Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

Kevin Jones

405 Rolling Hill

Cleburne, TX 76033

Email:klj12345@yahoo.com

The specific section or sections of 14 CFR from which you seek an exemption;

Petition for Exemption under Sec 333

Part 21; and §§ 45.23(b); 91.7(a); 91.9(b)(2); 91.103(b); 91.119; 91.121, 91.151(a);

91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(2); and 91.417(a) & (b) of Title 14,

Code of Federal Regulations

The extent of relief you seek and the reason you seek the relief:

Part 21 91.203(a) & (b)

Given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates)

subject to certain conditions and limitations, is warranted and meets the requirements for 

an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112 -95 

(Section 333).

45.23

Marking of the aircraft because UA will 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 a 

small aircraft with dimensions smaller than the minimal lettering requirement.

Will mark UAS in the largest possible lettering by placing the N-number on its fuselage as 

required by § 45.29(f) so that anyone assisting him as a spotter will see the markings.

91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b)

Maintenance inspections may be required and should be granted since they

only apply to aircraft with an airworthiness certificate . However as a safety precaution 

user will perform a preflight inspection of his UAS before each flight as outlined in his 

operating documents and follow manufacture maintenance recommendations as stated in 

UA user manual.

91.7(a)

prohibits the operation of an aircraft without an airworthiness certificate. There is currently 

no certificate applicable to this operation, this regulation is inapplicable.

91.9(b)(2)

requires an aircraft flight manual in the aircraft, however since there are no pilots or 

passengers on board his aircraft and given its size, this regulation is in applicable. An 
equivalent level of safety will be achieved by maintaining a safety/flight manual with the

UAS ground station.

91.103 (b)

The PIC will take all actions including reviewing weather, flight battery requirements,

landings, and takeoff distances and aircraft performance data before initiation of flight.

Stricter requirements with regard to visibility and distance from clouds; this is to both keep 

the UA from departing the VLOS and to preclude the UA from operating in the NAS. Sun

glare will be taken into account. PIC’s and VO’s ability to still see other air traffic, 

combined with the PIC’s ability to initiate a return - to-home sequence, are sufficient 

mitigations. The PIC will also account for all relevant site -specific conditions in his or her 

preflight procedures.

91.119

Prescribes safe altitudes for the operation of civil aircraft, but that it allows helicopters to 

be operated at lower altitudes in certain conditions. UAS will not be operated above the 

altitude of 400 feet above ground level (AGL) and will also only operate in safe areas 

away from the public and traffic, thus “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 the UAS, an equivalent or higher level of safety will be 

achieved.

91.121 

Altimeter settings is inapplicable since the UAS utilizes electronic GPS with a barometric

sensor. Sensor is calibrated before flight and reads AGL altitudes.

91.151 (a)

Fuel requirements for flight in VFR conditions, prior relief has been granted for manned

aircraft to operate at less than prescribed minimums, including Exemption Nos. 2689, 

5745, and 10650. In addition, similar UAS-specific relief has been granted in Exemption 

Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS will land prior to the

manufacturer’s recommended minimum level of battery power (30%). The operating

documents indicate that the low battery level failsafe is triggered when the battery is 

depleted to a point that may affect the safe return of the aircraft. Users are to return home 

or land the aircraft immediately when these warnings are shown. Pilot ground station will 

advise user to return the aircraft to the Home Point when low battery warning is triggered. 

Aircraft will automatically return to home point if no action is taken after 10 second

countdown. User can cancel the return to home any time. The thresholds for these 

warnings are automatically determined based on the current aircraft altitude and its

distance from home point. Aircraft will land automatically if the current battery level can 

only support the aircraft to land to the ground from the current altitude. User can use 

ground station to control the aircraft during landing process. 

(c) The extent of relief you seek, and the reason you seek the relief;
I seek the exemption for a period of 5 years starting August 15, 2015 in order to have time 

to build our business in a legal and responsible manner. We seek this relief to so that we 

may operate within the means of the law in this area.

(d)

The reasons why granting your request would be in the public interest; that is, how it 

would benefit the public as a whole; Aerial videography for geographical awareness

/mapping and for real estate marketing has been around for a long time through manned 

fixed wing aircraft and helicopters, but for small business owners, its expense has been 

cost-prohibitive. Granting this exemption would allow me to provide this service at a much 

lower cost. Further small UAS will pose no threat to the public given its small size and 

lack of combustible fuel when compared to larger manned aircraft.

The operation of this UAS will minimize ecological damage and promote economic growth 

by providing information to companies looking to relocate or build in this area.

(e)

The reasons why granting the exemption would not adversely affect safety, or how the 

exemption would provide a level of safety at least equal to that provided by the rule from 

which you seek the exemption;

Limitations under which the UAS will operate (i.e. VLOS and at or below 400 feet AGL) 

and the UAS emergency procedures as well as the size and speed of the aircraft

are sufficient mitigations to this risk so that the operations will not adversely affect

safety.

(f) A summary we can publish in the FEDERAL REGISTER, stating:

(1) The rule from which you seek the exemption; and Part 21; and §§ 45.23

(b); 91.7(a); 91.9(b)(2); 91.103(b); 91.119; 91.121, 91.151(a); 91.203(a) & (b); 91.405(a); 

91.407(a)(1); 91.409(a)(2); and 91.417(a) & (b) of Title 14, Code of Federal Regulations

(2) A brief description of the nature of the exemption you seek Kevin Jones vision is to 

provide access to unique, customized, and affordable aerial video, and photos using both 

unmanned aircraft. I would like an exemption to utilize the cost effectiveness of unmanned 

aircraft specifically the DJI Phantom Vision Plus 2. I know the cost of manned aircraft is 

too high and less efficient than small unmanned aircraft. Manned aircraft work great for 

large areas, but for a single photo/video the price is to high.