Operator name	and	address:

Thomas	O’Hara

1987	W	Fresh	Aire

Flagstaff,	AZ	86001

Tohara2802@aol.com

The	specific	applicable	regulations	from	which	relief	is	required	(CFRs):

Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	

the	Federal	Aviation	Regulations	from:	

14	CFR	21	subpart	H	

14	CFR	45.23(b)	14	CFR	61.113(a)	and	(b)	14	CFR	91.7(a)	14	CFR	91.9(b)(2)	14	CFR	

91.103	14	CFR	91.109	14	CFR	91.119(c)	14	CFR	91.121	14	CFR	91.151(a)	14	CFR	

91.203	(a)	and	(b)	14	CFR	91.405	(a)	14	CFR	91.407	(a)	(1)	14	CFR	91.409	(a)(1)	

and	(2)	14	CFR	91.417(a)	and	(b)	

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

“Reform	Act”)	and	14	CFR	Part	11,	Thomas	O’Hara,	operator	of	Unmanned	Aircraft	

Systems	(UAS),	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	

Regulations	(“FARs”)	to	allow	commercial	operation	of	designated	UAS,	provided	

such	operations	are	conducted	within	and	under	the	conditions	outlined	herein	or	

as	may	be	established	by	the	FAA	as	required	by	Section	333.	Commercial	operation	

of	an	UAS,	as	described	herein,	which	are	equipped	with	camera(s)	and	sensors,	

would	provide	professional	services	in	the	following	areas:	

1. Aerial	photography	and/or	video	providing	live	video	feed	to	assist	with	

Coconino	County	Search	&	Rescue	operations	in	cases	of	an	emergency	or	natural	

disaster	only	when	the	local	authorities	or	government	has	requested	it	by	contract	

or	donation.	

2. Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	

estate,	architecture,	land	surveying,	engineering	and	other	related	professional	

activities.

3. Aerial	video	and/or	photography	for	public	and/or	private	use	including	

television,	public	events,	cinematography	and	newsgathering.	

4. Aerial	inspection/photography	of	residential/commercial	structures	under	

contract	with	the	owners	or	local	government	authority.	

5. Aerial	art	video/photography

6. Aerial	video/photography	or	Training	to	persons	individually	or	belonging	to	

both	private	and/or	public	organizations	to	increase	awareness	and	improve	safety	

for	current	and	future	UAS	operations	within	the	NAS.	
How	the	operator	will	maintain	an	equivalent	level	of	safety	or	no	adverse	

impact	to	safety:	

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

designated	UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS	

that	would	be	a)	limited	b)	controlled	c)	predetermined	and	d)	safe.	Approval	of	this	

exemption	would	increase	public	awareness	of	UAS	operations	and	enhance	safety	

to	aid	in	fulfilling	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)	

responsibilities	to	“....	establish requirements	for	the	safe	operation	of	such	aircraft	

systems	in	the	national	airspace	system.”	

Given	the	small	size	of	the	UAS’s	involved	and	the	restricted	controlled	environment	

within	which	they	will	operate,	the	applicant	fits	within	that	zone	of	safety	(an	

equivalent	level	of	safety)	in	which	Congress	envisioned	that	the	FAA	must,	by	

exemption,	allow	commercial	operations	of	UASs	to	commence	immediately.	Also	

due	to	the	size	of	the	UASs	and	the	controlled	areas	in	which	the	relevant	UASs	will	

operate,	approval	of	the	application	presents	no	national	security	issue.	

The	make	and	model	of	the	aircraft	for	proposed	operations:

The	DJI	Phantom	3	Professional	is	a	vertical	takeoff	and	landing	(VTOL)	Unmanned	

Aircraft	(UA)	with	a	Ground	Control	Station	(GCS)	utilizing	electronic	tablet	or	smart	

phone	systems.	The	DJI	Phantom	3	Professional	has	a	maximum	gross	weight	of	

approximately	2	pounds	11	ounces,	while	having	a	length	of	16	inches	width	of	16	

inches,	height	of	8	inches,	and	a	maximum	speed	of	approximately	29	knots.	The	DJI	

Phantom	3	Professional	is	equipped	with	four	main	rotors;	driven	by	Lithium	

Polymer	battery	powered	electric	motors.	The	DJI	Phantom	3	UAS	that	will	be	

operated	by	Thomas	O’Hara	is	registered	#FA3M3Y4C39.

How	the	requested	exemption	will	benefit	the	public	as	a	whole:	

Aerial	photography	and	has	been	around	for	a	long	time	through	manned	fixed	wing	

aircraft	and	helicopters.	For	small	budget	productions	the	expense	of	such	aerial	

photography	and	videography	is	cost	prohibitive.	Only	larger	companies	can	afford	

to	absorb	such	expense.	Manned	aircraft	pose	a	threat	to	the	public	through	the	

potential	of	a	catastrophic	crash.		Thomas	O’Hara's	UAS	poses	no	such	threat	since	

size	and	lack	of	combustible	fuel	alleviates	any	potential	threat	to	the	public.	

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

commercially	flown	UASs	into	the	national	airspace	system,	hence	the	passing	of	the	

Reform	Act.	Granting	Thomas	O’Hara’s,	exemption	request	furthers	the	public	

interest	through	academic/visual	awareness	of	the	photography	and	videography	

fields	throughout	Arizona.	My	ultra-lightweights	UAS	is	battery	powered	and	

creates	no	emissions	that	can	harm	the	environment.	The	consequence	of	my	ultra-
lightweights	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.	The	public’s	interest	is	furthered	by	minimizing	ecological	and	crash	

threat	by	permitting	aerial	photography	and	videography	captured	through	my	

battery	operated	ultra-lightweights	UAS's.	Permitting	me	to	immediately	fly	within	

national	air	space	furthers	economic	growth.

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the	requested	

exemption	and	are	prepared	to modify	or	amend	any	part	of	this	request	to	satisfy	

the	need	for	an	equivalent	level	of	safety.	We	look	forward	to	working	with	your	

office.	Please	contact	us	at	any	time	if	additional	information	or	clarifications	are	

needed.	

Sincerely,	

Thomas	O’Hara