February 29, 2016

US Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Washington, DC 20591

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

Aviation Regulations from: 14 CFR 61.113(a) & (b); 91.7(a); 91.103; 91.119(c); 91.121; 91.151(a); 

91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, I, Leslie Thompson, 

operator of an Unmanned Aircraft System (UAS), hereby apply, on behalf of PhotogBuddies LLP,for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

UAS, 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.

I would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 

91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would 

allow the operation of unmanned aircraft systems (UAS) for the purposes of conducting aerial 

photography, and videography for events (public & private), real estate photography (commercial and 

residential), structural and roof inspections, construction site updates, cinematography, agriculture, 

landmarks, data collection, tourism and promos, surveying, marketing/advertising, news gathering, and 

assisting local media.

Applicant:

Ms. Leslie Thompson

Partner

PhotogBuddies LLP

1903A Muny Vista Ct

Alton, IL 62002

photogbuddies@gmail.com

618-606-2097

Commercial operation of an UAS, as described herein, which are equipped with camera and sensors, 

would operate in the following manner:

* Aerial photography for public and/or private use including events, real estate (commercial and 

private), structural and roof inspections, construction site updates, agriculture, landmarks, data 

collection, tourism and promos, surveying, marketing/advertising, news gathering, and assisting 

local media, and other related professional activities.

* Aerial videography for public and/or private use including events, real estate (commercial and 

private), structural and roof inspections, construction site updates, agriculture, landmarks, data 

collection, tourism and promos, surveying, marketing/advertising, news gathering, and assisting 

local media, and other related professional activities.
As described fully below, the requested exemption would permit the operation of a UAS under controlled 

conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and d) provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation 

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

airspace system.”

As found in Exemption No. 14790 (Anstine, Drone Difference LLC), the FAA recently approved similar 

use of a Yuneec Model Q500 Typhoon UAS. We will operate UAS(s), the Yuneec Model Q500 Typhoon, 

the DJI Phantom 3 Professional, which are comprised of an unmanned aircraft (UA or Typhoon, and/ or 

Phantom), an attached 4K camera and a transportable ground station.

The Yuneec Typhoon Q500 is a quad-copter with a gross weight of 60.0 oz. (3.75#s). It is equipped with 

four rotors that are driven by electric motors powered by batteries. The Typhoon has a maximum airspeed 

of 9.84 m/s. The Phantom 3 is also a quad-copter with a gross weight of 44.8 oz. (2.8#s). It is equipped 

with four rotors that are driven by electric motors powered by batteries. The Phantom has a maximum 

airspeed of 16 m/s. They will be operated over various metropolitan areas to augment real estate listing 

photos/ videos, capture event areal video and photography, and related business operations.

UAS Operating Parameters

We will abide by the following additional operating conditions under this exemption, which ensures a 

level of safety at least equal to existing rules:

 Operate UAS below 400 feet and within a radius distance of 1000 feet from the controller to 

aid in direct line of sight visual observation;

 Obtain permission from the owner/ controller of any vessels, vehicles and structures when 

operations may be conducted closer than 500 feet to any such vessels, vehicles or structures; 

we will conduct a safety assessment of the risk of operating closer to those objects and 

determine that it does not present an undue hazard;

 Operate the UAS for 5-12 minutes per flight;

 Land the UAS prior to the manufacturer’s recommended minimum level of battery power;

 Operate UAS during daylight hours only within visual line of sight (VLOS);

 Use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and 

then slowly lands if communication with the remote control pilot is lost;

 Conduct all operations under the flight safety protocols (including posting a warning sign 

reading: “Attention Aerial Photography in Progress- Remain Back 150 feet”) and will 

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

safety protocols;

 Contact respective airports if operations will be within 5 miles to advise them of our UAS’ 

estimated flight time, flight duration, elevation of flight and other pertinent information;

 Always obtain all necessary permissions prior to operation; have procedures in place to abort 

flights in the event of safety breaches or potential danger;

 Only operate in safe environments that are strictly controlled, are away from power lines, 

elevated lights, airports and densely populated areas (defined by areas depicted in “yellow” 

on VFR charts and through obtaining information regarding congested areas from the local

Flight Standards District Office (FSDO);

 Conduct extensive preflight inspections and protocols, during which safety carries primary 

importance.
Regarding UAS operational training, we have flown numerous practice flights in remote areas as 

hobbyists simulating flights for future commercial use to gain familiarization with the characteristics of 

the UAS’ performance under different temperature and weather conditions.

Any PIC (Pilot in Command) operating our UAS will have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 

hours logged as a UAS pilot with a multi-rotor UAS. The PIC will also have accumulated and logged a 

minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for 

operations. In addition to the hour requirements, the PIC will accomplish 3 take-offs and landings in the 

preceding 90 days (for currency purposes) prior to any flight.

Specific Exemptions Requested

Given the size, weight, speed, and limited operating area associated with the UA, we feel an exemption 

from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203(a) and (b) (Certifications 

required), subject to certain conditions and limitations, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not have a cabin, 

cockpit or pilot station on which to mark certain words or phrases. Further, the two-inch lettering is 

difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. 

Regardless of this, we can mark the UAS in the largest possible lettering by placing the word 

“Experimental” on its fuselage as required by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft without an 

airworthiness certificate, since there is currently no certificate applicable to our operations, this regulation 

is inapplicable.

We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance inspections since they only apply to aircraft with an airworthiness certificate. However, as a 

safety precaution we will perform preflight inspection of the UAS before each flight as outlined in the 

attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in the aircraft, 

however since there are no pilots or passengers on board the aircraft and given its size, this regulation is 

inapplicable. We believe an equivalent level of safety will be achieved by maintaining a safety/ flight 

manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, 

but it allows helicopters to be operated at lower altitudes in certain conditions. We will not operate our 

UAS above the altitude of 400 feet above ground level (AGL) and will also only operate in safe areas 

away from the public and traffic, thus “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 the UAS, an 

equivalent or higher level of safety will be achieved.

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the UAS utilizes 

electronic GPS with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 

100% electric and two low battery alerts are issued- per the operating documents, the UAV will be landed 

at the first alert. Also, our flights will last only 5-12 minutes each, and the UAS has an automated 
function, which results in immediate landing when a low battery is detected. The PIC will not begin a 

flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first 

point of intended landing and, assuming normal cruising speed, land the UA with 30% battery power 

remaining.

Public Interest

Aerial photography and videography for events and real estate 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 and benefit economic growth by providing information to companies and the public 

looking to relocate or build in the metro areas where we provide services such as cinematography, news 

gathering, agriculture, landmarks, data collection, structural and roof inspections, construction site 

updates, tourism and promos, surveying, marketing/advertising, and assisting local media. Private and 

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

citizens.

Summary

We will comply with all of the following conditions and limitations should this exemption be provided:

1) Operations will be limited to the following aircraft described in the operating documents, which 

is a quad-rotor aircraft weighing 60oz (3.75#s): Yuneec Q500 Typhoon Unmanned Aircraft 

System; a quad-rotor aircraft weighing 44.8oz (2.8#s): Phantom 3 Unmanned Aircraft System.

2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), all 

altitudes reported to ATC must be in feel AGL.

4) The UA will be operated within visual line of sight (VLOS) of the Pilot in Command (PIC) at all 

times.

5) All operations will utilize a visual observer (VO). The UA will be operated within the visual line 

of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at 

all times. The PIC will be designated before the flight and will not transfer his or her designation 

for the duration of the flight. The PIC will ensure that the VO can perform the functions 

prescribed in the operating documents.

6) The operating documents will be accessible during UAS operations and made available to the 

Administrator upon request. Any revisions to the operating documents will be presented to the 

Administrator upon request.

7) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be 

operated until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station will be included in the preflight inspection. 

All maintenance and alterations will be properly documented in the aircraft records.

8) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. 

replacement of a flight critical component, will undergo a functional test flight. The PIC who 

conducts the functional test flight will make an entry in the aircraft records.

9) The pre-flight inspection section in the operating documents will account for all discrepancies, 

i.e. inoperable components, items or equipment, not already covered in the relevant sections of 

the operating documents.
10) We will follow the UAS manufacturer’s aircraft/ component, maintenance, overhaul, 

replacement, inspection, and life limit requirements.

11) We will carry out maintenance, inspections, and record keeping requirements, in accordance with 

the operating documents. Maintenance, inspection, and alterations will be noted in the aircraft 

records, including total flight hours, description of work accomplished, and the signature of the 

authorized person returning the UAS to service.

12) Each UAS operated will comply with all manufacturer Safety Bulletins.

13) An authorized person will make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections.

14) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and at 

least a current third-class medical certificate. The PIC will 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.

15) Prior to operations conducted for the purpose of aerial videography/ photography and for real 

estate listing and videos and public and private events and cinematography, news gathering, 

agriculture, landmarks, data collections, structural and roof inspections, construction site updates, 

tourism and promos, surveying, marketing/advertising, and assisting local media, and similar 

operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 

hours logged as a UAS pilot with a multi-rotor UAS.

16) Prior to operations conducted for the purpose of aerial videography/ photography and for real 

estate listing and videos and public and private events and cinematography, news gathering, 

agriculture, landmarks, data collections, structural and roof inspections, construction site updates, 

tourism and promos, surveying, marketing/ advertising and assisting local media, and similar 

operations, the PIC will have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), a minimum of 5 hours of UAS pilot operating the make and model of the UAS to be 

used in operations. The PIC will accomplish 3 take-offs and landings in the preceding 90 days.

17) The PIC will not operate the UAS for the purpose of aerial videography/ photography and for real 

estate listing videos and public and private events and cinematography, news gathering, 

agriculture, landmarks, data collections, structural and roof inspections, construction site updates, 

tourism and promos, surveying, marketing/ advertising and assisting local media, and similar 

operations, unless the PIC has demonstrated and logged in a manner consistent with 14 CFR 

61.51(b), the ability to safely operate the UAS in a manner consistent with the operating 

documents, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.

18) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations will 

be conducted under visual meteorological conditions (VMC).

19) The UA will not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart.

20) The UA will 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.

21) If a UA loses communications or loses its GPS signal, it will return to a predetermined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents.

22) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in accordance 

with the operating documents.

23) The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly at normal cruising speed to the intended landing point and land the UA with 

30% battery power remaining.
24) We will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver of Authorization 

(COA) prior to conducting any operations, and also request a Notice to Air-man (NOTAM) not 

more than 72 hours in advance, but not less than 48 hours prior to the operation.

25) Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA will comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements.

26) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at the Ground 

Control Station of the UAS any time the UAS is operating. These documents will be made 

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

27) The UA will remain clear and yield the right of way to all manned aviation operations and 

activities at all times.

28) The UAS will not be operated by the PIC from any moving device or vehicle.

29) The UA will not be operated over congested or densely populated areas.

30) Flight operations will 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. We will 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 and/ or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/ 

controller of such vessels, vehicles or structures has granted permission 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, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those person per § 91.119(a).

31) All operations will be conducted over private or controlled-access property with permission from 

the land owner/ controller or authorized representative. Permission from land owner/ controller or 

authorized representative will be obtained for each flight to be conducted.

32) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

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

www.ntsb.gov.

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

photogbuddies@gmail.com or (618) 606-2097.

Thank you,

Ms. Leslie Thompson

Partner

PhotogBuddies LLP