FAA Section 333 Petition Request 21 August 2015

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Gary W. Ray, Jr.

157 Hickory Drive

Durant, OK 74701

Cell: 580.380.9327

uavairman@gmail.com

FAA

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

Dear Sir or Madam,

I, Gary W. Ray, Jr., am submitting my Petition for exemption/rulemaking: (Petitioning for Exemption 

under Section 333); (FAA Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, 

Section 333).

I am a certified Private Pilot (#3507762), have a current Third Class Medical (GX-1659391) and a valid 

Oklahoma driver’s license. I am knowledgeable in FARs, NOTAMs, TFRs, flight operations, aviation 

meteorology and safety.

My reason for this petition is to operate a UAS for commercial purposes in the United States. This would 

primarily provide UAS services for profit to potential clients. These services would be 

videography/photography/cinematography in the following areas: real estate, mapping, inspections, 

special events (public or private), sporting events, business advertisements, promotional events, and 

any other event to supply an aerial view for the general public and businesses.

I am currently seeking exemption from: Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 

61.113(a) and (b), 61.133(a), 91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) 

and (b), 91.319(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b).

I am seeking an exemption for the use of a UAS up to 55 pounds. The primary UAS is a DJI Phantom 3 

Professional. Due to the size of the operational manual it can be located at http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en.pdf . 

However, the size, weight and performance specifications have been conveniently listed below:

 Gross Weight- 1,280g

 Diagonal Size, which include props- 590mm

 Max. Ascent Speed- 5m/sec.

 Max. Descent Speed- 3m/sec.

 Vertical Hover Accuracy- +/-10cm

 Horizontal Hover Accuracy- +/-1m

 Max. Speed- 16m/sec

This unit is equipped with GPS/GLONASS and is controlled by a 2.4 GHz transmitter and has a Return To 

Home feature that returns to the take-off location in the event of loss of signal from the remote control. 
FAA Section 333 Petition Request 21 August 2015

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There are a lot of safety features on this model, which include: no-fly zones for controlled airports, exact 

location given with height (AGL +10’), speed indicator and battery life given in percentage and remaining 

minutes until return to home is initiated. 

Safe flight operations is my main concern, which would consist of other aircraft (they always have the 

right of way), public safety (never fly over crowds and stay a safe distance from people on the ground), 

and preflight and post flight check lists (See Attachment). Flight operations will end at 20 minutes or 

25% battery life, whichever occurs first. Under no circumstance, will any flight occur during Instrument 

Meteorological Conditions (IMC). Operations will be performed with VLOS and have a competent 

Visual Observer (VO) near-by and able to communicate to the PIC via voice or radio communications. If 

the equipment is found to be unsafe during pre or post inspection then it will be grounded immediately. 

The equipment will be repaired and tested to make sure it can operate safely, which all maintenance 

and repairs will be logged in aircraft’s records.

This exemption will allow me to provide aerial services to business and the public at a lower cost than 

previously contracted manned aircraft. Therefore, this would supply a safer and lower cost to the public 

for aerial videography/photography/cinematography than previously available to them. I look forward 

in receiving this exemption and helping to make UAS flights much safer and more accessible to 

businesses/general public.

Thanks for the consideration,

Gary W. Ray, Jr.