Petition for Exemption

Federal Aviation Administration

June 10, 2015

Petitioner Information:

Robert P. Ivers

Velocity Business Solutions

9064 Terwilligers Ridge Drive

Cincinnati, OH 45249

513-218-0312

Fax: 513-697-9992

rivers@velocitybiz.com

I seek relief from 14 CFR § 336 (a)(1) and H. R. 658—68 (3) (cited below) which specifically states that a 

model aircraft is flown strictly for hobby or recreational use. As a professional photographer, I seek an 

exemption in order that I be able to take photographs of homes, commercial buildings, farms, 

equipment and landscape, with proper permission granted from said property owners, for resale to 

realtors, advertisers, film makers and other entities, including local law enforcement. The aircraft shall 

be equipped with “No Fly Zone” GPS software to avoid airports, have fail-safe mechanisms for return-tohome on error, be flown under 400 feet and within plain eye sight of the operator. The aircraft will not 

be flown in any areas deemed restricted for any reason either by the FAA or local authorities, nor will it 

be flown in a manner deemed unsafe to bystanders or property. It is agreed that the operator shall:

 Fly below 400 feet and remain clear of surrounding obstacles

 Keep the aircraft within visual line of sight at all times

 Remain well clear of and do not interfere with manned aircraft operations

 Don't fly within 5 miles of an airport unless you contact the airport and control tower before 

flying

 Don't fly near people or stadiums

 Don't fly an aircraft that weighs more than 55 lbs

 Don't be careless or reckless with your unmanned aircraft – you could be fined for endangering 

people or other aircraft

The reason for the request for exemption is that I have been creating virtual tours of homes and 

businesses using ground based photography methods for over ten years. I have also created a number 

of professional commercial videos for the web that describe products or market a company in general. 

A logical extension of this business is to offer aerial photographs and video renderings as well. The 

result of my work helps sell homes and commercial property – benefitting homeowners, businesses and 

real estate agents. It also helps businesses grow by showing their facility or the product they produce in 

their marketing literature or website. It also benefits churches and schools for conducting very cost 

effective roof inspections on hard-to-reach steeples or towers that only cranes can reach. Farms could 

benefit from my services by analyzing irrigation and fertilizer runoff issues. I have also been asked to 

assist local police in crime investigations and have conducted introductory training for them on the 
safety and potential use of this type of equipment. I have been asked by a local university to assist with 

overhead photography of archeological survey sites, some perhaps outside of the US.

I feel that with the ability to charge a fee for my aerial photography services, I could grow my business 

and promote the sensible and safe use of these types of small airborne cameras without jeopardizing 

the intent of the existing rule.

Thank you for your consideration.

Robert P. Ivers

rivers@veloctybiz.com

513-218-0312

Specific Code:

SEC. 336. SPECIAL RULE FOR MODEL AIRCRAFT. (a) IN GENERAL.—Notwithstanding any other provision 

of law relating to the incorporation of unmanned aircraft systems into Federal Aviation Administration 

plans and policies, including this subtitle, the Administrator of the Federal Aviation Administration may 

not promulgate any rule or regulation regarding a model aircraft, or an aircraft being developed as a 

model aircraft, if— (1) the aircraft is flown strictly for hobby or recreational use; (2) the aircraft is 

operated in accordance with a communitybased set of safety guidelines and within the programming of 

a nationwide community-based organization; (3) the aircraft is limited to not more than 55 pounds 

unless otherwise certified through a design, construction, inspection, flight test, and operational safety 

program administered by a community-based organization; (4) the aircraft is operated in a manner that 

does not interfere with and gives way to any manned aircraft; and (5) when flown within 5 miles of an 

airport, the operator of the aircraft provides the airport operator and the airport air traffic control tower 

(when an air traffic facility is located at the airport) with prior notice of the operation (model aircraft 

operators flying from a permanent location within 5 miles of an airport should establish a mutuallyagreed upon operating procedure with the airport operator and the airport air traffic control tower 

(when an air traffic facility is located at the airport)). (b) STATUTORY CONSTRUCTION.—Nothing in this 

section shall be construed to limit the authority of the Administrator to pursue enforcement action 

against persons operating model aircraft who endanger the safety of the national airspace system. (c) 

MODEL AIRCRAFT DEFINED.—In this section, the term ‘‘model aircraft’’ means an unmanned aircraft 

that is— (1) capable of sustained flight in the atmosphere; H. R. 658—68 (2) flown within visual line of 

sight of the person operating the aircraft; and (3) flown for hobby or recreational purposes.