April 20, 2015 

Daryll Griff

1632 Briar Rose

Costa Mesa, Ca 92626

PlexusData@ca.rr.com

FAA 

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

To whom it may concern, Re: Docket Number FAA-2015-0150

I would like to start by giving a brief description of myself. I am a 53 year old married 

man, and I consider myself a professional adult and a responsible member of the community. I 

am hoping to take piloting an unmanned aerial system beyond the point of hobby and into a 

professional occupation. I have spent 13 years of the past 20 years my life in the field of 

Computer Hardware Manufacturing. I was the sole owner of Plexus Data Inc. in Irvine, California 

(now wound down) and was at many times in possession of private, privileged, and extremely 

confidential information, which entitled me to a huge level of professional trust with my 

customers. Prior to that in the mid 1980’s I was a Real Estate Agent and a Mortgage Broker.

I have been interested in remote control quadcopters since they began making them 

more user friendly. I have purchased a DJI Phantom Series and have flown it for many hours 

and feel very experienced with it. They are a fun and very addictive system with the potential to 

be a valuable business tool. What could be a better way to make money doing something that I 

consider fun? I began taking pictures with a camera attached to it not long after I purchased it. I 

took pictures for numerous family functions and looked into doing it professionally, for real 

estate, now that I have closed down Plexus Data Inc. due to the commoditization of computer 

hardware. 

In Southern California, there is an extremely large amount of real estate bought and 

sold, and having an extra tool available to offer a real estate company in this competitive 

market, I hope will help effectuate a sale, and would be an affordable way of providing such a 

service.

I found that there was not really any way of doing it professionally because the rules had 

not been written. I kept checking back periodically and eventually found my way here. I got wind 

of a realtor just getting an approved COA and jumped at the opportunity. My petition is basically 

going to shadow that of Mr. Trudeau. After reading over his grant of exemption, he has 

described basically everything I wish to do. I am not a realtor however, and if and when I were 

to receive a grant of exemption, I would take on a position of photographer, videographer, and 
editor. I do not have a business yet but receiving a grant would be the final step before starting 

one. I also plan to purchase an additional (new version of the DJI Phantom) and different model 

of quadcopter to use than that of Mr. Trudeau. Same manufacturer as his, but a more advanced 

and updated system. It has not been released to the public yet but will be soon, maybe by the 

time you read this. It is also manufactured by the same company that made my first quad, the 

original DJI phantom. I have funding resources available to me, and by the time I would receive 

exemption, I should already have many more hours of flight time with the UAS. I will begin the 

petition for exemption below: 

To the Federal Aviation Authority (FAA), 

I hereby request 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). 

I support my request with the following information: 

I plan to operate a UAS, the DJI Inspire 1, which is comprised of an unmanned aircraft 

and a transportable ground station. The Inspire 1 is referred to as a quad-copter with a 

maximum gross weight of about 3 kilograms. It is equipped with four rotors that are driven by 

electric motors powered by a battery. The UA has a maximum airspeed of 22 m/s. The quad 

has a built in high definition camera. I plan to operate the UA over various areas near Orange 

County California to enhance real estate listing videos and photographs. I make the following 

representations of operational enhancements which I propose to abide by to ensure this 

exemption will provide a level of safety at least equal to existing rules: 

• 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. 

I state that given the size, weight, speed, and limited operating area associated with the 

aircraft to be utilized, 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 request an exemption from § 45.23 Marking of the aircraft because his UA will not have 

a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, I state that 

two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. Regardless of this, I state that I will mark his UAS in the largest 

possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so 

that he or anyone assisting him as a spotter will see the markings. 

I state that 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. However, I state that as a safety precaution I will 

perform a preflight inspection of his UAS before each flight as outlined in my operating 

documents. 
UAS Pilot in Command (PIC) 

I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial 

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. Further, I state that, while 

helpful, a pilot license will not ensure remote control piloting skills. I further indicate 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 I request an exemption from § 61.113 Private Pilot Privileges 

and Limitations: Pilot in command. 

Regarding UAS operational training, I have flown numerous practice flights in remote areas as a 

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

characteristics of his UAS’ performance under different temperature and weather conditions. I 

have also practiced computerized simulated flights to maintain adequate skills and response 

reflex time. 

In a supplemental request to the FAA, I request consideration of a 120 day temporary airman 

certificate in accordance with § 63.13, to allow time to obtain a private pilot certificate or to allow 

the FAA time to establish minimum UAS airman certification standards. 

UAS Operating Parameters 

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 my own personal and flight safety protocols 

(including posting a warning sign reading: “Attention Aerial Photography in Progress – 

Remain Back 150 feet”) contained 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 note that § 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. I assert that since there is currently no certificate applicable to my operation, this 

regulation is inapplicable. 

I note that § 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 further indicate an equivalent level of safety will be achieved by maintaining a 

safety/flight manual with the UAS ground station. 
I note that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it 

allows helicopters to be operated at lower altitudes in certain conditions. I state that I will not 

operate his UAS above the altitude of 300 feet above ground level (AGL) and will also only 

operate in safe areas away from the public and traffic, thus “providing a level of safety at least 

equivalent to or below those in relation to minimum safe altitudes. I assert that given the size, 

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

achieved. 

I note that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic 

GPS with a barometric sensor. 

Public Interest 

I state that aerial videography and photography 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. Granting this 

exemption to myself would allow me to provide this service at a much lower cost. 

Further, I would like to indicate my small UAS will pose no threat to the public given its small 

size and lack of combustible fuel when compared to larger manned aircraft. I would also like to 

state that the operation of my UAS will minimize ecological damage and promote economic 

growth by providing information to companies or individuals doing business in the Southern 

California region. 

Conclusion

I would like to conclude by saying thank you for your consideration and time reading this 

petition. This has been a desire of mine since quadcopters became available to the public. I 

have only flown as a hobby to not break any laws until with hopes to become commercial. I see 

nothing but positive coming from it from this new technology. The state of California makes 

money from the sale of real estate. The realtor would have an advantage because of a much 

clearer view of properties. The consumer gets a better look at things. I get to pursue hopefully a 

new career and be a pioneer in a virtually new field of photography. All along the way, the 

federal government collects taxes from all of us. The economy benefits with very little risk of 

accidents and/or damages from these flyovers.

Thank you again. 

Very respectfully, 

Daryll Griff