Joseph Fletcher

6 Caverno Drive

Lee, NH 03861

Josephfletcher2@gmail.com

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 

C.F.R. Part 11, Joseph Fletcher, a freelance multimedia producer, hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of our Unmanned Aircraft System 

(UAS) 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 Joseph Fletcher to pursue his commercial interests in providing 

services to clients using a small advanced UAS in the following areas: Real Estate, Marketing, Land 

Management/Surveying, Scenic Photography, and Special Events. Joseph Fletcher feels that these services 

are in the interest of the public and therefore constitute an exemption from the current FAA regulation. 

Joseph Fletcher states that all UAS flights will occur over private or controlled access property and will do 

so with the property owner's consent and knowledge and that only people who have consented or otherwise 

have agreed to be within the UAS’ radius during filming and photography applications.

Joseph Fletcher has demonstrated the ability to safely and effectively fly the UAS DJI Phantom 3 

Professional, which will be used for all commercial and private purposes. Joseph Fletcher complies with 

local ordinances and laws regarding the operation of UAS, and adheres to all weather and environmental 

restrictions or limitations in reference to the operations of UAS. Furthermore, Joseph Fletcher has 

completed a formal UAS safety-training course offered by Dart Drones LLC, a company operating solely 

to educate and train UAS pilots. 

I, Joseph Fletcher, am seeking the exemption because I am committed to complying with all of the rules, 

guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the UAS in the 

manner that I have described, and for the purposes that I have described. Without the exemption request 

granted, I would be unable to safely and effectively run my business, and it is my intention to comply with 

the FAA and obtain an exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of 

responsibilities I assume as operator; it also contains information regarding the aircraft, safety features, and 

public interest.

Regulations from which exemption is requested: 

14 C.F.R. Part 21 

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. 91.109 

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. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Joseph Fletcher, operator of UAS, hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such 

operations are conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333. 

As described fully below, the requested exemption would permit the operation of designated UAS as set 

forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) 

predetermined and d) safe. Approval of this exemption would increase public awareness of UAS operations 

and enhance safety to aid in fulfilling the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “....establish requirements for the safe operation of such aircraft systems in the national 

airspace system.” 

I, Joseph Fletcher, plan to operate a UAS, the DJI Phantom 3 Professional, which is comprised of an 

unmanned aircraft (UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a 

quad-copter with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven 

by electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. 

Given the small size of the UAS involved and the restricted controlled environment within which it will 

operate, the applicant fits within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence 

immediately. Also due to the size of the UAS and the controlled areas in which the relevant UAS will 

operate, approval of the application presents no national security issue. Given the following, the grant of 

the requested exemptions is clearly in the public interest: Joseph Fletcher proposes that the exemption 

requested herein apply to civil aircraft that have the characteristics and that operate with the limitations 

listed herein. These limitations provide for an exceptional level of safety to operations. These limitations 

and conditions to which Joseph Fletcher agrees to be bound when conducting commercial operations under 

an FAA issued exemption including: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

4. Flights will be terminated at 25% battery power reserve. 

5. Flights will be operated at an altitude of no more than 400 feet AGL 

6. UAS operator will be trained and certified in the proper safety and operations of the UAS. 

7. The UAS will only operate within a controlled area as defined in the Procedures. 

8. The operator will post advisor notice around the controlled area. 

9. The operator will have been trained in operation of UAS generally and received up-to-date information 

on the particular UAS to be operated as required. 

10. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land. 

11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level of safety. 

We look forward to working with your office. Please contact us at any time if additional information or 

clarifications are needed. 

Sincerely, 

Joseph Fletcher