April 6, 2015

Jake Troutman

Program Analyst, Airmen and

Airspace Rules Division

Re: letter dated March 24, 2015.

Dear Mr. Jake Troutman,

Thank you for taking the time to review this exemption request and to follow up via writing. Per your 

request, I am happy to submit the additional information you requested in your letter dated March 24th, 

2015. Below is that additional information (*The specific sections of 14 CFR in which you seek relief and 

the extent of relief you seek *The reasons why granting the request would be in public interest *Any 

additional information views, or arguments to support your request). I hope that this fulfills your 

request and that if not you will contact me directly for any further requests. 

Respectfully submitted, 

Jason Hoffman

A) The name and address of the applicant is: Jason Hoffman P.O. Box 330526 Nashville, TN 37203

B) 14 CFR Regulations from which the exemption is requested

FAR Section Subject Justification

14 CFR § 45.23(b) Requirement to display 

registration number on vehicle 

Insufficient space on vehicle

14 CFR Part 21 Aircraft certification 

requirements and procedures

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS

14 CFR § 61.3 Requirement for pilot 

certificate

Part 61 requirements designed 

for manned aircraft, not sUAS; 

petition describes training for 

sUAS operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS

14 CFR § 91.9 (b) (2) Requirement for manual to be 

available in the cockpit

No one aboard to read manual

14 CFR § 91.103(b) Requirement for crew 

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual controls 

during flight instruction

No one aboard to operate 

controls

14 CFR § 91.119 Minimum altitudes for safe 

flight

Safety requires operation 

below these altitudes
14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard

No one aboard to read 

certificates

14 CFR § 91.205(b) Cockpit instruments No one aboard to read

Requirement instruments

14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful 

load; will be operated below 

ATC radar coverage

14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS

14 CFR § 91.407(a) (1) Inspection approval 

requirements

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS

14 CFR § 91.409 (a) (2) Airworthiness inspection Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS

14 CFR § 91.417 (a) & (b) Maintenance records 

requirements

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS

C) Extent of relief sought + reason:

The ability to commercially operate UAS: 

 Over Lakes and various waterways of Nashville and the state of Tennessee, outward of the shoreline

for aerial video compilations and photography.

 Over open water in marinas, anchorages, and rivers amongst and surrounding the city of Nashville for 

aerial video compilations and photography.

 Over lines of railroad and rail classification yards for aerial video compilations and photography.

 Over metropolitan Nashville parks for aerial video compilations and photography.

 Over nonresidential and noncommercial large-scale industrial areas for aerial video purposes and 

photography.

 Over private property when he has been commissioned by the person in legal possession of the 

property to do so for aerial video purposes and photography.

 Over public or private events petitioner is hired as photographer for aerial video purposes and 

photography.

D) Reasons granting the request could be in the public interest: Granting this exemption would allow 

petitioner to obtain aerial footage for commercial purposes in situations that would normally require 
the use of much more dangerous and expensive vehicles such as airplanes or helicopters in or near 

densely populated areas (for example commercial TV/MOTION PICTURE video shoots in public areas).

E) Reasons why granting exemption will not adversely affect safety: Granting this exemption would 

allow a professional photographer and already experienced UAS pilot to demonstrate operating the 

UAS as described in this petition in the safest manner, thus help in creating future safety and licensure 

laws. Petitioner agrees to pre-flight check all instruments and UAS itself prior to takeoff, then 

checking controls in the air by hovering directly above the ground for 30 seconds, before every flight. 

Pilot will adhere to all other safety laws not requesting exemption herein this petition.

F) Summary and additional information: UAS pilot seeking relief is a photographer looking to explore 

new methods of aerial photography in the safest manner possibly buy requesting proper exemptions 

and demonstrating safe flight. Pilot has many years of experience as a hobbyist flying RC aircraft much 

larger than the size UAS he proposes to use for commercial photographic and video purposes, without 

incident. Petitioner will adhere to the rules of exemption and all air safety laws not mentioned in this 

petition. Petitioner will only fly UAS as outline in Section “C” of this document.

Respectfully submitted,

Jason Hoffman

PO Box 330526

Nashville, TN 37203