Brandon Woods

Nathan Waters

125 Walmart Way Suite 8

Williamsburg, KY 40769

606-521-9423/606-344-4616

FAX: 606-549-1323

nwaters82@gmail.com

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 

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, we are the planned 

operator of Small unmanned Aircraft System (sUAS) equipped to conduct aerial photography, video, 

and survey for various industries hereby applies for an exemption from Federal Aviation Regulations 

(FAR) to allow commercial operation of their sUAS, so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as required by Section 

333.

Contact information:

Brandon Woods

Nathan Waters

125 Walmart Way Suite 8

Williamsburg, KY 40769

606-521-9423/606-344-4616

FAX: 606-549-1323

nwaters82@gmail.com

Equipment:

DJI Phantom 3 Advance

The specific section or sections of 14 CFR from which we seek an exemption:

Exemption Request Pursuant to Section 333 of the FMRA and Part 11 of the Federal Aviation 

Regulations, Seeking Exemption from:

14 CFR Part 21 Subpart H

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151

14 CFR 91.405

14 CFR 91.407 (a)(1)
14 CFR 91.409(a)(1) and (2)

14 CFR 91.417(a) and (b)

The extent of relief and the reason we seek the relief:

We are submitting this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking 

relief from any currently applicable FARs operating to prevent us from 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. Our sUAS meets the definition of “small unmanned aircraft” as 

defined in Section 331 and therefore the integration of our sUAS is covered under the Reform Act. We 

would like to operate our sUAS prior to the time period 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 related sUAS 

aerial video and photography. The Reform Act guides the Secretary in determining the types of sUAS 

that may operate safely in our national airspace system. Considerations include: The weight, size, speed 

and overall capabilities of the sUAS's; whether the sUAS will be operated near airports or heavily 

populated areas; and, Whether the sUAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each 

of these items reflect in favor of an exemption. Our sUAS utilizes four ( 4) counter-rotating propellers 

for balance, control and stability. Our sUAS is equipped with GPS and auto return safety technology. 

Weighing less than three (3) pounds {far below the maximum 55 pound limit); including payload.

We will concider safety as foremost with each flight. Built in safety systems include a GPS mode that 

allows our sUAS to hover in place when radio controls are released. When pilot communication is lost 

sUAS is designed slowly descend to point of takeoff. We do not operate sUAS near Hospitals nor 

Police heliports, and do not operate near areas where general public is within fifty to one hundred (50-

100) feet depending on location, conditions and weather. We constantly are on alert for any manned 

aircraft (Police/Medical helicopters, etc.) and prepared to land/abort immediately to the nearest and 

safest ground point should a manned aircraft approach our location or we suspect manned aircraft may

approach near our location. Our sUAS is capable of vertical and horizontal operations, and are flown 

only within my line of sight and my visual observer (VO), as the remote control pilot. Utilizing battery 

power rather than combustible fuels, flights generally last between five (5) to twenty (20) minutes, with 

an altitude generally under two hundred (200) feet. We utilize a fresh fully charged battery with each 

flight as a safety precaution; full flight time limit for each battery Is (25) minutes as tested. We do not 

operate our sUAS at or below manufacture recommend minimum charge levels for operations; 

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

radio control and sUAS to eliminate potential for crash, loss of control or hazard. We do not believe in 

taking risk that may cause a crash that could create hazard to the public, property, or other manned 

aircraft. We have logged numerous practice flights in remote areas as a hobbyist simulating flights for 

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

performance under different temperature and weather conditions. We also practice computerized 

simulated flights to maintain adequate skills and response reflex time. All for the sake of safety.

We are extremely cautious when operating our sUAS so we will not "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 this 

sUAS's it falls well within Congress's contemplated safety zone when it promulgated the Reform Act 

and the corresponding directive to integrate sUAS's into the national airspace system. We have used the 

sUAS in hobby flight, has a demonstrable safety record and does not pose any threat to the general 

public or national security. 
How the request would benefit the public as a whole: 

Aerial videography for geographical awareness has been around for a long time through manned fixed 

wing aircraft and helicopters. For small budget companies the expense of such aerial videography is 

cost prohibitive. Only large companies can afford to absorb such expense. Depriving lower budget 

business from a valuable marketing tool. Our sUAS pose no 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 sUAS's into the national airspace system, hence the 

passing of the Reform Act. Granting our exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits. Our sUAS is battery powered and creates no 

emissions that can harm the environment. The consequence of our sUAS crashing is far less than a full 

size helicopter or fixed wing aircraft; which 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 

video/photo capture through our battery operated sUAS. Permitting our request to immediately fly 

within national air space furthers economic growth. Granting our exemption request substantially

furthers the economic impact for the companies looking to relocate or build 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. 

Reasons why the exemption would not adversely affect safety, or how the exemption would provide a 

level of safety at least equal to the existing rule: 

Our exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting us 

to log more flight time in FAA controlled airspace, with communication with the FAA, will allow us to 

contribute to the innovation and implementation of new and novel, as of yet undiscovered safety 

protocols development in cooperation with the FAA.

• sUAS weighs 2.8 pounds including payload. 

• sUAS will not exceed 35.7 MPH (31.105 Knots). 

• I only operate my sUAS well within the 200 foot permissible ceiling.

• My sUAS will only operate for 5 -15 minutes per flight. 

• My sUAS meets or exceeds all FCC requirements."~ 

• We land my UAS prior to manufacturer recommended minimum level of battery power. 

• We pilot my UAS through remote control only by line of sight of the PIC and the visual observer.

• Our UAS has GPS a flight safety feature whereby it hovers and then slowly lands if communication 

with the remote control pilot is lost. 

• We actively analyze flight data and other sources of information to constantly update and enhance 

safety protocols. 

• We only operate in reasonably safe environment that are strictly controlled, are away from power 

lines, elevated lights and actively populated areas. 

• We conduct pre-flight inspections, during which safety carries primary importance. 

• We always obtains all necessary permissions prior to operation

Our safety protocols provide a level of safety equal to or exceeding existing rules. 

• First, the potential loss of life is diminished because UAS's carry no people on board and we only 
operate our 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 us to remotely pilot away from 

and avoid hazards quickly and safely.

• Lastly, given its small size and weight, even when close enough to capture amazing images, our 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. 

Accordingly, our UAS has been experimentally operated for familiarization/competency and will 

continue to operate at and above current safety levels. 

Any additional Information, views or argument available to support your request.

Currently, area awareness and aerial videography/photography relies primarily on the use of larger 

aircraft running on combustible fuel. Posing potential risk to the public. Granting our request for 

exemption will reduce current risk levels and thereby enhance safety. Our sUAS craft does not contain 

potentially explosive fuel, is smaller, lighter and more maneuverable than conventional video and 

photographic aircraft with much less flight time. We 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.