David	 Wiltshire,	 ATP	 Pilot	 Helicopter	 /	 ATP	 Pilot	 Multi-Engine	 Airplane - Section	 333	

Exemption	Petition for	Aerial	Data	Collection

Jan	5,	2016

U.	S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave,	SE

Washington,	DC	20590

Re:	 Exemption	 Request	 Section	 333	 of	 the	 FAA	 Reform	 Act	 of	 the	 Federal	 Aviation	 Regulations	 from	 14 C.F.R.	

45.23(b);	 14	 C.F.R.	 Part	 21;	 14	 C.F.R.	 61.113(a)&(b);	 91.7(a);	 91.9(b)	 (2);	 91.103(b);	 91.109; 119.121;	 91.151(a);	

91.203(a)&(b);	91.405(a);	91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)

Dear	Sir	or	Madam,

I,	David	Wiltshire,	am	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012	and	

the	procedures	contained	within	14	C.F.R.	11,	to	request	that	I,	David	Wiltshire,	an	owner	and	

operator	of	small	unmanned	aircraft,	be	exempted	from	the	Federal	Aviation	Regulations	

(“FARs”)	listed	below	so	that	I,	David	Wiltshire,	may	operate	my	small	ultra	light	weight	

unmanned	aircraft	system	(“UAS”)	commercially	in	airspace	regulated	by	the	Federal	Aviation

Administration	(“FAA”). The	FAA	has	issued	grants	of	exemption	in	circumstances	similar	in	all	

material	respects	to	those	presented	in	my petition.	(In	Grants	of	Exemption, Nos.	11138	to	

Douglas	Trudeau	(see	Docket	No.	FAA-2014- 0481),	Nos.	11062	to	Astraeus	Aerial	(see	Docket	

No.	FAA−2014−0352),	11109	to	Clayco,	Inc.	(see	Docket	No.	FAA−2014−0507),	 the	FAA	found	

that	the	enhanced	safety	achieved	using	an	unmanned	aircraft	(UAS)	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,	lends	good	

cause	to	find	that	the	UAS	operation	enabled	by	this	exemption	is	in	the	public	interest.	

As	described	herein	I,	David	Wiltshire,	am	a	FAA	Certified	ATP	Helicopter	and	ATP	Airplane	Pilot

with	Commercial	Privileges.	I	also	hold,	Instructor	Ratings	CFI,	CFII,	SEL,	and	MEL.	I	have	

accumulated	8800	hours	of	flight	experience in manned airplanes	and	helicopters without	

incident.	

I	am	a	member	of	AMA	with	experience	flying hobby	helicopters and	airplanes for	recreational	

purposes.	I	have	added (DJI	Phantom	3	Professional) a	hobby	grade	quad-copter		1			UAS	to	my	

inventory	equipped	with a 2.7/12 Megapixel	Camera	with	intent	to	conduct aerial	videography,	

cinematography,	photography,	videography,	surveying	of	boats,	real	estate,	agriculture,	

structural	inspections,	bridge	inspections,	remote	structure	inspections, landscape,	etc.,

																																																												 1	 DJI	Phantom	3	Professional
following	exemption	and	approval	by	the	FAA.	 I	plan	to	add	a	second	quad-copter,	(DJI	Inspire	

1)	 2			to	my	inventory	in	the near future	with	comparable	safety	capabilities.

I,	David	Wiltshire, have	flown	small	RC	electric	helicopters and	airplanes in	past	years	without	

incident.	 I	 am	 committed	 to	 safety	 with	 each	 flight.	My,	David	Wiltshire,	 exemption	 request	

would	 permit	 operation	 of	 ultra	 light	 weight,	 unmanned less	 than	 55	 lbs. (piloted	 by	 remote	

control)	 and	 comparatively	 inexpensive	 UAS(s)	 in	 tightly	 controlled	 and	 limited	 airspace.	

Conducting	predetermined	operation	in	areas	away	from	general	public,	airports,	heliports	and	

vehicular	traffic	for	community	videos,	and	within	property	boundaries	for	individual	homeowner	

real	 estate	 listing	 videos/photos.	 Currently,	 similar	 lightweight,	 remote	 controlled	 UAS's	 are	

legally	operated	by	unmonitored	amateur	hobbyists	with	no	safety	plan	or	controls	in	place	to	

prevent	catastrophe.	I,	David	Wiltshire,	have	personally	instilled	safety	protocols	and	controlsto	

avoid	and	prevent	public	hazard,	as	well	as	manned	aircraft	hazards/catastrophe.	This	will	act	to	

further	 safety	 protocols	 exclusive	 to	 lightweight	 UAS's	 specific	 to	 real	 estate	 video	 and	

photography	usage	as	I,	David	Wiltshire,	record	flight	data	and	other	information	gained	through	

permitted	flight	operations	to	share	with	the	FAA	through	any	required	FAA	reports	to	assist	with	

future	protocol	and	safety	regulation.

Granting	 my,	 David	 Wiltshire,	 request	 comports	 with	 the	 Secretary	 of	 Transportation’s	 (FAA	

Administrator’s)	 responsibilities	 and	 authority	 to	 not	 only	 integrate	 UAS's	 into	 the	 national	

airspace	system,	but	to	“...establish	requirements	for	the	safe	operation	of	such	aircraft	systems	

[UAS's]	in	the	national	airspace	system”	under	Section	333(c)	of	the	Reform	Act	specific	to	the	

use	 of	 UAS's	 for	 Aerial	 Data	 Collection purposes.	 Further	 I,	David	 Wiltshire,	 will	 conduct	 my	

operations	in	compliance	with	the	protocols	described	herein	or	as	otherwise	established	by	the	

FAA.	 For	 the	 reasons	 stated	 below	 I,	 David	 Wiltshire,	 respectfully	 request	 the	 grant	 of	 an

exemption	 allowing	 me	 to	 operate	 ultra	 light	 weight,	 remote	 controlled	 UAS’s	 for	 academic	

community	awareness	to	benefit/stimulate	attraction	to	the	Wiregrass area	and	to	enhance	real	

estate	listing	videos	for	homeowners	who	cannot	afford	expensive	manned	aircraft	for	the	same	

purpose.	Both	of	which	will	promote	local	economic	growth	through	increased	employment	and	

increased	tax	base.	Both	with	public	safety	in	mind	by	keeping	heavier	manned	aircraft	containing	

combustible	fuel that	that	poses	potential	public	hazard.

I.	Contact	Information:

David	Wiltshire,	Commercial Pilot

407	Eton	Drive

Dothan,	Alabama	36305

Office:	(334)	701-0350

Mobile:	(334)	701-0128

Email:	Wilt373@gmail.com

II.	 The	 Specific	 Sections	 of	 Title	 14	 of	 the	 Code	 of	 Federal	 Regulations	 from	 which	 David	

Wiltshire Requests	Exemption	are:

																																																												 								

2	-DJI	Inspire	1
14	CFR	21;

14	C.F.R.	45.23(b);

14	CFR	61.113	(a)	&	(b);

14	C.F.R.	91,	et	seq.;

14	CFR	407	(a)	(1);

14	CFR	409	(a)	(2);	and,

14	CFR	417	(a)	&	(b).

III.	The	Extent	of	relief	David	Wiltshire seeks	and	the	Reason	I	Seek Such	Relief:

I,	David	Wiltshire,	submit	this	application	in	accordance	with	the	Reform	Act,	112	P.L.	95	§§	331-

334,	seeking	relief	from	any	currently	applicable	FARs	operating	to	prevent	me,	David	Wiltshire,	

contemplated	commercial	cinematic,	academic	and	other	flight	operations	within	the	national	

airspace	system.	The	Reform	Act	in	Section	333 provides	for	such	integration	of	civil	unmanned	

aircraft	systems	into	our	national	airspace	system	as	it	is	in	the	public’s	interest	to	do	so.	My,	

David	Wiltshire’s,	ultra	light	weight	UAS	meets	 the	definition	of	“small	unmanned	aircraft”	as	

defined	in	Section	331 and	 therefore	 the	integration	of	my	ultra	light	weight	UAS	is	expressly	

contemplated	by	the	Reform	Act.	I	would	like	to	operate	my	ultra	light	weight	UAS	prior	to	the	

time	period	by	which	the	Reform	Act	requires	the	FAA	to	promulgate	rules	governing	such	craft.	

Thereby,	providing	direct	experience	and	valuable	information	for	formal	regulation	that	can	be	

administered	uniformly	 to	all	 real	estate, agriculture,	structural	and bridge	inspections,	 remote	

structure	inspections, landscaping related	UAS	aerial	video	and	photography.	The	Reform	Act	guides	

the	Secretary	in	determining	the	types	of	UAS's	that	may	operate	safely	in	our	national	airspace	

system.	 Considerations	 include:	 The	 weight,	 size,	 speed	 and	 overall	 capabilities	 of	 the	UAS's;	

Whether	the	UAS	will	be	operated	near	airports	or heavily	populated	areas;	and,	whether	the	

UAS	will	be	operated	by	line	of	sight.	112	P.L.	95	§	333	(a).	Each	of	these	items	reflect	in	favor	of	

an	exemption	 for	me,	David	Wiltshire. My	UAS	utilizes	 four	 (4)	counter-rotating	propellers	 for	

balance,	control	and	stability.	My	UAS	is	equipped	with	GPS	and	auto	return	safety	technology.	

Weighing	less	than	Ten	(10)	pounds	(far	below	the	maximum	55-pound limit);	including	camera	

with	gimbal.

I,	David	Wiltshire,	consider	safety	as	 foremost	with	each	 flight.	My	small	unmanned	aircraft	is	

designed	to	hover	in	place	via	GPS	and	operate	in	less	than	a	24	knot	(15	mph)	wind.	For	safety,	

stability	and	fear	of	financial	loss	I	will	not	fly	in	winds	exceeding	16	knot (10	mph).	Built	in	safety	

systems	 include	 a	 GPS	 mode	 that	 allows	 my	 UAS	 to	 hover	 in	 place	 when	 radio	 controls	 are	

released.	 With	 three	 modes	 to	 choose	 from,	 I	 utilize	 the	 GPS	 mode 3 for	 aerial	

videography/photography.	This	is	the	safest,	most	reliable	and	stable	mode	to	prevent	accident	

and	hazard.	When	pilot	communication	is	lost	this	UAS	is	designed	to	slowly	descend	to	the	home	

point	of	take	off.	I	do	not	operate	my	UAS	near	airports,	hospitals	nor	police	heliports,	and	do	

																																																												 3 GPS	Mode	includes	safe	circle	for	operation,	position	hold,	self-leveling,	altitude	command,	GPS,	return	home	feature,	and	safety

control	to	return	home	or	land	in	the	event	of	communication	interruption	between	RC	transmitter	and	UAS.	See	Appendix	A	-

Operator	Manual.
not	 operate	 near	 areas	 where	 general	 public	 is	 within	 fifty	 to	 one	 hundred	 (50-100)	 yards	

depending	on	location,	conditions	and	weather.	I	am	constantly	on	alert	for any	manned	aircraft	

(Police/Medical	 helicopters,	etc.)	and	 prepared	 to	land/abort	immediately	 to	 the	 nearest	and	

safest	ground	point	should	a	manned	aircraft	approach	my	location	or	I	suspect	manned	aircraft	

may	approach	near	my	location.	My	UAS	is	capable	of	vertical	and	horizontal	operations,	and	are	

flown	 only	within	my	line	 of	 sight	 of	me,	as	 the	 remote	 control	 pilot.	Utilizing	 battery	 power	

rather	 than	combustible	 fuels,	 flights generally	last	between	eight (8)	 to	twelve (12)	minutes,	

with	an	altitude	under	one	hundred	fifty	(150)	feet.	I,	David	Wiltshire,	utilize	a	fresh	fully	charged	

battery	with	each	flight	as	a	safety	precaution;	full	flight	time	limit	for	each	battery	is	twenty	(20)	

to	 twenty-three (23)	 minutes	 as	 tested.	 I	 do	 not	 operate	 my	 UAS	 at	 or	 below	 manufacture	

recommend	 minimum	 charge	 levels	 for	 operation;	 preferring	 to	 remain	 well	 within	 a	 safe	

operating	range,	line	of	sight	(LOS), to	insure	adequate	communication	between	radio	control	

and	UAS	to	eliminate	potential	for	crash,	loss	of	control	or	hazard.	Reserve	batteries	are	at	hand	

with	each	exercise	to	insure	replacement	for	sufficient	safe	level	of	operation.	I	do	not	believe	in	

taking	 risk	 that	 may	 cause	 a	 crash,	 that	 could	 create	 hazard	 to	 the	 public/property/manned	

aircraft,	and	have	no	desire	to	lose	an	investment.	In	addition	to	the	thousands	of	hours	I	have	

logged	in	manned	helicopters	and	airplanes,	I	have	clocked	numerous	practice	flights	in	remote	

areas	as	a	drone	hobbyist	simulating	flights	for	future commercial	use	to	gain	familiarization	with	

the	characteristics	of	this	specific	UAS's	performance	under	different	temperature	and	weather	

conditions.	I	have	logged in	excess	of	50	hours	in	DJI’s	make	and	model, specific	UAS	I	plan	to	

operate	for	hire.	I	also	practice	computerized	simulated	flights	to maintain	adequate	skills	and	

response	reflex	time.	In	order	to	hone	my	skills	and	enhance	my	knowledge	of	the	current	rules	

and	 regulations I	 physically	 attended	 DartDrones	 Flight	 Academy. I	 have	 also	 taken	

comprehensive	 and	 mastery	 courses	 online by the companies DroneU	 and	 UAV.	 	 	 Finally,	 I	

satisfactorily completed	the	course	of	study	and	have	passed	the	required	examination	Flying,	

Controlling,	Maneuvering	the	UAS	offered	by, National	Drone	School,	all for	the	sake	of	safety. I	

will	also	obtain	quad-copter	liability insurance in	the	event	of	unforeseen issues that	may	arise.	

I,	David	Wiltshire,	will	use	the	app	WingX	Pro	or	similar	as	a	tool	to	file	NOTAMS to	keep	my	fellow	

aviators	informed	of	drone	activity,	to	further	enhance	safety.	

I, David	Wiltshire, hold a	current	Medical	Certificate	First	Class.

I,	David	Wiltshire,	am	extremely	cautious	when	operating	of	my	UAS/ultra	light	weight	unmanned	

aircraft	and	will	not	“create	a	hazard	to	users	of	the	national	airspace	system	or	the	public.”	112	

P.L.	 95	 §	 333	 (b).	 Given	 the	 small	 size	 and	 weight	 of	 my	 UAS	 it	 falls	 well	 within	 Congress’s	

contemplated	safety	zone	when	it	promulgated	the	Reform	Act	and	the	corresponding	directive	

to	integrate	UAS's	into	the	national	airspace	system.	David	Wiltshire’s UAS,	used	in	hobby	flight,	

has	a	demonstrable	safety	record	and	does	not	pose	any	threat	to	the	general	public	or	national	

security.

IV.	How	David	Wiltshire’s Request	Will	Benefit	the	Public	as	a Whole:
Aerial	videography	for	geographical	awareness	and	for	real	estate	marketing	has	been	around	

for	a	long	time	through	manned	fixed wing	aircraft	and	helicopters.	For	small	budget	real	estate	

companies	and	average	homeowners	the	expense	of	such	aerial	videography	is	cost	prohibitive.	

Only	large	companies	and	high	end	Realtors	or	luxury	homeowners	can	afford	 to	absorb	such	

expense.	 Depriving	 non-luxury	 homeowners	 and	 lower	 budget	 Realtors	 from	 a	 valuable	

marketing	tool.	Manned	aircraft	pose	a	threat	to	the	public	through	potential	catastrophic	crash	

that	 the	Wiregrass community	 has	experienced	 in	 the	 past	 with	military	 aircraft	 and	medical	

helicopter	crashes	within	the	Wiregrass	area.	Each	resulting	in	loss	of	life.	Each	with	combustible	

fuel	that	exploded	and	burned	on	impact.	Police	helicopters	have	made	emergency	hard	landings	

within	 city	 limits.	 My,	 David	 Wiltshire’s,	 UAS	 pose	 no	 such	 threat	 since	 size	 and	 lack	 of	

combustible	fuel	alleviates	any	potential	threat	to	the	public.	Congress	has	already	proclaimed	

that	it	is	in	the	public’s	interest	to	integrate	commercially	flown	UAS's	into	the	national	airspace	

system,	hence	the	passing	of	the	Reform	Act.	Granting	my,	David	Wiltshire’s,	exemption	request	

furthers	the	public	interest	through	academic/visual	awareness	of	the	geographical	benefits	in	

and	around	 the	Wiregrass area.	My	ultra	light	weight	UAS	is	battery	powered	and	creates	no	

emissions	that	can	harm	the	environment.	The	consequence	of	my	ultra	light	weight	UAS	crashing	

is	far	less	than	a	full	size	helicopter	or	fixed	wing	aircraft;	which	are	heavy,	contain	combustible	

fuel	and	can	cause	catastrophic	devastation	to	the	public.

The	public’s	interest	is	furthered	by	minimizing	ecological	and	crash	threat	by	permitting	aerial	

video/photo	capture	through	my	battery	operated	ultra	light	weight	UAS's.	Permitting	me,	David	

Wiltshire,	to	immediately	 fly	within	national	air	space	 furthers	economic	growth.	Granting	my	

exemption	request	substantially	furthers	the	economic	impact	for	the	Wiregrass community	for	

companies	looking	 to	 relocate	 or	 build	in	 the	Wiregrass	area as	well	as	individuals	looking	 to	

relocate	for	career	advancement	through	academic	and	geographical	awareness.	Both	of	which	

serve	as	a	stimulus	to	the	community.

V.	 Reasons	 Why	David	 Wiltshire’s	 Exemption	 Will	 Not	 Adversely	 Affect	 Safety	 or	 How	 the	

Exemption	Will	Provide	a	Level	of	Safety	at Least	Equal	to Existing	Rule:

My,	David	Wiltshire’s,	 exemption	 will	 not	 adversely	 affect	 safety.	Quite	 the	 contrary,	 for	 the	

reasons	stated	permitting	me,	David	Wiltshire,	to	log	more	flight	time	in	FAA	controlled	airspace,	

with	 communication	 with	 the	 FAA,	 will	 allow	 me	 to	 contribute	 to	 the	 innovation	 and	

implementation	of	new	and	novel,	as	of	yet	undiscovered	safety	protocols	for	Realtors	that	can	

be	embraced	by	the	NAR		 4		,	AAR		,	and	TAR			for	development	in	cooperation	with	the	FAA.	In	

addition, I,	David	Wiltshire,	submit	 the	 following	 representations	of	enhancements	 to	current	

aerial	 videography	 and	 photography	 for	 real	 estate,	 aerial	 videography,	 cinematography,	

photography,	 videography,	 surveying	 of	 boats,	 real	 estate,	 agriculture,	structural	 inspections,	

bridge	inspections,	remote	structure	inspections, landscape,	etc.,

My,	David	Wiltshire’s	UAS	weighs	less	than	5	pounds	complete	with	a	small	ultra	light	weight	high	

quality	 camera;	 I	 only	 operate	 my	 UAS	 below	 200 feet, (well	 within	 the	 400-foot permissible	

																																																												 4 National	Association	of	Realtors,	http://www.realtor.org/
ceiling	set	by	the	FAA	Modernization	and	Reform	Act	of	2012);	my	UAS	only	operate	for	15-18	

minutes per	 flight;	I	will	land	my	UAS	prior	 to	manufacturer	 recommended	minimum	level	of	

battery	power;

• The	UAS will	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.	

• The	UAS will	not	be operated	at	a	speed	exceeding	87	knots	(100	miles	per	hour).	The	

exemption	holder	will use	either	groundspeed	or	calibrated	airspeed	to	determine	

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

airspeeds	greater	than	the	maximum	UAS operating	airspeed	recommended	by	the	

aircraft	manufacturer.	

• The	UAS will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	

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

• My	operations	will utilize	a	visual	observer	(VO).	The	UA	will be	operated	within	the	

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

the	VLOS	requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	and	

PIC	will be	able	to	communicate	verbally	at	all	times;	electronic	messaging	or	texting	will	

not	occur 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.	

• The	operating	documents	will be	accessible	during	UAS	operations	and	made	available	

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

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

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

Otherwise,	I,	David	Wiltshire,	the operator	will follow	the	procedures	as	outlined	in	its	

operating	documents.	I will update	or	revise	its	operating	documents	as	necessary.	 It	is	

my responsibility	to	track	such	revisions	and	present	updated	and	revised	documents	to	

the	Administrator	or	any	law	enforcement	official	upon	request.	I,	David	Wiltshire, will

also	present	updated	and	revised	documents	if	it	petitions	for	extension	or	amendment	

to	this	grant	of	exemption.	If	I,	David	Wiltshire, determines	that	any	update	or	revision	

would	affect	the	basis	upon	which	the	FAA	granted	this	exemption,	then	the	I will

petition	for	an	amendment	to	its	grant	of	exemption.	The	FAA’s	UAS	Integration	Office	

(AFS−80)	will be	contacted	if	questions	arise	regarding	updates	or	revisions	to	the	

operating	documents.	

• Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	operation	

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

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

Functional	test	flights	will be	conducted	by	a	PIC	with	a	VO	and	must	remain	at	least	500	

feet	from	other	people.	The	functional	test	flight	will be	conducted	in such	a	manner	so	

as	to	not	pose	an	undue	hazard	to	persons	and	property.	
• I,	David	Wiltshire,	is	responsible	for	maintaining	and	inspecting	the	UAS	to	ensure	that	it	

is	in	a	condition	for	safe	operation.	

• Prior	to	each	flight,	the	PIC	will conduct	a	pre-flight	inspection	and	determine	the	UAS	is	

in	a	condition	for	safe	flight.	The	pre-flight	inspection	will 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	will	not	be	

operated until	the	necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	

be	in	a	condition	for	safe	flight.	

• I,	David	Wiltshire, will follow	the	UAS	manufacturer’s	maintenance,	overhaul,	

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

components.	

• Each	UAS	operated	under	this	exemption	will comply	with	all	manufacturer	safety	

bulletins.	

• The PIC	will hold	either	an	airline	transport,	commercial,	private,	recreational,	or	sport	

pilot	certificate.	The	PIC	will 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	will also	meet	the	flight	review	

requirements	specified	in14	CFR	§	61.56	in	an	aircraft	in	which	the	PIC	is	rated	on	his	or	

her	pilot	certificate.	

• I,	David	Wiltshire, will not	permit	another PIC	to	operate	unless	that 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	will be	logged	in	a	manner	consistent	with	14	CFR	

§	61.51(b).	Flights	for	the	purposes	of	training	the	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	will operate	the	UAS with	appropriate	distance	from	

nonparticipants	in	accordance	with	14	CFR	§	91.119.	

• UAS	operations	will 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.	

• The	UAS will 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.	
• The	UAS will 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.	

• If	my	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS will return	to	a	predetermined	location	within	the	private	or	controlled-access	property.	

• The	PIC	will abort	the	flight	in	the	event	of	unpredicted	obstacles	or	emergencies.	

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

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

holder	will apply	for	a	new	or	amended	COA	if	it	intends	to	conduct	operations	that	

cannot	be	conducted	under	the	terms	of	the	enclosed	COA.	

• All	my	aircraft	will	be	operated	in	accordance	with	the exemption	will 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	will be	as	

large	as	practicable.	

• Documents used to	ensure	the	safe	operation	and	flight	of	the	UAS	and	any	documents	

required	under	14	CFR	§§	91.9	and	91.203	will be	available	to	the	PIC	at	the	Ground	

Control	Station	of	the	UAS	any	time	the	aircraft	is	operating.

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

official	upon	request.	

• The	UAS will remain	clear	and	give	way	to	all	manned	aviation	operations	and	activities	

at	all	times.	

• The	UAS	will not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.	

• All	Flight	operations	will be	conducted	at	least	500	feet	from	all	nonparticipating	

persons,	vessels,	vehicles,	and	structures	unless:	

o 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	will cease	immediately	in	a	manner	

ensuring	the	safety	of	nonparticipating	persons.

o The	owner/controller	of	any	vessels,	vehicles,	or	structures	will	obtain

permission	for	operating	closer	to	those	objects	and	the	PIC	will	ensure	a safety	

assessment	of	the	risk	of	operating	closer	to	those	objects	and	determined	that	

it	will not	present	an	undue	hazard.	

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

persons	under	the	requested exemption.	

• All	operations	will 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.	

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

boundaries	of	the	operational	area	as	defined	by	the	applicable	COA	will be	reported	to	
the	FAA's	UAS	Integration	Office	(AFS−80)	within	24	hours.	Accidents	will be	reported	to	

the	National	Transportation	Safety	Board	(NTSB)	per	instructions contained	on	the	NTSB	

Web	site.

My,	David	Wiltshire,safety	protocols	provide	a	level	of	safety	equal	to	or	exceeding	existing	rules.	

It	is	important	to	note	that	absent	the	integration	of	commercial	UAS	into	our	national	airspace	

system,	 helicopters	 are	 the	 primary	 means	 of	 aerial	 video	 and	 photography	 for community	

awareness	and	real	estate.	While	the	safety	record	of	such	helicopters	is	remarkably	astounding,	

there	has	been	local	incident	involving	loss	of	life	as	well	as	extensive	property	damage;	it	is	far	

safer	to	operate	a	battery	powered	ultra	light	weight	UAS.

First,	the	potential	loss	of	life	is	diminished	because	UAS's	carry	no	people	on	board	and	I	only	

operate my	UAS	in	specific	areas	away	from	mass	populations.	Second,	there	is	no	fuel	on	board	

a	UAS	and	thus	the	potential	for	fire	or	explosions	is	greatly	diminished.	Third,	the	small	size	and	

extreme	maneuverability	of	my	UAS	allow	me	 to	remotely	pilot	away	 from	and	avoid	hazards	

quickly	and	safely.	Lastly,	given	its	small	size	and	weight,	even	when	close	enough	 to	capture	

amazing	images,	my	UAS	need	not	be	so	close	to	the	objects	they	are	focused	on	through	the	

technology	and	use	of	post	editing	software	allowing	pan	and	zoom.

Accordingly,	my	UAS	has	been	experimentally	operated	for	familiarization/competency	and	will	

continue	to	operate	at	and	above	current	safety	levels.

VI.	A	Summary	The	FAA	May	Publish	in	the	Federal	Register:

A.	14	C.F.R.	21	and	14	C.F.R.	91:	Airworthiness	Certificates,	Manuals	and	The	Like.	14	C.F.R.	21,	

Subpart	 H,	 entitled	 Airworthiness	 Certificates,	 sets	 forth	 requirements	 for	 procurement	 of	

necessary	 airworthiness	 certificates	 in	 relation	 to	 FAR	 §	 91.203(a)(1).	 The	 size,	 weight	 and	

enclosed	operational	area	of	my,	David	Wiltshire’s,	UAS	permits	exemption	from	Part	21	because	

my	UAS	meets	(and	exceeds)	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	Reform	

Act.	 The	 FAA	 is	 authorized	 to	 exempt	 aircraft	 from	 the	 airworthiness	 certificate	 requirement	

under	both	 the	Act	 (49	U.S.C.	§	44701	 (f))	and	Section	333	of	 the	Reform	Act.	Both	pieces	of	

legislation	 permit	 the	FAA	 to	exempt	UAS's	 from	 the	airworthiness	 certificate	 requirement	in	

consideration	of	the	weight,	size,	speed,	maneuverability	and	proximity	to	areas	such	as	airports	

and	dense	populations.	My,	David	Wiltshire’s,	current	and	projected	UAS's	meet	or	exceed	each	

of	the	elements.

14	C.F.R.	91.7(a)	prohibits	the	operation	of	an	aircraft	without	an	airworthiness	certificate.	As	no	

such	 certificate	 will	 be	 applicable	 in	 the	 form	 contemplated	 by	 the	 FARs,	 this	 Regulation	 is	

inapplicable.		14	C.F.R.	§	91.9	(b)	(2)	requires	an	aircraft	flight	manual	in	the	aircraft.	As	there	are	

no	on	board	pilots	or	passengers,	and	given	the	size	of	the	UAS's,	this	Regulation	is	inapplicable.	

An	equivalent	level	of	safety	will	be	achieved	by	maintaining	a	safety/flight	manual	delineating	
areas	 of	 where	 safety	 can	 be	 defined.	 5 	 	 The	 FAA	 has	 previously	 issued	 exemptions	 to	 this	

regulation	 in	 Exemption	 Nos.	 8607,	 8737,	 8738,	 9299,	 9299A,	 9565,	 9565B,	 10167,	 10167A,	

10602,	10700	and	32827.	14	C.F.R.	§	91.121	regarding	altimeter	settings	is	inapplicable	insofar	as	my	

UAS	utilizes	electronic	global	positioning	systems	with	a	barometric	sensor.

14	C.F.R.	§	91.203	(a)	and	(b)	provides	for	the	carrying	of	civil	aircraft	certifications	and	registrations.	They	

are	inapplicable	for	the	same	reasons	described	above.	The	equivalent	level	of	safety	will	be	achieved	by	

maintaining	any	such	required	certifications	and	registrations	by	me,	David	Wiltshire.

B.	14	C.F.R.	§	45.23:	Marking	of	The	Aircraft.	Applicable	Codes	of	Federal	Regulation	require	aircraft	to	be	

marked	according	to	certain	specifications.	My	UAS	are,	by	definition,	unmanned.	They	therefore	do	not	

have	 a	 cabin,	 cockpit	 or	 pilot	 station	 on	 which	 to	 mark	 certain	 words	 or	 phrases.	 Further,	 two-inch	

lettering	 is	 difficult	 to	 place	 on	 such	 small	 aircraft	 with	 dimensions	 smaller	 that	 minimal	 lettering	

requirement.	 Regardless,	 I	 will	 mark	 its	 UASs	 in	 the	 largest	 possible	 lettering	 by	 placing	 the	 word	

“EXPERIMENTAL”	on	its	fuselage	as	required	by	14	C.F.R.	§45.29	(f)	so	that	I	the	pilot,	or	anyone	assisting	

me	as	a	spotter	with	the	UAV	will	see	the	markings.	The	FAA	has	previously	issued	exemptions	to	this	

regulation	through	Exemptions	Nos.	8738,	10167,	10167A	and	10700.

C.	14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC.	Pursuant	to	14	C.F.R.	§§	61.113	(a)	&	(b),	

private	pilots	are	limited	to	non-commercial	operations.	I,	David	Wiltshire,	can	achieve	an	equivalent	level	

of	safety	as	achieved	by	current	Regulations	because	my	UAS	does	not	carry	any	pilots	or	passengers.	

Furthermore,	I	have	operated	manned	helicopter	and	airplanes	without	incident for	the	past	30	years.	I	

hold	a	ATP-Airplane–Multiengine	Land	&	Rotorcraft	Helicopter	with	Commercial	privileges.	Also	I	hold	a	

CFI,	 CFII,	MEI-Airplane. The	 risks	 attended	 to	 the	 operation	 of	 my	 UAS	 is	 far	 less	 than	 the	 risk	 levels	

inherent	in	the	commercial	activities outlined	in	14	C.F.R.	§	61,	et	seq.	Thus,	allowing	me,	David	Wiltshire,	

to	operate	my	UAS	meet	and	exceed	current	safety	levels	in	relation	to	14	C.F.R.	§61.113	(a)	&	(b).

D.	14	C.F.R.	91.119:	Minimum	Safe	Altitudes.	14	C.F.R.	§	91.119	prescribes	safe	altitudes	for	the	operation	

of	civil	aircraft.	It	allows	helicopters	to	be	operated	at	lower	altitudes	in	certain	conditions.	My	UAS	will	

never	 operate	 at	 an	 altitude	 greater	 than	 200	 AGL;	 safely	 below	 the	 standard	 of	 400	 AGL.	 I,	 David

Wiltshire,	will	however	operate	my	UAS	in	safe	areas	away	from	public	and	traffic,	providing	a	level	of	

safety	at	least	equivalent	to	or	below	those	in	relation	to	minimum	safe	altitudes.	Given	the	size,	weight,	

maneuverability	and	speed	of	my	UAS,	an	equivalent	or	higher	level	of	safety	will	be	achieved.

E.	14	C.F.R.	91.405	 (a);	407	 (a)	 (1);	409	 (a)	 (2);	417(a)	&	 (b):	Maintenance	Inspections.	The	above-cited	

Regulations	require,	amongst	other	things,	aircraft	owners	and	operators	to	“have	[the]	aircraft	inspected	

as	 prescribed	 in	 subpart	 E	 of	 this	 part	 and	 shall	 between	 required	 inspections,	 except	 as	 provided	 in	

paragraph	 (c)	of	this	section,	have	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter.	.	.	.”	

These	Regulations	only	apply	to	aircraft	with	an	airworthiness	certificate.	They	will	not,	therefore,	apply	

to	my,	David	Wiltshire,	UAS.	However,	as	a	safety	precaution	I	inspect	my	UAS	before	and	after	each	flight.

A	 Summary	 The	 FAA	 May	 Publish	 in	 the	 Federal	 Register:	 A.	 14	 C.F.R.	 21	 and	 14	 C.F.R.	 91:	

Airworthiness	Certificates,	Manuals	and	The	Like.	14	C.F.R.	21,	Subpart	H,	entitled	Airworthiness	

																																																												 5 - Safety/Flight	Manual
Certificates,	sets	forth	requirements	for	procurement	of	necessary	airworthiness	certificates	in	

relation	to	FAR	§	91.203(a)(1).	The	size,	weight	and	enclosed	operational	area	of	my	UAS	permits	

exemption	from	Part	21	because	my,	David	Wiltshire’s,	UAS	meets	an	equivalent	level	of	safety	

pursuant	to	Section	333	of	the	Reform	Act.	The	FAA	is authorized	to	exempt	aircraft	from	the	

airworthiness	certificate	requirement	under	both	the	Act	(49	U.S.C.	§	44701	(f))	and	Section	333	

of	 the	 Reform	 Act.	 Both	 pieces	 of	 legislation	 permit	 the	 FAA	 to	 exempt	 UAS's	 from	 the	

airworthiness	 certificate	 requirement	 in	 consideration	 of	 the	 weight,	 size,	 speed,	

maneuverability	and	proximity	to	areas	such	as	airports	and	dense	populations.	My UAS	meets	

or	exceeds	each	of	the	elements.	14	C.F.R.	91.7(a)	prohibits	the	operation	of	an	aircraft	without	

an	airworthiness certificate.	As	no	such	certificate	will	be	applicable	in	the	form	contemplated	by	

the	FARs,	this	Regulation	is	inapplicable.	14	C.F.R.	§	91.9	(b)	(2)	requires	an	aircraft	flight	manual	

in	the	aircraft.	As	there	are	no	pilots	or	passengers,	and	given	the	size	of	the	UAS's,	this	Regulation	

is	inapplicable.	An	equivalent	level	of	safety	will	be	achieved	by	maintaining	a	manual.	The	FAA	

has	previously	issued	exemptions	to	this	regulation	in	Exemption	Nos.	8607,	8737,	8738,	9299,	

9299A,	9565,	9565B,	10167,	maintenance	program	that	involves	regular	software	updates	and	

curative	measures	 for	any	damaged	hardware.	Therefore,	an	equivalent	level	of	safety	will	be	

achieved.

In	summary,	David	Wiltshire	seeks	an	exemption	from	the	following

Regulations:

14	C.F.R.	21,	subpart	H;	14	C.F.R.	45.23(b);	14	C.F.R.	§§	61.113	(a)	&	(b);	14	C.F.R.	§	91.7	(a);	14	

C.F.R.	§	91.9	(b)(2);	14	C.F.R.	§	91.103(b);	14	C.F.R.	§	91.109;	14	C.F.R.	§	91.119;	14	C.F.R.	§	91.121;	

14	C.F.R.	§	91.151(a);	14	C.F.R.	§§	91.203(a)	and	(b);	14	C.F.R.	§	91.405	(a);	14	C.F.R.	§	91.407	

(a)(1);	14	C.F.R.	§	91.409	(a)(2);	14	C.F.R.	§	91.409	(a	)	(2);	and,	14	C.F.R.	§§	91.417	(a)	&	(b)	to	

commercially	 operate	 my,	 David	 Wiltshire’s,	 small	 unmanned	 vehicle/lightweight	 unmanned	

aircraft	vehicle	in	community	awareness	and	 real	estate	operations	and	 to	develop	economic	

platforms	for	real	estate	to	enhance	the	experience	of	those	seeking	to	relocate	to	the	Wiregrass

area.	Currently,	area	awareness	and	real	estate	aerial	videography/photography	relies	primarily	

on	 the	 use	 of	 larger	 aircraft	 running	 on	 combustible	 fuel.	 Posing	 potential	 risk	 to	 the	 public.	

Granting	my,	David	Wiltshire’s,	request	for	exemption	will	reduce	current	risk	levels	and	thereby	

enhance	safety.	My	UAS	craft	does not	contain	potentially	explosive	fuel,	is	smaller,	lighter	and	

more	maneuverable	 than	conventional	 real	estate	video	and	photographic	aircraft	with	much	

less	 flight	 time.	 Further,	 I	 operate	 at	 lower	 altitudes	 and	 in	 controlled	 airspace	 eliminating	

potential	 public	 risk	 flying	 to	 and	 from	 established	 air	 fields.	 I,	 David	 Wiltshire,	 have	 been	

informally	analyzing	flight	information	and	will	compile	safety	protocols	and	the	implementation	

of	a	flight	operations	manual	for	real	estate	usage	that	exceeds	currently	accepted	means	and	

methods	for	safe	flight.	Formal	collection	of	information	shared	with	the	FAA	will	enhance	the	

FAA's	 internal	 efforts	 to	 establish	 protocols	 for	 complying	 with	 the	 FAA	 Modernization	 and	

Reform	Act	of	2012.	There	are	no	personnel	on	board	my,	David	Wiltshire’s,	UAS	and	therefore	

the	likelihood	of	death	or	serious	bodily	injury	is	significantly	diminished.	My,	David	Wiltshire’s,	

operation	of	my	UAS,	weighing	less	than	5	pounds	and	travelling	at	lower	speeds	within	limited	

areas	will	provide	an	equivalent	level	of	safety	as	that	achieved	under	current	FARs.	Accordingly,

I,	David	Wiltshire’s,	respectfully	request	that	the	FAA	grant	my	exemption	request	and	am	willing	
to	cooperate	in	sharing	information	to	benefit	the	FAA,	safety	of	manned	aircraft,	and	the	general	

public	at	large.

Respectfully	submitted,

David Wiltshire

David	Wiltshire,	Commercial	Pilot

407	Eton	Drive

Dothan,	Alabama	36305

334	701-0128
David	Wiltshire

Personal	Protocols	and	Controls

Aerial	Data	Collection

Protocols	and	Controls	

Safety	for	public	on	the	ground	as	well	as	manned	aircraft	above	is	an	essential	and	utmost	

consideration	for	aerial	videos	and	photography.	As	such,	safety	protocols	and	controls	must	be	

implemented	through	pre-flight	preparation	and	during	flight.	

Pre-Flight	Protocol:	

Check	batteries	with	voltage	meter	to	insure	fully	charged	and	ready	for	use.

Inspect	batteries	for	damage	or	leakage	that	may	affect	proper	operation.

Inspect	propellers	for	cracks,	chips	or	damage	that	may	cause	sudden	loss	of	propulsion	or	

unmanageable/uncontrolled	flight.

Check	weather	forecasts	for	wind	advisory	or	other	conditions	that	my	impact	flight.

Consult	five	(5)	mile	radius	map	for	airport	vicinity.	

Contact	respective	airport	to	advise	of	estimated	flight	time,	estimated	flight	duration,	 																				

estimated	elevation	of	flight,	and	any	other	pertinent	information.	

Inspect	flight	area	for:

• vicinity	of	public	safety	helipads/heliports	

• vicinity	of	medical	helipads/heliports

• vicinity	of	light	poles
• vicinity	or	utility	wires

• vicinity	of	trees

• flocks	of	birds	that	may	cause	interference	and	potential	flight	impact	

• vicinity	of	any	elevated	obstructions	that	may	pose	potential	flight	hazard	

• vicinity	of	roadways	with	moderate	to	heavy	traffic	that	can	be	distracted	

• public	gatherings	that	may	attract	viewers

• optional	point	of	control	for	best	visual	site	of	UAS	while	inflight	

Takeoff	and	Landing:

• Inspect	flight	area	for safest	point	of	takeoff	and	landing

• if	in	a	subdivision	or	area	that	is	within	150	feet	of	a	residential	street,	post	warning	

sign(s)/stand(s)	"Attention	Aerial	Photography	in	Progress	- Remain	Back	150	Feet	"	

Flight	Protocol:	

• takeoff	and	land	from	same	location

• remain	alert	to	birds,	sound	or	aircraft,	curious	public,	and	approaching	vehicles	

• do	not	allow	anyone	to	engage	in	conversation	or	distract	the	remote	control	pilot

• restrict	flight	to	minimal	elevation	sufficient	to	acquire	desired	results

• remained	prepared	for	emergency	landing	at	all	times

• pay	attention	to	flight	time	

• if possible set a timer as a safety alert

• land	UAS	and	shut	down	propulsion	immediately	following	landing

Post	flight:	

• disconnect	battery	to	prevent	accidental	activation	of	propulsion	system

• secure	UAS	in	a	safe	location

• remove	all	warning	signs	from	public	access	areas   

Emergency	or	Suspected	Hazard:	

• Immediately land	UAS	at	safest	and	closet	ground	location	

• Manned aircraft	is heard or seen in vicinity of flight

• There is a public gathering within established safety boundary wanting to	observe flight

• Pilot is being distracted from focusing on flight and safety

• Sudden change in weather (wind bursts)
• Sudden increase in vehicular traffic in vicinity of flight

• Birds enter into proximity off light

• Any sudden unsafe event that can cause collision, distraction or interruption of control	

This Certificate certifies that 

David Wiltshire

Having satisfactorily completed the course of study

And having passed the required examination in Flying,Controlling, 

Maneuvering and FAA Rules & Regulations is a

Qualified for UAV Flight 

Given under my hand on the 5th day of January, 2016

Ken Taboh