September 30, 2015 

U. S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE 

Washington, DC 20590 

PETITIONER:

William K. Fowler, Jr. (FAA ATP 2665037) 

4735 HOWE 

Pensacola, FL 32504-9034 

SPECIFIC EXEMPTIONS AND INTENT TO SEEK

WILLIAM K. FOWLER, JR, hereafter referred to as ‘PETITIONER’ seeks exemption 

from the requirements of 14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate Unmanned 

Aerial Systems (UAS) for commercial purposes pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA) (PUBLIC LAW 112-95).

SCOPE

This exemption will permit the PETITIONER to operate an Unmanned Aircraft 

System (UAS) for commercial purposes in the National Airspace Sytem (NAS) of 

the United States for, but not limited to, the following endeavors; still and videographic content for real estate, marketing, media outlets, law enforcement/

government, event production/production, historical needs, and flight training 

individuals and institutions in UAS/NAS operations.

 
EQUIVALENT SAFETY & PUBLIC BENEFIT

PETITIONER has operated with zero mishaps during entire flying experience 

beginning in 1987. PETITIONER has approximately 8,000 hours of airline 

transport flight in, and a comprehensive knowledge of, operations and safety in the 

NAS. PETITIONER has in excess of 2 years experience in UAS operations and 

planning to include over 100 hours of UAS flight training. PETITIONER’s history 

of safety, and dedication thereto, will ensure equivalent safety and public benefit. 

PETITIONER will ensure ‘equivalent safety’ and ‘public benefit’ via, but not 

limited to the following practices and protocols for UAS operated under this 

exemption:

- situational awareness 

- ‘pre’ and ‘post’ flight inspections 

- manufacturer recommended maintenance 

- pre-flight planning; WX, TFRs, file NOTAMs, etc. 

- coordination with local law enforcement to mitigate public alarm

- compliance with 14 CFR and Federal Aviation Regulations (FARs)

PETITIONER, William K. Fowler, Jr., pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform 

Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to commercially operate UAS in the 

National Airspace System (NAS), and for an exemption from the requirements of 

14 C.F.R §§ 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b). 

PETITIONER shall comply with speed, weight, size, and operating area limitations 

set forth in FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, PETITIONER requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements 

for maintenance that only apply to aircraft with an airworthiness certificate. 
No relief from Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: pilot in command, is requested by the PETITIONER as he currently 

holds an FAA Medical Certificate and ATPL with three type-ratings in the course of 

his employ as a pilot executing air carrier operations with a large FAR 121 carrier. 

PETITIONER also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the UAS has no barometric altimeter onboard. Flight 

information (including altitude) are provided to the PIC via Global Positioning 

System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path. This 

altitude information, combined with the PETITIONER’s operation of the UAS 

within visual line of sight, at or below 200 feet AGL, at a speed no greater than 80 

knots will ensure a level of safety equivalent to Section 91.121. 

Additionally, PETITIONER seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. With average 

flight requirements of 15 minutes, safety will not be affected by operation of UAS 

during daylight hours in visual meteorological conditions (VMC) under visual flight 

rules (VFR), with enough battery power to fly for a total duration of approximately 

20 minutes. Flights will be aborted safely if battery charge reaches an unsafe level.

SUMMARY for Federal Registry

In accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, PETITIONER respectfully requests that the 

Administrator grant this petition for ‘Exemption from the requirements of 14 C.F.R 

Sections 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

and 91.417(a) & (b)’ and permit William K. Fowler, Jr. to operate UAS

commercially for the purpose of, but not limited to, conducting aerial videography/

marketing in the NAS of the United States. 
Due to the incongruent relationship of UAS and sections of 14 CFR intended for 

traditional aircraft, PETITIONER respectfully request exemption from any, and all, 

sections that do not apply to the UAS to be used. 

Examples of incongruity not applicable to many UAS: 

-traditional airframe vs. single piece composite hull 

-traditional power plant vs. electric motors 

-traditional fuel vs. electric power 

-weight & balance vs. fixed CG (within 18-36 inches) 

ADDENDUM

PETITIONER has operated with zero mishaps or violations during entire flying 

experience beginning in 1987. Petitioner has approximately 8,000 hours of airline 

transport flight in, and a comprehensive knowledge of, operations and safety in the 

NAS. PETITIONER is confident past performance and habits will translate into 

safe UAS/NAS operations. Further, petitioner will place a priority on outreach in 

attempt to educate fellow UAS operators, and the public, on the importance of safe 

UAS integration into the National Airspace System. 

FOREIGN OPERATIONS 

None sought.

Respectfully Submitted,

///W. FOWLER///

William K. Fowler, Jr.

FAA ATPL 2665037