Brian Dollar 

3500 SW 29th St., Apt. 125

Topeka, Kansas 66614-2029

(530) 604-2033

dollarlandsurvey@gmail.com

December 16, 2015

U.S. Dept. of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington, D.C. 20590

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir. Or Madam:

 We sincerely hope that this letter finds you in good health and spirits this holiday season, or 

shortly thereafter. I’m a commercial pilot and flight instructor as well as a former federal land 

surveyor, former elected county surveyor, and currently licensed land surveyor in five states. 

This document is my request for an exemption from the listed aviation regulations to allow 

commercial operation of small un-manned aerial vehicles to take aerial photographs, and conduct 

land surveys. This request promotes safety and is in the public interest.

This application is similar in many respects to the applications successfully presented to 

the FAA, resulting in the following grants of exemptions; No. 11062 (Astraeus Aerial), No. 

11109 (Clayco, Inc.), No. 11112 ( VDOS Global, LLC, and No. 12645 (Allied Drones).

(The following section can also serve as a publication summary)

As is typical of an application of this sort I request exemption from the following 

regulations subject to the ordinary conditions and limitations generally granted under similar 

circumstances.

a) 14 CFR part 21- Certification procedures for products and parts

b) 14 CFR part 45.23(b)- Display of marks

c) 14 CFR part 61.113(a) and (b)- Private pilot privileges/limitations

d) 14 CFR part 61.133(a)- Commercial pilot privileges

e) 14 CFR part 61.23- Medical certificates

f) 14 CFR part 61.56- Flight Review

g) 14 CFR part 61.57- Recent flight experience, PIC

h) 14 CFR part 91.7(a)- Airworthiness
2

i) 14 CFR part 91.9- Flight manual placards etc.

j) 14 CFR part 91.103- Required preflight actions

k) 14 CFR part 91.109- Simulated IFR and certain flight tests

l) 14 CFR part 91.119- Minimum safe altitudes

m) 14 CFR part 91.121- Altimeter settings

n) 14 CFR part 91.203- Aircraft certification

o) 14 CFR part 91.151- Fuel requirements

p) 14 CFR part 91.405- Maintenance

q) 14 CFR part 91.409- Inspections

r) 14 CFR part 91.417- Maintenance records

The relief that I seek would be in order to use small-unmanned aircraft systems for commercial 

purposes including aerial reconnaissance, video and still photography and, data collection in 

support of surveying and mapping activities. All aircraft would be limited to a final gross weight, 

including payload and batteries, of less than 55 pounds, operated at low speed, and below 400 

feet AGL, in daytime VMC. All flights will be conducted by a licensed pilot with a current 

medical and a safety assistant to visually observe for traffic.

(End publication summary section)

More specifically14 CFR 91.7(a)- Each aircraft will be maintained and repaired as required in accordance with 

manufacturer guidelines. A test flight will be made following repairs or maintenance. A log book 

will be kept for each UAV, and all maintenance, alteration or repair, shall be noted within it. Preflight inspections will be made before each flight. More thorough inspections will be made every

100 days. 14 CFR 91.119(b)- I propose to conduct flights a distance of at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures.

Each UAV will be registered separately, and marked prior to flight, as required by the 

newly drafted rules. I will register by mail if necessary, or I will web register if that service 

becomes available later this spring. 

The aircraft that I plan to use include1) DJI Phantom style quad-copter UAV

2) Skywalker style fixed wing UAV

3) 3DR SOLO style quad-copter UAV

4) Ritewing Drak style fixed wing UAV
3

5) Other models added by amendment to this application

The lightweight UAV’s that I plan to use will be safer to operate at low altitudes than 

manned aircraft carrying human passengers and fuel. They are also cheaper to operate and 

reduce carbon emissions. The mapping and photography that I do is often times in support of 

maintenance or construction projects. In some cases, the drone will be safer than using people on 

the ground for survey measurements and will protect people from exposure to electric lines, 

exposed trenches, dangerous vertical drops, and drowning hazards.

I do not desire to operate UAV’s outside the United States. While I included a summary

for publication, if it is possible, I would prefer that the summary not be published, it represents a 

work product of mine, does not set a precedent, and if it saves time, it is probably a good thing in 

this instance.

Respectfully Submitted,

Brian Dollar