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9

(b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R.

§ 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14

C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14

C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R.
§ 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, 

Scott Dodson, small unmanned vehicle/lightweight unmanned aircraft vehicle in 

community awareness, grounds and building maintenance, infrastructure 

inspections, real estate operations, and to develop economic platforms for real 

estate to enhance the experience of those seeking to relocate to the North Texas

area. Currently, such aerial videography/photography relies primarily on the use 

of larger aircraft running on combustible fuel. Posing potential risk to the public. 

Granting my, Scott Dodson, request for exemption will reduce current risk levels 

and thereby enhance safety.

My UAS craft do not contain potentially explosive fuel, is smaller, lighter and 

more maneuverable than conventional video and photographic aircraft with much 

less flight time. Further, I operate at lower altitudes and in controlled airspace 

eliminating potential public risk flying to and from established airfields. I, Scott 

Dodson, have been informally analyzing flight information and will compile safety

protocols and the implementation of a flight operations manual for aerial video 

and photographic usage that exceeds currently accepted means and methods for 

safe flight. Formal collection of information shared with the FAA will enhance the 

FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board my, 

Scott Dodson, UAS and therefore the likelihood of death or serious bodily injury is

significantly diminished. My, Scott Dodson's, operation of my UAS, weighing less 

than 5 pounds and traveling at lower speeds within limited areas will provide an 

equivalent level of safety as that achieved under current FARs. Accordingly I,

Scott Dodson, respectfully request that the FAA grant my exemption request and 

am willing to cooperate in sharing information to benefit the FAA, safety of 

manned aircraft, and the general public at large.

Respectfully Submitted,

Scott Dodson, Owner

Vid Flight

Subsidiary of Live It Again Productions, LLC

6810 High Country Trail

Arlington, Texas 76016