Douglas J. Linesch 

7089 Running Fox Court 

Florence, KY 41042 

dlinesch@fuse.net 

859-466-8183 

February 08, 2016 

U. S. Department of Transportation: 

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I, Douglas J. Linesch, would like to formally submit an exemption from part 21, subpart H; and Sections, 

45.23(b), 91.119, 91.121, 91.151(a)(1), 91.40S(a), 91.407(a)(1), 91.409(a)(1)and(2), 91.417(a)(b), of title 

14 Code of Federal Regulations (14 CFR). This proposal exemption would allow operation of unmanned 

aircraft systems (UAS) for the purpose of aerial videography, aerial photography and aerial survey for 

real estate, construction firms, landscape gardens, special events to include but not limited to weddings, 

private or public parties/events, business advertising, promotional events and sporting events. 

Regarding the Unmanned Aircraft PIC: 

I will operate the UAS, more specifically the DJI Phantom Ill, which is an unmanned aircraft (UA or 

PHANTOM), comprised of an attached high definition camera and a transportable ground station. I hold 

an ATP Certificate with four type ratings and I'm approaching eleven thousand hours of flight time. I 

currently am a captain on a Falcon 900. I also hold a Flight Instruction Certificate for airplane single and 

multiengine land, and instrument. Having flown thousands of hours in a multitude of aircraft, I am well 

aware of the importance of pre- flight planning and the significance of being safety oriented. Safety is 

extremely important and is my number one priority. Flying a UAS is no exception when it comes to 

fitness of flight and I intend to operate the UAS as I would any aircraft, always being in peak physical and 

mental condition. This will allow for safe operations on the ground and in the air, just as it is done in 

manned aircraft. 

Regarding the Operation of the Unmanned Aircraft: 

With my clear understanding of FAA regulations, my experience in flying in all kinds of airspace and my 

safety first attitude, I believe that I should be granted an exemption. I am well aware of the importance 

of safe flight operations and planning flight paths that minimize any overflight of crowds or in the 

vicinity of other manned aircraft. I am new to operating a UAS and I know how important proper 

training is. Because of this, I just enrolled for a 2 day drone training class taught by a CFI at Lunken 

Airport in Cincinnati. This includes both ground instruction and going to a local park for flight instruction. 

Preflight and post-flight checklists and UAS examinations will help detect any abnormalities prior to 

flight and after flight. Any UAS unable to satisfy safety checklists will be removed from service until the 

issue can be resolved. The UAS will not be operated above 200 feet AGL and will not be flown in wind 

conditions greater than 10 knots. The UAS will operate in temperatures between 0 degrees Celsius and 

40 degrees Celsius (32 degrees Fahrenheit -104 degrees Fahrenheit) as that is the range for the craft. 

Flights outside those temperature parameters will not be attempted. Furthermore, the UAS will 
maintain at least the Basic VFR Weather Minimums prescribed in 14 CFR 91.155 and operations will only 

commence during day visual meteorological conditions. 

If a property being enhanced by videography or photography is within 5 nautical miles of a towered 

airport, I will call the control tower and request permission to operate the UAS. Upon contact with the 

tower manager I will alert them to the location of the property that is to be filmed and provide the 

proximity of that property to the airport. I will also give at least a minimum of a 24 hour notice before 

filming or photographing the property. If permission is not granted, operations with not be conducted. 

Before operating within close proximity to another structure, building or person, the owner and/or 

those who Jive at the aforementioned will be given notice that aerial photography and/or videography 

will commence. Any complaint by a neighbor or member ofthe public worried about their privacy being 

invaded, will be ensured that only the property being videoed will be used for marketing purposes. If 

this is not sufficient, the DJI Phantom Ill will immediately be brought back to the ground and the 

videography and/or photography will cease until the complaint is resolved. 

The UAS will only be operated within visual line of sight visual contact between myself and the 

unmanned aircraft. This will further ensure safe operational control as I will always have visual line of 

sight on the UAS in order to scan the airspace it is operating in so as to see and avoid other aircraft, 

airborne objects or objects on the ground. Moreover, I will only operate in congested areas with another 

person (spotter) in order to help spot the aircraft from other angles to verify operations will be 

conducted safely. I will always be in verbal contact with the spotter. 

Additionally, in order to further enhance safety, flights will end when battery reserve reaches 25 

percent. The UAS has a 15.2 volt battery, allowing flight operations for up to 23 minutes. I have also 

purchased a second battery allowing for an additional 23 minutes of flight time. Operations with the 

UAS will not occur under IFR conditions. It is my understanding that granting this request would not 

adversely affect safety since operations would be in accordance with current UAS rules. 

Suggested Public Federal Register Summary: 

"The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS} under the new 

FAA "Summary Grant" approach, announced April 9th, 2015 that will hasten the Section 333 exemption 

approvals for many commercial UAS operators prior to finalizing the small UAS proposed rules published 

this past February." 

It is my understanding that the FAA will still review each Section 333 petition individually. However, I am 

hoping that the agency will accept my particular petition, include it in the next summary grant and issue 

an exemption to myself on the presumption that the FAA has already granted a previous exemption 

similar to this request. 

Currently, the new interim policy includes the granting of a Certificate of Waiver or Authorization (COA) 

for flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh 

less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual 

line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports such as 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. It is also understood that the "blanket" 200- foot COA allows flights 

anywhere in the country except restricted airspace and other areas, such as major cities, where the FAA 

prohibits UAS operations. 

UAS Description: 

I am asking for an exemption for a UAS up to 55 pounds because I will be using a craft that will be flown 

operationally, weighing less than ten pounds. More specifically, I will be operating a DJI Phantom Ill, 

which will be qualified as a UAS. The UAS can fly for up to 23 minutes in temperatures between 0 

degrees Celsius and 40 degrees Celsius. The UAS has a Sony EXMOR camera mounted on it with a 

gimbal. The remote control allows for a smartphone or tablet to be used in order to operate the drone 

with a live feed from the Sony camera mounted on it. This permits operation with a high level of safety. 

In the event a loss of communication occurs with the UAS, it will automatically rise up vertically to a safe 

height before beginning an automatic return to home function. If the control signal can be reconnected 

in flight, I will take over safe operations again if communication is reestablished. However, in the case of 

a GPS failure the craft will be able to be manually flown to a safe landing. The craft operates 

electronically, carries no flammable fuel, has an integrated GPS pilot system, location information along 

with height in AGL, speed, battery life, has programmed no-fly zones for controlled airports and 

provides direction of travel distance from the pilot. 

Based on the size of the UAS, my experience of being a pilot, and operational goals, this request appears 

to be well suited for approval using the current criteria outlined in Section 333 of the FAA Modernization 

and Reform Act of 2012 (including new interim policies). I believe that this gives the FAA good cause to 

find that the UAS operation enabled by this exemption is in the public interest. 

;J;at~P Douglas J. Linesch