Gowdy Brothers Aerospace, LLC Page 1

U. S. Department of Transportation April 12, 2016

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: FAA Docket FAA-2015-4348 Petition 

To Whom it May Concern:

Gowdy Brothers Aerospace, LLC, the leading section 333 Consulting Firm in the nation, 

is the Independent Consultant for Clay J Inskeep.

The Federal Aviation Administration (FAA) assigned Clay J Inskeep (hereafter 

“Operator”) an exemption number 13958 (the “Exemption”), a docket number FAA2015-4348 (the “Docket”), pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11. That Exemption when 

granted will authorize commercial operations by Operator. 

Operator herewith requests that its Exemption be amended, to the extent necessary, to 

make the following changes:

1.) Please change the name of the operator to: 

Drone-Aviation LLC.

2.) Add the following purposes/missions to the operators’ docket petition:

a. Aerial Data Collection to include the following: (1) bridge Inspections, 

(2) flare stack inspection, (3) utility-power generation system 

inspections and patrolling, (4) aerial inspection, (5) photography and 

(6) videography of residential and (7) commercial real estate, (8) 

weddings, (9) aerial inspection, (10) photography and (11) videography 

of (12) utility infrastructure including but not limited to (13) electrical 

power lines, (14) wind turbines and (15) cell towers, (16) pipeline 

inspection and (17) patrolling, (18) precision agriculture with one 

board sensors, (19) liquid and solid agriculture applications, (20) 

wildlife and forestry monitoring, (21) mosquito and insect control, (22) 

aerial surveying, (23) construction site inspection and (24) monitoring, 

(25) public entity support operations, (26) Aerial imaging for safety 

monitoring and (27) comparing work efforts and completion 
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percentages, (28) security of controlled environment of various sites, 

(29) Aerial Photography and video photography over water and marina 

for boats and Yachts, (30) surface mining, (31) special events: including 

(32) high schools, (33) colleges and universities, (34) professional 

sports, (35) open air events and (36) state and county fairs, (37) 

research, (38) forensic analysis of traffic patterns (39) Fire and arson 

inspection, (40) risk management and (41) geographical information 

systems, (42) LIDAR applications, (43) aerial assessment, (44) 

independent contracting and sub-contracting activities, (45) disaster 

and (46) catastrophe events.

b. Search and Rescue Operations(SRO) to include the following: (47) SRO 

independent contracting services, (48) SRO activities under the 

authority and support of local authority officials, (49) SRO first 

responders, including but not limited to Fire, Police, Forestry, County 

Sheriff’s department, private, (50) SRO with aerial video and live video 

feed.

c. Motion Picture, Television and Closed Set Filming to include the 

following: (51) filmmaking, (52) cinematography, and (53) 

videography, (54) aerial video and live video feed, (55) aerial video and 

photography for public and private use including television, public 

events, and (56) cinematography live feed and live newsgathering, (57) 

motion picture, (58) television and (59) closed set filming. (GBAMotion Picture and Television Flight Operations Manual) attached as 

Confidential Information.

d. Training to include the following: (60) training to persons individually 

or (61) belonging to both private and public organizations, (62) training 

to increase awareness and (63) training to improve safety for current 

and future UAS operations within the NAS, (64) educational and degree 

granting programs for colleges and universities, (65) training in 

conjunction with FAA pilots and other sUAV training certifications.

3.) Add the following new aircraft to Operator’s UAS operation/mission;

a. See the attached list of 1,120 sUAV’s attached as Confidential 

Information and all subsequent FAA approved sUAV’s.

4.) Add the Motion Picture, Television and Close Set Filming:

a. See the GBA-MPTFOM (GBA-Motion Picture and Television Flight 

Operations Manual) attached as Confidential Information.

This petition indicates that there are no changes in the conditions and reasons relative 

to public interest and safety that are in the original docket number for granting of this 

exemption.

The unmanned aircraft authorized in the original docket are comparable in type, size, 

weight, speed and operations capabilities to those in this amendment petition.
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As this amended Exemption request is identical to exemptions that already have granted, 

this request should qualify for summary processing. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in this 

petition.

This amended exemption application expressly fulfills Congress’ goal in passing Section 

333(a) through (c) of the Reform Act.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY/NATIONAL SECURITY

Operator states that operating in compliance with the conditions set forth in its Manuals 

will provide an equivalent level of safety for the operation of the its approved aircraft 

type for the purposes requested herein. 

THE REQUESTED AMENDMENT IS IN THE PUBLIC INTEREST

The FAA has granted exemptions to the regulations listed above. As discussed in detail for 

each of these regulations, the public interest will be served by an exemption because, 

with respect to each, operation in compliance with the requested conditions will ensure 

an equivalent level of safety. 

*********

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed Gowdy Brothers 

Aerospace, LLC can provide a summary upon request.

Attachments deemed Confidential Information

(The following attached items will be submitted under separate cover as they contain 

proprietary and commercial information exempt from disclosure under the Freedom of 

Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 

14 C.F.R. § 11.35(b)). 

1.) Gowdy Brothers Aerospace 1,120 UAV Aircraft List 

2.) GBA-Motion Picture and Television Flight Operations Manual

Sincerely,
Gowdy Brothers Aerospace, LLC Page 4

Stephen Gowdy, Chief Pilot, Gowdy Brothers Aerospace, LLC, as Independent 

Consultants for Operator.

www.GowdyBrothers.com

Info@GowdyBrothers.com

763-463-5885 Office