August 31, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey Ave.,

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations

To Whom it may concern:

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

Act"), Trent Raines (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") 

seeks an exemption from the Federal Aviation Regulations ("FARs") to allow for commercial 

operation for aerial imaging and video production, for use in the real estate, recreation and 

manufacturing industries.

Applicant

Trent Raines1256 SW Boswell Avenue Topeka, KS 66604

Attachments

Phantom 3 Professional User Manual

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H 14 CFR 45.23 (b)

14 CFR 91.7 (a)14 CFR 91.9 (b) (2)

14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 (c) 14 CFR 91.121

14 CFR 91.203 (a) and (b) 14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

Extent of relief I seek, and why

14 CFR Part 21 subpart H

The UAS to be operated carries neither pilot nor passenger and carries no explosive 

materials or flammable liquids. Given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized, I request exception. In the restricted environment 

and under the conditions proposed operation will be at least as safe, or safer, than a 

conventional aircraft operating with an airworthiness certificate without said restrictions.
14 CFR 45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to 

market certain words or phrases. Lettering would be very difficult to place on such a small 

aircraft and dimensions would need to be smaller than required minimum. Understanding the

importance of lettering I will mark my UAS with the largest possible letters by placing the 

word "Experimental" or assigned number or name, based on request/ruling of FAA, on UAS 

fuselage. The equivalent level of safety will be provided by having the UAS marked on its 

fuselage as required.

14 CFR 91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted,

no FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft for maintenance and use of safety check list prior to each flight an equivalent level of 

safety will be provided.

14 CFR 91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the 

aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. A 

equivalent level of safety will be maintained by keeping the flight manual at ground control 

point where the pilot will have immediate access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be 

needed. Normal procedures including but not limited to; reviewing weather, flight battery 

requirement, landing and takeoff distances, along will all of those found in attachment 

"Phantom 3 Professional User Manual". An equivalent level of safety will be provided by 

preflight protocol to properly match the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is 

achieved through the use of a control box that communicates with the aircraft via radio 

communications. The equivalent

level of safety provided because neither a pilot nor passenger will be carried in the aircraft, 

and by the speed and size of the aircraft.

14 CFR 91.113 (a) and (b)

I can achieve an equivalent level of safety as achieved by current regulations because my 

UAS does not carry pilot nor passenger. While helpful, a pilots' license will not ensure remote

control piloting skills.
14 CFR 91.121

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read 

out. I believe an exemption may be needed. An equivalent level of safety is achieve by the 

operator receiving live flight data monitoring and confirming current altitude along with 

altitude of launch site shown on GPS altitude indicator.

14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to 

carry certificate and registration documents on the aircraft. There is no room, capacity, or 

pilot on board to adequately manage such documents. An equivalent level of safety will be 

achieved by keeping these documents, to the extent they are applicable to the UAS, at the 

ground control point where pilot has immediate access to them.

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

Given these section only apply to aircraft with an airworthiness certificate, theses sections 

do not apply to this applicant. As a safety precaution, operator will perform preflight 

inspections and ensure UAS is in working condition before initiating each flight.

Trent Raines is seeking relief from all FARs above preventing applicant from conducting aerial

photography and video taken at levels less than 400ft, at a speed less than 33.5 mph, and 

with a maximum flight time of 25 minutes. The drone to be used is a DJI Phantom 3 

Professional. Drone is under 4 pounds of weight, and thus meets the definition of "small 

unmanned aircraft" found in section 331 “The Reform Act". In order to obtain high quality 

photography and video the UAS will be used at speeds much less than it's top speed of 33.5

mph. Due to the UAS being battery powered there are no combustible fuels onboard. 

Maximum flight time for these particular UASs is 25 minutes battery life, flights to be 

terminated with 25% battery life remaining. Given the size, weight, speed, and limited 

operating area associated with the aircraft to be utilized i find this exception to be reasonable

with an equivalent, or greater, level of safety to be reached by the operator.

Safety

*Please see attachment "Phantom 3 Professional User Manual" for safety precautions I use 

for every flight. Further, I am an experienced UAS Pilot with approximately 100 hours of fight 

time, operating in the National Airspace System for many years both in remote rural 

locations, and very congested areas.
Additionally:

1) I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the

airport manager has been made.

2) I land my UAS prior to manufacturer recommended minimum level of battery power.

3) I pilot my UAS through remote control by line of sight.

4) My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed 

position and then slowly lands if communication with the remote control pilot is lost.

5) I actively analyze flight data and other sources of information to constantly update and 

enhance safety protocols.

6) I conduct extensive pre-flight inspections and protocol, during which safety carries 

primary importance.

7) I always obtain all necessary permissions prior to operation.

8) I have procedures in place to abort fights in the event of safety breaches or potential 

danger.

Public Interest

The use of an UAS for artistic and commercial photography. This benefits the general public 

because it is much more efficient than traditional ways of using a plane or helicopter to 

achieve the aerial photography and videography. We can now provide this level of service 

while being conservative with fuel, time, emissions, noise, and other resources. Considering 

size, weight, speed, and absence of combustible fuels, my UAS will poses much less of a 

safety concern for the general public when compared to larger manned aircraft.

Thank you for your consideration.

Trent Raines