January 15, 2016

US Department of Transportation

Docket Management System

Federal Aviation Administration

1200 New Jersey Avenue, SE

Washington, DC

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation

Regulations from 14 C.F.R. §61.113(a)&(b); 14 C.F.R. §45.23; 14 C.F.R. §91.9; 14 

C.F.R. §91.119(c); 14 C.F.R. §91.121; 14 C.F.R. §91.151; 14 C.F.R. §91.405(a); 14 

C.F.R. §91.407(a); 14 C.F.R. §91.409(a)(1)&(2); 14 C.F.R. §91.417(a)&(b).

Submitted by:

Scott Robinson

dba Galago Vision

PO Box 723051

San Diego, CA 92172

scott@galagovision.com

858-444-7010

Dear Sir or Madam,

I, Scott Robinson, founder of Galago Vision, formally request Section 333 exemptions 

from several provisions of Title 14 of the Code of Federal Regulations. These 

exemptions will allow my company to operate the small, unmanned aerial systems

(sUAS’s) safely for compensation in the following aspects of aerial video and

photography:

• The marketing of real-estate properties.

• Monitoring of residential construction.

• Aerial photography and video of private events.

As described herein I, Scott Robinson, am a small business owner within the State of 

California; experienced in flying hobby type quad-copters for recreational purposes. I 

have two hobby grade quad-copter UAS’s (Phantom 3, and Hexo+) equipped with an 

attached camera with intent for aerial videography/cinematography to augment real 

estate listings, land development, events, promotional videos; following exemption and 

approval by the FAA.

The Hexo+ is a small, unmanned Arial system very similar in size, weight, and function to 

the DJI Phantom 3 for reference. My goals are to operate these systems as safely as 

possible no higher than 200 feet AGL under the blanket COA and in compliance with the 

protocols described herein or as otherwise established by the FAA.
Granting my request complies with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate sUAS's into the

National Air-Space System, but to “...establish requirements for the safe operation of 

such aircraft systems [UAS's] in the National Air-Space System” under Section 333(c) of 

the Reform Act specific to the use of sUAS's for real estate, photography and 

videography purposes. Further I, Scott Robinson dba Galago Vision, will conduct my 

operations in compliance with the protocols described herein or as otherwise established 

by the FAA.

For the reasons stated below I, Scott Robinson dba Galago Vision, respectfully request 

the grant of an exemption allowing me to operate ultra-lightweight, remote controlled 

sUAS’s to enhance real estate listing videos for homeowners who cannot afford 

expensive manned aircraft. This will promote local economic growth. This will keep public 

safety in mind by keeping heavier manned aircraft containing combustible fuel that poses 

potential public hazard out of these dangerous areas.

Sections from Which Seeking Exemption:

The specific sections I require relief from are as follows: 

Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the 

requirement for an airworthiness certificate based on a consideration of the size, weight,

speed, operational capability of the particular UAS, as well as its proximity to airports 

and populated areas.

14 C.F.R. §61.113(a)&(b) entitled Private pilot privileges and limitations.

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

14 C.F.R. §45.23 Display of markings;general.

(a) Each operator of an aircraft must display on that aircraft marks consisting of the 

Roman capital letter “N” (denoting United States registration) followed by the 

registration number of the aircraft. Each suffix letter used in the marks displayed must 

also be a Roman capital letter.

(b) When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.
14 C.F.R. §91.9 Civil aircraft flight manual, marking, and placardrequirements:

(a) Except as provided in paragraph (d) of this section, no person may operate a civil 

aircraft without complying with the operating limitations specified in the approved 

Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise 

prescribed by the certificating authority of the country of registry.

(b) No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotorcraft Flight Manual is required by §21.5 of this 

chapter unless there is available in the aircraft a current, approved Airplane or 

Rotorcraft Flight Manual or the manual provided for in §121.141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of 

this chapter, unless there is available in the aircraft a current approved 

Airplane or Rotorcraft Flight Manual, approved manual material, markings, and 

placards, or any combination thereof.

(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified 

in accordance with part 45 of this chapter.

(d) Any person taking off or landing a helicopter certificated under part 29 of this chapter 

at a heliport constructed over water may make such momentary flight as is necessary 

for takeoff or landing through the prohibited range of the limiting height-speed 

envelope established for the helicopter if that flight through the prohibited range takes 

place over water on which a safe ditching can be accomplished and if the helicopter 

is amphibious or is equipped with floats or other emergency flotation gear adequate 

to accomplish a safe emergency ditching on open water.

14 C.F.R. §91.119(c) Minimum safe altitudes: General

(a) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

14 C.F.R. §91.121 Altimeter settings:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when

operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(I) 

of this section, the current reported altimeter setting of an appropriate 

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available 

before departure; or

(2) At or above 18,000 feet MSL, to 29.92′′ Hg.

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.
(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 20

minutes.

14 C.F.R. §91.405(a) Maintenance required:

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter;

14 C.F.R. §91.407(a) Operation after maintenance, preventive maintenance, 

rebuilding, or alteration:

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 

of this chapter; and

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of 

this chapter has been made.

14 C.F.R. §91.409(a)(1)&(2) Inspections:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by §43.7 of this chapter; 

or

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter.

14 C.F.R. §91.417(a)&(b) Maintenance records:

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered 

owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100- hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service.

(2) Records containing the following information:

(iv) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

(v) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(vi) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis.
(vii) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(viii) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD 

or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required.

(ix) Copies of the forms prescribed by §43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under §43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

Extent of Relief:

Section 333 Aircraft Exemption Status:

DJI Phantom 3 and Hexo+ sUAS’s do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Galago Vision will ensure that 

the DJI Phantom 3 and Hexo+ sUAS’s are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Phantom 3 and Hexo+ Instruction Manual) prior to every flight. This is in line with other 

similar sUAS’s that have received exemptions for certificate of airworthiness. 

14 C.F.R. §61.113(a)&(b) entitled private pilot privileges and limitations.

Relief from Section 61.113(a) and (b), is requested to the extent necessary to allow a PIC 

holding a private pilot or higher level certificate, as well as a current and valid airman 

medical certificate, and who has met certain flight-hour and currency requirements, to 

conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for compensation 

or hire.

As set forth more fully below, Galago Vision submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the sUAS’s unless that PIC has 

met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

safely operate either the DJI Phantom 3 or Hexo+ sUAS’s in a manner consistent with the 

operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, 

vessels, vehicles and structures.
14 C.F.R. §45.23 Display of marks; general.

Even though the sUAS’s will have no airworthiness certificate, an exemption would be 

needed as the sUAS’s will have no entrance to the cabin, cockpit, or pilot station on which 

the word “Experimental” can be placed. Given the size of the sUAS’s, two-inch lettering is

impossible. Galago Vision will place the registration number and experimental markings in 

the largest lettering practical.

14 C.F.R. §91.9 Civil aircraft flight manual, marking, and placardrequirements:

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the sUAS will have immediate access to it. All 

manuals, flight logs and exemptions will be with the ground station in a binder and 

available for law enforcement.

14 C.F.R. §91.119 Minimum safe altitudes:

Galago Vision will never operate at an altitude greater than 200 AGL. The sUAS’s will operate in 

safe areas away from the public and traffic. Given the size, weight, maneuverability, and speed of 

the sUAS’s, an equivalent or higher level of safety will be achieved. The sUAS’s will never 

operate at an altitude greater than 200 AGL, safely below the standard of 400 AGL.

14 C.F.R. §91.121 Altimeter Settings:

Altimeter settings are inapplicable as the DJI Phantom 3 and Hexo+ utilizes electronic

global positioning systems (GPS) with a barometric sensor.

14 C.F.R. §91.151 Fuel requirements for flight in VFR conditions:

Relief from this section, is requested to the extent required to allow flights of the battery 

powered sUAS’s during daylight hours in visual meteorological conditions, under visual 

flight rules (VFR), for a total duration of 15 minutes, and assuming normal cruising speed, 

to fly after that for at least 5 minutes. Galago Vision seeks the requested relief because 

without an exemption, the flight time duration of the battery powered sUAS’s will severely 

constrain the practicality of any aerial video or still photo flight operations proposes to be 

conducted pursuant to this petition.

14 C.F.R. §91.405(a) Maintenance required, 14 C.F.R. §91.407(a) Operation after 

maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R.

§91.409(a)(1)&(2) Inspections, 14 C.F.R. §91.417(a)&(b) Maintenance Records:

Galago Vision requests relief from these regulations as they relate to §43 and apply to the 

aircraft with a certificate of airworthiness. Since the DJI Phantom 3 and Hexo+ do not 

require a Certificate of Airworthiness, relief is requested. As a model aircraft pilot, I take 

maintenance very seriously. The sUAS’s are always serviced in accordance with the 

guidance in the manufacturer provided manuals. The manufacturer will also be consulted 

should any maintenance discrepancies arise. Maintenance records are logged and 

annotated in the aircraft flight log. All manuals, flight logs, and exemptions will be with the 

ground station in a binder and available for law enforcement.

How the Request Benefits the Public:

My company, Galago Vision, can and will benefit the public in the aspects of safety and 

economic growth. First and foremost, safety is the biggest public benefit of utilizing Galago 

Vision. My services reduce the risk of injury and death to the general public, discouraging 

climbing tall ladders or trees with a camera to gain a similar vantage point. It also 

alleviates the inherent dangers of operating a full scale aircraft at low altitudes while 
capturing photos and video. Aerial photos and video from a sUAS give customers a very 

unique and valuable perspective of properties and events. Galago Vision’s sUAS’s

provides one of a kind high-definition and gyro-stabilized video and photographs. These

luxuries would normally be reserved for customers that could afford to charter a full scale 

aircraftand video crew. My service brings that product to the average citizen.

Why the Exemption Does Not Adversely Affect Safety:

Safety is of the upmost importance to Galago Vision. The DJI Phantom 3 and Hexo+ fall 

well below the maximum limitations for a sUAS. It has a fully integrated GPS that returns 

the sUAS back to a predetermined point to land automatically if there is a signal loss or if 

the Home switch is activated from the ground transmitting station. The switch is easily 

accessed and can be activated by the Visual Observer in the unlikely event that the Pilot 

in Command is incapacitated; furthermore, it will be part of the preflight brief. Galago 

Vision never flies over any persons, vessels or structures that are non-participating. 

Sound judgment, airmanship, and experience are used while flying near participants. The 

sUAS’s will only be flown over property that Galago Vision has prior client permission to 

operate over. Galago Vision operates using Line of Sight (LOS) operations in daytime 

VFR conditions at all times. Galago Vision never plans a flight longer than 15 minutes to 

allow a minimum of 25% battery remaining at landing. Galago Vision always consults 

aviation charts and will honor the blanket COA parameters. Galago Vision never operates 

at an altitude higher than 200-feet AGL. Galago Vision also utilizes a Visual Observer 

throughout the flights entirety to include an extensive brief prior to flight. An extensive 

preflight and post-flight check will be performed before and after each flight. additionally, 

in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe 

special conditions for the intended operation of the sUAS’s, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety equivalent to 

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a)&(b), 

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).

Respectfully submitted,

Scott Robinson

dba Galago Vision

PO Box 723051

San Diego, CA 92172

scott@galagovision.com

858-444-7010
Appendix A

Summary for Federal Register Publication

Petitioner Scott Robinson d/b/a Galago Vision

Sections of 14 C.F.R. that are affected.

Section 333 Aircraft Exemption Status - Relief from certificate of air worthiness. 

14 C.F.R. §61.113(a)&(b) – Entitled Private pilot privileges and limitations.

14 C.F.R. §45.23 - Relief of markings size.

14 C.F.R. §91.9 - Relief from aircraft flight manual, marking, and placard requirements. 

14 C.F.R. §91.119(c) - Relief from minimum safe altitudes.

14 C.F.R. §91.121 – Relief from altimeter settings.

14 C.F.R. §91.151 – Relief from VFR fuel requirements. 

14 C.F.R. §91.405(a) – Relief from maintenance required.

14 C.F.R. §91.407(a) – Relief from operation after maintenance. 

14 C.F.R. §91.409(a)(1)&(2) – Relief from inspections.

14 C.F.R. §91.417(a)&(b) – Relief from maintenance records.

Petitioner seeks relief from the preceding regulations and requirements to operate the

DJI Phantom 3 and Hexo+ sUAS’s for the purpose of compensated aerial video and 

photography. The operations will include real-estate, residential construction, and private 

events. It is the belief of Scott Robinson d/b/a Galago Vision that these operations are 

pursuant to theFAA’s stance of legally entering the sUAS marketplace by operating 

safely in the National Airspace System.

Galago Vision will honor the blanket 200-foot AGL blanket COA by adhering to the 

following flight parameters as well as other limitation the Administration finds 

necessary to establish an equivalent level of safety. 

No flight with in:

• 5 nautical miles (NM) from an airport having an operational control tower; or

• 3 NM from an airport with a published instrument flight procedure, but not an

operational tower; or

• 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or

• 2 NM from a heliport with a published instrument flight procedure

Scott Robinson

dba Galago Vision

PO Box 723051

San Diego, CA 92172

scott@galagovision.com

858-444-7010