September 17, 2015

Exemption No. 12894

Regulatory Docket No. FAA−2015−2620

Mr. John Looper

Owner

Elevated Loop, LLC

2609 South 13th Street

Broken Arrow, OK 74012

Dear Mr. Looper:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated June 15, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption on behalf of Elevated Loop, LLC. The petitioner requested to operate an 

unmanned aircraft system (UAS) to conduct aerial videography, cinematography, and 

photography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Inspire 1.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 
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consideration of the size, weight, speed, and limited operating area associated with the 

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, 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. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) 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, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Elevated Loop, LLC is granted an exemption from 

14 CFR §§ 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, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Elevated Loop, LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

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

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

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

5. The UA must 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.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

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

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted 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.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

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

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

the conditions and limitations herein take precedence and must be followed. 
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Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

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

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

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must 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 is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

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

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must 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 must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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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 must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s 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 must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may 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.

16. The UA may 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.

17. The UA may 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

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

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

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
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(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. 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 must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

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

nonparticipating persons under this exemption.

27. All operations shall 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.

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

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on September 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
John Looper, Broken Arrow, OK -74012- Section 333 Exemption Petition 

June 15, 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); 

91.1 03(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, John Looper, 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, John Looper, an owner and operator 

of a small unmanned aircraft, be exempted from the Federal Aviation Regulations ("FARs") 

listed below so that I, John Looper, may operate my small ultra-light weight unmanned aircraft 

system ("UAS") commercially in airspace regulated by the Federal Aviation Administration 

("FAA"). 

As described herein I, John Looper, am an experienced pilot in flying hobby airplanes as well 

as mulit-rotor craft for recreational purposes. I have added a high grade quad-copter1 UAS to 

my inventory equipped with a HD Camera with intent for aerial videography/ cinematography/ 

photography to enhance academic community awareness for those individuals and companies 

unfamiliar with the geographical layout of the Northeastern Oklahoma/ Greater Tulsa area, and 

augment real estate listing photos/ videos; following exemption and approval by the FAA. 

Thereby enhancing their academic research experience for the Northeastern Oklahoma/ 

Greater Tulsa area. 

I have flown RC aircraft for over twenty (20) years. Committed to safety with each flight. My, 

John Looper's, exemption request would permit operation of ultralight weight, unmanned 

(piloted by remote control with FPV systems) and comparatively inexpensive UAS in tightly 

1 Inspire 1 quad-copter specifications 
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John Looper Broken Arrow, OK22 - Section 333 Exemption Petition 

controlled and limited airspace. Predetermined 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, John Looper, have personally instilled safety 

protocols and controls to 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, John Looper, 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, John Looper's, 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 real estate/Realtor purposes. Further I, John Looper, will conduct my 

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

FAA. 

For the reasons stated below I, John Looper, 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 Northeastern Oklahoma/ Greater Tulsa area and 

to enhance real estate listing videos/photos 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 poses potential public hazard. 

I. Contact Information: 

John Looper Owner 

Elevated Loop, LLC 2609 South 13th Street 

Broken Arrow, OK 74012 

Mobile: (918)533-0699 

Email: jlooper500@gmail.com 

11. The Specific Sections of Title 14 of the Code of Federal Regulations From Which John 

Looper Requests Exemption are: 
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John Looper Broken Arrow, OK - Section 333 Exemption Petition 

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). 

Ill. The Extent of relief John Looper seeks and the Reason he Seeks Such Relief: 

I, John Looper, 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, John 

Looper, 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, John Looper'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 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, John Looper. 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 seven (7) pounds (far below the maximum 55 

pound limit); including camera with gimbal. 

I, John Looper, considers 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 kph (1 0 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 Inspire 1 I GPS Mode for 

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

accident and hazard. When pilot communication is lost UAS, Inspire 1 /GPS Mode includes safe 

circle for operation, position hold, self-leveling, altitude command, GPS, return to home feature, 
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John Looper Broken Arrow, OK- Section 333 Exemption Petition 

and failsafe control to return home or land in the event of communication interruption between 

RC transmitter and UAS, being designed to slowly descend to point of takeoff. I do not operate 

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

general public is within fifty to one hundred (50-1 00) yards depending on location, conditions 

and weather. I am constantly on alert for any manned aircraft (Airplanes/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 five (5) to fifteen (15) minutes, with an altitude 

under four hundred (400) feet. I, John Looper, utilize a fresh fully charged battery with each 

flight as a safety precaution; full flight time limit for each battery is up to fifteen (15) 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 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. I have 

clocked numerous practice flights in remote areas as a 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 also practice computerized simulated 

flights to maintain adequate skills and response reflex time. All for the sake of safety. I, John 

Looper, 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. John Looper'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 John Looper's Request Will Benefit the Public as A Whole: 

Aerial photography/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 

photography/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 crashes. Each resulting in loss of life. Each with 
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John looper Broken Arrow, OK - Section 333 Exemption Petition 

combustible fuel that exploded and burned on impact. My, John Looper'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, 

John Looper's, exemption request furthers the public interest through academic/visual 

awareness of the geographical benefits in and around the Northeastern Oklahoma/ Greater 

Tulsa 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, John 

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

exemption request substantially furthers the economic impact for the Northeastern Oklahoma/ 

Greater Tulsa community for companies looking to relocate or build in the Northeastern 

Oklahoma/ Greater Tulsa 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 John Looper's Exemption Will Not Adversely Affect Safety Or How the 

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

My, John Looper's, exemption will not adversely affect safety. Quite the contrary, for the reasons 

stated permitting me, John Looper, to log more flight time in FAA controlled airspace, with 

communication with the FAA . 

• My UAS weighs less than 7 pounds complete with a small ultra-light weight high definition 

(HD) camera; 

• I only operate my UAS below 400 feet (well within the 400 foot permissible ceiling set by the 

FAA Modernization and Reform Act of 2012); 

• My UAS will only operate for up to 15 minutes per flight; I land my UAS prior to manufacturer 

recommended minimum level of battery power; 

• I pilot my UAS through remote controi/FPV only by line of sight; 

• My UAS 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; 
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John Looper Broken Arrow, OK - Section 333 Exemption Petition 

• I only operate in reasonably safe environment that are strictly controlled, are away from power 

lines, elevated lights, airports and actively populated areas; 

• 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, John Looper'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 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 incident's 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, John Looper'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 
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John Looper Broken Arrow, OK - Section 333 Exemption Petition 

such as airports and dense populations. My, John Looper'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.9 The FAA has previously issued exemptions to this 

regulation in Exemption Nos. 8607, 8737,8738, 9299, 9299A, 9565,95658, 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. A. § 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, John Looper. 

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. A. §45.29 (f) so that I the pilo~~ 

anyone assisting me as a spotter with the UAV will see the markings. The FAA has previously 

issued exemptions to this regulation through Ex~~Rt!9n~ ~~()S. 8738; 10·167, lOJ67A and 10700. 

C.14C.F.R. §61.113: Private Pilot Privileges and Limitations: PIC. 

..- .... , ..,. ,.. .. ' ~ ....... . Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited t<frion~commercial .............. . 

operations. I, John Looper, can achieve an equivalent level of safety as achieved by current 

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

John Looper Broken Arrow, OK - Section 333 Exemption Petition 

pilot license will not ensure remote control piloting skills. 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, John Looper, 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 400 AGL; safely below the standard of 400 AGL. I, John Looper, 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, John Looper's, 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. A. 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 UAS 

permits exemption from Part 21 because my, John Looper'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 
Page9 

John Looper Broken Arrow, OK - Section 333 Exemption Petition 

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, 95658, 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, John Looper 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. § 91.1 09; 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, John Looper'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 Northeastern Oklahoma/ Greater Tulsa 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, John Looper's, request for 

exemption will reduce current risk levels and thereby enhance safety. My UAS craft do 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, John Looper, 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, John 

Looper's, UAS and therefore the likelihood of death or serious bodily injury is significantly 

diminished. My, John Looper's, operation of my UAS, weighing less than 7 pounds and traveling 

at lower speeds within limited areas will provide an equivalent level of safety as that achieved 

under current FARs. Accordingly I, John Looper, 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. 
Page 10 

John Looper Broken Arrow, OK - Section 333 Exemption Petition 

Respectfully Submitted, 

John Looper 

John Looper, Owner 

Elevated Loop LLC, Broken Arrow, OK 74012 
lnsJ?ire 1 - Specs I DJI 6/11/15,11:14 PM 

r j)J JHttp"I/Www dii.com/1 Store IHttp://Store.dii.comD. Products v (Http://Www.cjji.com/productsl. D!l Events v JJ:ill.p://Event.djj.coml. 

Community v ~Http://Fiysafe.dji.coml 

Search dji.com ... Q United States {Engtish) (/Select 

~~ ~!:!llP·I!Www.dii.com/Product/lnspjre-1 Nideol Downloads <t!llP·t!Www djj.com/Prodqct/lnspjre-1/Downloadl 

.EAQJ!:!llP'IIWww.di~l ~~ ~l:!np:f!Www.dji.com/Product/lnspjre-1/Dealerl 

24-Hour SuRP...QrU!:!llP://Www.dji.com/lnfo/News/24-Hour-Technicai-Su~mort-lnsRire-1 l 

Aircraft Model 

Weight (Battery Included) 

Hovering Accuracy (GPS Mode) 

Max Angular Velocity 

Max Tilt Angle 

Max Ascent Speed 

Max Descent Speed 

Max Speed 

Max Flight Altitude 

Max Wind Speed Resistance 

Max Flight Time 

Motor Model 

Propeller Model 

Indoor Hovering 

Operating Temperature Range 

Diagonal Distance 

Dimensions 

Gimbal Model 

http://www. dji .com/prod uct/inspi re-1/spec 

Suy 

T600 

2935g 

Vertical: 0.5 m 

Horizontal: 2.5 m 

Pitch: 3oo•ts 

Yaw: 1SO•ts 

Sm/s 

4 m/s 

22 m/s (A Til mode, no wind) 

4500m 

10m/s 

Approximately 18 minutes 

Qj/3510 

Djl1345 

Enabled by default 

559to 581 mm 

438x451 x301 mm 

ZENMUSEX3 

Page 1 of 5 
Inspire 1 - Spi!CS I DJI 

Output Power (With Camera) 

Operating Current 

Angular Vibration Range 

Mounting 

Controllable Range 

Mechanical Range 

Max Controllable Speed 

Camera Name 

Model 

Total Pixels 

Effective Pixels 

Image Max Size 

ISO Range 

Electronic Shutter Speed 

FOV (Field Of View) 

CMOS 

Lens 

Still Photography Modes 

Video Recording Modes 

Max Bitrate Of Video Storage 

Supported File Formats 

Supported SO Card Types 

Operating Temperature Range 

http://www. dji. com/product/inspire-1 /spec 

Static: 9 W 

In Motion: 11 W 

Station: 750 rnA 

Motion: 900 rnA 

±0.03° 

Detachable 

Pitch: -90" to +30" 

Pan: ±320" 

Pitch: -125" to +45" 

Pan:±330" 

Pitch: 120"/s 

Pan: 180"/s 

X3 

FC350 

12.76M 

12.4M 

4000x3000 

1 00-3200 (video) 

1 00-1600 (photo) 

8s- 1/80005 

94° 

Sony EXMOR 1/2.3" 

20mm (35mm format equivalent)f/2.8 focus at "' 

9 Elements in 9 groups 

Anti-distortion 

Single shoot 

Burst shooting: 3/50 frames 

6/11/15,11:14 PM 

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias 

Time-lapse 

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30 

FHD: 1920x1 080p24/25/30/48/50/60 

HD: 1280x720p24/25/30/48/50/60 

60Mbps 

FAT321exFAT 

Photo:jPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264) 

MicroSD 

Max capacity: 64 GB. Class1 0 or UHS-1 rating required. 

o• to 40" c 

Page 2 of 5 
lnsp'ife 1 - Specs I DJI 

Remote Controller Name 

Operating Frequency 

Transmitting Distance (Outdoor And Unobstructed) 

EIRP 

Video Output Port 

Power Supply 

Charging 

Dual User Capability 

Mobile Device Holder 

Max Mobile Device Width 

Output Power 

Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Battery 

Charger Model 

Voltage 

Rated Power 

Battery (Standard) Name 

Model 

Capacity 

Voltage 

Battery Type 

Energy 

http://www.dji.com/productlinspire-1/spec 

(1 

922.7-927.7 MHz(Japan Only) 

5.725-5.825 GHz 

2.400-2.483 G Hz 

2km 

10dBm@900m,13dBm@5.8G, 20dBm@2.4G 

USB, mini-HDMI 

Built-in battery 

DJI charger 

Host-and-Slave connection 

Tablet or Phone 

170mm 

9W 

-10• to 40° C 

Less than 3 months: -20° to 45° C 

More than 3 months: 22° to 28° C 

0-40° c 

6000 mAh LiPo 25 

A14-100P1A 

26.3V 

100W 

Intelligent Flight Battery 

TB47 

4500mAh 

22.2V 

Li Po 65 High voltage battery 

99.9Wh 

6/11/15,11:14 PM 

Page 3 of 5 
lnsr;>ire_ 1 .- SJ>ecs I DJI 

Net Weight 

Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Max Charging Power 

Battery {Optional) Name 

Model 

Capacity 

Voltage 

Battery Type 

Energy 

Net Weight 

Operating Temperature Range 

Storage Temperature Range 

Charging Temperature Range 

Max Charging Power 

Vision Positioning Velocity Range 

Altitude Range 

Operating Environment 

Operating Range 

Djl Pilot App Mobile Device System Requirements 

Supported Mobile Devices 

http://www. dji.com/prod uct/inspire-1 /spec 

570g 

-10°to 40° c 

Less than 3 months: -20• to 45° C 

More than 3 months: 22° C to 28° C 

oo to40° c 

180W 

Intelligent Flight Battery 

TB48 

5700mAh 

22.8V 

LiPo 65 

129.96Wh 

670 g 

-10°to 40° c 

Less than 3 months: -20 to 45° C 

More than 3 months: 22° to 28° C 

oo to 40° c 

180W 

Below 8 m/s (2m above ground) 

5-500 em 

Brightly lit (lux> 15) patternep surfaces 

0-250cm 

lOS 8.0 or later 

Android 4.1.2 or later 

6/11/15,11:14 PM 

*Compatible with iPhone Ss, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + C 

iPad mini 2, iPad mini 2 Wi-Fi +Cellular, iPad Air 2, !Pad Air 2 Wi-Fi +Cellular, iPa' 

3, and I Pad mini 3 Wi-Fi +Cellular. This app is optimized for !Phone 5s, !Phone 6, 

!Phone 6 Plus. 

* Samsung 55, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, 

Z7mini 

*Support for additional Android devices available as testing and development 

continues 

Page 4 of 5