Donald Pillow

10738 Dana Dr.

Roscommon, MI 48653

drones@dp-designs.biz

DP Designs, llc

Website: www.dp-designs.biz

989-302-7322

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations from: 14 CFR 21 subpart H

14 CFR 45.23(b)

14 CFR 61.113(a) and (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 91.151(a)

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

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

14 CFR 91.417(a) and (b)

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

CFR Part 11, Donald Pillow, operator of Unmanned Aircraft Systems (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.

Commercial operation of an UAS, as described herein, which are equipped with camera(s)

and sensors, would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but 

not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

6. Training to persons individually or belonging to both private and/or public organizations to 

increase awareness and improve safety for current and future UAS operations within the

NAS.

7. Working with local Fire Departments in creating Arial video/photography of structural and wildland 

fires, also training sessions to help improve on scene safety and proficiency.

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.” The use of UAS in Firefighting would expand the knowledge and 

aid in safety while training many firefighters.

I plan to operate a UAS, the Tarot 680 PRO which is comprised of an unmanned aircraft and camera 

gimbal connected to a transportable ground station. The Tarot Pro is referred to as a hexa-copter 

with a maximum gross weight of about 11 pounds. It is equipped with six rotors that are driven by 

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

rotors allow the UAS to safety land in case of a motor/propeller failure.

I also plan to operate a UAS, the DJI S1000 which is comprised of an unmanned aircraft and camera 

gimbal connected to a transportable ground station. The S1000 is referred to as an octo-copter with 

a maximum gross weight of about 15 pounds. It is equipped with eight rotors that are driven by

electric motors powered by batteries. The UA has a maximum airspeed of 12 m/s. By design the 

eight rotors allow the UAS to safety land in case of a motor/propeller failure.

I am also in the process of designing/building a custom octo-copter, heavy lift with a maximum 

weight of 20 pounds. The UAS is equipped with redundant control and power in case of 

electrical/component failure. The UAS can safety land with up to two motor failures. The design is of 

low speed and long duration flights (6-7 m/s and 30 minute flight time). Multiple sensors for

proximity limits are installed to facilitate safety. This UAS will be useful in close proximity building 

inspection and post wildfire video/photography. This UAS is in design/testing stage and will be 

submitted for COA in the near future.

Also, given the small size of the UAS’s involved and the restricted controlled environment within 

which they 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 UASs and the controlled areas in 

which the relevant UASs 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: 

James Bender 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 James Bender 

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 15% battery power reserve.

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

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

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

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

8. The operator will have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated as required.

9. 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.

10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.
I have been flying RC planes, jets and helicopters for 40 years. I have studied, built and flown UAS’s for 

the last 2-1/2 years. I am currently taking a training class for getting my FCC Private Pilots Practical Test 

to help better understand the safety and responsibilities of the UAS operators. I have been firefighter 

for the past 32 years. I work full time for the State of Michigan, designing wildland firefighting 

equipment. Michigan is currently looking into qualifying operators for the use of UAS’s in land and 

wildlife surveys. I hope to be involved in the implementation of this system.

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, 

Donald 

Pillow