June 23, 2015

Exemption No. 11870

Regulatory Docket No. FAA–2015-1241

Thomas Simonsen

7300 France Avenue South, #112

Edina, MN 55435

Dear Mr. Simonsen:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on April 27, 2015, you petitioned the Federal Aviation 

Administration (FAA) for an exemption. The petitioner requested to operate an unmanned 

aircraft system (UAS) to conduct aerial videography and cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a Phantom 2 Vision+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 
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14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Thomas Simonsen is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Thomas Simonsen is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Phantom 2 Vision+

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
I, Thomas Simonsen, would like an exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) 

and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). The 

proposed exemption would allow Tom Simonsen to operate the PHANTOM 2 Vision+ quad-copter 

unmanned aircraft system (UAS) to conduct aerial videography and cinematography to enhance 

academic community awareness for those individuals and companies unfamiliar with the geographical 

layout of the Minneapolis/St Paul and surrounding areas and to do real estate listing videos. 

I would like relief from the following regulations:

Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions 

approvals, airworthiness certificates, and airworthiness approvals. Section 45.23(b) prescribes that 

when marks include only the Roman capital letter ―N‖ and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words ―limited,‖ ―restricted,‖ ―lightsport,‖ ―experimental,‖ or ―provisional,‖ as applicable. Section 61.113(a) and (b) prescribes that— (a) 

no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is 

carrying passengers or property for compensation or hire; nor may that person, for compensation or 

hire, act as pilot in command of an aircraft. (b) a private pilot may, for compensation or hire, act as pilot 

in command of an aircraft in connection with any business or employment if: (1) The flight is only 

incidental to that business or employment; and (2) The aircraft does not carry passengers or property 

for compensation or hire. Section 91.7(a) prescribes that no person may operate a civil aircraft unless it 

is in an airworthy condition. Section 91.7(b) prescribes that the pilot in command of a civil aircraft is 

responsible for determining whether that aircraft is in condition for safe flight and that the PIC shall 

discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur. Section 

91.9(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available in the aircraft a 

current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof. Section 91.103(b) prescribes that a pilot shall for any flight, 

become familiar with runway lengths at airports of intended use, and takeoff and landing distance 

information. Section 91.109(a) prescribes, in pertinent part, that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. Section 91.119 prescribes that, except when necessary for takeoff or landing, 

no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. (b) Over congested areas. Over any congested 

area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 

1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) 

Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, and 

weight-shift-control aircraft. If the operation is conducted without hazard to persons or 
property on the surface— (1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A 

powered parachute or weight-shift-control aircraft may be operated at less than the minimums 

prescribed in paragraph (c) of this section. Section 91.121 requires, in pertinent part, each 

person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set 

―...to the elevation of the departure airport or an appropriate altimeter setting available before 

departure.‖ Section 91.151(a) prescribes that no person may begin a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel 

to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the 

day, to fly after that for at least 30 minutes [emphasis added]. Section 91.203(a) prohibits, in 

pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate 

and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to 

its owner or, for operation within the United States, the second copy of the Aircraft registration 

Application as provided for in § 47.31(c). Section 91.203(b) prescribes, in pertinent part, that no 

person may operate a civil aircraft unless the airworthiness certificate or a special flight 

authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. Section 91.405(a) requires, in pertinent part, that an aircraft 

operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part 

and shall, between required inspections, except as provided in paragraph (c) of the same 

section, have discrepancies repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under § 43.7 of the same chapter. Section 

91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within 

the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter. Section 91.417(a) and (b) prescribes, in 

pertinent part, that— (a) Each registered owner or operator shall keep the following records for 

the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive 

maintenance, and alteration and records of the 100-hour, annual, progressive, and other 

required or approved inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must include— (i) A 

description (or reference to data acceptable to the Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and (iii) The signature, and certificate 

number of the person approving the aircraft for return to service. (2) Records containing the 

following information: (i) The total time in service of the airframe, each engine, each propeller, 

and each rotor. (ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. (iv) The current inspection status of the 

aircraft, including the time since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If the 

AD or safety directive involves recurring action, the time and date when the next action is 

required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) 

The owner or operator shall retain the following records for the periods prescribed: (1) The 

records specified in paragraph (a)(1) of this section shall be retained until the work is repeated 

or superseded by other work or for 1 year after the work is performed. (2) The records specified 

in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time 

the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 

of this chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

I plan to operate a UAS, the PHANTOM 2 Vision+, which is comprised of an unmanned aircraft 

(UA or PHANTOM) and a transportable ground station. The PHANTOM is referred to as a quadcopter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are 

driven by electric motors powered by batteries. The UA has a maximum airspeed of 30 knots. 

Petitioner plans to attach a small ultra- 6 lightweight GoPro 3+ camera to his UA and operate 

the UA over the Minneapolis/St Paul and surrounding areas to enhance academic community 

awareness and augment real estate listing videos.

I will only operate in reasonably safe environments that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas; and I will conduct extensive 

preflight inspections and protocols, during which safety carries primary importance. 

Since the size, weight, speed, and limited operating area associated with the aircraft will be 

utilized by me, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 

91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is 

warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 

and Section 333 of P.L. 112-95 (Section 333).

I also request an exemption from § 45.23 Marking of the aircraft because my UA will not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Plus the two-inch 

lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal 

lettering requirement. Also, I will mark my UAS in the largest possible lettering by placing the 

word ―Experimental on its fuselage as required by § 45.29(f) so that I or anyone helping me as 

a spotter will see the markings.

I also would like an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and 

(b) Maintenance inspections may be required and should be granted since they only apply to 

aircraft with an airworthiness certificate. I will also, as a safety precaution perform a preflight 

inspection of my UAS before each flight as outlined in the operating documents.
I would also like to be exempt from § 61.113 (a) and (b) private pilots are limited to 

noncommercial operations, however he can achieve an equivalent level of safety as achieved by 

current regulations because his UAS does not carry any pilots or passengers. Further, he states 

that, while helpful, a pilot license will not ensure remote control piloting skills. He further 

indicates that the risks of operating a UAS are far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR part 61, et seq., thus he requests an exemption from § 

61.113 Private Pilot Privileges and Limitations: Pilot in command.

I will abide by the following additional operating conditions under this exemption: operate my 

UAS below 300 feet and within a radius distance of 1000 feet from the controller to both aid in 

direct line of sight visual observation; 1 operate the UAS for 3-7 minutes per flight; land my UAS 

prior to the manufacturer’s recommended minimum level of battery power; operate my UAS 

only within visual line of sight (VLOS); use the UAS’ global positioning system (GPS) flight safety 

feature whereby it hovers and then slowly lands if communication with the remote control pilot 

is lost; conduct all operations under his own personal and flight safety protocols (including 

posting a warning sign reading: ―Attention Aerial Photography in Progress – Remain Back 150 

feet as stated in the operating documents and will actively analyze flight data and other sources 

of information to constantly update and enhance my safety protocols; contact respective 

airports if operations will be within 5 miles to advise them of my estimated flight time, flight 

duration, elevation of flight and other pertinent information; always obtain all necessary 

permissions prior to operation; and have procedures in place to abort flights in the event of 

safety breaches or potential danger.

I also would like to be exempt which § 91.9(b)(2) requires an aircraft flight manual in the 

aircraft, however since there are no pilots or passengers on board his aircraft and given its size, 

this regulation is inapplicable. I also will ensure that a level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station.

I am a Realtor and aerial videography for geographical awareness and for real estate marketing 

has been around for a long time through manned fixed wing aircraft and helicopters, but for 

small business owners, its expense has been cost-prohibitive. I would like this exemption so it 

would allow me to provide this service at a much lower cost. Small UAS will pose no threat to 

the public given its small size and lack of combustible fuel when compared to larger manned 

aircraft. The petitioner also states that the operation of my UAS will minimize ecological damage 

and promote economic growth by providing information to companies looking to relocate or 

build in the Minneapolis/St Paul and surrounding areas.