February 1, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washing ton, DC 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and 

Part 11 of the Federal Aviation Regulations. 

Name and Address of Petitioner: 

James Parrish 

932 Colonial Drive 

St Augustine, FL 32086 

561-929-6903 

Born2flyone@yahoo.com 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 

C.F.R. Part 11, James Parrish, the Petitioner, request exemption from the following Federal Aviation 

Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace 

System. 

Regulations from which the exemption is requested: 

14CFR 21 H 

14 CFR 45.23 (b) 

14 CFR 61.113 (A) 7 (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b) 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14CFR91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) & (b) 

14 CFR 91.417 (a) & (b) 

14 CFR Title 14 Chapter 1 Sub D Part 60 thru 67- 61.1 to 61.429 

The Petitioner wishes to be granted the exemption for use of the UAS of commercial operations list 

below. 

to operate the DJIInspire 1 UAS for commercial purposes of aerial videography and 

photography as a service to public and business interests, including: real-estate 

photography and videography, wedding and private individual photography and 

videography, public and commercial photography and videography, and agricultural 

photography and videography. 

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations: 

The Petitioner requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of UAS's. 

14 CFR 21 H: Airworthiness Certificates 
~r 

¥ Certification Procedures for Products and Parts 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness certificate as granted in 

Exemption No. 11623, 11650, 11664 and 11734. 

14 CFR 45.23 (b): Marking of the Aircraft 

Because the DJI Inspire 1 does not have a cabin, cockpit, pilot station, 

fuselage, boom, or tail on which to mark large words, numbers, or phrases, I request 

exemption from the above regulation. However, in efforts to comply with the above 

regulation I will affix a small label to the external hull of the UAS with the FAA registered N number 

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167A. 

14 CFR 61.113 (a), (b): Private Pilot Privileges and Limitations 

The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft 

of the United States, unless that person: (1) has a pilot certificate or special purpose authorization 

issued under this part in that person's physical possession or readily accessible. (2) The flight is only 

incidental to that business or employment. (3) The aircraft does not carry passengers or property for 

compensation or hire. 

Reason for Exception 

The Petitioner will follow all manufacturers' training program and safety manual. I also believe these 

requirements are unnecessary for pilot controlled drone flight. Additionally, current FAA proposals have 

omitted this as a future requirement for small UAS's. 

14 CFR 91.7 (a): Civil Aircraft Airworthiness 

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy 

condition. 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness certificate, however the 

petitioner will ensure airworthiness through the combined use of the manufacture's Operations Manual 

and preflight checks. 

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

This regulation provides that no person may operate an aircraft unless a current, approved flight manual 

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation; the documentation would 

not be available to the crew. 

Reason for Exception 

The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the UAS will have immediate access to it. The FSS has issued the following 

exemptions to this regulation: Exemption #8607, 8737, 8738, 9299, 9299A to list a few. 

14 CFR 91.103 (b): Preflight Action 
: 

\'*L 

This regulation requires each pilot in commend to take certain actions before flight to insure the safety 

of flight. AS FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The petitioner will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 

14 CFR 91.109: Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being used for flight 

instruction unless that aircraft has fully functioning dual controls." 

Reason for Exception 

UAS's and remotely piloted aircraft, by their design so not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See exemption Nos. 

5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passenger 

will be carried in the aircraft and by the size and speed of the aircraft. 

14 CFR 91.119: Minimum Safe Altitudes 

The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 

400 feet AGL, we cannot comply with this requirement. 

Reason for Exception 

The use of UAS will be flown no higher than 400 feet AGL in LOS over developed and developing 

residential areas that may be considered congested areas. That will not always be the case when 

providing a 'Property Survey' flight because they could be conducted over empty lots or acreages with 

no structures. In the case of flying over or near existing private property while providing aerial imagery, 

property inspections, and property assessments, landowners will be notified in person by the Petitioner, 

or by a card left behind by the Petitioner if requested. The Petitioner will review with the landowners of 

associated risks to people and property. Due to the small size of the UAS the associated risk to persons, 

vessels, vehicles and structures is not comparable to manned aircraft and should be taken into 

consideration. 

14 CFR 91.121: Altimeter Settings 

This section requires that each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating below 18,000 feet MSL. 

Reason for Exception 

Most UAS do not have a barometric altimeter. If does have a GPS that will calculate altitude. The 

Petitioner will limit flights to a maximum altitude of 400 feet AGL as granted in Exemption No. 11623, 

11664, and 11734. 

14 CFR 90.151 (a): Fuel Requirements for Flight in VFR Conditions 

Fuel requirements for flight in VFR conditions: (a) No person may begin a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed. (1) During the day, to fly after that 

for at least 30 minutes. 
-~~eason for Exception 

The UAS provides a low battery warning to indicate when you should return the UAS to the launch point. 

In addition, a "low" and "critical" battery level warnings and implemented a "return to Home" (or "Go 

land") action in these situations. The Petitioner will not initiate a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and all flights will be conducted during daylight hours and at times not to be a nuisance to 

others. 

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

• No person may operate a civil aircraft unless the airworthiness certificate required 

by paragraph (a) of this section or a special flight authorization issued under 19.715 

is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. 

Reason for Exception 

To obtain an equivalent level of safety and meet the intent of 91.203, documentation will be housed at a 

ground control point where the pilot is flying the UAS for immediate access to the extent they are 

applicable to the UAS's. In doing some research the FAA has issued numerous exemptions to this 

regulation. 

14 CFR 91.405 (a): Maintenance Inspections 

Each owner or operator of an aircraft- (a) shall have that aircraft inspected as prescribed in Subpart E of 

this part and shall between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter. 

Reason for Exception 

The Petitioner shall inspect the aircraft prior to every flight. The Petitioner also will follow the 

manufacturer's recommended preflight checklist and make any repair necessary before flights occur. 

The Petitioner will also maintain a log of any maintenance or repairs performed. 

14 CFR 91.407 {a) {1): Maintenance 

Operation after maintenance, preventative maintenance, rebuilding or alteration: (a) No person may 

operate any aircraft that has under gone maintenance, preventative maintenance, rebuilding, or 

alteration unless (1) it has been approved for return to service by a person authorized under 43.7 of this 

chapter. 

Reason for Exception 

The Petitioner who has the responsibility for the operation and safety of the UAS will follow the 

manufactures suggested replacement parts. 

14 FR 91.409 (a){l) & (2): Inspections 

Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had (1) an annual inspection in accordance with 

part 43 of this chapter and has been approved for return to service by a person authorized by 43.7 of 

this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for 

any inspection required by this paragraph unless it is performed by a person authorized to perform 

annual inspections and is entered as an "annual" inspection in the required maintenance records. 

Reason for Exception 

The Petitioner will follow manufacturer's suggestions to ensure that the UAS is in a condition for safe 

flight at all times. 
v 

14 CFR 91.417 (a) & (b): Maintenance Records 

Except for work performed in accordance with 91.411 and 91.413 each registered owner or operator 

shall keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)(vi) for the periods specified in paragraph (b) 

of this section: ( 1) (2) (3) 

Reason for Exception 

The Petitioner will keep a record of all repairs and modifications. The Petitioner also proclaims to use 

approved manufactured parts for all repairs and modifications. 

14CFR Title 14 Chapter 1 Subchapter 0 Parts 60 thru 67-61.1 to 61.429: Pilot Certification 

This section pertains to flight rules, pilot certificate requirements, manuals, etc. 

Reason for Exception 

The Petitioner believes that these requirements are unnecessary for pilot controlled drone flights and 

current FSS proposals have omitted this as a future requirement for small UAS's. All PIC's will hold an airline transport, 

commercial, private, recreational, or sport pilot certificate, as well as an FAA airman medical certificate or a valid U.S. 

driver's license. 

Summary 

With the exemptions of the mentioned rules I, James Parrish, will be 

seeking to make my UAS photography/videography services available to public and 

commercial interests. The FAA has authorized similar operations under Exemption Nos. 

12045 and 12053. Alternatively, public and commercial interests had previously sought 

the use of manned aircraft to achieve what I can offer in a safer, more cost-efficient and 

environmentally-friendly 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 DJI Inspire 1 safely in accordance with its operator's manual 

• Always flying below 400 feet 

• Completing thorough inspection of UAS before and after flights 

• Keeping the UAS in visual sight at all times when in operation 

• Using an observer to assist if needed 

• Remaining safely clear of and do not interfere with manned aircraft operations 

• Not flying directly over unprotected persons or moving vehicles 

• Not flying within 5 miles of an airport or control tower 

• Not flying in adverse weather conditions such as high winds, rain, or impaired visibility 

• Not flying under the influence of alcohol or drugs 

• Ensuring the operating environment is safe 

• Not flying over sensitive infrastructure or property such as power stations, water 

treatment facilities, correctional facilities, etc. 

• Checking and following all local laws and ordinances before flying over private 

property 

• Not conducting surveillance or photographing persons in areas where there is an 

expectation of privacy without the individual's permission 

In Conclusion: 

I, James Parrish, the Petitioner request for exemption from the above mentioned Federal Aviation 

Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace 

System in order to perform the Operations outlined above and work in a safe and controlled environment. The Petitioner 

hopes for a timely consideration as I have made a considerable 

investment in time and finances on this project. 

Sincerely, 

James Parish