U.S. Department of Transportation 10/9/2015

Docket Management System 

1200 New Jersey Ave. SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam, 

This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant 

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

11, Stout Aerial (SA), a Kentucky based Veteran owned small business operating a Small Unmanned 

Aircraft System (sUAS) equipped to conduct aerial photography/video, survey for various industries, and 

Search and Rescue operations hereby applies for an exemption from the Federal Aviation Regulations 

(FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal 

Aviation Administration (FAA) so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit Stout Aerial to pursue its commercial interests in providing 

services to consumers interested aerial data capture using a small advanced sUAS in the following areas: 

• Agricultural Surveying 

• sUAS Operator Training 

• Real Estate Photography 

• Product Demonstrations 

• Research and Development 

SA states that all sUAS flights that will occur over private or controlled access property will do so with 

the property owner's prior consent and knowledge and that only people who have consented or 

otherwise have agreed to be in the area where photography and videography will take place will be 

captured. 

Additionally, observers who are not qualified pilots, will be trained by SA pilots to understand the proper 

roles of an observer, communication procedures, proper visual scan techniques, operations at nontowered airports, and appropriate sections of the Aeronautical Information Manual. 

Regulations from which the exemption is requested: 

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 

C.F.R. 91.109 14 C.F.R . 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 

91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401 - 91.417) 
Unmanned Aircraft System 

sUAS are a feasible method to obtain information of agricultural cropland to determine optimum inputs 

that result in cost savings to farmers, yield security, and reduce environmental impact of excess 

fertilizers and chemicals in the soil. 

We are petitioning for exemption to enable SA to operate a DJI Inspire 1 multi-rotor equipped with a 

three-axis gimbaled camera. This sUAS weighs less than 25 lbs., have a built- in capability to limit the 

height it flies above the ground, to limit the radius of the distance it flies from the operator and to 

exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the 

failsafe function of the autopilot system, which means when the communication between the Main 

Controller and the transmitter is lost, the system will automatically trigger Return to Home and will land 

safely. 

The above specifications meet standards listed below, some derived in accordance with the Model 

Aircraft Operating Standards: 

• The petitioner will only operate its sUAS in line of sight of a pilot and/or observer and will operate at 

sites that are a 'sufficient distance' from populated areas within the sterile area described in the 

operators’ manual. Such operations will insure that the sUAS will "not create a hazard to users of the 

national airspace system or the public." 

• When flying sUAV within 3 miles of an airport, airport operators will be notified and the operator will 

give the right of way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 60 minutes. 

• Flights will be terminated at 20% battery power reserve should that occur prior to the 60 minute limit. 

• The sUAV will be programmed so that it will not be operated at an altitude of no more than 600 feet 

AGL, and not more than 200 feet above an elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 

• The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. camera, 

lens, and gimbal). 

• The sUAS will operate at speeds of no more than 55 knots. 

• Given the small size of the sUAS and the restricted sterile environment within which they will operate, 

our sUAS operations adhere to the Reform Act's safety requirements. 

Additionally, as aviation enthusiasts; we have a high regard to safe operations with an understanding of 

FARs, pre-flight inspections, maintenance and repair, operations within airspace, as well as being trained 

to high safety standards. 

Under the requested exemption SA ensures that all operators have completed a small unmanned 

aircraft systems (UAS) education and training program including all applicable regulations and guidance 

documents; including aeronautical background information such as charts, NOTAMS and Aircraft 

Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic 
Small UAS Aerodynamics; Weather factors; Airmanship and Decision-making and Safe Operating 

Procedures. 

We respectfully request exemption under Section 333 to enable SA to operate safe, low-risk commercial 

sUAV operations for the activities stated. SA at all times will respect the space and privacy of citizens 

and property whilst keeping our skies safe. 

Sincerely 

//E-Signature//

David Stout 

Stout Aerial 

115 Double Court, Vine Grove Kentucky 40175 

(270) 872-6268