Ricky W. Doyle 

19222 CR. 1500

Ada, Ok 74820

Cell: 1-580-320-7707

Email: ricky.doyle@hotmail.com

I, Ricky W. Doyle, hereby submit this petition for exemption under Section 333; FAA Modernization and Reform Act of 

2012, Public Law 112-95 FEB. 14, 2012, Section 333.

I request this exemption in order to operate my UAV/UAS, DJI Phantom 2 Vision Plus Quadcopter Aircraft, in order to 

provide services for profit to include aerial photography, aerial cinematography, aerial filming and photography for real 

estate, construction firms, aerial mapping, agriculture mapping, special events to include but not limited to weddings, 

private or public parties/events, business advertising, promotional events, geological surveying, and environmental 

studies. I also request to use other UAS’s of similar configuration.

The ability to provide these services to other local businesses and individuals in my community will benefit them by 

opening up opportunities they otherwise did not have before. Traditional methods of aerial photography/videography 

are simply not viable options for the average consumer as they are costly and involve greater risks to everyone involved; 

i.e. the use of larger aircraft carrying humans and flammable fuel. By utilizing the UAV/UAS the same results can be 

achieved with much safer conditions.

I plan to operate a UAS, the DJI PHANTOM 2 Vision+, which is comprised of an unmanned aircraft (UA or Phantom 2) and 

a transportable ground station. The Phantom 2 is referred to as a quad-copter with a maximum gross weight of about 3 

pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum 

airspeed of 16 m/s. Also, given the small size of the UAS involved and the restricted controlled environment within 

which they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due 

to the size of the UASs and the controlled areas in which the relevant UASs will operate, approval of the application 

presents no national security issue. Given the following, the grant of the requested exemptions is clearly in the public 

interest. I, Ricky W Doyle, propose that the exemption requested herein apply to civil aircraft that have these

characteristics and that operate with the limitations listed herein. These limitations provide for an exceptional level of 

safety to operations. These limitations and conditions to which I, Ricky W. Doyle, agree to be bound to when conducting 

commercial operations under an FAA issued exemption including: 1. The UAS will weigh less than 55 lbs. 2. Flights will 

be operated within line of sight of operator. 3. Maximum total flight time for each operational flight will be 30 minutes. 

4. Flights will be terminated at 15% battery power reserve. 4. Flights will be operated at an altitude of no more than 400 

feet AGL. 5. The UAS will only operate within a controlled area as defined in the Procedures. 6. The operator will post 

advisor notice around the controlled area. 7. The operator will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated as required. 8. If the UAS loses communications 

or loses its GPS signal, the UAS will have capability to return to a pre-determined location within the Security Perimeter 

and land. 9. The operator will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

 
I, Ricky W. Doyle, do also request an exemption to the requirement of being required to hold, at least, a sport pilot 

certificate. The FAA has filed a Notice of Proposed Rule Making, Docket No.: FAA-2015-0150, that requires an operator to 

pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center. Be vetted by the Transportation 

Security Administration. Obtain an unmanned aircraft operator certificate with a small UAS rating (like existing pilot 

airman certificates, never expires). Pass a recurrent aeronautical knowledge test every 24 months. Be at least 17 years old. 

Make available to the FAA, upon request, the small UAS for inspection or testing, and any associated documents/records 

required to be kept under the proposed rule. Report an accident to the FAA within 10 days of any operation that results in 

injury or property damage. Conduct a preflight inspection, to include specific aircraft and control station systems checks, 

to ensure the small UAS is safe for operation.

I, Ricky W. Doyle, have also filed the necessary paperwork with the aircraft registration branch of the FAA to receive my 

“N” number to be in full compliance with any registration requirements. Attached are also Aircraft Log Sheets that I have 

made to comply with documentation relating to flight times, locations and maintenance including battery logs. You will 

also find a copy of my Pre-flight and Post-Flight Checklist. All of this is in a binder that will be available for inspection 

by anyone who has concerns about the safety of my operations and equipment being used. The DJI Phantom 2 Vision+ 

factory manual is also in the log book. Please find the link to the User Manual of which I have reviewed for safe flight 

operations.

The requests of this petition are similar to those of Mr. Todd Thomas Drone Pics, and Mr. Mike Lloyd & Associates, all of 

who have received Section 333 exemptions for comparable aircraft for similar operations.

The specific sections of 14 C.F.R from which I am seeking exemption are as follows:

14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.101(e)(4), & (5); 14 C.F.R. 61.113(a) & (b); 14 C.F.R. 61.133 (a);

14 C.F.R. 61.23(a) & (c); 14 C.F.R 91.7(a) 14 C.F.R. 91.9(b)(2); 14C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.121;

14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2};

14 C.F.R. 91.417(a) & (b).

Accordingly, I, Ricky W. Doyle, respectfully request that the FAA grant the requested exemption and are prepared to 

modify or amend any part of this request to satisfy the need for an equivalent level of safety. I look forward to working 

with your office. Please contact me at any time if additional information or clarifications are needed. 

Sincerely, 

Ricky W. Doyle

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.

8_en.pdf