Marc Finney

207 South Livingston St.

Bucklin, MO 64631

mf14@me.com

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 

14 CFR 21 subpart H 14 CFR 45.23(b)

14 CFR 61.113(a) and (b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119(c)

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a)(1) and (2) 

14 CFR 91.417(a) and (b) 

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

(the “Reform Act”) and 14 CFR Part 11, Marc Finney, operator of Unmanned 

Aircraft Systems (UAS), hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of 
designated UAS, provided such operations are conducted within and under 

the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped 

with camera(s) and sensors, would provide professional services in the 

following areas:

1. Aerial photography and/or video for public and/or private use including 

real estate, architecture, land surveying, engineering and other related 

professional activities. 

2. Aerial video and/or photography for public and/or private use including 

television, public events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under 

contract with the owners or local government authority.

4. Aerial video/photography of lawn care and landscaping structures for 

analyzing lawn care jobs and retaining wall construction.

5. Aerial video/photography of crops, livestock, and other agricultural assets 

for farmers. Would consist of assessing crop production and livestock 

counts.

I plan to operate a UAS, the DJI PHANTOM 3 Professional which is 

comprised of an unmanned aircraft (UA or Phantom 3) and a transportable 

ground station. The Phantom 3 is referred to as a quad-copter with a 

maximum gross weight of about 3 pounds. It is equipped with four rotors that 

are driven by electric motors powered by batteries, a hard plastic body, and a 

4K video camera. The UA has a maximum airspeed of 16 m/s. 

Given the small size of the UAS involved and the restricted controlled 

environment within which it will operate, the applicant fits within that zone 

of safety (an equivalent level of safety) in which Congress envisioned that the 

FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UAS and the controlled

areas in which the relevant UAS will operate, approval of the application 

presents no national security issue. Given the following, the grant of the 
requested exemptions is clearly in the public interest: Marc Finney proposes 

that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These 

limitations provide for an exceptional level of safety to operations. These 

limitations and conditions to which Marc Finney agrees to be bound when 

conducting commercial operations under an FAA issued exemption 

including: 

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 30 minutes.

4. Flights will be terminated at 15% battery power reserve.

4. Flights will be operated at an altitude of no more than 400 feet AGL

5. UAS operator will be trained and certified in the proper safety and 

operations of the UAS. 

6. The UAS will only operate within a controlled area as defined in the 

Procedures.

7. The operator will post advisor notice around the controlled area.

8. The operator will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as 

required.

9. If the UAS loses communications or loses its GPS signal, the UAS will 

have capability to return to a pre-determined location within the Security 

Perimeter and land.

10. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies. 

Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption and are prepared to modify or amend any part of this 
request to satisfy the need for an equivalent level of safety. I look forward to 

working with your office. Please contact me at any time if additional 

information or clarifications are needed. 

Sincerely, Marc Finney