1 | Page Colley Petition

Jeffrey Ring

Papa Power Productions

40 Middlebrook Lane

Rochester, New York 14608-4406

(Office) 585-442-2742

(Cell) 585-747-5508

June 16, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

SE Washington, DC 20590 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I, 

Jeffrey Ring, a Film and Video Media Production specialist for the past 30 years, preparing this 

exemption request myself, would like to apply for an exemption from the following Code of Federal 

Regulations (C.F.R) to be allowed commercial operation of lightweight Unmanned Aircraft Systems 

(SUAS) for the purposes of aerial imaging, data collection, Photography and Videography.

Jeffrey Ring seeks exemption from the requirements of 14 C.F.R 21(h), 43.7, 43.11, 45.11 (a,b,c), 

45.27(a), 45.29(3), 61.56, 61.113(a,b), 61.113, 91.7(a), 91.9(b2, c), 91.103(b2), 91.105, 91.113(b), 

91.119(c), 91.121, 91.151, 91.403, 91.405(a,d), 91.407(a,b), 91.409, 91.417, to operate commercially

small Unmanned Aircraft System (SUAS) pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA). Approval of the exemptions requested will allow for commercial operations of the 

DJI S900 and Phantom to be conducted, LOS only, for the purposes of collecting aerial video, mapping, 

photography, and sensory data to be used in support of agriculture applications, inspection operations, 

forestry, land management, new sensor development and the expansion of basic and fundamental 

research principles and applications related to the above, in addition to search and rescue. All flights 

will be under 400 feet in altitude, never within 5 miles of any Commercial or private Airport, always with 

a spotter/assistant and within Class G airspace within the United States.

Following examples of; FAA Exemption No. 11381 - Regulatory Docket No. FAA-2014-0481, FAA 

Exemption No. 11784 - Regulatory Docket No. FAA - 2015-0288, FAA Exemption No. 11788 - Regulatory 

Docket No. FAA – 2015-1003 and FAA Exemption No. 11769 – Regulatory Docket No. FAA – 2015-0896

I have included:

1) Supplemental Response for Petition 

2) The DJI S900 and Phantom manuals are too large for upload to regulations.gov. Therefore, if 

interested, please follow the link below to the assembly and operating manual for the sUAS.

http://www.dji.com/product/spreading-wings-s900/download

3) Personal protocols and controls - Safety/Flight concerns
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I have vast experience in flying Remote Control Airplanes (fixed-wing) for over 40 years and Multicopters for the past 5 years for recreation, testing, reviewing and photographic purposes, without

incident. I currently have dozens of planes and numerous Multi-copters including the DJI S900 and 

Phantom which I am requesting this exemption for.

Approval of my exemption request would permit operation of these two particular Multi-copters in 

predetermined areas away from general public, airports, heliports and vehicular traffic, under 400 ft. 

and after carefully reviewing, inspecting and examining the area of aerial observation. I will abide all 

FAA requirements to ensure this exemption will provide a level of safety at least equal to existing rules 

and will only operate in a safe environment that is 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. As a member of the AMA #869451 and

the RCCR for many years, my primary concern has, and always will be, Safety! Our club has always had

a passion for proper training for the younger generation of RC flyers and works closely with local 

Colleges and Universities to promote interest in the Aeronautical arena. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized, I am 

asking exemption from 14CFRpart21, 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 under14CFRpart 11 and Section 333 of P.L. 112-95 

(Section 333). It is evident, by many of your previous approvals, that you are totally aware of the

attributes of these specific two Multi-copters. 

14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of 

Marks 

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will not have 

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

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

requirement. I understand the need for markings and will mark my UAS in the largest possible lettering 

by placing the word “Experimental” or assigned number or name (based on a request or ruling by the 

FAA ) on its fuselage as required by §45.29(f) so that anyone assisting as a spotter will see the markings. 

I also ask for 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. But, as a safety precaution, I always have and will continue to perform a 

preflight inspection of my UAS before each flight as outlined in operating documents. 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command. 

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, however I can achieve 

an equivalent level of safety as achieved by current regulations because my UAS does not carry any 

pilots or passengers. While helpful, a pilots’ license will not ensure remote control piloting skills. The 

risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 

14 CFR part61,et seq., I requests an exemption from §61.113 Private Pilot Privileges and Limitations. In 
3 | Page Colley Petition

my decades of RC flight, I have conducted seminars on flight training, maintenance and assembly in 

addition to being a reviewer/contributor to RC Groups on line Magazine and Fly RC Magazine. I have

also flown almost every class of RC Airplane including control line, glow & gas, gliders, 3D, Sport, 1⁄4

& 1/3 Scale, EDF Jets and every size Multi-copter micro/mini, Quads, Hexas and Octos. Multi-copters

and the many positive uses that they have the capacity to perform has become my passion and I will

continue to properly promote and inform the general public, whenever I have the opportunity to do so ,

that this technology has many advantages for advancing data collection and discovery in the world of 

flight.

14 C.F.R. 91.103 (b) (1), (b)(2): Preflight Action 

If granted an exemption I agree to additional safety procedures including, but not limited to:

1. Keeping my UAS within a radius distance of 1000 feet from the controller to both aid in direct 

line of sight visual observation.

2. Operate the UAS for 8-15 minutes per flight; land my UAS according to the manufacturer’s 

recommended minimum level of battery power.

3. Operate my UAS only within visual line of sight (VLOS). 

 4. Use the UAS’ global positioning system (GPS) flight safety feature; Return to Home. 

 5. Conduct all operations under stringent flight safety protocols.

 6. I will operate and will actively analyze flight data and other sources of information to constantly 

 7. Always obtain all necessary permissions prior to operation

 8. Always have procedures in place to abort flights in the event of safety breaches or danger.

I wish to thank you for giving me this opportunity to apply for a 333 Exemption and I hope that my

application will meet with your approval. I look forward to continue my exploration of RC flight with

the proper FAA credentials for SUAS operation. With your approval, I will have the ability to be 

commercially able to provide a positive service in many exciting industries including; agriculture,

forestry, aerial photography and video for real estate, architecture, land surveying, commercial utility 

infrastructure engineering, public events, news gathering, aerial inspection of residential and 

commercial structures, closed set filming of motion pictures, music videos, web videos, corporate 

videos, television programs and commercials, training for proper UAS operation, photos and videos to 

assist with search and rescue operations; and any other related professional activities. How exciting!

Sincerely yours,

Jeffrey Ring

Papa Power Productions