May6, 2015 

Hon. Michael Huerta 

Administrator 

Federal Aviation Administration 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from certain parts of the F ARs. 

Dear Administrator Huerta: 

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

and 14 C.P.R. Part 11, I (Thomas G. Rueckl) hereby apply for an exemption from the listed 

Federal Aviation Regulations ("F ARs") to allow him to operate a small Unmanned Aircraft 

System ("sUAS") under the conditions and limitations set forth in this Petition. 

The requested exemption would permit the operation of small, unmanned and relatively 

inexpensive sUAS under controlled conditions in airspace that is (1) limited and (2) 

predetermined. 

The name and address of the applicant is: 

Thomas G. Rueckl 

Telephone: (920) 360-3868 

Email: tom.ruecld®gmail.com 

Address: 1812 Pine Tree Court 

Luxemburg, WI 54217 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.P.R.§ 45.23(b) 

14CFR§61.3 

14 C.P.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.P.R.§ 91.103 

14 C.P.R. § 91.109 
14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 

14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 3 

The Appendix describes the F ARs from which an exemption is requested and summarizes 

the justification for each requested exemption. 

The Petition is submitted to fulfill Congress' goal under Section 333(a) through (c) of the 

Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Administrator must determine which types of UASs do not create a 

hazard to users of the NAS or the public or pose a threat to national security in light of the 

following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). 

If the Adminstrator determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." ld. § 333(c). 

The Secretary has delegated his aviation authority to the Administrator of the FAA. 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from 

its regulatory requirements for civil aircraft, a term defined under §40101 of the Act, which 

includes sUASs. The Administrator may grant an exemption from a requirement of a 

regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 

of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 

U.S.C. § 44701(£) See also 49 USC§ 44711(a); 49 USC§ 44704; 14 CFR §91.203 (a) (1). 
The petitioner wishes to become a professional aerial photographer/videographer. The 

scope of operations will include aerial photography and videography in Northeastern 

Wisconsin. Projects will include freelance news footage and photos, and various 

assignments from clients including surveying farmland. 

The wide availability of small Unmanned Aircraft Systems, also known as "microdrones," 

capable of carrying high-quality video cameras and priced at affordable levels intrigued the 

petitioner. His entire life has involved exploring new technologies and refining their use. In 

October 2014, he bought a DJI Phantom 2 Vision, and has flown it for total of 30 hours over 

remote areas of N ortheastem Wisconsin, including Lake Michigan, the Kewaunee River, the 

Fox River and many other locations, exploring the potential and the limitations of its video 

subsystem. 

He is pleased with the quality of the imagery captured and has edited it into a number of 

photographic vignettes that meet his high standards for technical quality and artistic merit. 

Now, a number of people, farmers in particular, have heard about Petitioner's activities and 

have seen the results and are pressing Petitioner to undertake additional microdrone 

photography for compensation. 

He has been advised by counsel that this is not now permissible unless he obtains special 

permission from the FAA. Many competitors of Petitioner are actively flying sUAS to 

conduct aerial photography for commercial purposes, notwithstanding the FAA's stated 

prohibition. He also notes and has read the congressional mandate in sections 332 and 333 

of the FAA Revitalization and Reform Act of 2012 that the FAA move quickly to 

accommodate the economic and societal benefits that can result from widespread 

deployment of sUAS technology. 

Accordingly, Petitioner applies for authorization under the Federal Aviation Act, and the 

F ARs rules to undertake the following activities for commercial purposes. Unless the 

Petition is granted, Petitioner will be at a significant competitive advantage if he, as he 

prefers, complies with FAA policy. 

Vehicle 

The Petitioner will fly a DJI Phantom 2 Vision. This vehicle has built in capability to limit 

the height it flies above the ground, to limit the radius of the distance it flies from the 

operator, and to exclude it from class B, C, 5 and D airspace. The vehicle also has the builtin capability to return to the launching point if the wireless control link is interrupted or if 

the operator attempts to exceed any of the height, radius, or airspace limitations 

programmed into it. 
The vehicle weighs about five pounds empty and has a maximum gross weight of 

approximately twenty pounds. It has a top speed of about 30 knots. It has four fixed-pitch 

rotors, thrust from which is varied by changing RPM. It is powered by a lithium polymer 

battery. 

Flight profiles 

The petitioner will program the Phantom so that it will not fly above 400 feet above ground 

level, or more than 1500 feet away from him. He will carefully preflight the vehicle before 

each mission to assure that its compass and GPS system are properly calibrated and that the 

return-to-home feature, altitude, and radius limitations work. 

He will operate it on aerial photography missions only in areas and at times when few 

people are out and about. He will operate it only over largely unpopulated areas where the 

potential of uncontrolled descent to cause injury or damage is low. He will not operate it in 

controlled airspace. In the unlikely event that a manned aircraft flies below 400 feet AGL 

where the petitioners operating his Phantom, he will keep both the vehicle and manned 

aircraft in sight and avoid the manned aircraft. More particularly, the Petitioner will fly the 

Phantom primarily over the following types of areas in Northeastern Wisconsin: 

@1> Over farmland to survey fields and crops 

@ Over Lake Michigan, outward of the shoreline 

w Over open water in marinas, anchorages, and rivers appurtenant to Lake Michigan 

@ Over lines of railroad and rail classification yards 

@ Over expressways 

@ Over nonresidential and noncommercial large-scale industrial areas 

@1> Over private property when he has been commissioned by the person in legal 

possession of the property to do so 

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the 

Reform Act relating to size, weight, speed, operating capabilities, proximity to airports 

and populated areas and operation within visual line of sight and national security. The 

Petition justifies grant of the requested exemptions allow the Petitioner to obtain aerial_ 

photography with his microdrone. 

Respectfully subm~·tted,~ a ;g 

Thomas G. Rueckl · , X/ 

1812 Pine Tree Co 

Luxemburg, WI 54217 
Appendix FAR Subject Justification 

section 

14 CFR § 45.23(b) Requirement to display Insufficient space on 

registration number on vehicle 

vehicle 

14 CFR Part 21 Aircraft certification Designed for manned 

requirements and aircraft; not suitable for offprocedures the-shelf sUAS 

14 CFR § 61.3 Requirement for pilot Part 61 requirements 

certificate designed for manned 

aircraft, not sUAS; petition 

describes training for s U AS 

operator 

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned 

aircraft; not suitable for offthe-shelf sUAS 

14 CFR § 91.9 (b) (2) Requirement for manual to No one aboard to read 

be available in the cockpit manual 

14 CFR § 91.103(b) Requirement for crew Unmanned vehicle 

members to be onboard 

14 CFR § 91.109 Requirement for dual No one aboard to operate 

controls during flight controls 

instruction 

14 CFR § 91.119 Minimum altitudes for safe Safety requires operation 

flight below these altitudes 

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter 

14 CFR § 91.151(a) Fuel requirements Vehicle does not use fuel 

14 CFR § 91.203 (a) & (b) Requirement for No one aboard to read 

registration and certificates 

airworthiness certificates to 

be onboard 

14 CFR § 91.205(b) Cockpit instruments No one aboard to read