Douglas Scott

1855 Ne Lotus Dr Apt 71

Bend, OR 97701

Petitioner’s Contact Information

Dwscottbngr@outlook.com

360-471-1040

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

Regulations from: 14 CFR 21 subpart H

 14 CFR 45.23(b)

 14 CFR 61.113(a) and (b)

 14 CFR 91.7(a)

 14 CFR 91.9(b)(2)

 14 CFR 91.103

 14 CFR 91.109

 14 CFR 91.119(c)

 14 CFR 91.121

 14 CFR 91.151(a)

 14 CFR 91.203 (a) and (b)

 14 CFR 91.405 (a)

 14 CFR 91.407 (a) (1)

 14 CFR 91.409 (a)(1) and (2)

 14 CFR 91.417(a) and (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

CFR Part 11, Douglas Scott, operator of Unmanned Aircraft Systems (UAS), hereby applies for an 

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

designated UAS, provided such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333.

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

would provide professional services in the following areas:

 Aerial photography and/or video use including real estate, architecture, land surveying, 

engineering and other related professional activities.

 Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and newsgathering.

 Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure.
 Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it.

As described fully below, the requested exemption would permit the operation of designated UAS as set 

forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) 

predetermined and d) safe. Approval of this exemption would increase public awareness of UAS 

operations and enhance safety to aid in fulfilling the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” It would also be of public benefit by allowing for safer and 

lower-cost alternatives to traditional aerial photography already in use in many of the operations listed

above, due to the lower operational costs of small UAS systems compared to traditional aircraft and the 

eliminated need for combustible fuels.

I plan to operate a UAS, the DJI PHANTOM 3 which is comprised of an unmanned aircraft (UA or 

Phantom 3) and a transportable ground station. The Phantom 3 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’s 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:

Douglas Scott proposes that the exemption requested herein apply to civil aircraft that have the 

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 Douglas Scott agrees 

to be bound 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 the operator and visual observer.

3) A Visual Observer will be utilized for each flight. The visual observer and the operator will be 

able to communicate by voice at all times during the flight operation.

4) Maximum total flight time for each operational flight will be 30 minutes.

5) Flights will be terminated at 15% battery power reserve.

6) Flights will be operated at an altitude of no more than 400 feet AGL

7) Flights will be operated in Day VFR weather conditions only, maintaining at least 3 statues miles 

of visibility and ceilings of at least 1,000 feet AGL.

8) UAS operator will hold at least a Sport Pilot or Recreational Pilot Certificate.

9) The UAS will only operate within a controlled area as defined in the Procedures.

10) The operator will post advisor notice around the controlled area.
11) 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.

12) 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.

13) The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

14) Before operation within 5NM of an airport with a control tower, permission will be obtained by 

the tower. The UAS operator will provide position, altitude, and times of operation. The UAS will 

not be operated at an altitude of over 200 feet AGL within 5 NM of an airport with a control 

tower, within the final approach path for any runway, and will give way to manned aircraft.

15) Before operation within 5NM of a non-towered airport, airport operators will be notified and 

the UAS operator will give way to manned aircraft. The UAS operator will remain clear of final 

approach and takeoff courses for all runways, and will not operate at an altitude of over 200 

feet AGL, or in such a way that will interfere with the operations of the airport.

Accordingly, the applicant respectfully requests 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. Please contact us at any time if additional information or clarifications are needed.

Sincerely,

Douglas Scott