U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, S.E.

West Building Ground Floor, Room W12-140 Washington, DC 20590 

May 26, 2015

Petitioner:

Falcon Aerial Engineering and Inspection Co.

Maryville, TN 37803

Phone: 865-228-2130

Email: tchood@bellsouth.net

Dear Sir or Madam:

Falcon seeks exemption from section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.F.R. part 11.81. This is to allow commercial operation of small, 

unmanned aircraft drones for purposes of public interest including but not limited to: 

engineering, inspections, photogrammetry, and photography. All operations shall be 

conducted within and under the conditions and limitations outlined previously by the 

FAA as required by Section 333 and conducted in compliance with the attached 

operator’s manuals. 

1) Application for the exemption of the following sections is made:

1. 14 CFR Part 21, part H 

2. 14 CFR Part 61.113(a) and (b) 

3. 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

x. 91.417 

2) Public benefit:

Falcon plans to utilize drone technology to obtain information and data for public 

benefit, by safely and professionally flown unmanned aircraft. Some of the benefits 

include: 

1) Reduction to cost/effort of obtaining information on remote or hard to reach areas. 

This will benefit the economy by allowing important information to be obtained and 

processed relatively quickly onsite. 
2) UAV technology has little to no negative environmental impact and will thus eliminate

many of the current methods used today that produce hydrocarbon emissions and other 

toxins in the atmosphere

3) Reduces the risk of human injury by performing jobs or tasks that would otherwise be 

dangerous for a person to attempt (high roof inspections and things of that nature) by 

providing a safe way of inspection with an ultra high-resolution camera.

4) UAV unmanned aircraft is quickly gaining in popularity and it is important that our 

pilots of tomorrow begin their training today so we are better prepared for the future.

3) Relief Sought: 

1) Falcon wishes to operate small Unmanned Aircraft (sUAS) for commercial 

purposes to include (but not be limited to) engineering, industrial inspection, 

photogrammetry, and photography. Relief from section 333 is sought because law 

currently prohibits the commercial use of sUAS unless an exemption is granted. 

2) This exemption is sought for use of the following aircraft, both of which will 

weigh less than 55 pounds including cameras and energy sources.

a) DJI Phantom 2

b) DJI Phantom 3

c) Future models to be added by amendments to this exemption

4) Safety Guidelines and Regulations:

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

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

qualified personnel , and will require a test flight after such work. Records of all 

maintenance and repair work will be kept in a maintenance log for each aircraft. 

2. All flight operations will be conducted by at least two individuals (Pilot and 

observer) 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: 

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

Authorization. 

4. All flight operations will comply with the following:

The manufacturers’ user manuals. 

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

assessments will be conducted prior to each flight. 

Flight altitudes will remain below 200 feet above ground level

Flight speeds will not exceed 35 knots

Not intrude into Class B, C or D airspace, or published approach, SID or STAR, 

or take place within 5 nautical miles of an airport. 

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

the ground without their prior permission. 

5. Each flight will be logged in both the pilot’s logbook and the aircraft logbook

6. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 minutes, 

whichever occurs first. 

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

8. All other applicable regulations concerned with the operation of aircraft. 
9. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft 

with well-defined and tested lost link procedures. 

Falcon Aerial Engineering and Inspection

Cole Hood

(865) 228-2130