12/18/2015

John Eric Morrison

603 Laurel Circle,

Bartow, Florida 33830

(636)236-5713

johneric262@gmail.com

Dear Sir or Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11.81, John Morrison, certified as a Private Pilot as of July 1985 and 

active as a RC Helicopter and fix wing aircraft operator for over 20 years, hereby applies for an 

exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation 

of small, unmanned aircraft for

 Crop monitoring/inspection;

 Research and development;

 Educational/academic uses;

 Power-line/pipeline inspection in hilly or mountainous terrain; 

 Industrial inspections (infrastructure including plants and manufacturing facilities),

 Antenna inspections;

 Aiding certain rescue operations such as locating snow avalanche victims;

 Bridge inspections;

 Aerial photography; and cinematography

 Wildlife nesting area evaluations / aquatic habitat inspection and evaluations.

 Photogrammetry, LiDar applications (scanning and mapping technologies)

 Agricultural field inspection / related applications, 

 Aerial survey /observation, and associated operations and analyses. 

All operations shall be conducted within and under the conditions and limitations outlined

previously by the FAA as required by Section 333 and conducted in compliance with the

appropriate operator’s manuals.

1. Sections from which exemptions are sought : Application is hereby made for

exemption from:

a. 14 CFR Part 21, subpart H

b. 14 CFR Part 61.113(a) and (b)

c. 14 CFT Part 91:

i. 91.103(b)(2)

ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409
x. 91.417

2. Relief sought :

a. Petitioner wishes to operate small Unmanned Aircraft Systems (sUAS)

for commercial purposes to include (but not be limited to) those previously listed in this 

petition. This relief is sought because commercial use of sUAS is currently prohibited

by law unless performed under an exemption.

b. This exemption will cover use of the following specific commercially available and also 

comparable airframes, all of which will weigh less than 55 pounds including payload and 

energy sources:

i. DJI Phantom 2 Vision+

ii. DJI Phantom 3 (Standard/Advanced/Professional)

iii. DJI Inspire 1

iv. 3D Robotics Solo

3. Public benefit include the following:

a. Use of sUAS technology to obtain imagery, information and data currently

obtained by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft

accidents (e.g., infrastructure inspections) and due to other

dangerous activities that can be avoided (e.g., scaffolding/rigging

failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits

consumers and the economy. 

iii. Due to the cost effectiveness of sUAS, more frequent inspections of infrastructure may be 

scheduled.

iv Reduces environmental impact by eliminating sources of

hydrocarbon emissions from manned aircraft

iv. Reduces statistical risk to human life and property due to the relatively small size of the 

sUAS when compared to manned aircraft.

4. Safety not adversely affected :

a. If required, aircraft will be registered and marked in accordance with Section

44711 and Part 47 and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the

manufacturer. All repair and maintenance work will be conducted or approved

by qualified personnel, such as those authorized by DJI/3D Robotics (or their

reasonable equivalent), and will require a test flight after such work. Records

of all maintenance and repair work will be kept in a maintenance log for each

aircraft.

c. All operations will be conducted in accordance with valid Certificates of

Authorization.

d. All flight operations will comply with the following:

i. Employment of the reasonably available manufacturers’ user

manuals.
ii. Flight Operations and Procedures Manual (FOPM) and Aircraft

Flight Manuals (AFM), which include lost communication and

other emergency and safety procedures.

iii. Flights will be conducted in VMC conditions during daylight

hours.

iv. PIC (Pilot in Command) will maintain VLOS at all times. Adequate additional crew, (acting 

as observers when needed), will be tasked for appropriate flights. 

v. Preflight inspections (including ground control station, if any) and

safety risk assessments will be conducted prior to each flight.

vi. Flight altitudes will remain below 500 feet above ground level,

unless otherwise authorized by FAA regulations or exceptions.

vii. Flight ground speeds will not, under normal ops, exceed 87 knots.

viii. Not intrude into Class B, C or D airspace, or published approach,

SID or STAR, or take place within 5 nautical miles of an airport

without reasonable notice (if practical). When flown within 5 miles of an airport, the operator of 

the aircraft will provides the airport operator and the airport air traffic control tower (when an air 

traffic facility is located at the airport) with prior notice of the operation.

ix. Made clear of persons in conformance with 14 CFR 91.119.

x. Not exceed 75% of the battery or fuel capacity of the aircraft.

xi. Any significant incidents will be reported within 24 hours of

occurrence.

xii. Any applicable local FSDO requirements.

xiii. All other applicable regulations concerned with the operation of

aircraft.

e. Aircraft will use FCC compliant 2.4 GHz for command & control of the

aircraft with well defined and tested lost link procedures.

Please advise of any additional information or changes that may be required.

Sincerely,

John Eric Morrison