Allen Wilson

1807 Road X

Reading, KS 66868

February 3, 2016

U.S. Department of Transportation, Docket Operations

West Building Ground Floor Room W12-140

1200 New Jersey Ave., SE Washington DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 

14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 

91.151(a)(1), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 

C.F.R. 91.409(a)(1) and (2), 14 C.F.R. 91.417(a) and (b).

Federal Aviation Administration:

I, Allen Wilson, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained within 14 C.F.R. 11, to request that I, Allen Wilson, an owner and 

operator of small unmanned aircraft be exempted from the Federal Aviation Regulations 

(“FARs”) listed below so that I, Allen Wilson, may operate a small unmanned aircraft system 

(“UAS”) commercially in airspace regulated by the Federal Aviation Administration (“FAA”) in 

accordance with FAA UAS Regulations and Policies.

I hereby formally submit my request for an exemption from the following Section 333 

regulations: 14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a),

14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14

C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1)

and (2), 14 C.F.R. 91.417(a) and (b). To operate DJI’s following UAS: Phantom 2, Phantom

3, Matrice, and Inspire 1 along with the guidelines of the accompanying DJI Phantom 2, DJI 

Inspire 1, Matrice, and DJI Phantom 3 operator, safety and maintenance manuals. These UAS 

will be equipped with detachable cameras and will be transported in proper storage. This 

proposed exemption would allow me operation of unmanned aircraft systems (UAS) for the 

purpose of aerial videography/photography as a service to the public/ business interests.

These UASs are multi-rotor craft weighing no more than 55 lbs including payload. Under 

normal conditions they operate at speeds of no more than 50 kts and have the ability to hover 

and move along a vertical and horizontal plane simultaneously. The UASs have proven reliable 

flying capabilities managed by gyro stabilized flight, ground detection (phantom 3 and inspire 1), 

GPS aided navigation, a compass, blinking LEDs, failsafe mode for returning home and prop 

guards. This will act to further safety protocols exclusive to lightweight UAS’s specific to video 

and photography usage as I, Allen Wilson, record flight data and other information gained
through permitted flight operations to share with the FAA through any required FAA reports to 

assists with future protocol and safety regulations.

The requested exemption would permit the operation of the UASs under controlled conditions in 

the NAS that would be:

a) limited b) controlled c) predetermined and will provide safety enhancements to the already 

safe operations in the industry presently using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation’s responsibility to 

“...establish requirements for the safe operation of such aircraft systems in the national airspace 

system.”

The name, phone number, and address of the applicant is:

Attn: Allen Wilson

Address: 1807 Road X, Reading, KS 66868

Phone: 913-339-8753

Email: alw1451@gmail.com

Specific section or sections of 14 CFR from which I seek relief and the reason I seek 

relief:

14 C.F.R. Part 21: Airworthiness Certificates

Given the size and limited operating area associated with the aircrafts to be utilized by I, Allen 

Wilson, an exemption from Part 21 meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the reform Act. In all cases, an analysis of these criteria 

demonstrates that the UA operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than 

conventional aircraft operating with an airworthiness certificate without restrictions and 

conditions proposed.

14 C.F.R. 45.23: Display of marks: general

The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on which to mark 

certain words or phrases. Further, the two inch lettering is difficult to place on such a

small aircraft with dimensions smaller than the minimal lettering requirement.

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

The FAA has previously declared that additional manned airship experience of a commercially 

certified pilot would not correlate to the airmanship skills necessary for similarly proposed 

operations in previously issued exemptions to this regulation through Exemption Nos. 11062 

and 11138.
14 C.F.R 91.7: Civil aircraft airworthiness

Currently, since there is no certificate applicable to the UAs in question, this regulation is 

inapplicable.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard requirements

Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on 

board this aircraft and given its size, this regulation is inapplicable. An equivalent level of safety 

will be achieved by maintaining a safety/flight manual with the operator.

14 C.F.R. 91.119(c): Minimum safe altitudes

I, Allen Wilson will ensure that UAS do not operate any higher than 400 feet at ground level. I 

will not fly over congested areas. I will plan operations before hand, for proper flight safety, and 

proper height analysis as to avoid collisions.

14 C.F.R. 91.121: Altimeter settings

The UAS utilize electronic GPS with a barometric sensor. An equivalent level of safety will be 

achieved by using this.

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that I will fly are powered by electricity, using lithium polymer batteries that

currently have a flight limit of approximately no more than 20 minutes. Therefore, due to the

limitations of the batteries, it is currently impossible to comply with part 91.151.

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Currently, there are no procedures for providing airworthiness certificates for the

mentioned UAS. I, Allen Wilson, however will always fly safely while having the manuals of

the DJI Phantom 2, DJI Inspire 1, and the DJI Phantom 3.

14 C.F.R. 91.405(a): Maintenance Required,

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, rebuilding, or

alteration,

14 C.F.R. 91.409(a)(1) and (2): Inspections &

14 C.F.R. 91.417 (a) and (b): Maintenance records

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

to aircraft with an airworthiness certificate. However I, Allen Wilson, will perform preflight
inspections of the UAS before each flight as outlined in the operating and maintenance 

documents. I, Allen Wilson, will also follow manufacturer recommendations from said operating 

documents.

Public Interest

The use of UAS technology coupled with camera and video capture technology enables a more 

cost effective means of gathering information than can be achieved with larger and much more 

expensive fixed wing or rotary aircraft. Additionally, larger aircraft are noisy and much more 

dangerous due to their size and combustible fuel capacities.

I, Allen Wilson, intend to offer my services, primarily, to public safety agencies for the purposes 

of collecting aerial imagery for use in supporting those agencies in the performance of their role 

in serving the community. Operations will be purely for the benefit of the public and no payment 

will be requested for services provided.

Examples of the uses of the UAS are that these services will:

• significantly improve their ability to conduct size up for fires and locate access and egress 

routes for these fires.

• directly benefit searches for missing persons.

• assist in evaluating flood and wind damage while reducing the danger to first responder 

personnel.

Summary

I, Allen Wilson, am seeking exemption from the following rules:

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R.

91.9(b)(2), 14 C.F.R. 91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R.

91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 91.407(a)(1), 14 C.F.R. 91.409(a)(1) and

(2), 14 C.F.R. 91.417(a) and (b)

With the exemptions of the mentioned rules I, Allen Wilson, will be seeking to make

my UAS photography/videography services available to the public. Alternatively the public

had sought to use helicopters and aircraft to achieve what I can offer in a safer, more cost

efficient manner. By not using combustible fuel, flying at safe heights and strictly following the

operational, safety, and maintenance recommendations from DJI.

These include but are not limited to:

● Flying the following UAS Safely

• DJI Inspire 1

• DJI Phantom 2

• DJI Phantom 3

• DJI Matrice
● Flying below 400 feet

● Proper visual inspection of UAS before flights

● Keeping mentioned UAS in visual sight at all times when in operation

● Using an observer to assist if needed

● Remain well clear of and do not interfere with manned aircraft operations, and avoid

other aircraft and obstacles at all times

● Not intentionally fly over unprotected persons or moving vehicles

● Contact the airport or control tower before flying within 5 miles of an airport

● Not flying in adverse weather conditions such as high winds or reduced visibility

● Not flying under the influence of alcohol or drugs

● Ensure the operating environment is safe

● Not flying over sensitive infrastructure or property such as power stations, water

treatment facilities, correctional facilities, etc.

● Check and follow all local laws and ordinances before flying over private property

● Do not conduct surveillance or photograph persons in areas where there is an

expectation of privacy without the individual's permission.

Respectfully,

Allen Wilson

1807 Road X

Reading, KS 66868

Phone: 913-339-8753

Email: alw1451@gmail.com