May 1, 2015

Exemption No. 11478

Regulatory Docket No. FAA-2015-0125

Richard Bowden Dobbins 

The Dobbins Company

3827 Cliff Crest Drive

Smyrna, Georgia 30080

Dear Mr. Dobbins:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter dated January 12, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of The Dobbins Company (hereinafter petitioner or operator) for an exemption. 

The exemption would allow the petitioner to operate an unmanned aircraft system (UAS) to 

conduct commercial operations for real estate inspections including; residential, commercial 

and rural properties.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2.
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In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that the relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, The Dobbins Company is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, The Dobbins Company is hereafter referred to as the operator.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

(not) permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on May, 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
THE DOBBINS CC~?vfPANY 

January 12, 2015 

United States Department of Transportation 

Federal Aviation Administration 

8oo Independence Ave, SW 

Washington, DC 20591 

RE: Petition for Exemption from certain Title 14 CFRs in regards to Section 333 of the 

FAA Modernization & Reform Act of 2012 concerning Unmanned Aerial Systems (UAS) 

To whom it may concern: 

Good day. Per this letter of request, I seek exemption from several Title 14 CFRs that 

relate to the commercial use of unmanned aerial systems (UAS). The following will be 

included in this request: Name & information of Petitioner; Executive Summary of 

Petitioner summarizing the rules Petitioner seeks exemption from and reasons the 

exemptions would serve the public good; Specific Title 14 CFRs to which an exemption 

is sought; the extent & reasons for the requested exemptions; reasons why safety would 

not be compromised. 

PERSONAL INFORMATION 

Name Richard Bowden Dobbins (hereafter referred to as "Petitioner") 

Company The Dobbins Company 

Address 3827 Cliff Crest Dr. 

Smyrna, Georgia 30080 

404-451-1595 

rick@dobbinscompany.com 

EXECUTIVE SUMMARY 

The Petitioner was born on December 7, 1959 in Atlanta, Ga. and is a US citizen. He is 

the CEO of The Dobbins Company which has been in business since 1975. The Dobbins 

Company is a consulting firm whose primary clients are banks and commercial finance 

companies located mainly in the southeast USA. The petitioner is a licensed private pilot 

with an instrument rating. He has previously owned a 1975 Cessna Cardinal RG. 

Petitioner has never been cited for any FAA violations. Since 2013, Petitioner has owned 

a DJI Phantom 2 and a Phantom 2 Vision UAS. As a hobbyist, Petitioner has become 

very proficient with the Phantom models with over 100 hours flown in type. Petitioner is 

requesting an exemption from the current rules in Section 333 which govern the uses of 

UASs for commercial purposes. The Petitioner seeks authorization to perform 

commercial UAS operations for real estate inspections. This would include residential, 

commercial and rural properties. Pmspective customers and clients would include real 

P. 0. Box 20001 • Atlanta, GA 30325 • 404-352-2638 
estate agents & brokers, management companies, insurance companies & vendors, 

banks and private property owners. 

The Title 14 CFRs exemptions that this request entails are 61.113(a) & (b); 91.7(a); 

91.119; 91.121; 91.151(a); 91.405; 91.407(a); 91.409(a)(1) & (2); 91.417(a) & (b). Reasons 

for request are cited below. 

PUBLIC GOOD 

Aerial videography for geographical awareness and for real estate marketing and 

inspections has been around for a long time through manned fixed wing aircraft and 

helicopters. But for small business owners, its expense has been cost-prohibitive. 

Granting this exemption to the Petitioner would allow him to provide this service at a 

much lower cost. Further, the small UAS being utilized in this application will pose no 

threat to the public given its small size and lack of combustible fuel when compared to 

larger manned aircraft. The operation of this U A S will minimize ecological damage 

and promote economic growth by providing information to businesses & individuals in 

the metro Atlanta and north Georgia area. 

DESCRIPTION OF UAV TO BE DEPLOYED UNDER REQUESTED 

EXEMPTIONS 

Petitioner currently owns a DJI Phantom 2 quad copter and a DJI Phantom 2 Vision 

quad copter. These are virtually the same model of UAV. The difference is in camera 

capabilities and slightly different control links. The petitioner intends to use the 

Phantom 2 as the primary UAV in commercial applications described herein. The 

Phantom 2 is a quad copter that can take off and land vertically. It weighs approximately 

3 lbs. and has a maximum airspeed of approximately 25 knots. This UAS uses lithium 

polymer batteries which have approximately 20-25 minutes of total charge time. This 

gives this UAS approximately 12-15 minutes of flight time with sufficient remaining 

battery charge to land safely. The particular model of Phantom 2 being utilized under 

this request for exemption has First Person View (FPV) which allows the PIC to visually 

monitor certain telemetry data on a ground station monitor including altitude (AGL), 

GPS signal strength, battery charge information, etc. This FPValso gives the PIC video 

feed from the attached Go Pro camera shovving what images are being captured. This is a 

significant safety feature as it shows the attitude of the UAS and its forward direction. 

However, this FPV feature will never be used as a tool to deviate from VLOS operation 

by the PIC. 

PREFLIGHT 

The petitioner will always follow procedures outlined in the UAS operator's manual as to 

proper preflight inspection of all hardware, software, environment and any other factors 

needed to ensure a safe flight. 

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FCC INFORMATION 

The UAS be deployed here is a DJI Phantom 2. The control link operates on the 2-4 GHz 

ISM radio frequency. Its published range is 1000 meters (3280 feet). The receiver 

sensitivity is -97dBm. 

PIC QUALIFICATIONS 

The petitioner holds a FAA Private Pilot's License with an instrument rating. Petitioner 

has over 6oo hours PIC time in a variety of Cessna and Piper aircraft with the majority 

being in the 1975 Cessna 177RG he previously owned. Petitioner has owned the UAS 

described above since 2013 and has over 100 hours in this type of UAS as a hobbyist. 

The petitioner envisions being the PIC in all operations that will be performed under the 

requested rule exemptions and the subsequent COA request. However, if another PIC is 

used for these operations, petitioner agrees that any PIC of the UAS in the envisioned 

operations will hold at least a FAA Private pilots certificate, hold at least a 3rd class 

medical certificate, have no less than 25 hours of PIC time in the UAS being deployed 

before beginning any type of commercial for hire operations and conform to all safety 

protocols. 

DESCRIPTION OF INTENDED COMMERCIAL OPERATIONS 

Petitioner intends to solicit work for aerial real estate inspections from real estate agents 

& brokers, insurance companies & related vendors, banks and private property owners 

to provide photography and videography of residential, commercial and rural real 

estate. This work will always be conducted with the permission of the property owner or 

their respective agent. Flight operations will be restricted to flights directly over the 

property that has granted permission. Given the type of work being targeted here, the 

Petitioner does not foresee any instance where the UAS would be flown over any crowds 

or assemblages of people in an open air environment. If in fact any job does entail flights 

over crowds, petitioner will elect not to make said flight. Safety will always be the 

primary concern regarding any flight at any time. 

Petitioner agrees to place a sign during any flight operation that says: CAUTIONUNMANNED AERIAL VEHICLE IN OPERATION. STAY BACK 100 FEET FROM 

AIRCRAFT. 

UAS OPERATING PARAMETERS 

The UAS being deployed in these exemption request can fly at a speed of approximately 

25 knots. However, given the intended use describe here, this speed will never be 

necessary. Much slower speeds are preferred to collect the photographic material 

needed. 

Although the UAS being deployed has an approximate control link distance of 3/4 mile, 

this is much more than VLOS will allow. Petitioner agrees never to fly UAS outside of 

VLOS. 

Petitioner will only fly UAS during the day in VMC conditions. Given the petitioner 

agrees to never fly higher than 300 feet AGL, distance from clouds should not be a factor 

if flown in VMC conditions. 

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Petitioner agrees to use a Visual Observer (VO) during all operations. The VO will be 

used to help assure VLOS at all times. 

The UAS will not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA published aeronautical chart. 

The UAS being deployed with these exemption requests has the capability of using GPS 

signals to return to its initial point of take off if connection with the radio control link is 

lost. 

The petitioner agrees to yield right of way to all manned aviation activities at all times. 

EXEMPTION REQUESTS 

The following are a list of Title 14 CF As which the petitioner seeks exemption. Please 

note that the Petitioner has used Exemption No. 11138 to Douglas Trudeau (Regulatory 

Docket No. FAA-2014-0481) as a reference. Given that the petitioner and Mr. Trudeau 

intend to use the exemptions in similar manners and both use similar equipment, it 

seemed prudent not to burden the reviewer in this matter with exemption requests that 

have been previously deemed that relieve was not necessary. These rules are Part 21, 

45.23(b), 91.9(b)(2), 91.103(b), 91.109 and 91.203(a) & (b). If the reviewer believes that 

these rules need to be addressed in this request, the petitioner will make a supplemental 

request including these additional rule exemptions. 

RULE 61.113 PRIVATE PILOT PREVELEGES AND LIMITATIONS 

The Petitioner currently holds an FAA Private Pilot Certificate with an Instrument 

Rating (a copy of this certificate is included in supplemental material as part of this 

request). In addition to the certificate, Petitioner agrees to maintain a 3rd Class Medical 

Certificate. However, petitioner has an eye sight problem that may cause rejection of the 

medical unless addressed by rule exemption. Petitioner has what is called a unilateral 

papilledema of the right eye. This is an inflammation of the right optic nerve to which 

there is no cure or corrective lens solution. This causes blurriness in the right eye. The 

left eye has 20j2o vision and when using both eyes, Petitioner has 20/20 long distance 

sight. Corrective lens are need for reading. This sight condition has caused Petitioner to 

cease operating manned aircraft. However, this condition does not affect Petitioner's 

ability to operate a UAS in any way. The petitioner seeks an exemption from some 

eyesight requirements for the 3rd Class medical certificate. 

As to private pilot limitations concerning operations for hire or compensation, it seems 

that Exemption No. 11062 to Astraeus has allowed this exemption previously and was 

noted in the Trudeau Exemption No. 11138. 

As to airmanship skills, the Petitioner has been operating his UAS since 2013 and has 

over 100 hours of flight time. Petitioner currently fly's this UAS several hours a month 

as a hobby and is very proficient and has the skills to maintain altitude, maintain VLOS, 

navigate, avoid obstacles, avoid air traffic and respond to loss of control link. Petitioner 

understands that he must make at least 3 takeoffs and landings within a 90 day period 

for currency purposes. 

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RULE q1.7(a) CIVIL AIRCRAFT AIRWORTHINESS 

There is no current FAA regulatory standard for determining airworthiness of UAS and 

there is no certificate currently available for UAS airworthiness. Petitioner seeks an 

exemption from this rule by ensuring that the UAS is in an airworthy condition based on 

compliance with the operating documents prior to every flight. Flight manuals and other 

important documents will be kept in a location readily accessible to the PIC at all times. 

RULE qt.nq(c) MINIMUM SAFE ALTITUDES 

91.119 prescribes safe altitudes for the operation of civil aircraft: but it allows helicopters 

to be operated at lower altitudes in certain conditions. Petitioner seeks an exemption 

from this rule as Petitioner will only operate the UAS in a range from ground level up to 

but not exceeding 300 feet (AGL) and will only operate in safe areas away from the 

public thus providing a level of safety not available to manned aircraft. The petitioner 

asserts that given the size, weight, maneuverability and speed of the UAS, an equivalent 

or higher level of safety will be achieved that from conventional manned helicopters. 

Petitioner will avoid actively populated areas. These areas will be interpreted to include 

areas on a FVR chart depicted in yellow and will be supplemented with information 

from a Flights Standard District Office (FSDO). Petitioner intends to operate the UAS 

over real estate for inspection purposes. Petitioner will not operate over any assemblage 

of people in an open air environment 

Per the exemption granted in No. 11138 concerning 91.119(c), Petitioner agrees to act in 

strict accordance to that exemption. However, Petitioner seeks an exemption from the 

rule stipulating that a UAS cannot be operated within 500 feet of a structure without 

permission of the owner. Given the intended use Petitioner will use these exemptions 

for, which is for photography and videography of real estate for marketing & inspection 

purposes, agreement from the engaging property owner or their agent is an absolute 

necessity. The UAS will only be flown over properties with this permission. However, 

given the housing density in the Atlanta, GA area, maintaining a 500 foot distance from 

other structures even while strictly flying over a permission granting owner's property is 

impossible in many instances. The Petitioner seeks an exemption to this rule which 

would allow a so' stand-off from other structures as long as the UAS is operated 

completely over and within the property boundary lines of a permission granting 

property owner. Petitioner agrees to always keep privacy rights of other property owners 

in mind and will never engage a UAS in any type of surveillance or spying. 

RULE 91.121 ALTIMETER SETTINGS 

Petitioners' UAS has GPS derived altitude capabilities with a barometric sensor. The 

petitioner believes this rule in not applicable to the UAS operations intended. 

RULE 91.151(a) FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS 

Petitioner seeks relief from this rule due to the UAS being deployed is battery operated 

and the requirements under this rule are not applicable. The UAV in question has First 

Person Vision capabilities which transmits certain telemetry to a monitor where the PIC 

can monitor certain aspects of the flight including battery level. A typical battery for a 

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Phantom 2 UAS will last approximately 20-25 minutes before total exhaustion. Certain 

battery level warnings are set where the PIC will know when the battery state is at 30% 

and 15% remaining charge levels. This will normally allow a flight of 12 - 15 minutes 

with sufficient battery charge to make a safe landing. Petitioner will never begin a flight 

unless a fully charged battery is used. 

RULE q1.405(a) MAINTENANCE REQIOERD, <U.407(a) OPERATION 

AFTER MAINTENANCE, PREBVENTITIVE MAINTENANCE, REBUILDING 

ORAL TERATION; 91.40q(a)(2) INSPECTIONS; 91.417(a)(b) 

MAINTENANCE RECORDS 

Petitioner seeks relief from these rules due to it being an alternate inspection 

requirement of 91.409(a)(2). The Petitioner will inspect and ensure UAS is in a 

condition for safe flight and adhere to all operating documents. 

SUPPLEMENTAL INFORMATION 

The Petitioner has provided the following information to support these requests for rule 

exemptions: 

1) Copy of petitioners FAA Private Pilot's License, 2) Phantom 2 User Manual v.1.04, 3) 

NAZA M-V2 Main Controller Quick Start Guide v.1.26 (This is the micro controller that 

operates the UAS), 3) iOSD Mini User Manual (This provides telemetry data during 

flight). 

CLOSING 

The Petitioner believes that exemption from the above listed Title 14 CFRs is warranted 

given Petitioner's background as a Private Pilot, the nature of the type of UAS flights 

that will be undertaken, the size & weight of the UAS being deployed, the safety 

precautions to the general public and the NAS the Petitioner intends to adhere to, the 

positive environmental impact the flight operations would have compared to manned 

fuel consuming missions and the economic benefit the Petitioner's business would have 

in this new area of aviation. 

Thank you for your review of this matter. Please feel free to contact me at any time with 

any questions regarding this matter. 

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