N6037 Timberline Drive

Sherwood, WI 54169

(920) 213-7235

May 28, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave.

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the FederalAviation 

Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103

Dear Sir or Madam:

Following the format of FAA Exemption No. 11550-Regulatory Docket No. FAA–2015–0419, I 

have included the following documents:

1) Supplemental Response for Petition

2) PHANTOM Flying Flowchart V1.0

3) PHANTOM Quick Start Manual v1.7

4) PHANTOM 2 Vision+ User Manual

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 

11,I, Steve Clothier on behalf of myself am submitting this request and would like to apply for 

an exemption from the following Code of Federal Regulations (C.F.R) to be allowed commercial 

operation of lightweight Unmanned Aircraft Systems (UAS) for aerial imaging andvideo in 

Northeastern Wisconsin. This would include real estate for sale and capturing aerial business 

images for advertising.

I own a hobby grade DJI Phantom 2 Vision+ V 3.0 quad copter that has a maximum gross 

weight of 3 pounds. It is equipped with four rotors that are driven by electric motors which are 

powered by batteries. The UAS has a top speed of 15 m/s, but flying at this speed is not 

recommended. It is equipped with a Phantom 2 Vision+ Camera that is 14 megapixels and has a 

HD resolution of 1080p. The purpose is for the aerial photography/videography to improve 

academic community awareness and enhance real estate listings. The aerial photography and 

video could also augment business advertising.

My exemption request would permit the operation of my ultra-light weight, unmanned (piloted 

by remote control) in predetermined areas that are away from the general public, airports, 

heliports and vehicular traffic during daylight hours only and operated under 300 feet. This 

would be done only after carefully reviewing all pre-flight checks of the Phantom and examining 

the area of aerial observation. This would allow for the videos/images within the individual 

home or business owner’s property boundaries.

I will abide by all FAA requirements and regulations to ensure that this exemption will follow 

existing rules and will only operate in a safe environment that is strictly controlled, away from 
power lines, elevated lighting, airports and actively populated areas. And, I will conduct 

thorough pre-flight inspections and protocols, which safety is of the utmost importance. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203

Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized,

I am asking exemption from 14CFRpart21,Subpart H(Airworthiness Certificates)and§91.203 (a) 

and(b) (Certifications required),subject to certain conditions and limitations, is warranted and 

meetsthe requirements for an equivalent level of safety under14CFRpart 11 and Section 333 of 

P.L.112-95 (Section 333).

14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3)

(c)(d)(e)(f)(h): Size of Marks

Also, I am requesting an exemption from §45.23 Marking of the aircraft because my UAS will not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally twoinch lettering is difficult to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. I understand the need for markings and will mark my UAS in the 

largest possible lettering by placing the word “Experimental” or assigned number or name, based 

on a request or ruling by the FAA on its fuselage as required by §45.29(f).

I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 91.417(a) and(b) 

Maintenance inspections may be required and should be granted since they only apply to aircraft

with an airworthiness certificate. Therefore, these sections do not apply to this applicant. 

However, as a safety precaution, I will perform preflight inspections of myUAS before each 

flight as outlined in the operating instructions.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot incommand.

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, however Ican 

achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry any pilots or passengers. While helpful, a pilots’ license will not ensure remote control

piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the

commercial activities outlined in 14 CFR part61,et seq., I requests an exemption from §61.113 

PrivatePilot Privileges and Limitations.

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

If granted an exemption I agree to additional safety procedures including, but not limited to:

1) Keeping my UAS within a distance of 1000 feet from the controller to both aid in direct 

line of sight visual observation.

2) Operate the UAS for 10-15 minutes per flight; land my UAS according to the

manufacturer’s recommended minimum level of battery power.

3) Operate my UAS only within visual line of sight (VLOS). Daylight hours only.

4) Use the UAS’s global positioning system (GPS) flight safety feature; it hovers and then 

slowly landsif communication is lost with the remote control.

5) Conduct all operations under my own personal and flight safety protocols.

6) I will operate and will actively analyze flight data and other sources of information to 

constantlyupdate and enhance my safety protocols.
7) Contact respective airports if operations will be within 5 miles to advise them of my

estimatedflight time, flight duration, elevation of flight and other pertinent information.

8) Always obtain all necessary permissions prior to operation.

9) Have procedures in place to abort flights in the event of safety breaches or potential danger.

Aerial videography for geographical awareness of real estate marketing has been around for many 

years via manned fixed winged aircraft and helicopters. However, for small business owners, its 

expense has been cost-prohibitive over the years. Granting this exemption would allow me to 

provide this service at a muchlower cost. Furthermore, my small UAS, when following strict 

operating procedures, will pose no threat to the public given its small size and lack of combustible 

fuel when compared to larger manned aircraft.

This becomes a tool that is less invasive and more efficient than the traditional ways of using a 

plane or helicopter. It conserves fuel, along with lessening emissions, noise, time and other 

resources. The lowered costs make it more accessible to the masses, which help with sales and 

drive our economy.

Thank you for your time and consideration.

Steven R. Clothier

Steven R. Clothier