Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

Gary Roberts

2802 S Pantano Rd

Tucson, AZ 85730

(520) 790-1222

gary@hmmaz.com

The specific section or sections of 14 CFR from which you seek an exemption;

Petition for Exemption under Sec 333

The extent of relief you seek and the reason you seek the relief;

Sec 333 prohibits the use of a UAS for commercial purposes. I am a member of the Academy of 

Model Aeronautics and am simply petitioning for an exemption to provide a commercial service 

for non-profit faith based organizations which are working with poor and underprivileged people, 

or unwed mothers, such as Hands of Hope and Gospel Rescue Mission. I will do this through 

Harvest Media Ministry, who I work for. I cofounded Harvest Media Ministry in 1996, and have 

experience in video production since 1992. I’ve traveled to 26 countries, having produced 

videos for dozens of organizations both locally and abroad. Our website is 

www.harvestmediaministry.com. We desire to increase the production value of the videos we 

produce by adding the dimension of aerial cinematography. I would like to be able to accept 

payment for these services therefore making this a commercial use of a UAS.

How your request would benefit the public as a whole;

My request benefits the public as a whole by providing an opportunity for small non-profit 

organizations to take advantage of the technology that now exists in the form of UAS’s. It would 

add production value to the promotional videos we produce for them which could, in turn, reach 

a wider audience, resulting possibly in them receiving more donations, allowing them to help 

more people in need.

The proposed operations

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

production, public events, landscape cinematography and network news imaging; aerial 

inspection/photography of residential/commercial structures under contract with the owners or 

local government authority.

Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule;

Being a certified AMA RC Pilot and therefore understanding the importance of different uses and 

safety concerns regarding FAA regulated airspace, I would be a good candidate for exemption 
of Sec 333 while not putting Air Safety in any accelerated risk. I plan on using any of the 

following UASs: DJI Inspire 1, DJI Phantom 2, GoPro’s Karma, YUNEEC Typhoon H, Yuneec 

Tornado H920, DJI Phantom 4. The DJI Phantom 4 has some innovative safety features, 

including a range of new onboard sensors and computing capabilities that make it easy to pilot 

and very difficult to crash. It is embodied by two small optical sensors embedded in the front of 

the aircraft that let the Phantom “see” what’s in front of it. These, along with the drone’s primary 

camera, motion sensors, and a downward-facing optical sensor on the belly of the aircraft, allow 

the drone’s computer vision software to create a volumetric map of its environment. This is 

otherwise known as “sense-and-avoid” technologies. By using this UAV, I would not be 

adversely affecting safety.

A summary we can publish in the Federal Register

I, Gary Roberts am seeking an exemption of the FAA’s Sec 333 rules that does not allow the 

use of an Unmanned Aircraft to be used for Commercial purposes in regards to National 

Airspace Safety. I am simply petitioning for an exemption to provide a commercial service for 

non-profit organizations which are working with poor and underprivileged people.

I would be a good candidate for exemption of Sec 333 while not putting Air Safety in any 

accelerated risk. I appreciate the FAA’s consideration of this petition for exemption.

Any	addi(onal	informa(on,	views,	or	arguments	available	to	support	your	request;	

I	am	fully	aware	of	the	pre	flight	safety	checks	and	procedures	implicated	in	the	opera8on	manual	

for	the	Inspire	1	and	Phantom	2,	and	intend	to	implement	pre	flight	safety	checks	and	u8lize	the	

safety	technology	provided	with	these	units,	and	any	others	I	purchase.	I	intend	to	be	fully	aware	of	

my	surroundings	at	all	8mes	and	to	only	fly	the	unmanned	aircraA	within	a	visual	line	of	sight	and	

only	in	Visual	Flight	Condi8ons.	

I	believe	I	would	be	a	good	candidate	for	exemp8on	of	Sec	333	since	I	graduated	from	Unmanned	

Vehicle	University’s	drone	pilot	training	program	in	July,	2014,	which	consists	of	three	phases.	Phase	

one	was	16	hours	of	ground	school	where	I	covered	a	variety	of	drone	training	topics.	In	phase	two	I	

received	10	hours	of	simula8on	where	I	was	able	to	fly	47	different	UAVs.	In	phase	three	I	took	16	

hours	of	drone	flight	training	at	the	training	center	in	PrescoQ,	AZ,	where	I	learned	how	to	fly	a	UAS.		

Since	then,	I	have	been	opera8ng	the	Phantom	2	since	July,	2014	for	recrea8onal	purposes,	but	now	

I	would	like	to	be	able	to	fly	my	UAS	commercially.