the 

FEDERAL AVIATION ADMINISTRATION 

U.S. DEPARTMENT OF TRANSPORTATION 

Docket Operation 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Petitioner: 

Limitless AP, LLC 

22432 Bolender Pontius Rd

Circleville, Oh 43113 

Office: 740-601-8140 

Email: wesmurphy762@gmail.com

INTRODUCTION AND BACKGROUND 

Limitless AP, LLC (Petitioner) is a new entity interested in providing aerial 

photography and videography to local businesses and individuals in the Midwest 

Ohio region on a for-profit basis. Petitioner's service will benefit the public as a 

whole by providing the local area with an economic means of acquiring these 

services at prices far below the traditional methods of service delivery. Until now, 

only fully manned aircraft could deliver such services with their attendant high cost

structures and flammable-fuel-risks to humans in the aircraft and on the ground.

Petitioner is part of a new industry that will benefit the public as whole in Ohio 

and around the entire United States. Individuals and business that could not afford

this type of service now can. 
REQUEST FOR EXEMPTION 

Pursuant to of the FAA Modernization and Reform of 2012 

14 CFR Part 1 exemption from the Federal Aviation 

Regulations as follows: 

14 C.F.R. Part 21; Certification Procedures for Products and Parts 

14 C.F.R. 45.23(b); Display of marks; general. 

14 C.F.R. 61.101(e)(4), & (5); Recreational pilot privileges and limitations. 

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

14 C.F.R. 61.133 (a); Commercial pilot privileges and limitations. 

14 C.F.R. 61.23(a) & (c); Medical certificates: Requirement and duration. 

14 C.F.R 91.7(a); Civil aircraft airworthiness. 

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

14 C.F.R. 91.109(a); Flight instruction; Simulated instrument flight and flight tests. 

14 C.F.R. 91.103; Preflight action. 

14 C.F.R. 91.119; Minimum safe altitudes: General. 

14 C.F.R. 91.121; Altimeter settings. 

14 C.F.R. 91.151(a); Fuel requirements for flight in VFR conditions. 

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

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)(2); Inspections. 

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

Petitioner requests that exemption from these federal regulations should be 

to the extent necessary to allow Petitioner to provide service to individuals and 

businesses on a commercial basis. 

DJI Phantom 3 

a 

is are 

2 
OPERATIONS AND SAFETY 

A grant of Petitioner's exemption request will not adversely affect public 

safety for the following reasons: 

1. The Phantom 3 weighs less than three pounds and far less than fifty-five pounds. 

2. Flights will be in the line-of-sight of the operator or a spotter in constant 

communication with the operator. 

3. Flights are terminated and the Phantom 3 returns to an established home-point 

when its smart battery determines low battery voltage. 

4. Flights will maintain an altitude of 400 feet or less. 

5. Operators will be educated/trained to safely operate the Phantom 3 and this 

education will be maintained in a current state. 

6. If the Phantom 3 looses contract with its controller or its GPS signal, it will safely 

land itself with its ground sensor functions. 

SUMMARY 

As technology advances, federal regulations should also advance. Without 

this natural progression of both, the American public will lack innovative services 

as proposed When change is slow and involved, the 

should of new 

is 

on public 

not use sort 

3 
CONCLUSION 

Wherefore, the premises considered, the Petitioner respectfully request 

exemptions as described above be granted as stated or modified in furtherance 

of public safety, necessity and convenience. Moreover, Petitioner stands ready to 

modify, augment or amend this request to satisfy any safety requirements deemed 

necessary. 

January 13, 2016

Limitless AP, 

22432 Bolender Pontius Rd 

Circleville, OH 43113 

Email: 

wesmurphy762@gmail.com 

Office ( 740) 601-8140 

Respectfully submitted, 

Limitless AP, LLC 

4 

George Wesley Murphy