Steve Fincher Photography 

6240 N. Pinnacle Dr. 

Spartanburg, S.C. 29303 

Cell:864-216-5083 

email: steve@fincherphoto.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

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Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

This application is being submitted on our own behalf without legal council or consulting services. 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.P.R. 

Part 11, Steve Fincher Photography Inc. does hereby apply for an exemption from the Federal Aviation Regulations to allow commercial use of small unmanned aerial systems ("sUAS") for the purpose of aerial photography 

and videography in the upstate area of South Carolina. 

Also, pursuant to 14 CPR§ 11.87, we request that the FAA not publish this petition request in the Federal Register and not delay action based on the following: 

1. This petition for exemption does not set precedent. Previous identical exemption requests have been approved. 

2. A delay in action on this petition would adversely affect pending requests for aerial photography operations 

and result in lost opportunity and wages as several of my clients have been approached or have currently used 

amateur photographers providing this service without FAA exemption., the competitive advantage for unapproved commercial sUAS operators exists and continues to grow every day. 

The requested exemption would authorize remote control low altitude operations using the 3DR Iris+. for still 

photography and video. These operations will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to current operations using large construction booms and camera attached cable operations. We are not looking to operate the Iris as an aircraft but as a low altitude hovering camera platform. No operation would ever enter airspace that would be occupied by traditional aircraft and would 

pose no risk to other aircraft. Steve Fincher Photography Inc, has established itself as a leader in commercial and 

aerial photography with 35 years in business. We currently use small manned aircraft as well as aerial booms and 

cable constucts to carry both still and video cameras. We would like to replace these with the use of a lightweight 

remote control camera UAS. This would also allow us to operate in a much more cost effective as well as a much 

safer manner as the UAS would be much safer to operate. It \~ould also allow us to acheive the low altitudes that 

are not possible to safely acheive with larger, heavier aircraft. We understand that there is a small risk associated 

with the use of UAV's but the risk posed by the crashing of a small plastic UAV is much less than the associated 

risk of dropping a heavy metal and glass camera or lens while flying from a helcopter or suspended from a crane 

or lift 100 feet in the air. 
Steve Fincher Photography Inc, serves clients that include automotive manufacturing, industrial manufacturing, architectural clients, construction companies, law enforcment, city, county and state agencies as well as 

many other commercial and industrial cleints. We photograph performance automobiles on the manufacturer's 

closed test facility, industrial equipment in use on construction sites, monthly construction progress recording, architectural photography, road and bridge construction, sports photography for manufactures of boating 

equipment, real estate, photographing events for schools and university's and many other uses. While some of 

these operations are conducted above 500 feet and are carried out using helicopters and small airplanes most of 

our photography is done at altitues below 100 feet, usually below surrounding tree level, never more than 200 

feet AGL. We currently use scissor lifts, booms and scaffolding platforms, run cable and electrical lines in order 

to get the just below roof top level or higher angles to meet our clients needs. All these needs could be meet 

\vith the simple use of a camera mounted UAS weighing less than 5 pounds. The safety factor alone should be 

enough to autorize an exemption. 

Examples of use: 

We photograph large groups of people, usually employees of an industrial plant or possibly the construction 

crew of a completed building, ect. These groups can be as small as 50 but sometimes will have several hundred 

in the group and is usually shot in front of a building or structure. In order to see the faces of everyone we need 

to shoot from and elevated angle of somewhere between 15 and 50 feet. This is usually accomplished by renting 

and hauling in a scissors lift of larger boom lift. The use of either of these requires finding a level surface which 

is sometimes hard to find and occasionally damages surrounding landscaping. This also requires the use of an 

operataor and use of safety harness, ect. With the use of a UAV we coud simply position the UAV, ascend to the 

required height, hit the hover switch, take the photos, hit the return to launch switch which would safely land 

the UAV. This would be much safer, more practical, more economical and could be accomplished without ever 

entering into any space that would be occupied by any other aircraft. 

Another use is in monthly construction progress photos. We photograph many construction sites on a monthly 

basis. One of the requirments of this is that we shoot from the same altitude and location each month. While 

we now try to accomlish this by flying at low alttitude with a small helicopter it would be much easier to do 

with the computer aided programming of the UAV. The Iris+ has the capability to setup waypoints on a map 

that would allow the UAV to automatically go to a predetermined location and altitude and take the photos. 

This could be saved and repeated in order to get exactly the same required photos each month which is almost 

impossible to achieve in a helicopter. The desired angle for this is always below 200 feet AGL. By using the UAV 

we are saving rental cost of the helicopter, fuel usage and the danger of flying a helicpoter over a constution site. 

The arcitectrual photography we do almost always requires elevated still photos as well as video. Currently this 

is accomplished vvith lifts, cranes and scaffolding with cables run to support cameras. In some case we have had 

to use vertical lifts as tall as 130 feet in order to get panaromic views required by the client. With the use of the 

UAV we could easily accomplish the same tasks in a much shorter time frame and without the need to rent and 

haul large pieces of equipment. At no time would we ever be in airspace occupied by any aircraft, usually this 

type of photography is done between 15 and 100 feet, hardly ever more than 50 feet above the surrounding tree 

level. The use of a 5 pound UAV would be far safer than all this heavy equipment. 

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We shoot photos and video of cars on a test track and boats on open water for advertising purposes. These require the use of low flying helcopters or trying to shoot from elevated platfo.rms on a moving boat which is very 

difficult and sometimes dangerous. We use car mounted cameras or shoot from elevated plaforms. All of this 

could be replaced with the use of a 5 pound UAV mounted camera. This would allow more accurate positioning 

and following of the vehicle without the need or danger of the helicopter or boats. The desired ~ti~de fo~ this 

is usually about 20 to SO feet which would not interfere with the operation of other aircraft and ts tmpossible to 

achieve in a helcopter but which could easily be done with the samll UAV. 
The UAS to be used: 

The 3DR Iris+ is a smallS pound UAS with an on-board GPS and related flight management software that allows 

the operator to safely and efficiently plan a mission in 30 and monitor it in real-time using Mission Planner 

Software. The software has built in limitations that keep the flight to Line of Sight, limit the aircraft to altitudes 

of no more than 400 feet. Additionally the software provides automatic land with return to home function in 

case oflow battery, GPS signal loss or also with the flip of a switch in case of an emergency. The 3DR Iris plus is 

electric powered with a flight time or no more than 20 minutes per battery so there is no flamable fuel onboard. 

Currently, this identical as well as similar lightweight, remote controlled UASs have been aaproved for exemption 

by the FAA, as well as many are legally operated by amateurs with no flight experience, safety plan or controls in 

place to prevent catastrophe. It is only logical to allow Steve Fincher Photography Inc. highly experienced remote 

control pilot, to operate similar lightweight UASs. Steve Fincher Photography notes that the airworthiness of the 

Iris+ has already been approved for exemption in many cases by the FAA. 

I request exemption for the requirement of a private pilots license since the UAS would never under any circumstances enter into controlled airspace. I feel that it places an unfair and unnecessary financial and safety burden 

to pay the thousnads of dollars and spend the required hours learning to fly a manned aircraft that I have no 

desire or intention of ever piloting. I feel it is unsafe to require me to fly solo in an aircraft that I never intend 

to operate. There is nothing about the training for manned flight in a small plane that prepares you to operate a 

small remote controlled UAV in the manner that I intend to use it. One of the main reasons for using the UAV 

is to stay out of manned aircraft and lift equipment, which under the best conditions put life at risk. While I can 

see uses of UAV's that might benefit from the training such as airspace rules and regualtions, weather condition, 

airport operations and procedures, ect .. I do not intend to operate in airspace that would be occupied by other 

aircraft, will not fly from one airport to another, will not operate in any conditions that would require advance 

knowlege of out of the area weather patterns or conditions. I would never fly to or from an airport, never have an 

on board pilot, crew or passengers. Weather would not be a serious consideration since we would never operate 

more than 200 feet AGL or at a distance of more than 1000 feet from the operator so the platform could land at a 

moments notice if weather were to change. Steve Fincher is the operator of the s UAV with 40 years of RC Aircraft 

experience and a member of the Academy of Model Aeronautics (AMA), Mr. Fincher is extremely concerned 

with safety in the operation of sUAS systems and has lOO's of hours operating small remote control aircraft as 

well as many hours operating the 3DR Iris+ which is the sUAS that will be used for both still photography and 

video. Steve Fincher has been operating lightweight model aircraft as a hobby for many years without incident 

and would like to formally request permission to fly its UASs commercially in the United States at altitudes 

below 200 feet to capture aerial photography and video without the requirement of a private pilots license. Each 

flight is flown Line of Sight (LOS) and always below 200 feet AG L. Predetermined, specifically marked areas of 

operation, over private property with the land owners permissionand corresponding current safety controls will 

allow Steve Fincher Photography Inc. to operate within current safety parameters. To date, Steve Fincher Photography Inc. has flown countless flights and has done so safely and successfully. Steve Fincher Photography Inc. 

exemption request would permit its operation of lightweight, unmanned (piloted by remote control) and comparatively inexpensive UASs in tightly controlled and limited airspace under 200 feet during daylight hours. 

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The 3DR Iris+ will be operated by Steve Fincher who has the following requirements: 

• Is a registered member of the AMA. 

• Has over 100 hours of flight time using the 3DR Iris+. 

• Has studied and complet~d the 3DR manufacturers online video instruction for the assembly, 

maintenance and repair of the Iris+. 

• Has studied and completed the 3DR manufacturers online video instruction for Pre-flight 

procedures, flight procedures including both software controlled as well as manual controlled 

flight and landing. The operator has logged over 100 hour of flight time with th Iris+. 

• Has studied and completed the 3DR manufacturers online video instruction for the use and pro 

gramming of flight patterns and flight procdures using both the Droidplanner and Mission 

Planner software that is used in flight planning for the Iris+. This software allows the flight to 

be pre-planned and programmed into the Iris+ which allow parameters to be set for maximum 

altitude, distance from pilot as well as many other parameters. This allows for the 

flight to be safely undertaked and controlled by the software but also allow with the flip 

of one switch return of complete control back to the pilot. 

• Has held a General Class Amateur Radio Operators License for over 30 years that gives a unique 

understanding of electronic circuitry for maintence and repair of the circuits used in the 

Iris+, transmitter and antenna lobe characteristics and radio frequency characeristics that 

help in understanding of RF interference as well as the limitations of the technology 

associated with remote control aircraft. 

• Has been flying model aircraft for over 40 years with 1 OO's of hours flying remote control craft. 

• Has been flying ultralight aircraft for over 20 years and has completed a certified 

training course including ground school for ultralight aircraft by Flight World, LLC . 

• 35 years experience shooting aerial photography from helicopters as well as small fixed wing air 

craft is very familiar with rules and regulations reguarding altitude, flight patterns around airports 

as well as other aircraft and communication with air traffic contollers when needed. 

• Has a valid driver's license 

• Steve Fincher Photography Inc. is covered with $2,000,000 of commercial insurance. 
Grant of the exemption to Steve Fincher Photography for use of the Iris+ will be subject to the following ope rating conditions. 

• Operations to be conducted over private, controlled-access, or public property where approved from an 

established fixed location with the portable ground station, and where we will post a sign near the ground station stating, "Aerial Photography in Progress- Remain Back 150 feet:' 

• Permission from the land owner/authority required before commencing any flight 

• Prior to the start of a flight, We will activate and use the VAS's global positioning system flight safety procedure and lost -link procedure to ensure return of the aircraft in the event of a lost link or compromised communication. 

• Operations must not interfere with manned aircraft operations, must yield the right of way to manned aircraft, 

and operators must See & Avoid other aircraft and obstacles at all times 

• Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours 

• Operations must remain within Visual Line of Sight (VLOS) and will be visually monitored at all times; 

• Visual Line of Sight operations guaranteed with a GPS geo-fence around operator of 0.15 miles 

• Flight ceiling pre-programed at 200 feet; 

• All operations conducted within 5 miles from an airport shall only be initiated after verbal coordination with 

the airport authority, or air traffic control when a control tower is present at the airport; 

• All operations shall comply with required permissions and permits established by territorial, state, county or 

city jurisdictions; including local law enforcement, fire, or other appropriate governmental agencies. 

• The Iris+ operations will be compliant with ex:isting safety procedures inherent to the activities of the related 

company. 

• The Iris+ plus will have a sticker with the name, address and phone number as well as the AMA 

membership number and insurance info of the operatior in case of an incident. 

• Operations of the platform would in most case stay slightly above surrounding tree level and all missions will 

be conducted below 200' AGL, and within a radius distance of 1000' from the portable ground station 

• In terms of proximity to the persons or structure being photographed, We may operate in a close proximity 

to the structure, and in some cases as close as 25' from the structure. On these occasions, we will operate at less 

than two miles per hour, making the risk of collision almost negligible . 

• Operations of the UAV while away from people and structures will never exceed 50 mph 

• All operations of the UAV will be performed by Steve Fincher, an experienced UAV operator 

• All operations will be covered by a minimum of $2,000,000 of commercial insurance 
Public Interest and Benefit Considerations. 

Aerial photography generally require use of a manned platform. Close-proximity aerial photography is difficult 

to do, and usually requires the use of a helicopter or slow-moving aircraft at an appropriate distance over a populated area. The operation must be conducted in VFR conditions, and adds aircraft in congested airspace. 

By using the small UAS, Steve Fincher Photography aims to provide the public with quality aerial photography 

services at a fraction of the cost involved with manned flight without entering or adding congestion to that airspace. Furthermore, the risks inherent with manned flight are significantly reduced where the aircraft conducting 

the operation is less than five pounds, remains below 200' AG L, and can operate within a very confined space on 

or directly over the location being photographed. Thus the public will be better served by having more affordable 

aerial imaging options available, and can be done more safely with the UAS than with traditional aircraft, boom 

and lifts. 

Why the Exemptions Would Not Adversely Affect Safety. 

The proposed operations will not adversely affect safety for many reasons. 

The operations will be conducted in airspace where there is typically no activity among other users of the NAS. 

Flights are limited to property over which the owner has requested that the Subject UAS operate, so the owners 

will be aware of the flight operation. We fully recognizes the dangers that a small UAV could pose to all types 

of manned aircraft. The operations we are proposing to undertake pending approval of this Exemption Request 

are operations where manned aircraft will not fly. There would be a rigid separation between where a manned 

aircraft can fly (particularly due to FAR 91.119 which establishes minimum safe altitudes, to include an absolute 

prohibition of operating an aircraft within 500' of any structure) and where we would operate the UA V. 

Second, the Subject UAS is simply not a large aircraft. Weighing in at a maximum of five pounds fully loaded, the 

likelihood that it would damage property or injure a person is low, even in the event of a mishap. Furthermore, 

aerial imaging is still something done via manned aircraft, and the risk there is at least equal to the risk posed by 

the proposed operation. Also, the UAS has inherent lost-link capabilities to bring it back to its operating base for 

each mission. It is a redundant system for a more foreseeable problem that could arise. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of2012--size, weight, speed, operating 

capabilities, proximity to airports and populated areas and operation within visual line of sight and national 

security- provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of applicant's sUAS in the commercial photography industry. Therefore we respectfully request 

an exepmtion for the use of the Iris+ as use of a remote control camera platform at altitudes of less than 200 feet 

AGL without the need of a private pilot license. 

Steve Fincher 

Steve Fincher Photography Inc.