September 10, 2015

Name and Address of Petitioner: 

Bradley Wood 

495 Grove Creek Dr

Pleasant Grove UT 84062

602-402-8546

bradley.j.wood@gmail.com

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation 

Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l) & 

(a)(2), 91.409(a)(l), 91.417(a)&(b) 

I, Bradley Wood, the petitioner, request exemptions in order to legally operate an Unmanned 

Aircraft Systems (UAS), a DJI Phantom 3 Professional, in the National Airspace System. The DJI 

Phantom 3 Professional this petitioner seeks exemption to use will be referred to as ‘Named 

UAS’. All flights of the ‘Named UAS’ will be flown by line of sight (LOS) and performed under 

400' above ground line (AGL). The ‘Named UAS’ does have GPS guidance and "return to home" 

safety feature installed. The ‘Named UAS’ also uses a smartphone to enhance controls by 

showing current AGL and visual location of the ‘Named UAS’ to the subject and its 

surroundings. The petitioner wishes to be granted the exemption for use of the ‘Named UAS’ for 

commercial videography and photography of: 

1. Residential and Commercial Real Estate, for marketing the sale of each. 

2. Construction Process (Residential and Commercial), providing a visual review of the 

 construction process to be used for marketing of a construction company or 

 documentation to be provided to the owner. 

3. Property Survey, providing a visual review of the property to the land owner to be sold, 

purchased, or prior to construction. 

4. Property Inspection, providing a visual review of existing conditions to the land owner. 

5. Property Landscape, provide visual documentation of ‘before and after’ improvement to a land 

owner. 

The Petitioner believes the use of the DJI Phantom 3 Professional is more economical and safe to 

use than a manned aircraft for the aforementioned purposes. In the past, a manned aircraft would 

be used to provide a visual review of land and property, which involves pilot fees, inspections,

and use of an airport. Use of the ‘Named UAS’ rather than a manned aircraft is more economical 

to the consumer, and beneficial to the general public due to its small size, low noise, and minimal 

potential for accident. 

Additionally, I, the petitioner, would like to point out that in order to have a successful business it 

is in my best interest to be safe. That safety will directly benefit the public because that safety 

relates to protecting my investment in a UAS. If the UAS is damaged, so is my means of 

providing a service and profiting from it. Also, if I don’t provide a safe service to my customers, 

they will be less likely to recommend me to their neighbors. So I have to provide a safe service in 
order to gain the trust of other potential customers. 

My request for the following exceptions are based on those provided to Exemption No. 11623, 

11650, 11664, and 11734. I reviewed and quote these public letters because of the similarities to 

the use of a UAS to capture photography and videography of real estate and construction for hire. 

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation 

Regulations: 

14 CFR Part 21 

Certification Procedures For Products and Parts 

REASON FOR EXCEPTION 

It has been determined that similar UAS’s do not require an airworthiness certificate as granted in 

Exemption No. 11623, 11650, 11664, and 11734. 

14 CFR 91.7(a) 

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy 

condition.

REASON FOR EXCEPTION 

It has been determined that similar UAS’s do not require an airworthiness certificate, however the 

petitioner will ensure airworthiness through the combined use of the manufacturer's Operations 

Manual and preflight checks. 

14 CFR 91.119(c) 

Minimum Safe Altitudes:( c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, the aircraft may not 

be operated closer than 500 feet to any person, vessel, vehicle or structure.

REASON FOR EXCEPTION 

The use of ‘Named UAS’ will be flown no higher than 400’ AGL in LOS over developed and 

developing residential areas that may be considered congested areas. That will not always be the 

case when providing a ‘Property Survey’ flight because they could be conducted over empty lots 

or acreages with no structures. This will minimize the amount of bystanders present or in the 

surrounding area. In the case of flying over or near existing private property while providing a 

‘Residential and Commercial Marketing’, ‘Construction Process’, ‘Property Inspection’, and 

‘Property Landscaping’ landowners will be notified in person by the petitioner, or by a card left 

behind by the petitioner, of an occurring ‘Named UAS’ flight. The petitioner also proposes to 

display a caution sign on site while a ‘Named UAS’ flight is ongoing. The petitioner will review 

with the landowners of associated risks to people and property. Due to the small size of the 

‘Named UAS’ the associated risk to persons, vessels, vehicles, and structures is not comparable 

to manned aircraft and should be taken into consideration. 

14 CFR 91.121 

Altimeter Settings: 

REASON FOR EXCEPTION 

The ‘Named UAS’ does not have a barometric altimeter. It does have a GPS that will calculate 

altitude. The petitioner will limit flights to a maximum altitude of 400 feet AGL as granted in 

Exemption No. 11623, 11650, 11664, and 11734. 

14 CFR 91.151(a)(l) 
Fuel requirements for flight in VFR conditions:( a) No person may begin a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) there is enough 

fuel to fly to the first point of intended landing and, assuming normal cruising speed( 1) During 

the day, to fly after that for at least 30 minutes. 

REASON FOR EXCEPTION 

The ‘Named UAS’ provides low battery warnings to indicate when you should return the ‘Named 

UAS” to the launch point. A fail-safe automatic landing will occur if the battery reaches critical 

low voltage. The ‘Named UAS’ will be landed upon the 1st low battery alert. The petitioner will 

not initiate a flight unless (considering wind and forecast weather conditions) there is enough 

power to fly at normal cruising speed to the intended landing point. All flights will be done 

during the day and at an appropriate time as to not be a nuisance to others. 

14 CFR 91.405(a) 

Maintenance required: Each owner or operator of an aircraft- (a) Shall have that 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.

REASON FOR EXCEPTION 

The petitioner shall inspect the aircraft prior to every flight. The petitioner plans to follow 

manufacturer's recommended preflight checklist. Reference given to the Operations Manual. 

14 CFR 91.407(a)(l) 

Operation after maintenance, preventive maintenance, rebuilding, or alteration: (a) No person 

may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or 

alteration unless( 1 )It has been approved for returned to service by a person authorized under 

43.7 of this chapter.

REASON FOR EXCEPTION 

The petitioner who has the responsibility for the operation and safety of the ‘Name UAS’ will 

follow the manufacturer's suggestions for maintenance and repair. Including the use of suggested 

replacement parts. 

14 CFR 91.409(a)(l) & (2) 

Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had (1) An annual inspection in 

accordance with part 43 of this chapter and has been approved for return to service by a person 

authorized by 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter. No inspection performed under paragraph 

(b) of this section may be substituted for any inspection required by this paragraph unless it is 

performed by a person authorized to perform annual inspections and is entered as an "annual" 

inspection in the required maintenance records. 

REASON FOR EXCEPTION 

The petitioner will follow manufacturer’s suggestions to ensure that the ‘Named UAS’ is in a 

condition for safe flight. 

14 CFR 91.417(a) & (b) 

Maintenance Records: (a) Except for work performed in accordance with 91.411 and 91.413, 

each registered owner or operator shall keep the following records (l)(i) (ii)(iii) 

(2)(i)(ii)(iii)(iv)(v)( vi) for the periods specified in paragraph (b) of this section: ( 1 )(2)(3) 

REASON FOR EXCEPTION 

The petitioner will keep a record of all repairs and modifications. The petitioner also proclaims to 
use approved manufactured parts for repairs and modifications. 

SUMMARY 

I, Bradley Wood, the petitioner, submit a request for exemption, Section 333 of the FAA Reform 

Act pertaining to Federal Aviation Regulations 14 CFR, Part 21, 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(l) & (a)(2), 91.409(a)(l), 91.417(a)&(b) in order to legally 

operate an Unmanned Aircraft Systems (UAS), a DJI Phantom 3 Professional, in the National 

Airspace System in order to take aerial video and photography of real estate and construction 

processes.