September 4, 2015 

To: 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

From: 

Jeffrey Cline 

15400 Cedar Leaf Ct 

Cedar Springs, MI 49319 

616-337-3138 

jeffrey. ted.cline@gmail. com 

Petitioning for Exemption Under Section 333. FAA authorization to operate a UAS for civil (nongovernmental) purposes other than for recreation or hobby. This is the new FAA streamlined UAS for 

commercial operation at or below 200 feet. 

I seek relief of operation of a UAS for commercial photography and videography. 

It will benefit the public by flying at a lower altitude and by providing unique views in video and 

photographs. 

Safety will not adversely be affected since the FAA created safety guidelines that will be followed. 

The rule is: 

PUBLIC LAW 112-95-FEB. 14,2012 126 STAT. 77 

SEC 336. SPECIAL RULE FOR MODEL AIRCRAFL 

(I) the aircraft is flown strictly for hobby or recreational use; 

The exemption requested is to operate a UAS for commercial purposes at or below 200 feet. 

Thank you, 

Jeffrey Cline 
Pursuant to Section 333 of the FAA Modernization and Reform Act o:£2012 (the "Reform Act") and 14 

C.P.R. Part 11, Jeffrey Cline, an individual, seeks exemption from requirements of 14 C.P.R. § 21, 

Subpart H; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103; 14 C.P.R.§ 91.105; 14 C.P.R.§ 91.109; 14 C.P.R.§ 

91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.15l(a); 14 C.P.R.§ 91.405(a) and (d); 14 C.P.R.§ 

91.407(a)(l); 14 C.P.R. § 91.409(a)(2); 14 C.P.R. § 417(a) and (b) to operate an unmanned aerial vehicle 

(U A V) in support of commercial aerial photography and videography of individual commercial, public, 

and residential properties and structures with owners/operators permission and appropriate authorization. 

The request for this exemption is in the Public Interest as there are many consumer applications for the 

services that can be provided by U A V that are currently conducted by manned aircraft. Using aU A V for 

many of these applications creates an environmentally friendly, lower cost solution to both the operator 

and consumer. These aircraft can be operated safely, and without significant financial impact to the 

operator or any person or property on the ground in the event of the loss of an aircraft. Utilizing these 

UA V will create a safe and more productive work environment. reduce environmental pollution and have 

a positive impact on the local economy, which is in the Public Interest. 

Jeffrey Cline respectfully request that the FAA grant the following requested exemptions: 

14 C.P.R.§ 21, Subpart H; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103;14 C.P.R.§ 91.105; 

14 C.P.R.§ 91.109; 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 

14 C.P.R.§ 91.215; 14 C.P.R. § 91.405(a) and (d); 14 C.P.R. § 91.407(a)(1); 

14 C.P.R.§ 91.409(a)(2); 14 C.P.R.§ 417(a) and (b). 

14 C.P.R. 21, Subpart H: Airworthiness Certificate 

Jeffrey Cline requests an exemption from 14 C.P.R. 21, Subpart H. This Subpart establishes the 

procedures for the issuance of an airworthiness certificate. Jeffrey Cline requests an exemption from Part 

21, Subpart H because the UAV is under 50 pounds (including payload) and meets an equivalent level of 

safety pursuant to Section 333 of the Reform Act due to its small size, light weight, and restricted 

operating environment. 

14 C.P.R. 43.11: Records for Inspections 

Jeffrey Cline requests an exemption from 14 C.P.R. 43 .11. This part provides that maintenance record 

entries be maintained, that the inspector list discrepancies, and to afftx placards to the aircraft. Due to its 

small size the U A V proposed for use, does not have room for placards to be placed in or on it and no 

inspections for UA V have been certified by FAA at the present time. However, as a condition to the 

grant of the exemption, Jeffrey Cline will perform the inspections and time replaceable items 

recommended by the manufacturer and keep records and log books of all maintenance and repairs. 

14 C.F .R 91.103: Preflight Action 

Jeffrey Cline requests an exemption from 14 C.F .R. 91.103. This regulation requires each pilot to take 

certain actions before flight to insure the safety of flight. As FAA approved flight manuals will not be 

provided for the UAV, an exemption is needed. Jeffrey Cline will follow the manufactures preflight 

inspection. 

14 C.F.R 91.105: Flight Crewmembers at Stations 

Jeffrey Cline requests an exemption from 14 C.F .R. 91.105. Jeffrey Cline requests an exemption from 14 

C.P.R. 91.105 since this part is not applicable due to the UAV carrying no flight crewmembers. An 

equivalent level of safety will be maintained by ensuring the pilot does not change inflight. 
SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 

Department of Transportation 

Federal Aviation Administration 

Petitioner: Jeffrey Cline 

Petition of exemption from sections of; 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121,91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

Description of relief sought; 

Jeffrey Cline seeks an exemption for commercial operation of an unmanned aerial vehicle that is under 50 

pounds including payload. 

The unmanned aircraft vehicle has an onboard camera system capable of acquiring high resolution data. 

Proposed operations will offer real estate aerial photography, videography and aerial surveying services 

forother commercial industries.