U.S. Department of Transportation, Docket Operations

West Building Ground Floor

Room w12-140

1200 New Jersey Avenue, S.E.

Washington, DC 20590

Petition for Exemption Under 14 CFR § 11.81 to Allow Commercial Use of Unmanned Aircraft Systems

August 20, 2015

Petitioner:

Siteswork.com, LLC

David S. Smith, Owner

306 Woodstock Ave.

Kenilworth, IL 60043

Cell: 847-256-8918

Email: dsmith@siteswork.com

Website: www.siteswork.com

Dear Sir or Madam:

This application is substantially based on the FAA's findings in Exemption No. 11062 granted to Astraeus 

Aerial on September 25, 2014, and in reliance on the analysis provided therein.

Siteswork.com, LLC designs and manages websites for various types of sports teams, with golf and 

tennis facilities being the primary focus currently. These websites include data consisting of 

photography and videography of the venues. We at Siteswork.com, LLC would like to enhance our 

services by offering videography that can be collected using Small Unmanned Aircraft Systems (sUAS). 

An example is performing flyovers of golf and tennis facilities to capture the scope and quality of the 

facilities. The data collected by the sUAS will be done in a competent and safe manner, following local, 

state, and federal laws and regulations. The operation of the sUAs will be done with the authorization 

and supervision of the managers of these facilities.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFT Part 91:

1.1. 91.103(b)(2)

1.2. 91.105

1.3. 91.109

1.4. 91.119

1.5. 91.121

1.6. 91.151

1.7. 91.405

1.8. 91.407

1.9. 91.409
1.10. 91.417

2. Relief sought:

 Siteswork.com wishes to operate sUAS for commercial purposes to include (but not limited to) 

videography, photography, inspections and analyses. This relief is sought because commercial 

use of UAS's is currently prohibited by law unless performed under an exemption.

 This exemption will cover use of the following airframes, all of which will weigh less than 55 

pounds including payload and energy sources, and have similar operating characteristics:

o MULTIROTOR service-drone G4 models

o DJI Phantom and Inspire models

o 3DR Solo models 

3. Public benefit:

 Use of UAS technology to obtain imagery, information and data currently obtained by use of 

manned flight or manual methods:

 Reduces statistical risk to human life due to manned aircraft accidents (e.g., power line 

inspections) and due to other dangerous activities that can be avoided (e.g., scaffolding/rigging 

failures during stack or bridge inspections).

 Reduces the cost of obtaining such information, which benefits consumers and the economy.

 Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned 

aircraft.

 The videography displayed on the internet gives the public a more detailed and realistic view of 

facilities so that they can make informed choices about using those facilities.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 

45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All 

repair and maintenance work will be conducted or approved by qualified personnel and will 

require a test flight after such work. Records of all maintenance and repair work will be kept in a 

maintenance log for each aircraft.

c. All flight operations will be conducted by two individuals who will maintain verbal 

communication capability with each other at all times during the flight, and who will remain 

stationary on the ground during the flight operations:

i. A Pilot in Command (PIC) with extensive experience flying sUAS:

ii. A Visual Observer (V).

d. All flight operations will comply with the following:

 i. The manufacturers' Aircraft Flight Manuals and operation guidelines

 ii. Siteswork.com flight operations policies including lost communication and other 

emergency and safety procedures.
 iii. Conducted in Visual Meteorological Conditions (VMC) during daylight hours

 iv. PIC and VO will maintain Visual Line of Site (VLOS) at all times.

 v. Pre-flight inspections (including ground control station, if any) and safety risk assessments will 

be conducted prior to each flight

 vi. Flight altitudes will remain below 400 feet above ground level

 vii. Flight ground speeds will not exceed 50 knots.

 viii. Not intrude into Class B, C or D airspace. Not be made near persons as required in 14 CFR 91.119 

and not over persons on the ground without their prior permission

 ix. Each flight will be logged in both the PIC's logbook and the aircraft logbook

 x. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, whichever occurs 

first.

 xi. Any incidents will be reported within 24 hours of occurrence.

 xii. All other applicable regulations concerned with the operation of aircraft.

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for sending data.

In summary, Siteswork.com, LLC seeks an exemption under 14 CFR § 11.81 to allow commercial use of 

sUAS which will be used to collect videography of sports facilities, primarily golf and tennis clubs. The 

videography will be used to enhance the websites of these facilities so that the public can get a realistic 

view of the scope and quality of the facilities. The videography will be collected in a safe and competent 

manner, using a PIC, VO, and under the supervision of the management of the facilities. 

Please advise us of any additional information or changes that are required.

Sincerely,

David S. Smith

Owner, Siteswork.com, LLC