February 10, 2016

Jeremy Rueth

1042 Woodgrove Drive

Cardiff by the Sea CA. 92007

760-859-6340

jrueth@live.com

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the 

Federal

Aviation Regulations

Dear Sir or Madam;

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333,

I, Jeremy Rueth request exemption from the Federal Aviation Regulations to allow for ·j···

commercial UAS operations of a DJI Phantom 3 Professional, for the purpose of aerial 

photography, videography, and other flight operations that could be performed safely and 

more cost effectively than a traditional manned aircraft.

Applicant:

Jeremy Rueth

1042 Woodgrove Drive

Cardiff by the Sea, CA. 92007

760-859-6340 

Regulations from which the exemption is requested:

14 CFR 21, Subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

14 CFR 91.7 (a)

14 CFR 91.9 (b)(2)

14 CFR 91.103 (b)(2)

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a)(l)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b)

14 CFR 21, Subpart H- In consideration of the size, weight, speed, and limited operating 

area associated with this U AS and its operation, I Jeremy Rueth request relief from 14 CFR 

part 21,

Subpart H, and any associated noise certification and testing requirements of part 36. The 

UAS will carry neither pilot, passenger, explosive materials or flammable liquids.

14 CFR 45.23 (b)- Even though the UAS will have no airworthiness certificate, an 

exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot 

station on which the word "Experimental" can be placed. Given the size of the UAS, twoinch lettering will be impossible. The
word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The 

equivalent level of safety will be provided by having the UAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the UAS will see 

the identification of the UAS as "Experimental."

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the UAS will not carry a pilot or 

passengers Jeremy Rueth requests a relief from these regulations. Any pilot in command or 

(PIC) operating the UAS will hold a Sport Pilot (or greater) certificate. A visual observer or 

(VO) will be utilized and required to communicate verbally at all times. The UAS will be 

limited to operations within visual distance of both the PIC and VO. All UAS operations will 

take place in a controlled area. The risks associated with the use of a UAS are far less than 

similar commercial aircraft operations.

14 CFR 91.7 (a)- Since the UAS will not carry a pilot or passengers there will be no 

airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard exists for determining airworthiness. Given the size of the aircraft, 

maintenance, and use of safety checklist prior to each flight, an equivalent level of safety 

will be provided. All flights will be in accordance with the safety and maintenance 

recommendations found in the Turbo Ace Infinity-6

attachments.

14 CFR 91.9 (b)(2)- Given the size and configuration, the UAS has no ability to carry a 

flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately 

carry a flight manual. An equivalent level of safety will be maintained by keeping the flight 

manual at the ground station where the UAS pilot will have immediate access to it.

14 CFR 91.103 (b)(2) -As no FAA approved flight manuals will be provided for the aircraft 

an exemption is needed. Alternate procedures including but not limited to reviewing weather 

conditions, checking flight battery requirements, checking takeoff and landing distances 

along with those found

in the attached "Infinity-6 Pilot Training" will be implemented. These actions will provide an

equivalent or higher level of safety.

14 CFR 91.109- UAS and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is achieved through the use of a control box that communicates with 

the aircraft via radio communications. An equivalent level of safety will be achieved using 

the real time ground station data and given the UAS will carry neither a pilot or passengers.

14 CFR 91.119 (c)- The UAS will never be operated at an altitude higher than 400 feetAGL. 

The UAS will operate in safe areas away from public and traffic and only with permission of 

the property and structure owners. The UAS will also be restricted by the flight controller to 

a maximum vertical height of 400 feet AGL, and 1500 feet horizontal. Given the size, 

weight, maneuverability and speed

of the UAS, an equivalent or higher level of safety will be achieved.

14 CFR 91.121- As the UAS may not have a barometric altimeter, but instead a GPS 

barometric sensor for altitude information an exemption may be required. An equivalent 

level of safety will be achieved using a ground station which links to a telemetry data link. 

This will provide the pilot with live flight data monitoring, confirming the altitude of the launch 

site shown on the GPS altitude

indicator prior to flight.

14 CFR 91.151 (a)- The UAS has a limited range and will be limited to operations in a 

controlled environment. The battery power the U AS provides approximately 20 minutes of 
flight time. The UAS is unable to meet the 30 minute reserve requirement and therefore 

requires an exemption. An equivalent level of safety will be achieved by monitoring the 

battery through the ground station and landing with a minimum of 30 percent battery power 

remaining.

14 CFR 91.203 (a) & (b)- Given the size and configuration, the UAS has no ability to carry a 

flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately 

carry a flight manual. An equivalent level of safety will be maintained by keeping the flight 

manual at the ground station where the UAS pilot will have immediate access to it.

Given the following sections only apply to aircraft with an airworthiness certificate, these 

sections do not apply to this applicant. As a safety precaution, the operator will perform 

preflight inspections and ensure UAS is in working condition before initiating each flight:

14 CFR 91.405 (a)

14 CFR 91.407 (a)(1)

14 CFR 91.409 (a)(l) & (a)(2)

14 CFR 91.417 (a) & (b)

Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS will adhere to the following 

additional

guidelines:

1. The U AS will not be operated within 5 miles of an airport unless prior contact to Air 

Traffic Control has been established.

2. Flights will not exceed the an airspeed of 36 mph (31.3 knots)

3. Flights will be operated at or below an altitude never exceeding 400 feet AGL.

4. The PIC and VO will communicate verbally at all times.

5. UAS operations will not be conducted during night.

6. All operations will be conducted under visual meteorological conditions.

7. The UAS will land with a minimum 30 percent battery reserve remaining.

8. The UAS will only be piloted within visual line of sight.

9. The UAS will utilize an internal flight safety feature that will return to a preprogrammed

position and land if communication with the remote control is lost.

10. Preflight inspections and protocol will be followed prior to all operations.

11. The UAS will abort flight in the event of unpredictable obstacles or emergencies.

Public Interest

We believe the use of a UAS in lieu of a manned aircraft would enhance safety and reduce 

the environmental impact compared to similar operations conducted with a manned aircraft 

carrying a crew and flammable fuel.

The use of a UAS in the real estate industry provides both the buyer and seller with a higher

level of marketing and service. The UAS is able to provide a view which encompasses the 

entire property in a single photo or short video clip. When compared to similar operations, 

utilizing a UAS poses much less of a safety concern for the general public with less fuel, 

time, noise and other resources.

Privacy

All flights will occur over private or controlled areas with the owner's consent. Capturing 

people in images will rarely occur. If a person is captured in a collected image they will have 

consented prior to filming or otherwise have agreed to being in the area prior to the filming 

taking place.
-Jeremy Rueth