Chris Turner 07/16/2015

323-839-9828

13921 W Saratoga Ave

Morrison, CO 80465

bonemanchris@hotmail.com

Federal Aviation Administration: 

Dear Sir or Madam,

I, Chris Turner, am writing pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, to request that I, Chris Turner, an 

owner and operator of small unmanned aircraft, be exempted from the Federal Aviation 

Regulations (“FARs”) listed below so that I, Chris Turner, may operate a small ultra light 

weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the 

Federal Aviation Administration (“FAA”) in accordance with FAA UAS Regulations & 

Policies. 

I would like to formally submit for an exemption from the following Section 333 

regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 

91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 

91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 

14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b). To operate DJI’s following 

UAS: Phantom 3, and Inspire 1 along the guidelines of the accompanying DJI Inspire 1, 

and DJI Phantom 3 Operator’s manuals. These UAS will be equipped with detachable 

cameras and will be transported in proper storage. 

This proposed exemption would allow me operation of unmanned aircraft systems (UAS) 

for the purpose of aerial videography/ photography as a service to the public/ business 

interests. As found in exemption No. 11138 (Trudeau), the FAA recently approved 

similar use of a DJI UAS. These devices were selected because they have proven reliable 

flying capabilities managed by gyro stabilized flight, ground detection (phantom 3 and 

inspire 1) ,GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning 

home and prop guards. 

This will act to further safety protocols exclusive to lightweight UAS’s specific to video 

and photography usage as I, Chris Turner, record flight data and other information gained 

through permitted flight operations to share with the FAA through any required FAA 

reports to assists with future protocol and safety regulations. Specific section or sections 

of 14 CFR which I seek relief and the reason I seek relief: 14 C.F.R. Part 21: 

Airworthiness Certificates Given the size and limited operating area associated with the 

aircrafts to be utilized by I, Chris Turner, an exemption from Part 21 meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the reform 

Act. 
In all cases, an analysis of these criteria demonstrates that the UA operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than conventional aircraft operating with an airworthiness 

certificate without restrictions and conditions proposed. 14 C.F.R. 45.23: Display of 

marks: general The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or 

tail on which to mark certain words or phrases. Further, the two inch lettering is difficult 

to place on such a small aircraft with dimensions smaller than the minimal lettering 

requirement. 14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in 

command The FAA has previously declared that additional manned airship experience of 

a commercially certified pilot would not correlate to the airmanship skills necessary for 

similarly proposed operations in previously issued exemptions to this regulation through 

Exemption Nos. 11062 and 11138. 14 C.F.R 91.7: Civil aircraft airworthiness Currently, 

since there is no certificate applicable to the UAs in question, this regulation is 

inapplicable. 14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard 

requirements Requires an aircraft flight manual in the aircraft, however there are no pilots 

or passengers on board this aircraft and given its size, this regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual with the 

operator. 14 C.F.R. 91.119(c): Minimum safe altitudes I, Chris Turner will ensure that 

UAS do not operate any higher than 400 feet at ground level. I will not fly over congested 

areas. I will plan operations before hand, for proper flight safety, and proper height 

analysis as to avoid collisions. 14 C.F.R. 91.121: Altimeter settings The UAS utilize 

electronic GPS with a barometric sensor. An equivalent level of safety will be achieved 

by using this. 14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions 

The UAS that I will fly are powered by electricity, using lithium polymer batteries that 

currently have a flight limit of approximately no more than 20 minutes. Therefore, due to 

the limitations of the batteries, it is currently impossible to comply with part 91.151. 14 

C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required Currently, there are no 

procedures for providing airworthiness certificates for the mentioned UAS. 

I, Chris Turner, however will always fly safely while having the manuals of the DJI 

Phantom 2, DJI Inspire 1, and the DJI Phantom 3. 14 C.F.R. 91.405(a): Maintenance 

Required, 14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, 14 C.F.R. 91.409(a)(1) and (2): Inspections & 14 C.F.R. 91.417 

(a) and (b): Maintenance records Maintenance inspections may be required and should be 

granted since they only apply to aircraft with an airworthiness certificate. However I, 

Chris Turner, will perform preflight inspections of the UAS before each flight as outlined 

in the operating documents. I, Chris Turner, will also follow manufacturer 

recommendations from said operating documents. Public Interest Aerial photography and 

videography as an available service to the public allows for a cheaper method to 

capturing imagery than its alternative. The alternatives are aircraft and helicopters. They 

are expensive, create lots of noise, and are much more threatening due to size and 

combustible fuel. I, Chris Turner, would gladly offer my services upon request and with 

proper coordination to any official search and rescue or emergency services organization 

to benefit the public. Also as mentioned in the Trudeau exemption, exemption No.11138: 

““Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or 
more, are operated by an onboard pilot and may carry other onboard crewmembers, as 

well as 100 gallons or more of fuel. The petitioner’s [sUAS] weighs less than 3 lbs. The 

pilot and crew will be remotely located from the aircraft. The limited weight reduces the 

potential for harm to persons or damage to property in the event of an incident or 

accident. The risk of an onboard pilot and crew during an incident or accident is 

eliminated with the use of a [sUAS] for the proposed operation.” 

I, Chris Turner, am seeking exemption from the following rules: 14 C.F.R. Part 21, 14 

C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 

91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 

C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 

91.417(a) and (b) With the exemptions of the mentioned rules I, Chris Turner, will be 

seeking to make my drone photography/videography services available to the public. 

Alternatively the public had looked to use helicopters and aircraft to achieve what I can 

offer in a safer, more cost efficient manner. By not using combustible fuel, flying at safe 

heights and strictly following the usage recommendations from DJI. These include but 

are not limited to: ● Flying the following UAS Safely ○ DJI Inspire 1 ○ DJI Phantom 3 ●

Flying below 400 feet ● Proper visual inspection of UAS before flights ● Keeping 

mentioned UAS in visual sight at all times when in operation ● Using an observer to 

assist if needed ● Remain well clear of and do not interfere with manned aircraft 

operations, and avoid other aircraft and obstacles at all times ● Not intentionally fly over 

unprotected persons or moving vehicles ● Contact the airport or control tower before 

flying within 5 miles of an airport ● Not flying in adverse weather conditions such as 

high winds or reduced visibility ● Not flying under the influence of alcohol or drugs ●

Ensure the operating environment is safe ● Not flying over sensitive infrastructure or 

property such as power stations, water treatment facilities, correctional facilities, etc. ●

Check and follow all local laws and ordinances before flying over private property ● Do 

not conduct surveillance or photograph persons in areas where there is an expectation of 

privacy without the individual's permission.

Thank you for your time,

Chris Turner

323-839-9828

13921 W Saratoga Ave

Morrison, CO 80465

bonemanchris@hotmail.com