Michael Ryan Froelich

242 Magnolia Avenue

Mocksville, NC 27028

ryan.froelich1@gmail.com

February 16, 2015

Dear FAA;

This petition is being submitted on my own behalf without legal counsel or consulting 

services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act), and 14 C.F.R. Part 11, I, operating a Small Unmanned Aircraft System 

(“sUAS”) equipped to conduct aerial photography and survey for my personal Real 

Estate business, hereby apply for an exemption from the Federal Aviation Regulations 

(FARs) listed below to allow operation of my sUAS commercially in airspace regulated 

by the Federal Aviation Administration (FAA) so long as such operations are conducted 

with and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. The requested exemption would permit me to pursue by 

commercial interests in providing services to consumers interested in aerial data 

capture using a small advance sUAS in the following areas:

 Media Production 

 Real Estate Photography 

 Agricultural & Land Surveying 

 Aerial Mapping 

 Product Demonstrations 

I hereby state that all sUAS flights that will occur over private or controlled access 

property will do so with the property owner's prior consent and knowledge and that 

only people who have consented or otherwise have agreed to be in the area where 

photography and videography will take place will be captured in identifiable form. 

Regulations from which the exemption is requested:

14 C.F.R. Part 21 

14 C.F.R. 45.23 (b) 

14 C.F.R. 91.7 (a) 

14 C.F.R. 91.9 (b) (2)

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) & (b) 

14 C.F .R. (91.401 - 91.417)

Small Unmanned Aircraft System (sUAS) are a feasible method to perform valuable 

commercial media, film and photography functions more safely and effectively than 

other methods. sUAS are a feasible method for capturing imagery for survey and 3D 

mapping. I am petitioning for exemption to operate a DJI Phantom 2 multi-rotor 

equipped with a three-axis gimbaled camera. This sUAS weighs less than 55 lbs., has a 

built-in capability to limit the height flown above the ground and to limit the radius of 

the distance flown from the operator and to exclude the sUAS from Class B, C and D 

airspace including a no fly zone feature. This system also has the failsafe function of the 

autopilot system, which means that when the communication between the Main 

Controller and the transmitter is lost, the system will automatically trigger Return to 

Home and will land safely at the original launch point.

The sUAS utilizes four counter-rotating propellers for balance, control and stability in all 

segments of flight. The craft weighs less than 55 pounds, including cinematic and other 

equipment. The small unmanned aircraft is designed to primarily hover in place and 

operate at less than a 50 knot maximum speed. It is capable of vertical and horizontal 

operations but operates only within the line of sight of the remote control pilot. The 

above specifications meet standards listed below, some derived in accordance with 

the Model Aircraft Operating Standards: 

• The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and 

will operate at a 'sufficient distance' from populated areas. Such operations will insure 

that the sUAS will "not create a hazard to users of the national airspace system or the 

public."

• When flying sUAS within 3 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of fullscale aircraft. 

• During sUAS operations, the petitioner will place visual notifications at the operation 

site to alert any nearby persons that sUAS operations are in progress.

• Maximum flight time for each operational flight will be 60 minutes. 

• Flights will be terminated at 25% battery power reserve should that occur prior to the 

60 minute limit.

• The sUAS will be programmed so that it will not be operated at an altitude of no more 

than 600 feet AGL, and not more than 200 feet above an elevated platform from which 

filming is planned.
• Minimum crew for sUAS operations will consist of the sUAS Pilot and the Visual 

Observer. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the 

payload (i.e. camera, lens, and gimbal).

• The sUAS will operate at speeds of no more than 55 knots. 

• Given the small size of the sUAS and the restricted sterile environment within which 

they will operate, our sUAS operations adhere to the Reform Act's safety requirements.

My operation of the sUAS aircraft will not "create a hazard to users of the national

airspace system or the public." 112 P.L. 95 § 3 3 3 (b). Given the small size and weight of 

my sUAS, combined with my safety focused operation standards, my flight operations 

fall within Congress's contemplated safety zone when it disseminated the Reform Act 

and the corresponding directive to integrate UASs into the national airspace system. My 

sUAS does not pose any threat to the general public or national security. As an

operator, I have extensive knowledge of and experience with sUAS systems, and have 

a high regard to safety and coordination with general aviation. 

I respectfully request exemption under Section 333 to enable me to operate safe, lowrisk commercial sUAS for the activities stated. I, at all times, will respect the space and 

privacy of citizens and property whilst keeping our skies safe. 

Sincerely,

M. Ryan Froelich

242 Magnolia Avenue

Mocksville, NC 27028
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

I, Michael Ryan Froelich, request an exemption from the following regulations as well as 

any additional regulations that may technically apply to the operation of the sUAS 

System: 

14 CFR Part 21, Airworthiness Certificates

Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 

21, Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR§ 

91.203(a)(1 ). Given the size of the aircraft and the limited operating area associated 

with its utilization, it is unnecessary to go through the certificate of airworthiness process 

under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption 

meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the-requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the UAS involved. In this case, an analysis 

of these criteria demonstrates that my UAS operated without an airworthiness 

certificate, under the conditions proposed herein, will be at least as safe, or safer, than 

a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 

UASs will remain less than 55 lbs. GTOW, will not carry a pilot or passenger, will not carry 

flammable fuel, and will operate exclusively within an area predisclosed and in 

compliance with conditions set forth herein. Operations under this exemption will be 

tightly controlled and monitored by both the operator, pursuant to the conditions set 

forth above, and by local public safety requirements. The FAA will have advance 

notice of all operations through the filings with the FSDO. Receipt of the prior permission 

of the land owner, or controlling authority, the size of the aircraft, the lack of flammable 

fuel, and the fact that the aircraft is carried to the location and not flown there all 

establish the equivalent level of safety. The UASs construction with absorbent material 

provides at least an equivalent level of safety to that of such operations being 

conducted with conventional aircraft that would be orders of magnitude larger and 

would be carrying passengers, cargo, and flammable fuel. 

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must display 

the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, 

cockpit, or pilot station. The sUAS does not have an entrance in which the word 

"EXPERIMENTAL" can be placed, and may not have a registration number assigned to it 

by the FAA. I propose to achieve an equivalent level of safety by including the word 
"EXPERIMENTAL" in the placard on the top of the aircraft where the PIC, VO and others 

in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. 

14 CFR 91.7 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 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. I assume that the intent of this requirement is to 

ensure that flight manual information is available to the aircrew while operating the 

aircraft. I request an exemption to this requirement since the aircraft is not only too small 

to carry documentation, the documentation would not be available to the crew during 

flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, I

propose that a current, approved sUAS Flight Manual must be available to the PIC at 

the ground station anytime the aircraft is in, or preparing for, flight. 

14 CFR 91.119 Minimum safe altitudes: General. 

The regulation states that over sparsely populated areas the aircraft cannot be 

operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the 

typical mission of the sUAS would be photography or survey of persons, vessels, vehicles 

or structures it would be necessary to operate closer than 500 feet to the items listed. 

Operations will only be flown over property or persons where permission has been 

obtained and careful pre-planning has been performed. The aircraft will be operated 

at a low altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface. Therefore I maintain that, due to the small 

size of the UAS, the hazard to persons, vehicles and structures is minimal compared to 

umanned aircraft, which should be considered in granting the exemption. 

14 CFR 91.121 Altimeter settings. The regulation requires that aircraft shall maintain 

cruising altitudes by reference to an altimeter setting available within 100 NM of the 

aircraft. The sUAS will always fly below 600 feet AGL and will not need to maintain 

cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the sUAS 

on-board computer to the display screen held by the PIC, providing a constantly 

updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point of intended landing and to 

fly after that for at least 30 minutes. I feel the intention of this paragraph is to provide an 

energy reserve as a safety buffer for delays to landing. The sUAS is battery operated 
and the maximum duration of flight from a single battery charge is 12-45 (depending on 

which sUAS) minutes with a 20% reserve. Since the aircraft will never fly more than 1/2 

NM from the point of intended landing, a full battery charge at launch will ensure that I

meet the reserve energy requirement of this paragraph. I request an exemption to the 

word "fuel" and ask for an equivalent interpretation with the word "energy". I also 

request exemption from the 30 min reserve and ask that my reserve will be to fly the 

mission to the point of intended landing and have at least a 20% battery reserve after 

that. 

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required. The regulation provides that 

an airworthiness certificate, with the registration number assigned to the aircraft and a 

registration certificate must be aboard the aircraft. Additionally, subparagraph (b) 

provides that the airworthiness certificate be "displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew." With the DJI Phantom 2, at a 

maximum gross weight of 13 pounds, the sUAS is too small to carry documentation, 

does not have an entrance, and is not capable of carrying passengers or crew. To 

obtain an equivalent level of safety and meet the intent of 91.203, I propose that 

documents deemed appropriate for this aircraft by the FAA will be collocated with the 

crew at the ground control station and available for inspection upon request. In order 

to identify the aircraft, I propose that the information found on airworthiness and 

registration certificates be permanently affixed to the aircraft via placard containing 

the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 

CFR 45.23. 

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations.

The regulation provides that the operator is primarily responsible for maintaining the 

aircraft in an airworthy condition, including compliance with part 39 and 43. 

Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to 

service by a person authorized under 43.7" after maintenance and inspection. It is my

intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the 

aircraft is in an airworthy condition prior to every flight and in addition, conduct 

detailed inspections after every two hours of flight. Maintenance performed by the PIC 

is limited to repairing small cracks, replacing a propeller, checking electrical 

connections and updating software and firmware for the on-board computer. All other 

maintenance will be performed by the manufacturer or their designated repair facility. 

The PIC will document work performed in accordance with 91.417. I feel that due to the 

size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level 

of safety