August 18, 2015

Exemption No. 12501

Regulatory Docket No. FAA−2015−1258

Mr. John P. Creed

8009 Cooke Road

Elkins Park, PA 19027

Dear Mr. Creed:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on April 28, 2015 and additional information dated 

July 11, 2015, you petitioned the Federal Aviation Administration (FAA) for an exemption. 

The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

photography, videography, and inspection.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 +.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 
2

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. John P. Creed is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. John P. Creed is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 +

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
4

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
7

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
John P. C reed - Exem ption/Rulem aking

This Other document was issued by the Federal Aviation Administration

(FAA)

For related information, Open Docket Folder 

C ontent

John P Creed 

8009 Cooke Rd 

Elkins Park, Pa. 19027 

April 22, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 205909 

To whom it may concern, 

This is an Exemption Request Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations from 14 CFR Part 21, 45.27

(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.105, 91.109, 

91.119, 91.121, 91.151, 91.405, 91.407, 91.409, 91.417. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.F.R. Part 11, I am personally preparing this document to 

request exemption from the above mentioned items to allow for the 

operation of a lightweight Unmanned Aircraft Systems (UAS) for use as 

a video and still imaging and inspection tool for my business in Home 

Improvements and related services. 

The exemption would pertain to the DJI Phantom 2 + Vision quad copter 

(UAS) with zenmuse and gimbal/camera attached (part of the original 

sales package). This is a lightweight quad copter that would operate at a 

height of no more than 400 feet and speeds less than 87 knots 

(100mph). As this tool would be used to take video and still images for 

inspection and Home Improvement projects, high rates of speed are 

unnecessary. Visual line of site (VLOS) rules would apply in all 

applications and proposed scenarios. A personal safety implementation 

would be to operate the system at or better than optimal weather 

conditions. The best safety feature of this system is that when the 

controls are released, the unit remains stationary until the PIC reingages the controls. It has a return home button that when utilized, the on 

board GPS system communicates with the control unit and safely 

returns the unit to its original lift off site. This unit would be operated with 

a 2 man team at all times, 1 to control the system (PIC) and the other as 

spotter and visual guide. The operation of this tool would not pose a 

threat to NAS or security and would never be flown in active air space or 

near any airport. Since the system requires no fuel, oil or a manned flight 

crew or any payload at any time there is no risk to the public, the 

operator or its team. This system would actually protect the public and 

contractors from future injury by eliminating the need for extension 

ladders and high reaching ground based equipment for Home 

 

C om m ent N ow !

ID: FAA-2015-1258-0001

D ocum ent Inform ati

Date Posted:

Apr 28, 2015

Show More Details 

Subm itter Inform atio

Submitter Name:

John Creed

Mailing Address:

8009 Cooke Rd

City:

Elkins Park

Country:

United States

State or Province:

PA

ZIP/Postal Code:

19027

C om m ents

0

D ocket Inform ation

This document is contained in

FAA-2015-1258

Related Dockets:

None

Related RINs:

None

Related Documents:

None

C om m ents Received

Regulations.gov - Other Document Page 1 of 3

http://www.regulations.gov/ 4/29/2015
Improvement or insurance inspections, thus eliminating or lessening 

insurance claims as a whole. This would result in lower pricing for many 

industries and would serve the public well. This system would never be 

used for anything other than work related items. 

I have had experience flying with these and other models and have 

some flight experience myself. I have always been extremely interested 

in flying and took a course once. I have over 120 hours of flight simulator 

experience as well as flying right seat on numerous occasions, both in 

state, over open ocean and cross country, with my brother who is a very 

experienced pilot. My brother and I would take his boat to and from 

Florida every 7 months from Massachusetts and my experience from my 

Navigation course at Massachusetts Maritime Academy has served me 

well both on the water and in the air as I was always the navigator that 

would assist my brother in flight. He and I believed that electronic 

equipment is essential but that a backup plan, a compass and a map 

never hurt. I try to follow these things I have learned over the years and 

take great pride in the fact that safety is always first. I look forward to 

continuing my aviation education in the years to come. 

It is my greatest hope that the use of UAS will increase in the future as 

long as it is properly regulated. I do not feel that usage of these craft for 

delivery purposes, as a whole, are necessary but in emergency 

situations I see a great benefit. A man who worked for me last summer 

had his son run away into a large park one evening. They asked the 

police for help and they kept a look out. They asked for a helicopter 

search but none was provided. The boy, Steven Salazar Jr, was found 

dead a week later not far from his home in Philadelphia. That has 

haunted me ever since. I know now that my time and my UAS will 

always be available to assist when a child goes missing. I see a great 

potential future in this industries infancy and firmly believe that these 

systems could actually save lives. Is there any greater good to the 

public? 

Since the quad copter has no flight crew, fuel or would carry passengers 

or payloads at any time I would seek relief from the above mentioned 

Regulations from 14 CFR. 

I have sent the following attachment to assist in your evaluation; 

1) DJI Phantom 2 + Vision Pilot Training Guide 

2) DJI Phantom 2 + Vision Quick Start Guide 

Please feel free to mail, email or call me at any time if you have any 

questions 

Sincerely, 

John P Creed 

Owner/operator John P Creed Painting & Home Repairs 

Rotogistics 

215-627-4610 

jpcpainting@gmail.com 

A ttachm ents (2) 

 This count refers to the total 

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yesterday. Note: Agencies revie

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View Attachment:

John P. C reed - Phantom 2 Vision Plus Pilot 

Training Guide

*

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View Attachment:

John P. C reed - Phantom 2 Vision Plus Q uick 

Start Guide

Regulations.gov - Other Document Page 3 of 3

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John P Creed

8009 Cooke Rd

Elkins Park, Pa. 19027

July 11, 2015

US Department of Transportation

Docket Management Facility

West Building Ground Floor

1200 New Jersey Avenue, S.E.

Washington, D.C. 20590

To whom it may concern,

In response to your letter for the request for additional information, dated July 1, 2015, I have prepared this 

document in the hope that I have supplied the items you have asked for in order to grant me an exemption to 

operate UAS’s for aerial data collection.

I seek relief and/or Exemption of Section 333 of the FAA Reform Act and part 11 of the Federal Aviation 

Regulations from 14 C.F.R. Part 21 Subpart H ,§§ 45.23, 45.27 (a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.23 (a)(c), 

61.113 (a)(b), 91.7, 91.9, 91.103, 91.105, 91.107, 91.109, 91.119 (c), 91.121, 91.151 (a) (1), 91.405 (a), 

91.407 (a) (1), 91.409 (a) (1) & (2), 91.417 (a) & (b) 

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

personally preparing this document to request exemption from the above mentioned items to allow for the 

operation of a small lightweight Unmanned Aircraft Systems s (UAS) for use as a video and still imaging, data 

collection and inspection tool for my business in Home Improvements and Media services. I seek relief 

because existing regulations would be an unnecessary burden to my business and the exemption would be in 

the public interest.

The FAA has the authority to grant exemptions from operating rules and regulations and the Secretary of 

Transportation has this authority based on section 333 of Public Law 112-95 in reference to the operation of 

UAS.

Exemptions sought from 14 CFR:

Part 21 Subpart H

This regulation requires the issuance of an Airworthiness Certificate for an aircraft operating in the National 

Air Space (NAS). The fact that my s(UAS) craft will operate in limited capacity and area and at a height no 

greater than 400 feet AGL, this situation meets the requirement of an equivalent level of safety under Part 11 

and section 333 of the Reform Act. Since the FAA has the authorization to grant exemptions based on the 

size, weight, speed, capabilities and proximity to airports and populated areas and given these criteria in 

relations to larger, manned aircraft, it is clear that the UAS will operate with a safety level greater than 

conventional aircraft.

Part 45 Identification and Registration Markings

§§ 45.23, 45.27 (a), 45.29 (3) (c)(d)(e)(f)(g)(h)
July 11, 2015

Page 2

With an exemption granted and given the size and operational restrictions for the UAS, an Airworthiness 

Certificate would not be required as (1) No ample space for registration markings and (2) no cabin or fuselage 

exists and the craft would not carry passengers or fuel and (3) the UAS is not a fix winged craft or rotorcraft 

§that meets size requirements.

Part 61 Medical Certificates

§§ 61.113 (a)(b), 61.23 (a)(c)

These regulations require pilots of manned aircraft to hold a medical certificate. Also private pilot privileges 

or Pilot in Command (PIC), limit private pilots to non-commercial operations. Since the UAS, given the size , 

weight and limitations, would not be carrying fuel or passengers and therefor would pose a decreased threat 

level as compared to manned aircraft. Based on these facts that the UAS will operate in a limited airspace, at 

minimal speeds less than 87 knots and 400 feet AGL (above ground level) or less and in non-congested 

airspace or near any airports the craft can safely be operated without a commercial pilots license.

Part 91 General Operating and Flight Rules

§§ 91.105, 91.107

Since the UAS is a small craft that does not carry or need a crew, passengers or have a cabin these rules 

would not be applicable.

§ 91.109 Flight Instruction

This rule states that no person can operate a civil aircraft that is utilized for flight instruction without the 

presence of dual controls. Since the UAS is not piloted and does not carry passengers flight instruction would 

not take place and is not possible. The craft is operated remotely by a hand held radio frequency control unit 

by a single person with a spotter and visual guide on ground level. This situation makes the operation of the

UAS at a far greater level of safety than conventional manned aircraft.

§§ 91.119 (c), 91.121, 91.151 (a) Minimal Safe Altitudes; Altimeter Settings; Fuel Requirements for Flight in 

VFR Conditions

Since the UAS will operate at a height no greater than 400 feet AGL, does not have an altimeter ( height and 

range of craft are regulated by GPS from ground control unit) and does not carry fuel and can only operate 

during daylight hours with VLOS (Visual Line of Sight) these regulations would not be applicable. Given the 

fact that the UAS does not carry fuel and is battery operated with a maximum flight time of 25 minutes a 30 

minute additional fuel capacity past destination point would not apply and since it would not fly in 

commercial air space it would not follow conventional aircraft VFR conditions.

§§ 91.405 (a), 91.407 (a) (1), 91.409 (a) (1)(2), 91.417 (a)(b) Maintenance Required; Operation After 

Maintenance; Inspections; Maintenance Records

This regulation would require maintenance of conventional aircraft to meet stipulations pertaining to Part 43. 

Since these apply to aircraft with an Air Worthiness Certificate it would not apply to the UAS. Maintenance 

would be performed as needed after inspections prior to and directly after each flight and as suggested by 

the manufacturer. Given the fact that the UAS would not be carrying a payload (other than camera) is 

lightweight and carries no fuel (battery powered) and has far fewer working parts than commercial aircraft, 

maintenance is minimal and can be done much safer. 
July 11, 2015

Page 3

National Security, Serving the Public Interest and Public Safety

It is for the greater good to the public, as a whole, to allow for the operation of small UAS for data collection, 

video and still imagery and inspections. Current standards and practices used for these actions involve the 

use of larger and more conventional manned aircraft which carry fuel and a larger payload and if mechanical 

failure were to occur would pose a greater threat to the public than UAS’s. It is also common knowledge that 

the use of ladders and other items for inspections have led to countless injuries and accidents that could 

have been avoided with the assistance of UAS’s. By utilizing UAS for these actions and data gathering it best 

serves The Public Interest by reducing injuries and accident and would also assist in lowering of liability and 

insurance claims and Hospital visits. A greater item that both serves the public interest and public safety is 

the fact that the UAS’s leave a small carbon footprint and has no harmful emissions and thus helps protect 

the environment and the public well-being. UAS’s will be operated in a controlled environment. In limited 

space, away from the general public, on private property with the client signing an agreement to proceed 

with the use of the UAS on his or her property. It will be safely operated at an altitude not to exceed 400 feet 

AGL (Above Ground Level) with a PIC and visual spotter at all times. It will be operated in fair weather 

conditions and only during daylight hours. The UAS has a maximum flight time of 25 minutes and no flight 

would exceed 20 minutes or with 25% remaining battery life (battery life is monitored remotely for every 

flight). The UAS will not be operated in the NAS of commercial flight paths nor will it operate near or around 

any airport, thus poses no threat to National Security. Because the UAS will be flown at low altitudes and low 

speeds and is lightweight and carries no fuel or payload or passengers the situation commands a far greater 

level of safety than commercial craft and thus serves Public Safety.

Safe Operation of UAS’s

Proper preparation and thought went into a procedural plan to operate UAS’s safely and efficiently to be 

utilized for data collection. Steps and protocols will be adhered to at all times. No operation will involve a 

threat to public safety or National Security. No operation will take place if proximity to the public is too close 

and will be cancelled or rescheduled to a time where there will be no safety issues. Everyone will be trained 

to be operators and visual spotters so that everyone has the knowledge to operate and safely bring down the 

UAS if any problems should occur. All operators will train with flight simulators and General Aviation 

knowledge to understand pitch, yaw and attitude of craft so as to better understand technical data and the 

standards of flight. No operation will commence unless a 2 person team is on site. All operations will be done 

at a height of no greater than 400 feet AGL, at low speeds less than 30 knots, with a PIC and visual spotter 

and the craft will have VLOS (Visual Line of Sight) at all times. Because the UAS is the DJI Phantom 2+ it has a 

“return home” feature that will safely return the craft to its lift off point should any problem occur. Another 

safety feature of the UAS is that when the remote control device is not engaged the craft will hover until it is 

directed to move in any particular fashion so if by chance the remote was dropped the craft would hover 

until re-engaged. UAS’s are small, lightweight and slow moving tools that leave a tiny carbon footprint, 

carries no dangerous fuels, leaves no emissions or toxic fumes is far safer than conventional aircraft, poses no 

threat to National Security, and Serves the Public Interest and Public Safety. 

In Summary
July 11, 2015

Page 4

I have asked for exemptions under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR Part 21, Subpart H

§§ 45.23, 45.27 (a), 45.29 (3) (c)(d)(e)(f)(g)(h)

Continuation of Requested Exemptions

§§ 91.105, 91. 107, 91.109, 91.119 (c), 91.121, 91.151 (a), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1)(2), 

§ 91.417 (a) (b)

Similar situations with other people seeking exemptions have been granted with similar craft. I feel I have 

satisfied and met the conditions and criteria provided in Section 333 of the Reform Act and ask that the FAA 

grant the above listed exemptions I have requested as soon as possible. 

Sincerely,

John P Creed

Owner/operator John P Creed Painting & Home Repairs

Rotogistics

215-627-4610

jpcpainting@gmail.com