Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-0102 

bcasdorph®hotmai I. com 

November 3, 2015 

US Department ofTransportation, Docket Operations 

West Building, Ground Floor, Rm. wl2-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: FAA Exemption Rulemaking Section 333 of the FAA Reform Act and Part 11- 14 C.F.R. § 

45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a) & (b); 91.7(a); 91.9(b)(2); 91.103(b); 91.109; 

119.121; 91.151(a); 91.203(a) & (b) 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a) & (b) 

Dear Sir or Madam: 

I, Bradley H. Casdorph, a sole proprietor for Timeless Imagery Photography, and being a certified 

Private Pilot- Airplane Single Engine Land (Appendix A), am requesting an exemption from the 

Federal Aviation Regulations ("FARs") listed below and pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C.F .R. 11 so that I may 

commercially operate a small ultra-light weight unmanned aircraft system ("UAS"), specifically 

the DJI Phantom 3 Professional, quad- copter Unmanned Aircraft or equivalent and ground 

station-based equipment and crew for the purpose of general contract photography I videography, 

cinematography, inspections, and surveying. 

I have been an FAA-certified Private Pilot since July 17, 2007. I am also a Registered 

Professional Engineer and Professional Land Surveyor, in good standing, in the State of West 

Virginia. I am applying for this exemption to allow me to legally perform aerial 

photography/videography contract work for commercial land development, institutional land and 

architectural development, real estate transfers, private individuals, photography/videography 

organizations, and other entities that may desire aerial photography/videography services. As a 

Private Pilot, I understand the importance of pre-flight, in-flight, and post-flight safety measures 

to ensure public safety. As a pilot of a UAS, all VAS-pertinent safety and risk management 

measures as specified in the FAA's Risk Management Handbook shall be complied with. 

A grant of my exemption request by the FAA would permit operation of the above-specified UAS 

in predetermined areas and within the limits and specifications set forth in this document. All 

flights shall be logged and recorded to minimally include the date and time of flight, name of 

pilot (PIC) and Visual Observer (VO), address or location of the flight, duration of flight, weather 

conditions, and "flight notes" to include the maximum altitude and speed along with signatures of 

the PIC and VO. A copy of the images shall also be retained for a minimum of 12 months from 

the date of flight. 

Page 1 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-0102 

bcasdorph®hotma i l. com 

In summary and in accordance with this request of exemption as authorized and outlined by the 

FAA under section 333(c) of the Reform Act specified for use of UAS' for general contract 

purposes, I, Bradley H. Casdorph, will adhere to all FAA regulations at all times and shall 

conduct all flight operations in strict compliance and safety protocols as mandated and required 

by regulations and best practices. I request the grant of exemption to operate the above specified 

UAS for commercial purposes as described in this request and as allowable by law. This grant of 

exemption will allow me to offer my services to commercial land developers, real estate agencies, 

private individuals, and any other organization requiring aerial photography/videography who 

does not have the required knowledge, experience, or certifications to operate a UAS safely and 

in compliance with FAA regulations. The essence of this application is that I, Bradley H. 

Casdorph, meet and exceed the FAA's expected competency for piloting my UAS for commercial 

purposes and that my U AS meets and exceeds the safety requirements set forth by the Secretary 

of Transportation thereby prompting my request for COA under section 333. 

1. Contact Information: 

Timeless Imagery Photography 

Bradley H. Casdorph 

124 Edwin Street 

Morgantown, WV 26501 

304-322-0102 

bcasdorph@hotmail.com 

2. The specific sections of 14 C.F.R. I seek exemption from are: 

• 14 CFR21; 

• 14 C.F.R. 45.23(b); 

• 14 CFR 61.113 (a) & (b); 

• 14 C.F.R. 91, et seq.; 

• 14 CFR 407 (a) (1); 

• 14 CFR 409 (a) (2); and, 

• 14 CFR 417 (a) & (b) 

3. The extent and reason of relief I seek: 

I, Bradley Hall Casdorph, am seeking relief from existing F ARs that currently 

prohibit my use ofUASs from operating commercially for the purpose of aerial 

photography/videography in accordance with the FAA Modernization and 

Reform Act of2012 112 P.L. 95 § 331-334. The Reform Act Subtitle B: 

Unmanned Aircraft Systems - (Sec. 332) "Requires the Secretary to develop a 

plan to accelerate safely the integration by September 30, 2015, of civil 

unmanned aircraft systems (UASes, or drones) into the national airspace system." 

Page 2 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-0102 

bcasdorph®hotmai l. com 

Accordingly, I attest that my personal qualifications, as well as my ultra-light 

weight UAS, meet the definition of such approved drones (UAS) as defined in 

Section 331 and allows for exemption status consideration. Further, I humbly 

request that I be allowed to commercially operate my UAS during the time 

period the FAA is further establishing rules and regulations governing the 

operations of such craft. 

The Secretary of Transportation has been asked by Congress to, among other 

things, consider whether certain unmanned aircraft systems may operate safely in 

the national airspace system before completion of the rulemaking required under 

Section 332 of the Reform Act. In making this determination, the Secretary is 

required to determine which types ofUASs do not create a hazard to users of the 

National Airspace System 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 (VLOS) of the Pilot and VO 

Accordingly, all flights will be conducted by a PIC and aVO in accordance with 

FAA Policy N 8900.227 Section 14 Operational Requirements for UASs" and 

with the following restrictions: 

a. All aircraft will be made with a UA Gross weight ofless than 55 pounds (my 

exemption request is for an aircraft less than 5 lbs.) 

b. All flights will occur only during daylight hours. 

c. All flights will occur at or below 400 feet AGL 

d. 5 nautical miles from an airport having an operational control tower; or 

e. 3 NM from an airport with a published instrument flight procedure, but not 

an operational tower; or 

f. 2 NM from an airport without a published instrument flight procedure or an 

operation tower; or 

g. 2 NM from a heliport with a published instrument flight procedure. 

h. For safety, no flight with winds over 10 mph. 

i. Flight only in GPS mode that allows UAS to hover in place when radio 

controls are released. All operations to be conducted in GPS mode only 

4. How my request will benefit the public as a whole: 

Aerial photography is a critical component of marketing commercially available 

property, safer commercial inspections, and general photography. With today's 

high-tech Internet market and ever demanding consumer, it is more important 

than ever for realtors to stay ahead of the curve by utilizing any and all available 

technology to grab the attention of the consumer. The use of U AS for these 

photography/videography services is significantly safer than capturing similar 

Page 3 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-0102 

bcasdorph®hotmail.com 

data utilizing manned aircraft, most notably at elevations within this exemption 

request (below 400 AGL). By using the specified UAS noted above to perform 

aerial acquisitions, the risk to life and property in the air and on the ground, 

which is usually associated with traditional manned aircraft flight operations, will 

be practically eliminated. Additionally, conducting aerial acquisitions with the 

DJI Phantom 3 Professional UAS, instead of manned aircraft, will greatly benefit 

the public by drastically reducing the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. In closing, 

there are not enough certified UAS pilots to cover the demand for these 

photos/videos, which ultimately results in untrained/unqualified operators and 

increased risk due to lack of safety knowledge. 

5. Reasons why the exemption would not adversely affect safety; or how the exemption 

would provide a level for safety at least equal to the existing rule: 

An exemption would not adversely affect safety because this application applies 

only to aircraft characteristics and applications within FAA specified limitations. 

These limitations provide for at least an equivalent safety standard. However, my 

experience as a certified Private Pilot allows me to utilize my experience in UAS 

operations thereby exceeding safety and improving airspace operations by 

allowing aerial imaging clients to choose an experienced pilot that has the 

knowledge and skills necessary to pilot an aircraft safely and within regulated 

limits. In addition, by providing unmanned services to the market place, there 

will be less of a demand for manned operations, which will provide for safer and 

quieter residential photography. 

As previously stated, all flights will be conducted by a PIC and VO in 

accordance with FAA Policy N 8900.227 Section 14 "Operational Requirements 

for UASs" and with the following restrictions: 

a. All aircraft will be made with a UA gross weight of less than 55 pounds 

b. All flights will occur only during daylight hours 

c. All flights will occur at or below 400 feet AGL 

d. 5 nautical miles from an airport having an operational tower; or 

e. 3 nautical miles from an airport with a published instrument flight procedure, but 

not an operational tower; or 

f. 2 nautical miles from an airport without a published instrument flight procedure or 

operational tower; or 

g. 2 nautical miles from a heliport with a published instrument flight procedure. 

h. Maximum total flight time for each operational flight will be 20 minutes. Flights 

will be terminated at 25% battery power reserve should that occur prior to the 20 

minute limit 

1. Extensive, pre-flight briefings are required between the PIC and VO 

j. A flight plan is required prior to each flight 

k. All aircraft operations must be conducted within manufacturer recommended 

specifications 

l. All site permissions must be obtained prior to flight 

Page 4 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-01 02 

bcasdorph@hotmai l. com 

6. A summary that the FAA may publish in the Federal Register: 

a. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F .R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation 

to FAR §91.203(a)(1). The size, weight and enclosed operational area of my 

UAS permit exemption from Part 21 because my UAS meets (and exceeds) an 

equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is 

authorized to exempt aircraft from the airworthiness certificate requirement 

under both the Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act. 

Both pieces of legislation permit the FAA to exempt UAS's from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. 

My current and projected UAS's meet or exceed each of the elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the F ARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no on board pilots or passengers, and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining such manuals on location with the Pilot. The FAA has previously 

issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my 

UAS utilizes electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same reasons 

described above. The equivalent level of safety will be achieved by maintaining 

any such required certifications and registrations with the Pilot. 

b. 14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according 

to certain specifications. My UAS are, by definition, unmanned. They therefore 

do not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, two-inch lettering is difficult to place on such small aircraft 

with dimensions smaller that minimal lettering requirement. Regardless, I will 

mark its UASs in the largest possible lettering by placing the word 

"EXPERIMENTAL" on its fuselage as required by 14 C.F.R. §45.29 (f) so that I, 

Page 5 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-0102 

bcasdorph®hotmail. com 

the pilot, or anyone assisting me as a spotter with the UAV will see the markings. 

The FAA has previously issued exemptions to this regulation through 

Exemptions Nos. 8738, 10167, 10167A and 10700. 

c. C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. I, Bradley Hall Casdorph, can achieve an equivalent level 

of safety as achieved by current Regulations because my UAS does not carry any 

pilots or passengers. Further, I do possess an FAA pilot certificate, which helps 

my remote control piloting skills and factors in my experience in assessing any 

flight risks. The risks attended to the operation of my UAS is far less than the 

risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

thus, allowing me to operate my UAS and meet and exceed current safety levels 

in relation to 14 C.F .R. §61.113 (a) & (b). 

d. D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. My 

UAS will never operate at an altitude greater than 400ft AGL. I will also operate 

my UAS in safe areas, providing a level of safety at least equivalent to or below 

those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of my UAS, an equivalent or higher level of safety 

will be achieved. 

e. E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to "have [the] 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. . 

" 

These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to my UAS. However, as a safety precaution I inspect 

my U AS before and after each flight. 

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 

14 C.F .R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F .R. 21, 

Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 

91.203(a)(l). The size, weight and enclosed operational area of my UAS permit 

exemption from Part 21 because my UAS meets an equivalent level of safety 

pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt 

aircraft from the airworthiness certificate requirement under both the Act ( 49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces oflegislation 

Page 6 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-01 02 

bcasdorph@hotmai l. com 

permit the FAA to exempt VAS's from the airworthiness certificate requirement 

in consideration of the weight, size, speed, maneuverability and proximity to 

areas such as airports and dense populations. My UAS meets or exceeds each of 

the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the form 

contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. §91.9 (b) 

(2) requires an aircraft flight manual in the aircraft. As there are no pilots or 

passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The 

FAA has previously issued exemptions to this regulation in Exemption Nos. 

8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that 

involves regular software updates and curative measures for any damaged 

hardware. Therefore, an equivalent level of safety will be achieved. 

In summary I, Bradley Hall Casdorph, request that the FAA grant my exemption request and 

further volunteer any information gathered during flights in the event the FAA is interested in live 

field data. I do agree to attest to adhere to any further limitations the FAA imposes, now or in the 

future. Satisfaction of the current criteria provided in Section 333 of the Reform Act of 2012-

size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security- provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of my UAS 

for commercial purposes. I look forward to support the FAA and UAS community in its quest to 

establish proper regulations and protocols for the safe introduction of unmanned aircraft into the 

national airspace. 

Sincerely, 

Bradley Hall Casdorph, PS PE 

Page 7 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-01 02 

bcasdorph®hotmai l. com 

APPENDIX-A 

Page 8 of9 
Timeless Imagery Photography 

Bradley H. Casdorph, Sole Proprietor 

124 Edwin Street 

Morgantown, WV 26501 

304-322-0102 

bcasdorph®hotmai l. com 

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Page 9 of9