Anthony	Roberts

155	Old	Millstone	Landing	Ln

Sneads	Ferry,	NC	28460

Dear	Sir	or	Madam:	

This	petition	is	being	submitted	on	my 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,	Anthony	Roberts,	a multimedia	producer,	hereby	applies	for	an	

exemption	from	the	Federal	Aviation	Regulations	(FARs)	listed	below	to	allow	operation	of	

Small	Unmanned	Aircraft	System	(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	Anthony	Roberts to	pursue	his commercial	interests	in	

providing	services	to	clients	using	a	small	advanced	sUAS in	the	following	areas:	 Real	Estate,	

Marketing,	Land	Management/Surveying,	and	Special	Events.	 Anthony	Roberts states	that	all	

sUAS	flights	will	occur	over	private	or	controlled	access	property	and	will	do	so	with	the	

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

otherwise	have	agreed	to	be	within	the	UAS’s radius	during	filming	and	photography	

applications.

Anthony	Roberts has	demonstrated	the	ability	to	safely	and	effectively	fly	the	sUAS	DJI	Inspire	

1, which	will	be	used	for	commercial	and	private	purposes.		Anthony	Roberts complies	with	

local	ordinances	and	laws	regarding	the	operation	of sUAS,	and	adheres	to	all	weather	and	

environmental	restrictions	or	limitations	in	reference	to	the	operations	of	sUAS.

All	flights	will	occur	in	ordinance	with	any	state	or	local	laws	regarding	privacy.

I,	Anthony	Roberts,	am	seeking	the	exemption	because	I	am	committed	to	complying	with all	of	

the	rules,	guidelines,	limitations,	and	future	legislation set	forth	by	the	FAA.		I	agree	to	operate	

the	sUAS	in	the	manner	that	I	have	described,	and	for	the	purposes	that	I	have	described.		

Without	the	exemption	request	granted,	I	would	be	unable	to	safely	and	effectively	run	my	

business,	and	it	is	my	intention	to	comply	with	the	FAA	and	obtain	an	exemption of	the	

following	regulations.
The	following	contains	my	list	of	regulations	from	which I	am	seeking	exemption,	and	a	

complete	list	of	responsibilities	I	assume	as	operator; it	also	contains information	regarding	the	

aircraft,	public	benefit	and	safety	features,	and	similar	petitions	requests	granted.

Regulations	from	which	exemption	is	requested:	

14	C.F.R.	Part	21	

14	C.F.R.	45.23(b)	

14	C.F.R.	61.113(a)	&	(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

I,	THE	OPERATOR, ASSUME	THE	FOLLOWING	RESPONSIBILITIES

1.	Operations	authorized	by	this	grant	of	exemption	are	limited	to	the	DJI	Inspire	1 when	

weighing	less	than	55	pounds	including	payload.	Proposed	operations	of	any	other	aircraft	will	

require	a	new	petition	or	a	petition	to	amend	this	exemption.	

2.	Operations	for	the	purpose	of	closed-set	motion	picture	and	television	filming	are	not	

permitted.	

3.	The	UA	may	not	be	operated	at	a	speed	exceeding	87	knots	(100	miles	per	hour).	The	

exemption	holder	may	use	either	groundspeed	or	calibrated	airspeed	to	determine	compliance	

with	the	87	knot	speed	restriction.	In	no	case	will	the	UA	be	operated at	airspeeds	greater	than	

the	maximum	UA	operating	airspeed	recommended	by	the	aircraft	manufacturer.	

4.	The	UA	must	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	(AGL).	

Altitude	must	be	reported	in	feet	AGL.	

5.	The	UA	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	PIC	at	all	times.	This	

requires	the	PIC	to	be	able	to	use	human	vision	unaided	by	any	device	other	than	corrective	

lenses,	as	specified	on	the	PIC’s	FAA-issued	airman	medical	certificate	or	U.S.	driver’s	license.	
6.	All	operations	must	utilize	a	visual	observer	(VO).	The	UA	must	be	operated	within	the	visual	

line	of	sight	(VLOS)	of	the	PIC	and	VO	at	all	times.	The	VO	may	be	used	to	satisfy	the	VLOS	

requirement	as	long	as	the	PIC	always	maintains	VLOS	capability.	The	VO	and	PIC	must	be	able	

to	communicate	verbally	at	all	times;	electronic	messaging	or	texting	is	not	permitted	during	

flight	operations.	The	PIC	must	be	designated	before	the	flight	and	cannot	transfer	his	or	her	

designation	for	the	duration	of	the	flight.	The	PIC	must	ensure	that	the	VO	can	perform	the	

duties	required	of	the	VO.	

7.	This	exemption	and	all	documents	needed	to	operate	the	UAS	and	conduct	its	operations	in	

accordance	with	the	conditions	and	limitations	stated	in	this	grant	of	exemption,	are	

hereinafter	referred	to	as	the	operating	documents.	The	operating	documents	must	be	

accessible	during	UAS	operations	and	made	available	to	the	Administrator	upon	request.	If	a	

discrepancy	exists	between	the	conditions	and	4	limitations	in	this	exemption	and	the	

procedures	outlined	in	the	operating	documents,	the	conditions	and	limitations	herein	take	

precedence	and	must	be	followed.	Otherwise,	the	operator	must	follow	the	procedures	as	

outlined	in	its	operating	documents.	The	operator	may	update	or revise	its	operating	

documents.	It	is	the	operator’s	responsibility	to	track	such	revisions	and	present	updated	and	

revised	documents	to	the	Administrator	or	any	law	enforcement	official	upon	request.	The	

operator	must	also	present	updated	and	revised	documents	if	it	petitions	for	extension	or	

amendment	to	this	grant	of	exemption.	If	the	operator	determines	that	any	update	or	revision	

would	affect	the	basis	upon	which	the	FAA	granted	this	exemption,	then	the	operator	must	

petition	for	an	amendment	to	its	grant	of	exemption.	The	FAA’s	UAS	Integration	Office	(AFS−80)	

may	be	contacted	if	questions	arise	regarding	updates	or	revisions	to	the	operating	documents.	

8.	Any	UAS	that	has	undergone	maintenance	or	alterations	that	affect	the	UAS	operation	or	

flight	characteristics,	e.g.,	replacement	of	a	flight	critical	component,	must	undergo	a	functional	

test	flight	prior	to	conducting	further	operations	under	this	exemption.	Functional	test	flights	

may	only	be	conducted	by	a	PIC	with	a	VO	and	must	remain	at	least	500	feet	from	other	people.	

The	functional	test	flight	must	be	conducted	in	such	a	manner	so	as	to	not	pose	an	undue	

hazard	to	persons	and	property.	

9.	The	operator	is	responsible	for	maintaining	and	inspecting	the	UAS	to	ensure	that	it	is	in	a	

condition	for	safe	operation.	

10.	Prior	to	each	flight,	the	PIC	must	conduct	a	pre-flight	inspection	and	determine	the	UAS	is	in	

a	condition	for	safe	flight.	The	pre-flight	inspection	must	account	for	all	potential	discrepancies,	

e.g.,	inoperable	components,	items,	or	equipment.	If	the	inspection	reveals	a	condition	that	

affects	the	safe	operation	of	the	UAS,	the	aircraft	is	prohibited	from	operating	until	the	

necessary	maintenance	has	been	performed	and	the	UAS	is	found	to	be	in	a	condition	for	safe	

flight.	

11.	The	operator	must	follow	the	UAS	manufacturer’s	maintenance,	overhaul,	replacement,	

inspection,	and	life	limit	requirements	for	the	aircraft	and	aircraft	components.	
12.	Each	UAS	operated	under	this	exemption	must	comply	with	all	manufacturer	safety	

bulletins.	

13.	Under	this	grant	of	exemption,	a	PIC	must	hold	either	an	airline	transport,	commercial,	

private,	recreational,	or	sport	pilot	certificate.	The	PIC	must	also	hold	a	current	FAA	airman	

medical	certificate	or	a	valid	U.S.	driver’s	license	issued	by	a	state,	the	District	of	Columbia,	

Puerto	Rico,	a	territory,	a	possession,	or	the	Federal	government.	The	PIC	must	also	meet	the	

flight	review	requirements	specified	in	14	CFR	§	61.56	in	an	aircraft	in	which	the	PIC	is	rated	on	

his	or	her	pilot	certificate.

14.	The	operator	may	not	permit	any	PIC	to	operate	unless	the	PIC	demonstrates	the	ability	to	

safely	operate	the	UAS	in	a	manner	consistent	with	how	the	UAS	will	be	operated	under	this	

exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	distances	

from	persons,	vessels,	vehicles	and	structures.	PIC	qualification	flight	hours	and	currency	must	

be	logged	in	a	manner	consistent	with	14	CFR	§	61.51(b).	Flights	for	the	purposes	of	training	the	

operator’s	PICs	and	VOs	(training,	proficiency,	and	experience-building)	and	determining	the	

PIC’s	ability	to	safely	operate	the	UAS	in	a	manner	consistent	with	how	the	UAS	will	be	

operated	under	this	exemption	are	permitted	under	the	terms	of	this	exemption.	However,	

training	operations	may	only	be	conducted	during	dedicated	training	sessions.	During	training,	

proficiency,	and	experience-building	flights,	all	persons	not	essential	for	flight	operations	are	

considered	nonparticipants,	and	the	PIC	must	operate	the	UA	with	appropriate	distance	from	

nonparticipants	in	accordance	with	14	CFR	§	91.119.	

15.	UAS	operations	may	not	be	conducted	during	night,	as	defined	in	14	CFR	§	1.1.	All	

operations	must	be	conducted	under	visual	meteorological	conditions	(VMC).	Flights	under	

special	visual	flight	rules	(SVFR)	are	not	authorized.	

16.	The	UA	may	not	operate	within	5	nautical	miles	of	an	airport	reference	point	(ARP)	as	

denoted	in	the	current	FAA	Airport/Facility	Directory	(AFD)	or	for	airports	not	denoted	with	an	

ARP,	the	center	of	the	airport	symbol	as	denoted	on	the	current	FAA-published	aeronautical	

chart,	unless	a	letter	of	agreement	with	that	airport’s	management	is	obtained	or	otherwise	

permitted	by	a	COA	issued	to	the	exemption	holder.	The	letter	of	agreement	with	the	airport	

management	must	be	made	available	to	the	Administrator	or	any	law	enforcement	official	

upon	request.	

17.	The	UA	may	not	be	operated	less	than	500	feet	below	or	less	than	2,000	feet	horizontally	

from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	PIC.	

18.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UA	must	return	to	a	predetermined	location	within	the	private	or	controlled-access	property.	

19.	The	PIC	must	abort	the	flight	in	the	event	of	unpredicted	obstacles	or	emergencies.	

20.	The PIC	is	prohibited	from	beginning	a	flight	unless	(considering	wind	and	forecast	weather	

conditions)	there	is	enough	available	power	for	the	UA	to	conduct	the	intended	operation	and	
to	operate	after	that	for	at	least	five	minutes	or	with	the	reserve	power	recommended	by	the	

manufacturer	if	greater.	

21.	Air	Traffic	Organization	(ATO)	Certificate	of	Waiver	or	Authorization	(COA).	All	operations	

shall	be	conducted	in	accordance	with	an	ATO-issued	COA.	The	exemption	holder	may	apply	for	

a	new	or	amended	COA	if it	intends	to	conduct	operations	that	cannot	be	conducted	under	the	

terms	of	the	attached	COA.

22.	All	aircraft	operated	in	accordance	with	this	exemption	must	be	identified	by	serial	number,	

registered	in	accordance	with	14	CFR	part	47,	and	have	identification	(N−Number)	markings	in	

accordance	with	14	CFR	part	45,	Subpart	C.	Markings	must	be	as	large	as	practicable.	

23.	Documents	used	by	the	operator	to	ensure	the	safe	operation	and	flight	of	the	UAS	and	any	

documents	required	under	14	CFR	§§	91.9	and	91.203	must	be	available	to	the	PIC	at	the	

Ground	Control	Station	of	the	UAS	any	time	the	aircraft	is	operating.	These	documents	must	be	

made	available	to	the	Administrator	or	any	law	enforcement	official	upon	request.	

24.	The	UA	must	remain	clear	and	give	way	to	all	manned	aviation	operations	and	activities	at	

all	times.	

25.	The	UAS	may	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.	

26.	All	Flight	operations	must	be	conducted	at	least	500	feet	from	all	nonparticipating	persons,	

vessels,	vehicles,	and	structures	unless:	a.	Barriers	or	structures	are	present	that	sufficiently	

protect	nonparticipating	persons	from	the	UA	and/or	debris	in	the	event	of	an	accident.	The	

operator	must	ensure	that	nonparticipating	persons	remain	under	such	protection.	If	a	

situation	arises	where	nonparticipating	persons	leave	such	protection	and	are	within	500	feet	

of	the	UA,	flight	operations	must	cease	immediately	in	a	manner	ensuring	the	safety	of	

nonparticipating	persons;	and	b.	The	owner/controller	of	any	vessels,	vehicles	or	structures	has	

granted	permission	for	operating	closer	to	those	objects	and	the	PIC	has	made	a	safety	

assessment	of	the	risk	of	operating	closer	to	those	objects	and	determined	that	it	does	not	

present	an	undue	hazard.	The	PIC,	VO,	operator	trainees	or	essential	persons	are	not	

considered	nonparticipating	persons	under	this	exemption.	

27.	All	operations	shall	be	conducted	over	private	or	controlled-access	property	with	

permission	from	the	property	owner/controller	or	authorized	representative.	Permission	from	

property	owner/controller	or	authorized	representative	will	be	obtained	for	each	flight	to	be	

conducted.	

28.	Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical	

boundaries	of	the	operational	area	as	defined	by	the	applicable	COA	must	be	reported	to	the	

FAA's	UAS	Integration	Office	(AFS−80)	within	24	hours.	Accidents	must	be	reported	to	the	

National	Transportation	Safety	Board	(NTSB)	per	instructions	contained	on	the	NTSB	Web	site:	

www.ntsb.gov.
SIMILAR	EXEMPTIONS

This	request	is	similar	to	relief	previously	requested	in	Grant	of	Exemption	Nos.	11062,	11109,	

11112, 11138, and	11213

Public	Benefit	and	Safety

Small	Unmanned	Aircraft	Systems sUAS’s are	often	seen	as	superior	to	helicopters	as	an	aerial	

video	gathering	platform	due	to	the	smaller	devices	less	expensive equipment	and	personnel	

cost,	reduced	noise	and	as	such,	a	much	smaller	environmental	impact	which	promotes	public	

safety.	

Aerial	photography	and	videography	for	real	estate	and	events	are	proven	strategies	to	

enhance	marketing	efforts	and	increase	business	success.	The	industry	is	not	new.	However,	

until	recently	it	was	conducted	through	the	use	of	costly	manned	aircraft,	a	prohibitive	business	

activity	for	small	companies.	By	granting	this	exemption	I	would	be	able	to	provide	affordable	

services.	

Further,	the	small	UAS	will	pose	no	threat	to	the	public	given	its	small	size	and	lack	of	

combustible	fuel	when	compared	to	larger	manned	aircraft.	Additionally,	the	operation	of	our	

UAS	will	minimize	harm	to	the	environment	economic	growth	by	providing	information	to	

companies	and	the	public	looking	to	relocate	or	build	in	the	metro	areas	we	service.	Public	and	

private	events	serviced	by	our	business	enhance	vibrancy	and	add	culture	to	the	community	

and	its	citizens.	

Anthony	Roberts is	petitioning	for	an	exemption	to	operate	a	DJI	Inspire	1 with	a	built-in

stabilized	HD	camera	and	GPS	safety	features	which	limit	its	ability	to	limit	the	height	it	flies	

above	ground	level	(AGL),	to	limit	the	radius	of	the	distance	it	flies	from	the	operator	and	to	

exclude	it	from	operations	within	designated	Class	B,	C	and	D airspace	including	a	no-fly	zone	

feature.	

The	DJI	Inspire	1 also	has	a	failsafe	function	that	is	triggered	in	the	event	communication	is	lost	

between	the	sUAS	and	the	main	controller	transmitter.	At	that	time,	the	sUAS	will	return	to	its	

point	of	takeoff	and	land	safety.	If	the	connection	is	restored,	the	PIC	can	regain	control	of	

flight	and	land	manually.	

These	specifications	meet	with	the	Model	Aircraft	Operating	Standards	as	set	below:	
• The	petitioner	will	only	operate	its	sUAS	in	line-of-sight	of	a	pilot	and/or	observer	and	will	

operate	at	sites	that	are	`sufficient	distance'	from	populated	areas	within	the	sterile	area	

described	in	the	FOPM.	Such	operations	will	ensure	that	the	sUAS	will	"not	create	a	hazard	to	

users	of	the	national	airspace	system	or	the	public."	

• When	flying	the	sUAS	within	three	(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	operation	will	be	30	minutes.	

• Flights	will	be	terminated	when	battery levels	reach	25%,	allowing	sufficient	reserve	flight	

time	to	safely	land	the	sUAS.	

• The	sUAS	will	be	programmed	so	it	will	not	be	operated	at	an	altitude	that	exceeds	400	feet	

AGL,	and	not	more	than	200	feet	above	an	elevated	platform	from	which	videography	is	

planned.	

• The	sUAS	operated	by	the	petitioner	weighs	less	than	25	pounds,	including	all	payload	(i.e.	

camera,	lens,	and	stabilized	gimbal).	

• The	sUAS	will	operate	at	speeds	of	no	more	than	50	knots,	can	hover,	and	can	simultaneously	

move	vertically	and	horizontally.	

• Given	the	small	size	of	the	sUAS	and	the	restricted	sterile	environment	within	which	it	will	

operate,	Alchemical	Media’s	operations	adhere	to	the	Reform	Act's	safety	requirements.

If	you	have	any	questions	or	need	additional	information,	please	contact	me	at:

910-378-9484	or	info@alchemicalmedia.com

Respectfully	Submitted,

Anthony	Roberts

Owner

Alchemical	Media,	LLC

For	Your	Reference:

DJI	Inspire	1	User	Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf