Gabriel Ryan Lowry 

1613 Laurel Lane Prescott, Arizona 86301• Phone: 928-533-6881 

July 15, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. S.E. 

Washington, D.C. 20590 

Dear Sir or Madam: 

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Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 and 14 C.F.R. Part 11 , Mr. G. Ryan Lowry files this petition for 

exemption as an operator of Small Unmanned Aircraft Systems (UAS) used for remote 

sensing to support aerial data collection, specifically photography and video capture of 

commercial and residential real estate properties. Mr. Lowry seeks an exemption from 

the Federal Aviation Regulations (FARs) listed in this petition to allow commercial 

operation of its UAs, so long as the operations are conducted under the conditions 

specified within this petition or as may be required by the FAA in granting this petition. 

BACKGROUND 

Approval of the exemption for Mr. Lowry will allow commercial operation of the DJI 

Phantom 1, and DJI Inspire 1 (model specifications listed below). The Unmanned 

Aircraft (UA) identified in this exemption petition are small, battery-powered aircraft, that 

weight less than 12 lbs. , including battery and sensing payload. The operation of the 

UAs in the photographic and video sensing mode, allow for a level of safety greater than 

that provided by larger manned aircraft, including helicopters and fixed wing aircraft that 

carry flammable fuel and operate at an above ground level (AGL) altitude that would 

increase risk to the aircraft operator as well as personnel and property on the ground. In 

addition, with a small payload and maximum flight time between 15 to 18 minutes, these 

UAs offer little to no risk to national security. 

UNMANNED AIRCRAFT (UA) SPECIFICATIONS 

1. DJ I Phantom 1 

• Take-Off Weight- <1200g 

• Hovering Accuracy (GPS)- Vertical: 0.8m; Horizontal: 2.5m 
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• Max Ascent/Descent Speed- 6m/s 

• Max Flight Velocity- 1 Om/s 

• Diagonal Distance (Motor Center to Motor Center) - 350mm 

• 12 to 15 minute maximum flight time depending on battery 

• Remote Controller (FCC approved portable handheld)- 2.4GHz ISM 

o Control Channels - 7 

o Communication Distance - 1 DOOm 

o System provides a fail-safe feature that allows the aircraft to return 

to the launch point and land automatically in the event the 

command and control signal is lost or the battery has reached a 

pre-determined threshold. 

2. DJI Inspire 1 

• Take-Off Weight- 2935g 

• Hovering Accuracy (GPS) -Vertical: 0.5m; Horizontal: 2.5m 

• Max Ascent Speed- 5 m/s 

• Max Descent Speed - 4 m/s 

• Max Speed - 22 m/s (A TTl mode, no wind) 

• Max Flight Time- 18 minutes 

• Dimensions- 438 X 451 X 301 mm 

• Remote Controller (C 1) 

o Operating Frequency- 5.725-5.825 GHz; 2.400-2.483 GHz 

o Transmitting Distance - 2km 

o Output Power - 9 W 

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•• 

GROUND CREW 

• Pilot in Command (PIC). The pilot in command will have at least a Sport Pilot 

Certificate or higher, and valid U.S. Drivers License (DL). 

• Visual Observer (VO) if required. The visual observer will provide additional 

situational awareness during flight operations. 

Flight Operation Parameters 

• The Unmanned Aircraft System will weigh less than 55 lbs. 

• Flights will be operated within visual line of sight (VLOS) of the PIC and VO (if a 

VO is required). 

• Flights will be conducted during day Visual Flight Rules (VFR) conditions 

• Flights will be operated at an altitude limit of 200 feet Above Ground Level (AGL) 

as indicated in the "blanket COA" unless a specific COA is obtained. 

• Operations in the vicinity of airports and/or heliports will be conducted according 

to the "blanket COA" as follows: 

o 5 nautical miles (NM) from an airport having an operational control tower; 

or 

o 3 NM from an airport with a published instrument flight procedure, but not 

an operational tower; or 

o 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or 

o 2 NM from a heliport with a published instrument flight procedure 

• PIC will be a U.S. certificated airman with at least a Sport Pilot Certificate and 

valid U.S. Drivers License. 

• PIC will have logged, as a minimum, at least 10 hours in the operations of the 

UAS aircraft specified with this exemption petition. 

• Permission will be obtained from the property owner of the aerial 

photography/video capture sight. 

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•• 

• Flight operations will not be conducted on board a moving vehicle 

PREFLIGHT OPERATIONS 

• Preflight weather briefing including current and forecast weather and Notice to 

Airmen (NOTAMs) pertinent to the intended flight location. This will be used by 

PIC to determine whether proposed flight operations can be conducted safely 

under day VFR conditions and in accordance with the pertinent COA. 

• Preflight inspection of UA to determine that aircraft is airworthy for the proposed 

flight operations. This will include, as a minimum, inspections of airframe, 

propellers, on-board aircraft and remote controller batteries, and a satisfactory 

preflight test of flight controls and pertinent switches. 

• Preflight visual inspection of the geographical area to be surveyed/photographed 

to determine location of structures, foliage, trees, and other natural or man-made 

obstacles that would present a hazard to the proposed flight. 

• Prior to the proposed flight, the PIC will have received permission from the owner 

or designee of the property to be surveyed/photographed to conduct the aerial 

survey of the property. 

PETITIONER'S CREDENTIALS 

• FAA COMMERCIAL PILOT CERTIFICATE 

o Date of Issue: 11/4/2004 

o Ratings: Airplane Single/Multiengine Land; Instrument Airplane 

• Arizona Drivers License 

o Class D; Expires 06/18/2042 

DOCUMENTATION 

The following documents are attached to support this petition: 

• DJI Phantom 1 Quick Start Manual (V. 1.7) 

• DJI Inspire 1 Users Manual (V. 1.2) 

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SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEKS AN EXEMPTION 

A. 14 C.F.R. Part 91.7(a) Civil Aircraft Airworthiness 

The UAs described within this petition will not be issued an airworthiness certificate (in 

accordance with 14 C.F.R. Subpart H), and decisions established by previous Section 

333 exemptions for small, unmanned UAS. The PIC will determine the airworthy 

condition prior to each flight. The petitioner seeks relief from this FAR. 

B. 14 C.F.R. Part 91.119(c) Minimum Safe Altitudes Over Congested and Other 

Areas 

The UAS operation will be conducted at or below 200 feet AGL (unless a higher limit 

COA is obtained) in a well-defined area where personnel and structures will not be 

exposed to UAS operations without consent. The petitioner seeks relief from this FAR. 

C. 14 C.F.R. Part 91.121 Altimeter Settings 

The UAS identified in this petition does not have a barometric altimeter but maintains its 

altitude by utilizing GPS equipment together with static pressure sensor. The petitioner 

seeks relief from this FAR. 

D. 14 C.F.R. Part 91.151 (a) Fuel Requirements for Flight in VFR Conditions 

The UAs described within this petition will fly for a maximum of 18 minutes due to onboard aircraft battery restrictions. The UAs have telemetry data that provides the PIC 

with remaining battery power in the aircraft that will allow the operator to terminate flight 

operations when the battery level reduces to a pre-determined 25 percent. The 

petitioner seeks relief from this FAR. 

E. 14 C.F.R. Part 91.405(a) Maintenance Required ; 14 C.F.R. Part 91.407(a)(1) 

Operation after Maintenance, Preventative Maintenance, Rebuilding or 

Alteration ; 14 C.F.R. Part 91.409(a)(1) and (2) Inspections; 14 C.F.R. Part 

91.417(a) and (b) Maintenance Records 

These sections apply to aircraft that have an airworthiness certificate and since the UAs 

described within this petition will not have an airworthiness certificate, these sections 

are not applicable to this proposed UAS. In addition, the FAA has issued a previously 

exemption to these regulations in Exemption No. 11062. The petitioner seeks relief from 

these FARs. 

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•• 

SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER 

Petitioner: Gabriel Ryan Lowry 

Sections of 14 C.F.R. Affected in Petition: Part 91.7(a); Part 91 .119(c); Part 91.121; 

Part 91.151 (a); Part 91.405(a); Part 91.407(a)(1 ), Part 91.409(a)(1 ); Part 91.417(a) and 

(b) 

Description of Relief Sought: Mr. Gabriel Ryan Lowry seeks relief from the 

requirements of 14 C.F.R. Part 91.7(a); 14 C.F.R. Part 91.119(c); 14 C.F.R. Part 

91.121; 14 C.F.R. Part 91.151(a); 14 C.F.R. Part 91.405(a); 14 C.F.R. Part 

91.407(a)(1); 14 C.F.R. Part 91.409(a)(1); 14 C.F.R. Part417(a) and (b) to operate 

small unmanned aircraft systems (UAS) for the purpose of real estate aerial photo and 

video data collection. 

Respectfully Submitted , 

Gabriel Ryan Lowry 

Petitioner/Owner of UAS 

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