IN THE MATTER OF: 

PETITION FILED BY 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

* REGULATORY DOCKET 

* NO. 

* 

ARTHUR RAY GRISSETT, JR. d/b/a * 

LORAY DRONES * 

FOR EXEMPTION FILED UNDER * 

SECTION 333 OF THE FAA * 

MODERNIZATION * 

AND REFORM ACT OF 2012 * 

SUBMITTED ON OCTOBER 7, 2015 

ARTHUR RAY GRISSETT, JR. D/B/A 

LORAY DRONES 

1572 HINES RD 

MORELAND, GA 30259 

(678) 949-7872 

raygrissett@gmail.com 
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR 

Part 11, Arthur Ray Grissett, Jr. d/b/a Loray Drones, operator of an Unmanned 

Aircraft System (UAS), hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of its UAS, so long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. I, Arthur Ray Grissett, Jr. d/b/a 

Loray Drones, request exemption from the following sections of Title 14, Code of 

Federal Regulations: 61.113(a)(b), 91.119(b)(c), 91.121, 91.151(a)(b), 91.405(a), 

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

Operations will be performed only at the request of and with the authorization and 

permission of clients or their authorized agents in order to facilitate commerce and raise 

awareness of the beneficial uses of small unmanned air systems. So long as such 

operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

I, Arthur Ray Grissett, Jr., have over 20 years of experience in the aviation industry 

and hold a commercial pilot's license. 

Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would operate in the following manner: 

Aerial photography and/or video for public and/or private use including real 

estate, architecture, land surveying, engineering and other related professional 

activities. 

Aerial inspection/photography of residential/commercial structures under 

contract with the owners or local governing authority. 

Aerial inspection/photography of residential/commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers. 

Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the 

local authorities or government has requested it by contract or donation. 

The ability to offer training to persons individually or belonging to both private 

and/or public organizations that have interests in the use and application of an 

UAS for the purpose of the safe operation of an UAS to enhance the safety of 

the National Airspace (NAS) as well as for the protection of the persons and 

property. 

Petitioner seeks an exemption to operate OJI Phantom 3 and OJI Inspire 1 UAS 

systems for compensation or hire within the NAS. The OJI Inspire 1 and the DJI 

Phantom 3 are vertical takeoff and landing with a ground control station utilizing 

electronic tablet or smart phone systems. 
The DJI Phantom 3 Professional and the OJ I Inspire 1 are highly successful consumer 

grade small rotorcrafts in the quadcopter configuration with an advertised weight of less 

than eight pounds designed primarily to carry a high definition camera. They have an 

advertised maximum speed of less than 30 knots and maximum climb rate of less than 

1200 fee per minute. It is powered by four electric motors with a distance between 

motors of less than 14 inches. It is controlled primarily through an FCC certified radio 

control unit. Real time video and telemetry information is transmitted back to a ground 

control station allowing the operator and/or PIC to monitor battery level, GPS signal 

strength, altitude and distance from PIC, camera imagery and control camera angle. 

They have fail safe modes of operation for either loss of RC or GPS signal. Altitude can 

be limited by the onboard flight controller and maximum altitude can be preprogrammed 

by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard 

flight controller will warn the pilot via telemetry and external lighting cues before 

reaching a low battery state. An automatic termination of flight and landing will be 

initiated when the battery reaches a predetermined low state. It is anticipated that 

flights will usually last less than 10 minutes. 

The DJI UAS Aircrafts will not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed and 

operational capacity. 

Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual 

Observer (VO). The PIC and VO will have been trained in operation of UAS and 

receive up-to-date information for the particular UAS to be operated. The PIC and VO 

will be able to communicate by voice or radio at all times. If the UAS loses 

communication with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a pre-determined location within a designated location and land 

autonomously. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather or emergencies. A preflight checklist will be developed and 

employed to ensure that the UAS airworthiness will be verified before launch. 

Airworthiness will be maintained by performance of routine inspections before each 

flight, maintaining flight and maintenance logs to record time on failure prone 

components. The risk of interference with another aircraft is minimal. UAS operations 

will be conducted at least five miles from any public airport. 

Given the small size of the UAS and the controlled environment in which they will be 

operating, the proposed operations will adhere to the Reform Act's safety requirements. 

The approval of this application presents no national security issues. Regarding the 

level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the 

grant of the requested exemption is in the public interest. The UAS will weigh less than 

55 lbs. and will have a maximum operating speed of no more than 50 mph. Flights will 

be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer 

(VO). Maximum flight time for each operational flight will be 25 minutes. Flights will be 
terminated at 25% battery power reserve or 25 minutes of flight time, whichever occurs 

first. Flights will be operated at an altitude of no more than 400 feet above ground level 

(AGL). 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft 

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 

in order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography. 

Aerial photography is a valuable marketing tool that can lead to increased commerce 

and use of pesticides and fertilizer and conservation of water as well as increased crop 

yields and decreased costs. Aerial surveying and inspections can increase work site 

efficiency, improve volumetric estimations and reduce risks. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. The granting of 

this petition will further the public interest by allowing me, Arthur Ray Grissett, Jr., to 

safely, efficiently and economically perform aerial photography and videography of real 

estate, construction sites, and landscape over certain areas of the United States. 

Additionally, use of the OJI UAS Aircrafts will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of 

petitioner's proposed operation of the OJI UAS aircrafts will be realized without 

implicating any privacy issues. 

In conclusion, said petitioner is requesting this exemption for the purposes of aerial 

photography, cinematography and videography. The primary purpose of seeking this 

exemption is to obtain the capability to offer those services while remaining in 

compliance with FAA regulations. 

Respectfully submitted this ih day of October, 2015.