September 20,2015

Submission by: Jared Gillis

4349 North Tonto Way

Prescott Valley, Az 86314

(928) 308-5723

jaredelm@gmail.com

U.S. Department of Transportation Docket

Management System

1200 New Jersey Ave. SE Washington,DC

20590

Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations.

Dear Sir or Madam,

I request an exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405, 91.407(a)(1), 91.409(a)

(2) and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14CFR) was granted in 

Exemptions Numbers 11138, 11395, 11428 and 11434.

I will operate a DJI Phantom or Multi Wii Rotor Bones Quad, UAS weighing less than 7 lbs. at 

takeoff, and can take photos and videos using the onboard camera. The operations preformed 

by myself with the UAS are to include but not limited to real estate photography, both residential 

and commercial, event coverage, and artistic photos and video. The use of UAS refuses the 

need for conventional aircraft in populated and rural areas and will allow never before possible 

photos and videos to be taken safely and experienced by the public.

Operations under this exemption will be conducted as outlined in the proposed rule set in 

motion on 02/23/2015 in docket FAA-2015-0150

• Operational Limitations - Visual line-of-sight (VLOS) only ; the unmanned aircraft must 

remain within VLOS of the operator and visual observer, in natural daylight.

• At all times the UAS must remain close enough to the operator for the operator to be capable

 of seeing the aircraft with vision unaided by any device other than corrective lenses.

• UAS may not operate over any persons not directly involved in the operation.

• Daylight-only operations(official sunrise to official sunset,local time).

• Must yield right-of-way to other aircraft, manned or unmanned.
• May use visual observer (VO) but not required

• First Person view camera cannot satisfy “see-and-avoid” requirement but can be used as 

long as requirement is satisfied in other ways.

• No operations are allowed in Class A (18,000 feet and Above) airspace

• Operations in Class B, C, D and, E airspace are allowed with the required ATC permission.

• Operations in Class G airspace are allowed with ought ATC permission

• No person may act as an operator of VO for more than one unmanned aircraft operation at 

one time

• No careless or Reckless operations.

• Requires preflight inspection by the operator.

• A Person may not operate a small unmanned aircraft if he or she knows or has a reason to 

know of any physical or mental condition that would interfere with the safe operation of a small 

UAS.

I request an exemption from 91.151. The Pilot in Command will abide by the following personal 

protocols and controls:

• Operator will only operate in reasonably safe environments that are strictly controlled, are 

away from power lines, elevated lights and airports. Operator will conduct extensive preflight 

inspections and protocols as outlined in the operating documents.

• Operate the sUAS below 500 feet and within a radius distance of 1500 feet from the controller 

while maintaining direct line of sight visual observation (VLOS).

• Land the sUAS before the manufacturer's recommended minimum battery level

• Use the sUAS’GPS flight safety feature whereby the aircraft raises to a predetermined safe 

altitude and then returns to point of take off should communication with the Transmitter used 

by the PIC is lost.

• Contact respective airports and/or Flight Standard District Offices if operations will be within 5 

miles to advise them of flight times, flight duration, elevation of flight and other pertinent 

information.

• Have procedures in place to abort flights in the event of safety breaches or potential danger.
91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that 

since there is currently no certificate applicable to my operation, this regulation is inapplicable.

91.119 Prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be 

operated as lower altitudes in Certain conditions. Operator will not operate the sUAS above the 

altitude of 400ft above ground level (AGL) and will also only operate in safe areas away from 

the public and traffic, thus providing a level of safety at least equivalent to or below those in 

relation to minimum safe altitudes.

91.121 Altimeter settings is inapplicable since my sUAS utilizes electronic GPS with a 

barometer sensor.

Public Interest

The acceptance of this request will provide the opportunity to our state to provide a service at a 

reasonable price to show a vantage point unobtainable by the average home buyer. It will 

provide the opportunity to view larger property from above and able to see improvements from 

above and not rely on out of date satellite info. It will provide a needed service in our 

community and surrounding areas with an affordable way to market residential and commercial 

properties allowing buyers to make a well informed decision. It can also provide the opportunity 

to effectively be used in Insurance claim investigation keeping workers out of dangerous 

positions and circumstances. It will provide the ability to document and showcase some of the 

great destinations we have in the southwestern United States to the general public. 

Jared Gillis