Tim Shingleton

Playthings Etc.

2483 William Flynn Hwy

Butler PA 16001

724-285-7529

fax 724-285-7594

Subject: Exemption Request Section 333 of the FAA Reform Act 

and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 

Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 

91.103

Following the format of FAA Exemption No. 11138 

-Regulatory Docket No. FAA –2014 –0481 I have included: 

1) Supplemental Response for Petition 

2) BLADE Chroma Drone with CGO2+ Manual

Pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 and 14 C.F.R. Part 11, I, Tim Shingleton, a Model 

Aircraft operator for 10+ years, preparing this exemption request

myself, would like to apply for an exemption from the following 

Code of Federal Regulations (C.F.R) to be allowed commercial 

operation of lightweight Unmanned Aircraft Systems (UAS) for 

aerial imaging and video of Western Pennsylvania properties

and buildings. I own a hobby grade BLADE Chroma Drone 

(maximum gross weight 3 pounds, equipped 

with four rotors that are driven by electric motors powered by 

batteries, the UAS has a maximum airspeed of 30 knots) 

manned only with a CGO2+ Camera for the intent of aerial 

photography/videography to enhance academic community 

awareness and augment real estate listing images and videos; 

following an exemption and approval by the FAA.

My exemption request would permit operation of ultra-light 

weight, unmanned (piloted by remote control) in predetermined 

areas away from general public, airports, heliports, and vehicular 
traffic, daylight hours only, under 200 ft. and after carefully 

reviewing, inspecting and examining the area of aerial

observation. This would allow for community and individual 

homeowner real estate listing videos/images within property 

boundaries.

I will abide all FAA requirements to ensure this exemption will 

provide a level of safety at least equal to existing rules and will 

only operate in a safe environment that is strictly controlled, are 

away from power lines, elevated lights, airports and actively 

populated areas; and I will conduct extensive preflight 

inspections and protocols, during which safety carries primary 

importance.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 

CFR § 91.203 

Given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized, I am asking exemption 

from 14CFR part21,Subpart H(Airworthiness Certificates) and

§91.203 (a) and (b) (Certifications required), subject to certain

conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14CFR part 

11 and Section 333 of P.L. 112-95 

(Section 333). 

14 C.F.R. 45.27(a): Location of marks; non fixed-wing 

aircraft. 14 C.F.R. 45.29 (3) (c)(d)(e)(f)(h): Size of Marks 

Furthermore I request an exemption from §45.23 Marking of the 

aircraft because my UAS will not have a cabin, cockpit or pilot 

station on which to mark certain words or phrases. Additionally 

two -inch lettering is difficult to place on such a small aircraft with 

dimensions smaller than the minimal lettering requirement. I 

understand the need for markings and will mark my UAS in the 

largest possible lettering by placing the word “Experimental” or 

assigned number or name (based on a request or ruling by the 

FAA ) on its fuselage as required by §45.29(f) so that anyone 
assisting him as a spotter will see the markings. I also ask for an 

exemption from §§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. But, as a safety precaution I will perform 

a preflight inspection of my UAS before each flight as outlined in 

it's operating documents. 

14 CFR 61.113 (a) & (b): Private pilot privileges and

limitations: Pilot in command. 

Under §61.113 (a) and (b) private pilots are limited to noncommercial operations, however I can achieve an equivalent 

level of safety as achieved by current regulations because my 

UAS does not carry any pilots or passengers. While helpful, a 

pilots’ license will not ensure remote control piloting skills. The 

risks of operating a UAS are far less than the risk levels inherent 

in the commercial activities outlined in 14 CFR part61,et seq., I 

requests an exemption from §61.113 Private Pilot Privileges and 

Limitations. 

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action 

If granted an exemption I agree to additional safety procedures 

including, but not limited to: 

1) Keeping my UAS within a radius distance of 1000 feet from the 

controller to both aid in direct line of sight visual observation. 

2) Operate the UAS for 15-20 minutes per flight; land my UAS 

according to the manufacturer’s recommended minimum level of 

battery power. 

3) Operate my UAS only within visual line of sight (VLOS). 

Daylight hours only.

4) Use the UAS’s global positioning system (GPS) flight safety 

feature; it hovers and then slowly lands if communication with the 

remote control. 

5) Conduct all operations under my own personal and flight safety 

protocols (including posting a warning sign reading: “Attention 

Aerial Photography in Progress –Remain Back 150 feet”). 
6) I will operate and will actively analyze flight data and other 

sources of information via telemetry to constantly update and 

enhance my safety protocols. 

7) Contact respective airports if operations will be within 5 miles to 

advise them of his estimated flight time, flight duration, elevation of 

flight and other pertinent information. 

8) Always obtain all necessary permissions prior to operation. 

9) Have procedures in place to abort flights in the event of safety 

breaches or potential danger. Aerial videography for geographical 

awareness of real estate marketing has been around for a long 

time through manned fixed winged 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, my small UAS, when used properly, will 

pose no threat to the public given its small size and lack of 

combustible fuel when compared to larger manned aircraft. I 

believe that the use of any tool that increases value to a home or 

community (by adding visibility to more potential buyers) is in the 

best interest of homeowners nationwide. Selling a home faster and 

for more money because of the use of new technology (being 

safely used and approved by the FAA) will go a long 

way to ensure our economy continues to grow.

Sincerely,

Tim Shingleton