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JANUARY 19, 2016

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, D.C. 20590 

Re: Petition of Michael Jeremiah Wraight for Exemption from Certain Federal Aviation 

Regulations to Operate Unmanned Aircraft Systems Pursuant to Section 333 of the FAA Modernization 

and Reform Act.

Dear Sir or Madam: 

Pursuant to Section333 of the FAA Modernization and Reform Act ("FMRA") and 14 

C.F.R. part 11, Michael Jeremiah Wraight (Hereafter referred to as “the operator") hereby petitions the 

Federal Aviation Administration ("FAA") for exemption from 14 C.F.R. §§ 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, 91.15l(a)(l), 91.405(a), 91.407(a)(l), 91.409(a)(l) 

and (2), and 91.417(a) and (b), and any other rules the FAA deems necessary, to enable Raycom to 

operate unmanned aircraft systems ("UAS") for aerial data collection. Specifically, the operator

seeks to operate UAS for Aerial data collection to include: Aerial photography, videography, inspection 

and monitoring of agricultural sites, land restoration and remediation sites, environmental monitoring, 

inspection and monitoring of construction sites and utilities infrastructure, search and rescue, first 

responder services, aerial photography and videography of real estate for marketing and land use and 

management, special events, UAS pilot training using the DJI Inspire 1, DJI Phantom 3 Pro, DJI Phantom 

3 Advanced, DJI Phantom 2, 3DR Solo, Yuneec Q500+. Because this petition is similar in all material 

respects to previously-granted Section 333 petitions, the operator requests expedited approval pursuant 

to the FAA's summary grant process.

I. PROPOSED OPERATIONS AND PUBLIC INTEREST BENEFITS

The operator holds and Airline Transport Pilot airmen certificate with multiengine land and commercial 

privileges as well as a Ground Instructor Instrument certificate and has 21 years’ experience as a 

professional aviator. The operator obtained an Associate’s Degree in General Aviation and a Bachelor’s 

Degree in Professional Pilot Technology from Indiana State University in Terre Haute, IN in 2001. The 

operator has been involved in model aeronautics for 19 years, including building and flying remote 

control aircraft both powered and unpowered. In 2004 the operator began working with nascent drone 

technology including GPS enabled autopilot as well as acting as a test pilot for a prototype drone. The 

operator was in charge of the technical writing and ab initio training program for this drone. Over the 

years the operator has gained thousands of hours operating both manned and unmanned aircraft and 

has extensive knowledge of the NAS, FARs, Navigation, Meteorology and Aviation Safety.

The operator proposes the following operations using UAS:

Aerial data collection to include aerial photography, videography, inspection and environmental 

monitoring of:

Agricultural sites,

Land restoration and remediation sites,

Land use and management, 

Inspection of and monitoring of construction sites and utilities infrastructure
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Search and rescue, 

First responder services, 

Real estate for marketing

Special events, 

UAS pilot training.

Currently these functions are primarily performed by full size aircraft. These aircraft weigh thousands of 

pounds, are piloted by humans in dangerous conditions and environments (i.e., in close proximity to the 

ground and structures), contain hundreds of gallons of highly flammable fuel and create disturbing noise 

levels. Full size aircraft can pose a substantial risk to property and individuals on the ground as well as 

the flight crew themselves. Using a lightweight drone allows these functions to be performed more 

safely to the public, with less risk of severe damage or loss of life or property. The reduced sound levels 

are beneficial to the public as well. 

Land restoration and remediation sites, environmental monitoring and land use and management sites 

are areas that are commonly populated by high concentrations of wildlife that may be disturbed by the 

noise levels created by low level full size aircraft. Migratory and other birds can cause a severe hazard to 

full size aircraft in these areas when disturbed en masse. 

Some of these sites require significant manpower and effort to access, exposing employees to 

dangerous conditions. Barriers to entry can include overgrowth of brush, running and standing water, 

and wildlife habitat. Further these employees are exposed to extremes of temperature and humidity 

and can be in inaccessible locations that render emergency extraction difficult and time consuming. 

Using a UAS to perform these inspections removes the potential hazards to humans. 

Inspection of infrastructure including towers require sending people up to dangerous heights or subject 

them to dangerous situations where the possibility of death or severe injury is heightened. Using UAS to 

perform these inspection functions nearly eliminates this risk to human life. Use of UAS also allows 

these sites to be accessed more expediently and with greater frequency.

Search and rescue with UAS benefits the public by being quick to deploy and operable in conditions 

where airports may not be available for use (i.e., the aftermath of a tornado outbreak, earthquakes, 

hurricanes).

UAS training offers the benefit of teaching and mentoring pilots intending to become UAS operators. By 

being trained by a highly experienced pilot with extensive experience in the NAS a culture of safety can 

be inculcated.

II. THE UAS

The operator requests an exemption to operate the following:

DJI Inspire 1,

DJI Phantom 3 Pro, 

DJI Phantom 3 Advanced, 

DJI Phantom 2,

3DR Solo,
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Yuneec Q500+,1

all of which are well below 55 pounds including payload. Through the Section 333 exemption process, 

the FAA has authorized use of all UAS for which exemption is requested herein. 

III. REQUEST FOR SUMMARY GRANT

Because this petition is similar in material respects to previous petitions the FAA has granted, the 

operator requests that the FAA issue a summary grant of exemption pursuant to the agency's expedited 

summary grant process. Specifically, the public interest and safety benefits the operator’s operations 

will achieve are materially similar to those recognized in Grants of Exemption Nos. 11062 to Astraeus 

Aerial (see Docket No. FAA-2014-0352), Ill 09 to Clay co, 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. FAA2014-0642). Ray com will adhere to a series of operating parameters that will offer the same level of 

safety as the conditions the FAA currently requires in its summary grants.2

IV. APPLICANT INFORMATION

The name and contact information of the applicant is:

Michael Jeremiah Wraight

522 Pennsylvania Ave.,

Plymouth, IN 46563-2759

Phone: (574) 540-9553

Email: michaeljwraight@gmail.com

V. REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

14 C.F.R. §§ 61.23(a) and (c); 

14 C.F.R. §§ 61.101(e)(4) and (5); 

14 C.F.R. § 61.113(a); 

14 C.F.R. § 61.315(a); 

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119(c); 

14 C.F.R. § 91.121; 

14 C.F.R. § 91.151(a)(1); 

14 C.F.R. § 91.405(a); 

14 C.F.R. § 91.407(a)(1); 

14 C.F.R. §§ 91.409(a)(1) and (2); 

14 C.F.R. §§ 91.417(a) and (b). 

 

1

See Exemption No. 11274A to United Services Automobile Association, Regulatory Docket No. FAA2014-0796 

(authorizing use of the 3DR Solo, DJI Phantom 3, and DJI lnspire); Exemption No. 11875 to Green Bee Limited, 

Regulatory Docket No. F AA-20 15-0698 (authorizing use of the DJI Phantom 2); Exemption No. 12023 to William J. 

Henderson, Regulatory Docket No. FAA-2015-1518 (authorizing use of the Yuneec Q500 Typhoon).

2

See, e.g., Exemption No. 12160 to Star Engineering Services LLC, Regulatory Docket No. FAA-2015-1690 (Jul. 27, 

2015)
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VI. OPERATING PARAMETERS

The Operator will adhere to the following operating parameters when operating UAS pursuant to a 

grant of the requested exemption: 

1. Operations will be conducted using the DJI Inspire 1, DJI Phantom 3 Pro, DJI Phantom 3 Advanced, 

DJI Phantom 2, 3DR Solo, Yuneec Q500+

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour), at an altitude 

greater than 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 

feet below or 2,000 feet horizontally from a cloud. All operations will be conducted during the day under 

visual meteorological conditions. 

3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization ("COA''). 

4. All operations will use a pilot-in-command ("PIC") and a visual observer ("VO"), and the UAS will 

remain within the visual line of sight of the PIC or the VO at all times. The PIC will maintain VLOS 

capability and the ability to communicate verbally with the VO at all times.

5. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot certificate, as 

well as an FAA airman medical certificate or a valid U.S. driver's license. The PIC will meet the flight 

review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. 

6. The operator will ensure prior to operation that the PIC has demonstrated 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 C.F.R. § 61.51(b). 

7. Raycom's operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. 

8. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS 

will not be operated until the necessary maintenance has been performed and the U AS is found to be in 

a condition for safe flight. 

9. 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. 

10. The operator will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, 

and life limit requirements, as well as safety bulletins, for the aircraft and aircraft components. 

11. The PIC will abort the flight in the event of unpredicted obstacles or emergencies, and will yield to all 

manned aviation activities. 

12. The operator will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45.
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VII. THE FAA’S AUTHORITY TO GRANT THIS PETITION

The FAA has authority to grant the exemption requested herein under the FMRA and the Federal 

Aviation Act. Section 333 of the FMRA deals specifically with integrating UAS into the national airspace, 

and directs the Secretary of Transportation to determine which UAS, "as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and operation within visual line 

of sight do not create a hazard to users of the national airspace system or the public or pose a threat to 

national security."3Section 333 further directs the Secretary to "establish requirements for the safe 

operation of such aircraft systems in the national airspace system. "4The Federal Aviation Act authorizes 

the Administrator of the FAA to grant exemptions from regulations prescribed under certain provisions 

of the Act where such exemptions are in the public interest.5Part 11 of the Federal Aviation Regulations 

governs the FAA's exemption process and requirements.6The FAA has granted more than 1,100 

exemptions to date pursuant to its Section 333 and exemption authority, enabling commercial UAS 

operations in a wide variety of industries

VIII. SUMMARY TO BE PUBLISHED IN THE FEDERAL REGISTER

Should the FAA determine that publication in the Federal Register is required, the operator offers the 

following summary pursuant to section 11.81 of the FAA's rules:7

Petitioner: Michael Jeremiah Wraight

Sections of 14 C. FR. Affected: 14 C.F.R. §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 

61.113(a); 14 C.F.R. § 61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 

91.15l(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(l); 14 

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

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. §§ 

61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. § 

61.315(a); 14 C.F.R. § 91.7(a); 14C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 

91.151(a)(l); 14 C.F.R. § 91.405(a); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. §§ 91.409(a)(l) and 

(2); 14 C.F.R. §§ 91.417(a) and (b) to operate unmanned aerial systems for aerial data collection to 

include aerial photography, videography, inspection and environmental monitoring of:

Agricultural sites,

Land restoration and remediation sites,

Land use and management, 

Inspection of and monitoring of construction sites and utilities infrastructure

Search and rescue, 

First responder services, 

Real estate for marketing

Special events, 

UAS pilot training.

 

3

Pub. L. No. 112-95, 126 Stat. 75-76 (codified as a Note to 49 U.S.C. § 40101)

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Id.

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49 U.S.C. § 44701 (f) ("The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator finds the 

exemption is in the public interest.")

6

See 49 C.F.R. Part 11

7

Id.§ 11.81(1)
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IX. CONCLUSION

As demonstrated above, the UAS operations the operator has proposed in this petition for exemption 

will garner significant public benefits while presenting minimal safety risks. The operator's petition 

satisfies the criteria of Section 333 of the FMRA and is substantially similar to previous petitions the FAA 

has granted, meriting a summary grant of exemption. The operator respectfully requests that the FAA 

grant this petition to grant the operator ability to provide important aerial data collections services.

Sincerely,

Michael Jeremiah Wraight