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IN THE UNITED STATES FEDERAL AVIATION ADMINISTRATION 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

___________________________________________________________ 

PETITION FOR EXEMPTION SECTION 333 

Exemption Request 

Sections: 

 Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 

CFR Part 21;14 CFR 61.113 (a) & (b); 91.7 (a);91.9 (b) 

(2);91.103(b); 91.109;91.119; 91.121; 

91.151(a);91.203(a) & (b);91.405 (a); 91.407(a) (1); 

91.409 (a) (2);91.417 (a) & (b) 

Applicant: Craig Anthony Miller 

Sunset Capture, Inc. 

Sunset Capture Address: 1201 Puerta Del Sol, Suite #229 

San Clemente, CA 92673 

Contact Information Email: craigmiller@sunsetcapture.com

Website: www.sunsetcapture.com

Aircraft (“UAS”) Iris Plus by 3D Robotics Inc. 

Operation Manual Attached as Exhibit A 

___________________________________________________ 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Dear Madam or Sir: 

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

Reform Act) and 14 C.F.R. Part 11, Craig Anthony Miller, developer and operator of Small 

Unmaned Aircraft Systems (“UASs”) respectfully petitions for the following: 
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Purpose: 

I am requesting an exemption to provide a commercial service to private and 

commercial land owners who wish to obtain and capture aerial photos and videos of their 

property for the purpose of inspection, real estate listings, insurance property claims and as a 

marketing tool for their businesses. 

Public Benefit: 

The benefit and service to the public is realized in several applications with the 

predominate application being building surveys. In the event a building is suspected of 

sustained damage of some type, through this exception, the UAS can provide aerial images that 

can be used by engineers and inspectors to ascertain the extent of the damage and document any 

repairs made for safety and wellbeing of the public. 

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; B 

Having been a recreational Unmanned Aircraft System operator for three years I have 

over 300 hours of experience and I understand the importance of different uses and safety 

concerns regarding FAA regulated airspace and I would be a good candidate for exemption of 

Sec 333. The specific UAS, Iris Plus, I am seeking exemption with is one with many safety 

programs, including SAFE technology and GPS navigating. When flying for this commercial 

purpose I would be flying at a maximum altitude of 40 meters and flying mostly vertically for 

the purposes of taking photos, decreasing the risk of any interference. My general knowledge of 

the aviation safety systems implemented by the FAA would be used to ensure that safety would 

not be affected by my operations. I would not be flying near disaster areas, sporting events, or 

high traffic areas including airports, and I would pay attention to NOTAMS. 

Flight Use & Restrictions: 

All flights will be flown using the UAS that is under 6 pounds, at or below 200 feet, 

during the daytime abovayikng Visual Flight Rules conditions, and I will operate them within a 

visual line of sight (VLOS), and will keep a distance from airports or heliports: 
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i. five (5) nautical miles (NM) from an airport having an operational control tower; 

or 

ii. three (3) NM from an airport with a published instrument flight procedure, but 

not an operational tower; or 

iii. two (2) NM from an airport without a published instrument flight procedure or 

an operational tower; or 

iv. two (2) NM from a heliport with a published instrument flight procedure 

 I will be flying with the: (i) GPS enabled, (ii) home position locked, and (iii) following 

all other preflight safety regulations and flight protocols directed and designed by the 

manufacture that do not conflict with FAA regulations. I Intend to follow these suggested 

safety regulations • Always keep aircraft in sight and under control. • Always keep people and 

pets at least 35 feet (10 meters) away when the battery is connected. • Keep children out of the 

vicinity of this product at all times. • Always use fully charged batteries. • Always keep 

transmitter powered on while aircraft is powered. • Always remove batteries before 

disassembly. • Always keep moving parts clean. • Always keep parts dry. • Always let parts 

cool after use before touching. • Always remove batteries after use. • Always have a first aid kit 

with you. • Always have an appropriate fire extinguisher with you. • Never operate aircraft with 

damaged wiring. • Never touch moving parts. 

I have no intention on using this exemption outside the United States. I would greatly 

appreciate the award of an exemption and please feel free to contact me if you have any 

questions or concerns. 

Respectfully submitted, 

 By: Craig Anthony Miller 
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Exhibit A 

UAS Operation Manual 

Separately Attached