April 20, 2015 

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, Dan Johnson, 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, Dan Johnson, an owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed 

below so that I, Dan Johnson, may operate my small ultra-lightweight unmanned aircraft system (“sUAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”). 

As described herein I, Dan Johnson, am a photographer and videographer ; experienced in flying hobby 

aircraft for recreational purposes. I have added a quad-copter1 sUAS to my inventory equipped with a selfcontained camera with intent for aerial photography and videography; following exemption and approval 

by the FAA. 

My, Dan Johnson's, exemption request would permit operation of ultra-light weight, unmanned (piloted by 

remote control) and comparatively inexpensive sUAS(s) in tightly controlled and limited airspace.2 

Predetermined in areas away from large public gatherings, airports and heliports for community videos, 

photos and video of new and remodeled commercial buildings/projects, individual homeowner aerial 

photography/videography, photography and video of land developments for builders, and nature photos and 

videos in completely unpopulated areas and other community related events upon request.

Currently, similar lightweight, remote controlled sUASs are legally operated by unmonitored amateur 

hobbyists with no safety plan or controls in place to prevent catastrophe. I, Dan Johnson, have personally 

instilled safety protocols and controls 3 to avoid and prevent public hazard, as well as manned aircraft 

hazards/catastrophe. This will act to further safety protocols exclusive to lightweight sUAS's specific to 

photography & videography usage as I, Dan Johnson, 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, Dan Johnson’s, request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate sUASs into the national airspace 

system, but to “...establish requirements for the safe operation of such aircraft systems [sUASs] in the 

national airspace system” under Section 333(c) of the Reform Act specific to the use of sUASs for 

photography & videography purposes. Further I, Dan Johnson, will conduct my operations in compliance 

with the protocols described herein or as otherwise established by the FAA. 

For the reasons stated below I, Dan Johnson, respectfully request the grant of an exemption allowing me to 

operate ultra-light weight, remote controlled sUASs for the purposes of acquiring aerial photos & videos, 

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. 

1 Supplemental File – Phantom 2 Vision Plus (User Manual 1.6) & Appendix A 2 Appendix B – Aeronautical Charts 3 Appendix C - Personal Protocols and Controls 

I. Contact Information: 

Dan Johnson, DSJ, LLC, 5244 Cottondale St. SW. Wyoming, MI. 49519. Office: (626) 261-2949 Mobile: 

(616) 293-0158. Email: dansjohnson@gmail.com
II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Dan Johnson

Requests Exemption are: 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 Dan Johnson seeks and the Reason He Seeks Such Relief: 

I, Dan Johnson, 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, Dan Johnson, contemplated 

commercial cinematic, academic and other flight operations within the national airspace system. The 

Reform Act in Section 332 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, Dan Johnson’s, ultra-lightweight sUAS meets the definition of “small unmanned aircraft” as defined in 

Section 331 and therefore the integration of my ultra-lightweight sUAS is expressly contemplated by the 

Reform Act. I would like to operate my ultra- lightweight sUAS 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 related 

sUAS aerial photography & videography. 

The Reform Act guides the Secretary in determining the types of sUASs that may operate safely in our 

national airspace system. Considerations include: The weight, size, speed and overall capabilities of the 

sUASs; whether the sUAS will be operated near airports or heavily populated areas; and, whether the sUAS 

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, Dan Johnson. My sUAS utilizes four (4) counter-rotating propellers for balance, control and 

stability. My sUAS is equipped with GPS and auto return safety technology. Weighing less than five (5) 

pounds (far below the maximum 55 pound limit); including camera with gimbal. 

I, Dan Johnson, consider safety as upmost importance with every flight. My small unmanned aircraft is 

designed to hover in place via GPS and operate in less than a 16 knot (17 mph) wind. For safety, stability 

and fear of financial loss I will not fly in winds exceeding 14 knot (15 mph). Built in safety systems include 

a GPS mode that allows my sUAS to hover in place when radio controls are released. With three modes to 

choose from, I utilize the GPS Mode4 for aerial photography and videography. This is the safest, most 

reliable and stable mode to prevent accidents and hazards. When pilot communication is lost, the sUAS is 

designed to slowly descend to point of take-off. 

I do not operate my sUAS near airports, Hospitals nor Police heliports, and do not operate near areas where 

general public is within thirty to one hundred (30-100) 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 sUAS 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 ten (10) to fifteen (15) 

minutes, with an altitude under two hundred (200) feet. I, Dan Johnson, 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-five 

(25) minutes as tested. 

I do not operate my sUAS at or below the manufacturer recommend minimum charge levels for operation; 

preferring to remain well within a safe operating range to insure adequate communication between radio 

control and sUAS to eliminate potential for crash, loss of control or hazards. 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, which could create hazards to the public / property / manned aircraft, and have no 

desire to lose an investment. I have done scores of practice flights in remote areas as a hobbyist simulating 

flights for future commercial use to gain familiarization with the characteristics of this specific sUAS’s 

performance under different temperature and weather conditions. All for the sake of safety. 
I, Dan Johnson, am extremely cautious when operating of my sUAS / ultra-lightweight 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 sUAS it falls well within Congress’s contemplated safety zone when 

it promulgated the Reform Act and the corresponding directive to integrate sUASs into the national 

airspace system. My, Dan Johnson’ sUAS, used in hobby flight, has a demonstrable safety record and does 

not pose any threat to the general public or national security. 

IV. How Dan Johnson’s Request Will Benefit the Public As A Whole: 

Aerial photography and has been around for a long time through manned fixed wing aircraft and 

helicopters. For small budget productions the expense of such aerial photography and videography is cost 

prohibitive. Only larger companies can afford to absorb such expense. Manned aircraft pose a threat to the 

public through the potential of a catastrophic crash. My, Dan Johnson's, sUAS poses 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 sUASs 

into the national airspace system, hence the passing of the Reform Act. Granting my, Dan Johnson’s, 

exemption request furthers the public interest through academic/visual awareness of the photography and 

videography fields throughout the Grand Rapids area. My ultra-lightweights UAS is battery powered and 

creates no emissions that can harm the environment. The consequence of my ultra-lightweights 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 

photography and videography captured through my battery operated ultra-lightweights UAS's. Permitting 

me, Dan Johnson, to immediately fly within national air space furthers economic growth. Granting my 

exemption request substantially furthers the economic impact for the Grand Rapids area for companies 

looking to use aerial photography and videography, both of which serve as a stimulus to the community. 

V. Reasons Why Dan Johnson’s Exemption Will Not Adversely Affect Safety Or How The Exemption 

Will Provide a Level of Safety At Least Equal To Existing Rule: 

My, Dan Johnson’s, exemption will not adversely affect safety. Quite the contrary, for the reasons stated 

permitting me, Dan Johnson, 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 photographers and videographers for development in cooperation with 

the FAA. 

In addition I, Dan Johnson, submit the following representations of enhancements to current aerial 

photography/videography. My sUAS weighs less than 5 pounds complete with a small ultra-lightweight 

high quality camera; I only operate my sUAS below 400 feet (within the 400 foot permissible ceiling set by 

the FAA Modernization and Reform Act of 2012); My sUAS only operates for ten (10) to twenty (20) 

minutes per flight; I land my sUAS prior to manufacturer recommended minimum level of battery power; 

I pilot my sUAS through remote control only by visual line of sight; My sUAS has GPS, a flight safety 

feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost; I 

actively analyze flight data and other sources of information to constantly update and enhance safety 

protocols; I only operate in reasonably safe environment away from airports and areas with large groups of 

people; I conduct extensive pre-flight inspections and protocol, during which safety carries primary 

importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place 

to abort flights in the event of safety breaches or potential danger. 

My, Dan Johnson’s, safety protocols provide a level of safety equal to or exceeding existing rules. It is 

important to note that absent the integration of commercial sUAS into our national airspace system, 

helicopters are the primary means of aerial photography and videography. While the safety record of such 

helicopters is remarkably astounding, there has been incidents involving loss of life as well as extensive 

property damage; it is far safer to operate a battery powered ultra-lightweight sUAS. 
First, the potential loss of life is diminished because sUASs carry no people on board and I only operate my 

sUAS in specific areas away from mass populations. Second, there is no fuel on board a sUAS and thus 

the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability 

of my sUAS 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 sUAS need not be so close 

to the objects they are focused on through the technology and use of post editing software allowing 

panning, tilting and zooming. 

Accordingly, my sUAS 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, Dan 

Johnson’s, sUAS permits exemption from Part 21 because my sUAS 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 sUASs from the airworthiness certificate 

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

airports and dense populations. My, Dan Johnson’, current and projected sUASs 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. B. C. D. E. 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 sUASs, 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 sUAS 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, 

Dan Johnson. 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 sUASs 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 the sUASs 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. 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, Dan Johnson, can achieve an equivalent level of safety as achieved by 

current Regulations because my sUAS does not carry any pilots or passengers. Further, while helpful, a 

pilot license will not ensure remote control piloting skills. The risks attended to the operation of my sUAS 

is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, 

allowing me, Dan Johnson, to operate my sUAS meet and exceed current safety levels in relation to 14 

C.F.R. §61.113 (a) & (b). 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 sUAS will never operate at an altitude greater than 400 AGL. I, Dan Johnson, will however 

operate my sUAS 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 sUAS, an equivalent or higher level of safety will be achieved. 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, Dan Johnson', sUAS. However, as a safety precaution I thoroughly inspect my sUAS before and after 

each flight. 

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 sUAS permits exemption from Part 21 because my, Dan 

Johnson’s, sUAS 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 sUASs from the airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My sUAS 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 sUASs, 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, Dan Johnson 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, Dan Johnson', small unmanned vehicle/lightweight unmanned 

aircraft vehicle in community awareness and aerial photography and videography operations. Currently, 

area awareness and aerial photography and videography relies primarily on the use of larger aircraft 

running on combustible fuel. Posing potential risk to the public. Granting my, Dan Johnson’, request for 

exemption will reduce current risk levels and thereby enhance safety. My sUAS craft does not contain 

potentially explosive fuel, is smaller, lighter and more maneuverable than conventional 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, Dan Johnson, have been informally analyzing flight 

information and will compile safety protocols and the implementation of a flight operations manual 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, Dan Johnson’s, sUAS and 

therefore the likelihood of death or serious bodily injury is significantly diminished. My, Dan Johnson’s, 

operation of my sUAS, 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, Dan Johnson, 

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, 

Dan Johnson, Photographer / Videographer 

DSJ, LLC

5244 Cottondale St. SW

Wyoming, MI. 49519