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October 27, 2015

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	Section	333	Exemption	Under	14	CFR	§	11.81 to	Allow	Commercial	Use	of	

Unmanned	Aircraft	Systems.

Petitioner: Christopher J. Riley

3684 Gould Drive

Carmel, IN 46033

Rilo1982@gmail.com

(317) 531-6022

Dear Sir or Madam,

This application is substantially based on the FAA’s findings in Exemption No. 11062 granted to Astraeus 

Aerial (Federal Aviation Admission (FAA)-2014-0352), Exemption No. 11109 Clayco, Inc. (FAA-2014-

0507), Exemption No. 11208, Sky-Futures UAS, Inc. (FAA-2014-0641), Exemption No. 11252, Nixon 

Engineering Solutions, LLC. (FAA-2014-0763), Exemption No. 11306, Hawk Aerial, LLC. (FAA-2014-1023), 

Exemption No. 11380, First Team Real Estate, (FAA-2015-0052), and in reliance on the analysis provided 

therein.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333

b. 14 CFR Part 21, subpart H

c. 14 CFR Part 61.113(a) and (b)

d. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409
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x. 91.417

xi. 91.119 

2. Relief sought:

a. Christopher J. Riley wishes to operate small Unmanned Aircraft Systems (UAS) for commercial 

purposes to include (but not limited to) aerial surveying, mapping, infrastructure inspection, 

videography, photography, aerial data collection, news gathering, construction, archaeology, 

training/education, closed-set film and movie production, emergency response/public safety, 

cinematography, search/rescue, maritime/port security, events, transportation support, and analyses. 

This relief is sought because commercial use of UAS is currently prohibited by law unless performed 

under an exemption.

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds 

including payload and energy sources:

DJI Inspire 1.

DJI Phantom 1, 2 & 3.

3DR Iris+.

3DR Solo.

Other models to be added by future amendment to this exemption.

3. Public benefit:

a. Use of UAS technology to obtain imagery, information and data currently obtained by

use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g.,

power line inspections) and due to other dangerous activities that can be

avoided (e.g., scaffolding/rigging failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits consumers and

the economy.

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from 

manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47

and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the

manufacturer. All repair and maintenance work will be conducted or approved by

qualified personnel such as those authorized by Robotic Skies (or equivalent), and will

require a test flight after such work. Records of all maintenance and repair work will
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be kept in a maintenance log for each aircraft, and available upon request.

c. All flight operations will be conducted by two individuals who will maintain verbal

communication capability with each other at all times during the flight, and who will

remain stationary on the ground during the flight operations:

d. A Pilot In Command (PIC) who possess the following credentials:

1. An airline transport, commercial, private, recreational, or sport pilot

certificate.

2. A Third Class medical certificate issued under 14 CFR 67 or valid U.S.

driver license.

3. A Bi-annual flight review under 14 CFR 61.56

4. At least 200 cycles and 25 hours of flight experience in a UAS rotorcraft

(or UAS fixed-wing in the case of fixed-wing flight operations under this

exemption). Such cycles and hours may be gained during flights under

this exemption if a safe distance is maintained from persons in

accordance with 14 CFR 91.119.

5. At least 5 hours of flight experience and 3 takeoffs and landings in make

and model being flown in the prior 90 days. Such cycles and hours may

be gained during flights under this exemption if a safe distance is

maintained from persons in accordance with 14 CFR 91.119.

e. A Visual Observer (VO).

f. All flight operations will be conducted in accordance with valid Certificates of Authorization.

g. All flight operations will comply with the following:

i. The manufacturers’ Aircraft Flight Manuals and operation guidelines.

ii. flight operations policies including lost communication and other

emergency and safety procedures.

iii. Conducted in visual meteorological conditions (VMC) conditions during daylight hours.

iv. Pilot in Charge (PIC) and Visual Observer (VO) will maintain visual line of sight (VLOS) at all 

times.

v. Pre-flight inspections (including ground control station, if any) and safety risk

assessments will be conducted prior to each flight.

vi. Flight altitudes will remain at or below 400 feet above ground level.

vii. Flight speeds will not exceed 87 knots.

viii. Not take place over urban areas or within 5 miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons

on the ground without their prior permission.

x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook.

xi. Not exceed 80% of the battery capacity of the aircraft.

xii. Any incidents will be reported within 24 hours of occurrence.

xiii. Any applicable local Flight Standards District Office (FSDO) requirements.

xiv. All other applicable regulations concerned with the operation of aircraft.

91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to 

persons or property on the surface.
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(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted 

without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this 

section, provided each person operating the helicopter complies with any routes or altitudes specifically 

prescribed for helicopters by the FAA.

Please advise us of any additional information or changes that are required.

Sincerely,

Christopher J. Riley

October 27, 2015