Nov 15, 2015

Robert Cecil

62 Allegheny Drive

Seneca Rocks, WV 26884

304-567-2115

tomcecil@gmail.com

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Request for Exemption IAW Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Robert Cecil

seeks exemption from the below listed Federal Aviation Regulations to allow commercial 

operation of 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.

Robert Cecil seeks exemption under Section 333 to offer for commercial purposes:

1. Promotional video and film production for businesses

2. Outdoor events (adventure sports, nature photography, weddings)

3. Thermal and HD inspection video of cell and radio towers

4. Video construction inspection of commercial and residential properties

5. Video showcasing residential and commercial grade properties for resale

6. Agricultural video for mapping and/or farm management

7. Training to persons individually or belonging to both private and/or public 

organizations that have interests in the safe use and application of UAS for 

commercial purposes.

8. Aerial video and/or photography to assist local authorities with search and rescue 

operations. 

Robert Cecil's fleet of UAS consist of manufacturer-built four (4) engine multirotor craft, 

weighing 55 or fewer pounds including payload.

DJI Phantom 3 Pro N555WV

DJI Inspire 1 Pro N222WV

These UAS operate at a speed of less than 50 knots and have the capability to hover and 

move in the vertical and horizontal plane simultaneously. They will operate only in line of 

sight and will operate only within controlled areas where Robert Cecil has permission to 

operate.

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Regulations for which Robert Cecil requests exemption:

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §91.203 (a) (1) 

Given the limited operating area associated with the UAS under consideration, an exemption

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 

11 and Section 333 of the Reform Act. The UAS, without a formal airworthiness certificate, 

under the operating conditions proposed, will be at least as safe, or safer, than a 

conventional aircraft operating with an airworthiness certificate.

The UAS weigh less than 55 pounds fully loaded, carry neither a pilot nor passenger, carry 

no explosive materials or flammable liquid fuels and operate exclusively within an area 

tightly controlled and monitored by the operator. These criteria demonstrate that there is no

credible threat to national security posed by the UAS due to its small size, low speed of 

operation, location of operation, lack of explosive materials or flammable liquid fuels, and 

inability to carry a substantial external load.

14 CFR §91.7(a): Civil aircraft airworthiness.

In consideration of airworthiness certificate standards for UAS, still under FAA review, each 

UAS operated by Robert Cecil will be maintained to manufacturer standards for safe 

operation through the use of pre and post flight checklists and aircraft inspections.

14 CFR § 91.9 (b) (2); 14 CFR 91.203 (a) and (b): Civil Aircraft Flight Manual in the 

Aircraft.

These diminutive UAS have no room or capacity to carry a flight manual and associated 

paperwork in or on the aircraft. This requirement will be met by keeping the current 

documentation at the ground control point where the operator flying the UAS will have 

immediate access to it. 

14 CFR § 91.103: Preflight action

As FAA approved UAS flight manuals are not yet available for the aircraft, this requirement 

will be met through pre-flight safety reviews and pre and post flight checklists to include, 

but not limited to; local weather forecasts, active TFRs in the area via KnowBeforeYouFly.org

website and manufacturer and in-house developed pre and post flight procedures, 

inspections and operations.

14 CFR §91.119: Minimum safe altitudes

Exemption is requested for authority to operate at altitudes up to a maximum of 400 feet 

AGL, with the understanding that a further COA may be needed to allow such operations. 

Safety will be achieved given the small size, low weight, and low speed of the UAS as well as 

the location where it is operated. Low-altitude operations of the UAS will ensure separation 

from conventional aircraft operating at altitude.

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14 CFR §91.121 Altimeter Settings

This regulation requires an altimeter on the aircraft be used to maintain flight level. Altitude

information is supplied to the PIC by GPS signal though real-time telemetry from the aircraft

to the PIC control device. Accurate operation will be provided by calibrating the GPS signal 

prior to conducting flight operations at all locations, before every flight.

14 CFR § 91.151(a): Fuel Requirements for Flight in VFR Conditions

In ideal conditions a battery powered UAS might provide up to 40 minutes of powered flight.

As currently required, a 30-minute reserve would then limit flights to 10 minutes or less, 

restricting utility. Given the limited area of operation and the limited capacity of small UAS, 

Robert Cecil believes safe operation can be achieved by limiting flights to 30 minutes or 

20% of battery power whichever occurs first. Reserve power at 20% is more than adequate 

to return the UAS to its planned landing zone from anywhere in its limited operating area.

14 CFR §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations apply to aircraft with an airworthiness certificate, and do not apply to the 

UAS proposed for flight operations. UAS maintenance will be accomplished in accordance 

with the Manufacturer's operating manual and procedures. The operator will ensure that 

the UAS is in working order prior to initiating flight, perform required maintenance, and 

keep a log of any maintenance performed.

These UAS are limited in size, carry a small payload and operate only in controlled areas for 

limited periods of time. If mechanical issues arise the PIC can land the UAS immediately. 

Additional safeguards against loss of battery charge or loss of GPS signal are incorporated 

into the operating software of the UAS, either landing the UAS autonomously or returning it 

to the point of origin of the flight.

Public Interest 

Use of battery powered, low impact UAS for unmanned aerial video inspection, 

photogrammetry, and photography services reduces reliance on conventional manned 

aircraft reducing congestion in the National Air Space. Unlike conventional aircraft, UAS are 

easily transported to and from area each of operation, eliminating the need for a resource 

intensive infrastructure to support flight operations. 

UAS are not at risk of fuel spillage and fire in the event of an accident. When compared to 

conventional aircraft operations, utilizing a 55 pound, battery powered UAS in a controlled 

environment, poses much less of a safety concern for the general public.

Photography and video collection will provide engineers, architects, and contractors with 

valuable information at costs previously unobtainable to small businesses. The reduction of 

risk in sending flesh and blood into a high fall situation will be avoided.

The use of a UAS in the real estate industry provides both the buyer and seller with a higher 

level of marketing and service.

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Robert Cecil will at all times offer our services to local, regional, and federal agencies who 

may require assistance, including fire fighters, local law enforcement agencies and others, 

with situational awareness, disaster relief, and response coordination while remaining 

subject to all limitations in regards to public safety and privacy.

No national security issue is raised by the grant of the requested exemptions. Given the 

small size, low load-carrying capacity, the low speeds at which the UAS operates, and the 

fact that they do not carry explosives or other dangerous materials, the use of the UAS pose 

no threat to national security. 

Additional Safety Information

The limitations and conditions under which UAS under the control of Robert Cecil will 

operate are, in general, as follows;

1. The UAS weigh less than 55 pounds including payload.

2. Flight speed will not exceed 50 knots in any direction.

3. Flights will operate at an altitude of no more than 200 feet Above Ground Level 

(AGL) when not coordinated with an ATC. Separate COA applications will be filed for

flights above 200’ AGL per the existing 333 application procedures. All altitudes will 

be reported in feet AGL.

4. The UAS pilot will be designated Pilot in Command (PIC) and hold, as a minimum, a 

current Sport Pilot license.

5. Flights will be operated within Visual Line Of Sight (VLOS) of the PIC unaided by any

device other than corrective lenses as specified in the PIC's FAA-issued airman 

medical certificate.

6. The PIC will be aided by a Visual Observer (VO) who will maintain VLOS to the UAS 

at all times, unaided by any device other than corrective lenses. The PIC will ensure 

the VO is qualified to perform duties required.

7. The PIC and VO will communicate verbally by voice or two way radio. No texting or 

electronic messaging will be allowed.

8. Minimum crew for each flight operation will consist of the PIC and the VO and may 

include, but not limited to, a Camera Operator.

9. Maximum flight time for each operational flight will be 30 minutes. Flights will be 

terminated at no less than 20% battery power reserve or 30 minutes flight time, 

whichever occurs first. 

10. Flights will be conducted under Visual Meteorological Considerations during 

daylight hours only. 

11. Prior to each flight operation a pre-flight inspection of the UAS and associated flight 

control equipment will be held and logged. All UAS maintenance, equipment and 

software will be current.

12. Prior to each flight operation all participants will be briefed regarding planned UAS 

operations consisting of all the days’ production activities. 

13. Prior to flight operations verbal/written consent of all persons involved with the 

planned operation will be obtained. Only consenting persons will be allowed within 

500 feet of the flight operation. 

14. The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated. 

15. If the UAS loses communications or loses GPS signal, the UAS have the capability to 

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return to a pre-determined location within a designated location and land 

autonomously. 

16. The PIC has the capability to abort a UAS flight in case of unpredicted obstacles, 

weather, or emergencies.

Respectfully,

Robert Cecil

Seneca Rocks, WV

References: Aircraft Flight Manuals

Intelligent Flight Battery Safety Operations

http://dl.djicdn.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_G

uidelines_en.pdf

DJI Phantom 3 Pro User Manual

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_M

anual__V1.6.pdf

DJI Phantom 3 Pro Safety Guidelines

http://dl.djicdn.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en_2

01509.pdf

DJI Inspire 1 Pro User Manual

https://dl.djicdn.com/downloads/inspire_1/en/Inspire

%20_1_User_Manual__V1.8.pdf

DJI Inspire 1 Pro Safety Guidelines

http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_en.pdf

DJI Inspire 1 Pro Maintenance Manual

http://dl.djicdn.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_

en.pdf

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