Albert Willard, Norwalk, CT Section 333 Exemption Petition 

November 12, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

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

91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2);

91.417(a)&(b) 

Dear Sir or Madam, 

I, Albert Willard, hereby petition the Secretary of Transportation and Federal Aviation 

Administration for exemption to the above referenced and below more fully described Federal 

Aviation Regulations (“FARs”), that currently may or may not apply to the recreational/business 

operations of model aircraft including small unmanned aerial systems (“UAS”s) within the 

National Airspace. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and the procedures 

contained within 14 C.F.R. 11, Petition that I, Albert Willard, an owner and operator of small 

unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed below so 

that I, Albert Willard, may operate my small ultra-lightweight unmanned aircraft system 

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

As described herein I, Albert Willard, am a licensed Private Pilot, Rotorcraft (Certificate # 

3813753) with current Third Class Medical Certificate; experienced in flying hobby model 

helicopters/airplanes and manned rotorcraft aircraft for recreational purposes. I acquired the DJI 

Inspire 11

 quadcopter UAS with the intent to conduct aerial photography including, but not 

limited to the following business sectors: Real Estate Marketing, Municipality Promotions, Golf 

Course Management, Wedding Events, Construction Surveillance, Agricultural Management, 

Insurance Reconnaissance, Equipment Inspections; over land, waterways, and oceans; operation 

over/in non-restricted National Parks, National Forests, flight in non-navigable airspace, using 

nonintrusive recording devices, operation in otherwise unrestricted U.S. States/Territories for 

commercial aerial videography/cinematography operations and to enhance academic/community 

awareness for those individuals and companies unfamiliar with the geographical layout of such 

areas. 

As described more fully below, the requested exemption would permit the operation of 

UAS under controlled conditions in airspace that is 1) limited; 2) predetermined in 

1

 Serial Number W13DCA18020023 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

areas away from general public, airports, heliports and vehicular traffic for community videos, 

and within property boundaries for individual homeowner real estate listing videos/photos; 3) 

over private or controlled access property with the property owner’s consent and knowledge and 

that only people who have consented or otherwise have agreed to be in the area where 

videography will take place and 3) controlled as to access. The exemption would also provide 

safety enhancements to the already safe operations within the aerial photography, film and 

television industry presently using conventional aircraft and small, unmanned and relatively 

inexpensive UASs. 

Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored 

amateur hobbyists with no safety plan or controls in place to prevent catastrophe. I will operate 

my UAS in compliance with all safety protocols and controls2 to avoid and prevent public 

hazard, as well as manned aircraft hazards/catastrophe. This will act to further safety protocols 

exclusive to lightweight UAS's specific to aerial video and photography usage as I record flight 

data and other information gained through permitted flight operations to share with the FAA 

through any required FAA reports to assist with future protocol and safety regulation. 

Granting my request comports with the Secretary of Transportation’s (FAA Administrator’s) 

responsibilities and authority to not only integrate UAS's into the national airspace system, but to 

“...establish requirements for the safe operation of such aircraft systems [UAS's] in the national 

airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for 

commercial purposes. Further I will conduct my operations in compliance with the protocols 

described herein or as otherwise established by the FAA. 

For the reasons stated below I respectfully request the grant of an exemption allowing me to 

operate ultra-lightweight, remote controlled UAS’s for academic community awareness, 

benefit/stimulate residential/business development within Connecticut, general aerial 

photography, and to enhance real estate listing videos for homeowners who cannot afford 

expensive manned aircraft for the same purpose, all of which will promote local economic 

growth through increased employment and increased tax base. Both with public safety in mind 

by keeping heavier manned aircraft containing combustible fuel that that possess potential public 

hazard. 

 

I. Contact Information: 

Albert Willard 

6 Trolley Place 

Norwalk, CT 06853 

Telephone: (203) 831-8771 

Mobile: (203) 219-7599 

Email: willard2@optonline.net

2 Safety Protocols & Controls Inspire One User Manual in addition to Minimum VFR regulations 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From 

Which Albert Willard Requests Exemption are: 

14 CFR 21;

14 C.F.R. 45.23(b);

14 CFR 61.113 (a) & (b);

14 C.F.R. 91.7 (a);

14 C.F.R. 91.9 (b) (2);

14 C.F.R. 91.103;

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. 91.405 (a);

14 CFR 407 (a) (1);

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

III. The Extent of relief Albert Willard seeks and the Reason He Seeks Such Relief: 

I, Albert Willard, submit this application in accordance with the Reform Act, 112 P.L. 95 §§

331334, seeking relief from any currently applicable FARs operating to prevent me, Albert 

Willard, from conducting commercial cinematic, academic and other flight operations within the 

national airspace system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systems into our national airspace system as it is in the public’s interest to do 

so. My ultra-light weight UAS meets the definition of “small unmanned aircraft” as defined in 

Section 331 and therefore the integration of my ultra-light weight UAS is expressly 

contemplated by the Reform Act. I would like to operate my ultra-lightweight UAS prior to the 

time period by which the Reform Act requires the FAA to promulgate rules governing such craft. 

Thereby, providing direct experience and valuable information for formal regulation that can be 

administered uniformly to all UAS aerial video and photography. The Reform Act guides the 

Secretary in determining the types of UASs that may operate safely in our national airspace 

system. Considerations include: The weight, size, speed and overall capabilities of the UAS's;

Whether the UAS will be operated near airports or heavily populated areas; and, Whether the 

UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor 

of an exemption for me, Albert Willard. My UAS utilizes four (4) counter-rotating propellers for 

balance, control and stability. My UAS is equipped with GPS and auto return safety technology. 

Weighing less than seven (7) pounds (far below the maximum 55 pound limit); including camera 

with gimbal. 

 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

Safety comes first and foremost with each flight. The DJI Inspire 1 UAS is designed to hover in 

place utilizing GPS or Optical Sensor control and operate in less than a 10 m/s wind 

(approximately 22 mph) wind. The UAS will not be operated with winds exceeding 7 m/s (15 

mph). Built in failsafe systems include a GPS mode whereby the UAS will hover motionless 

when radio control is lost, then execute a preset “Return to Home” command. The Positioning 

Mode3 will be used for aerial videography/photography. This is the safest, most reliable and 

stable mode to prevent accident and hazard. When pilot communication to the UAS is lost, the 

UAS is designed to ascend to a preset altitude AGL, return to the coordinates at takeoff, or near 

the control transmitter when utilizing Dynamic Mode, and descend to a safe unassisted landing. 

The UAS will not be operated within 5 miles of airports, and areas where general public is within 

fifty to one hundred (50-100) yards, depending on location, conditions and weather. A constant 

awareness of any manned aircraft is maintained at all times. Should any manned aircraft near the 

area, the UAS will be landed immediately to the nearest and safest ground point. The UAS is 

capable of vertical and horizontal operations, and will be flown only within line of sight. The 

UAS uses battery power rather than combustible fuels, with flights generally lasting between ten 

(10) to fifteen (15) minutes, with an altitude under four hundred (400) feet AGL. 

Fully charged batteries are mandatory with each flight as a safety precaution. Full flight duration 

for each battery is eighteen (18) to twenty-two (22) minutes as tested. The UAS will not be 

operated at or below manufacture recommend minimum charge levels for operation, preferring 

to remain well within a safe operating range to insure adequate communication between radio 

control transmitter and UAS to eliminate potential for crash, loss of control or hazard. Reserve 

batteries are at hand with each exercise to insure replacement for sufficient safe level of 

operation. Every precaution will be employed to minimize risk of failure that may create a 

hazard to the public and/or property. 

I have logged 40+ hours of flight time in remote locations as a hobbyist, simulating flights for 

future commercial use to gain familiarization with the characteristics of this specific UAS's 

performance under different temperature and weather conditions. 

The UAS/ultra-lightweight unmanned aircraft will not be operated in such a manner so as to 

“create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). 

Given the small size and weight of the UAS, it falls well within Congress’ contemplated safety 

zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's 

into the national airspace system. 

3

 Positioning Mode includes GPS, Vision Positioning Sensors, and Barometer for position hold, self-leveling, attitude command, GPS, 

return home and dynamic return to home feature, and safety control to return home or land in the event of communication interruption 

between RC transmitter and UAS. See “Flight Mode” in Inspire 1 User Manual Addendum 

 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

IV. How Albert Willard’s Request Will Benefit the Public As A Whole: 

Aerial videography for geographical awareness and for real estate marketing has been around for 

a long time through manned fixed wing aircraft and helicopters. For small budget real estate 

companies and average homeowners the expense of such aerial videography is cost prohibitive. 

Only large companies and high end Realtors or luxury homeowners can afford to absorb 

such an expense, depriving non-luxury homeowners and lower budget Realtors from a valuable 

marketing tool. The public’s interest is additionally furthered by allowing small businesses to 

afford the otherwise cost prohibitive aerial photography with manned aircraft. 

Congress has already proclaimed that it is in the public’s interest to integrate commercially flown 

UAS's into the national airspace system, hence the passing of the Reform Act. Granting my 

exemption request furthers the public interest through academic/visual awareness of the 

geographical benefits in and around the State of Connecticut. The DJI Inspire 1 UAS is light 

weight, battery powered and creates no emissions that can harm the environment. The 

consequence of my ultra-lightweight UAS crashing is far less than a full size helicopter or fixed 

wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation 

to the public. 

Manned aircraft can pose a threat to the public through potential catastrophic crash that many 

local communities have experienced.. These have resulted in a loss of life and endangered the 

public with combustible fuel that burned on impact. The UAS poses no such threat since size and 

lack of combustible fuel alleviates any potential threat to the public. Additionally, this actually 

furthers the public’s interest by making it safer for business to conduct aerial photography and 

videography without such risks. 

The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial 

video/photo capture through my battery operated ultra-light weight UAS's. Permitting me to 

immediately fly within national air space furthers economic growth. Granting my exemption 

request substantially furthers the economic impact within the State of Connecticut for companies 

looking to relocate or build in Connecticut as well as individuals looking to relocate for career 

advancement through academic and geographical awareness, both of which serve as a stimulus to 

the community. 

 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

V. Reasons Why Albert Willard’s Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least 

Equal To Existing Rule: 

My exemption will not adversely affect safety. Quite the contrary, for the reasons stated 

permitting me to log more flight time in FAA controlled airspace, with communication with the 

FAA, will allow me to contribute to the innovation and implementation of new and novel, as of 

yet undiscovered safety protocols for development in cooperation with the FAA. In addition I 

submit the following representations of enhancements to current aerial videography and 

photography: 

A. My UAS weighs less than 7 pounds complete with a small ultra-light 

weight high quality camera;

B. The UAS will be operated below the 400 foot AGL permissible ceiling 

Set forth by the FAA Modernization and Reform Act of 2012); 

C. The UAS will only be operated for 18 - 22 minutes per flight;

D. The UAS will be landed prior to 20% Remaining Battery Level;

E. The UAS will be operated only within line of sight;

F. UAS flights will be assisted with a visual observer present;

G. The UAS has Failsafe RTH4, a flight safety feature whereby it hovers, ascends to a 

preset altitude AGL, flies the most direct, level course to the takeoff position, then 

lands unassisted if communication with the remote control pilot is lost for 

3 seconds;

H. The UAS has GPS and a Vision Positioning System utilizing two sonar 

sensors and one monocular camera for positioning and to identify the 

current aircraft’s position;

I. The UAS has a flight recorder and I actively analyze flight data and other 

sources of information to constantly update and enhance safety protocols;

J. The UAS will be operated only in a safe environment that is controlled, 

 away from power lines, elevated lights, airports and actively 

 populated areas;

K. Extensive preflight inspections and protocol per the Inspire 1 

 User Manual are mandatory for each flight; 

L. All necessary permissions will be obtained prior to operation;

M. In the event of potential danger, the flight will be aborted and the UAV will be landed 

 Immediately. 

4

 Page 15 Inspire 1 User Manual Addendum 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

N. The UAS will only be operated well within “flight environment requirements5” & 

visual meteorological conditions (VMC). 

O. The UAS will only be operated6

 when VFR flight conditions prevail. 

P. Only I, Albert Willard, a licensed Private Pilot, Rotorcraft 

 (Certificate #3813753) with current Third Class Medical Certificate, act as Pilot in 

Command during flights. 

Q. The UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements will be strictly 

adhered to. 

R. The operating documents/manual will be accessible during UAS 

operations and made available upon request. 

S. Prior to flight, the aircraft will undergo a pre-flight inspection and the PIC will follow 

the published checklist7 

My safety protocols6 provide a level of safety equal to or exceeding existing rules. It is important 

to note that absent the integration of commercial UAS into our national airspace system, 

helicopters are the primary means of aerial video and photography for community awareness, 

real estate, and marketing purposes. While the safety record of such helicopters is remarkably 

astounding, there have been incidents involving loss of life as well as extensive property 

damage; it is far safer to operate a battery powered ultra-light weight UAS. 

 First, the potential loss of life is diminished because UAS's carry no people on board and 

I only operate my UAS in specific areas away from mass populations. 

 Second, there is no fuel on board a UAS and thus the potential for fire or explosions is 

greatly diminished. 

 Third, the small size and extreme maneuverability of my UAS allow me to remotely pilot 

away from and avoid hazards quickly and safely. 

 Fourth, given its small size and weight, even when close enough to capture amazing 

images, my UAS need not be so close to the objects they are focused on through the 

technology and use of post editing software allowing pan and zoom. 

VI. A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and 

The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in 

relation to FAR § 91.203(a)(1). The size, weight and enclosed 

5

 Flight Environment Requirements Page 45 Inspire 1 User Manual Addendum. 6

 Operating within Flight Limitations & Procedures outlined in User Manual, AR listed above, visual meteorological conditions (or 

VMC), & any Applicable FARs 

7

 See Inspire 1 Pre-Flight/Flight/Post-Flight Checklist Addendum 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

operational area of the UAS permits exemption from Part 21 because the 

UAS meets (and exceeds) an equivalent level of safety pursuant to 

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft 

from the airworthiness certificate requirement under both the Act (49 

U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of 

legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense 

populations. My current and projected UAS's meet or exceed each of the 

elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an 

airworthiness certificate. As no such certificate will be applicable in the 

form contemplated by the FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. 

As there are no on board pilots or passengers, and given the size of the 

UAS's, this Regulation is inapplicable. An equivalent level of safety will 

be achieved by maintaining a safety/flight manual delineating areas of 

where safety can be defined. 10 The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable in so far 

as my UAS utilizes electronic global positioning systems with a 

barometric sensor. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same 

reasons described above. The equivalent level of safety will be achieved 

by maintaining any such required certifications and registrations by me, 

Albert Willard. 

B. 14 C.F.R. § 45.23: Marking of The Aircraft 

Applicable Codes of Federal Regulation require aircraft to be marked 

according to certain specifications. My UAS is, by definition, unmanned. 

They therefore do not have a cabin, cockpit or pilot station on which to 

mark certain words or phrases. Further, two inch 

lettering is difficult to place on such small aircraft with dimensions smaller that 

minimal lettering requirement. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700. 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to 

Noncommercial operations. I, Albert Willard, can achieve an 

equivalent level of safety as achieved by current Regulations because 

the UAS does not carry any pilots or passengers. The risks attended to 

the operation of the UAS is far less than the risk levels inherent in the 

commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, allowing 

the UAS operation to meet and exceed current safety levels in relation 

to 14 C.F.R. §61.113 (a) & (b). In addition, Grant of Exemption No. 

11062 to Astraeus Aerial (Astraeus), the FAA determined that a PIC with 

a private pilot certificate operating the Astraeus UAS would not adversely 

affect operations in the NAS or present a hazard to persons or property 

on the ground. 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil 

aircraft. It allows helicopters to be operated at lower altitudes in certain 

conditions. The UAS will never operate at an altitude greater than 400 

AGL; safely below the standard of 400 AGL. I will however operate the 

UAS in safe areas away from public and traffic, providing a level of safety 

at least equivalent to or below those in relation to minimum safe altitudes. 

Given the size, weight, maneuverability and speed of my UAS, an 

equivalent or higher level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

 Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to “have [the] aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter. 

These Regulations only apply to aircraft with an airworthiness certificate. They will 

not, therefore, apply to my UAS. However, as a safety precaution I will inspect the 

UAS before and after each flight and the UAS will be maintained per the 

manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, 

and life limit requirements. 
Albert Willard, Norwalk, CT Section 333 Exemption Petition 

In summary, Albert Willard seeks an exemption from the 

following Regulations: 

14 C.F.R. 21, subpart H; 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. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a);

14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. 

§§ 91.417 (a) & (b) to commercially operate the DJI Inspire1 lightweight unmanned aircraft 

system for aerial photography/inspection including. but not limited to the following business 

sectors: Real Estate Marketing, Municipality Promotions, Golf Course Management, Wedding 

Events, Construction Surveillance, Insurance Reconnaissance, Equipment Inspections; over land, 

waterways, and oceans; operation over/in non-restricted National Parks, National Forests, flight 

in non-navigable airspace, using nonintrusive recording devices, operation in otherwise 

unrestricted U.S. States/Territories for aerial videography/cinematography for commercial 

operation and to enhance academic/community awareness for those individuals and companies 

unfamiliar with the geographical layout of such areas.

Currently, area awareness and real estate aerial videography/photography relies primarily on the 

use of larger aircraft running on combustible fuel, posing potential risk to the public. Granting 

my request for exemption will reduce current risk levels and thereby enhance safety. My UAS 

does not contain potentially explosive fuel, is smaller, lighter and more maneuverable than 

conventional photographic aircraft with much less flight time. Further, I operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and from 

established airfields. 

There are no personnel on board the UAS and therefore the likelihood of death or serious bodily 

injury is significantly diminished. The operation of the UAS, weighing less than 7 pounds and 

travelling at lower speeds within limited areas will provide an equivalent level of safety as that 

achieved under current FARs. Accordingly I respectfully request that the FAA grant my 

exemption request and am willing to cooperate in sharing information to benefit the FAA, safety 

of manned aircraft, and the general public at large. 

Respectfully Submitted, 

Albert Willard 

6 Trolley Place 

Norwalk, CT 06853 

ADDENDUMS: 

Addendum I: Inspire 1 User’s Manual 

Addendum II: Inspire 1 Safety Guidelines 

Addendum III: Inspire 1 Checklist