U.S.	Department	of	Transportation	Washington	DC	20590	

Re: 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) 

Dear Sir or Madam: 

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

(the “Reform Act”) and 14 CFR Part 11, Warren J Dorning operator of an 

Unmanned Aircraft System (UAS), hereby applies for an exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of its UAS, so long as 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 operate in the following manner: 

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

real estate, architecture, land surveying, engineering, marine, golf 

courses, Special events and other related professional activities. 

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

television, public events, cinematography and news gathering. 

3.Aerial inspection/photography of residential/commercial structures 

under contract with the owners or local government authority. 

4.Aerial inspection/photography of residential/commercial utility 

infrastructure including but not limited to electrical power lines, wind 

turbines and cell towers. 

5.Aerial video/photography or providing live video feed to assist with 

search and rescue operations in cases of an emergency or natural 
disaster only when the local authorities or government has 

requested it by contract or donation. 

6.The ability to offer training to persons individually or belonging to both 

private and/or public organizations that have interests in the use and 

application of a UAS for the purpose of the safe operation of a UAS to 

enhance the safety of the National Airspace System (NAS) as well as 

for the protection of the persons and property. 

As described fully below, the requested exemption would permit the 

operation of a UAS under controlled conditions in the NAS that would be a) 

limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently 

using conventional aircraft. Approval of this exemption would thereby 

enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” 
Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103

14 CRF 91.105

14 CFR 91.109

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

Equipment to be operated is the DJI Phantom 3, Dji Phantom 4 and DJI 

Inspire 1. The	DJI Phantom 3, DJI Phantom 4 and DJI Inspire 1 are vertical	

takeoff	and	landing	(VTOL)	Unmanned	Aircraft	(UA)	with	a	Ground	

Control	Station	(GCS)	utilizing	electronic	tablet	or	smart	phone	systems.	

The live video feed will have an operating frequency of 5.728GHz –

5.850GHz. The applicant will operate the UAS in line of sight within a closed 

off and predetermined area.
Given the small size of the UAS and the controlled environment provided 

the proposed operations will adhere to the Reform Act’s safety 

requirements. The approval of this application presents no national security 

issues. Regarding the level of safety surrounding the proposed operations 

and the public benefit, reduction in environmental impacts, including but 

not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly the applicant requests that 

the FAA grant the requested exemption with minimum delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of 

safety because operations will further enhance the safety of the persons 

and/or property using conventional aircraft. 

These limitations and conditions to which the applicant agrees to adhere to 

when conducting commercial operations under the FAA issued exemption 

as set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh less than 55 lbs.

2. The UAS will have a maximum operating speed of no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) 

and/or Visual Observer (VO).

4. Maximum flight time for each operational flight will be 30 minutes. 

Flights will be terminated at 25% battery power reserve or 30 minutes of 

flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above 

Ground Level (AGL) and not more than 200 feet above an elevated platform 

from which filming is planned.

6. Minimum crew for each operation will consist of the UAS Pilot, the Visual 

Observer (VO) and may include but not limited to a Camera Operator.
7. The UAS pilot will be a designated Pilot in Command (PIC) and hold a 

Medical Certificate. If the PIC feels another operator to be qualified with 

the necessary skills to be PIC & Class Medical Certificate, that person may 

be designated PIC.

8. A briefing will be performed regarding the planned UAS operations prior 

to each day’s flight consisting of all the days’ production activities. 

9. All flights will occur under Visual Flight Rules Meteorological Conditions 

(VMC) only. 

10. The flights will occur no closer than a 5 mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport. 

11. If operations will be within a 5 mile radius of the geographic 

center/Airport Reference Point (ARP) of a tower controlled or uncontrolled 

airport the respective airports will be contacted advising them of the 

estimated flight time, flight duration, elevation of flight and other pertinent 

information. 

12. The operator will file FAA Form 7711-1, or its equivalent, as modified in 

light of the requested exemption, with the appropriate local Flight 

Standards District Office (FSDO) no more than 72 hours but no less than 48 

hours from planned operation. 

13. The operator will obtain verbal/written consent of all persons involved 

with the planned operation and ensure that only consenting persons will be 

allowed within 100 feet of the flight operation, and the radius may be 

reduced to 30 feet based upon an equivalent level of safety determination, 

as required under the FOM. With the advanced permission of the FSDO, 

operations at closer range may be approved. 

14. The PIC and VO will have been trained in operation of UAS and receive 

up-to- date information for the particular UAS to be operated. 

15. The PIC and VO will be able to communicate by voice, radio, and/or text 
at all times. 

16. If the UAS loses communications with the remote controller or loses 

GPS signal, the UAS will have the capability to return to a pre-determined 

location within a designated location and land autonomously. 

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

obstacles, weather, or emergencies. 

Sincerely, 

Warren	J	Dorning

1200	SW	12th St Apt	316

Ft	Lauderdale	FL	33315

Phone	:	(954)579-9224

Email:	Wjdorning@gmail.com