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December 8, 2015 

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Ave., SE

Washington, D.C. 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11 -

I (Robert Kennon Williamson) hereby apply for an exemption from the listed Federal Aviation

Regulations (FARs) to conduct commercial operation of designated Unmanned Aircraft Systems 

(referred to as 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 operations of my UAS, equipped with camera(s) and sensors, would provide 

professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities. 

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

events, landscape cinematography and network news imaging. 

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

owners or local government authority.

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not

limited to electrical power lines, wind turbines and cell towers. 

5. 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 by contract or donation. 

6. Training to persons individually or belonging to both private and/or public organizations to

increase awareness and improve safety for current and future UAS operations within the

National Airspace System (NAS). 
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As described below, the requested exemption would permit the operation of a designated UAS as 

set forth in this document under controlled conditions in the NAS that would be compliant with all 

local, state, and federal regulations. Approval of this exemption would further the positive public 

image of UAS operations in a safe and responsible manner and further the seamless integration 

of these aircraft types into the National Airspace System. Additionally, because of the electric 

propulsion systems and their reduced impact on the environment (both in economic terms and 

ecological disruptions), a reasonable level of benefit to the public good would also be provided as 

I would be able to operate on a significantly minimized infrastructure while providing the same 

level of safety and service currently performed by conventional aerial photography and filming

aircraft. 

The name and address of the applicant is: 

Robert Kennon Williamson (Private Pilot Certificate: 3477943) 

1835 Russell Rd

Bolivar, Tennessee 38008

Phone: 731-609-4432

Email: bobwill0817@gmail.com

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

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

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b) 

It is my request to operate the following model type of UAS: 

DJI Phantom 3 Professional (please refer to the complete specifications on the next page) 
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UAS DJI Phantom 3 Professional Specifications: 

Type Quad rotor, fixed gear and propellers

Weight (Including Battery And Propellers) 1280 g

Diagonal Size (Including Propellers) 590 mm 

Max Ascent Speed 5 m/s 

Max Descent Speed 3 m/s 

Hover Accuracy

• Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m 

• Horizontal: +/- 1.5 m

Max Speed 35 miles per hour, or 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level 6000 m

Operating Temperature 0° to 40° C

Gps Mode GPS/GLONAS

Camera Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total

pixels: 12.76 M)

Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8,

focus at ∞

Iso Range 100-3200 (video) 100-1600 (photo)

Shutter Speed 8s -1/8000s

Image Max Size 4000 x 3000

Still Photography Modes

o Single Shot 

o Burst Shooting: 3/5/7 shots 

o Auto Exposure Bracketing (AEB): 3/5 

o Bracketed Frames at 0.7EV Bias 

o Time-lapse

Video Recording Modes

Phantom 3 Professional 

• UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

• FHD: 1920x1080p 24/25/30/48/50/60

• HD: 1280x720p 24/25/30/48/50/60

Supported Sd Card Types Micro SD 

Max capacity 64 GB Class 10 or UHS-1 rating required

Max Bit rate Of Video Storage 60 Mbps 

Supported File Formats

• FAT32/ex FAT 

• Photo: JPEG, DNG 

• Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature 0° to 40° C

Gimbal Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

Vision Positioning (VPS) Max Velocity Less than 8 m/s (when 2 m above

ground)

Altitude Range 30cm - 300cm

Operating Range 30cm - 300cm

Operating Environment Surface with clear pattern and adequate lighting

(Lux > 15)
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DJI Phantom 3 Remote Controller Specifications: 

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance 2000m (outdoors and unobstructed)

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone

Receiver Sensitivity (1%Per) -101 dBm ±2 dBm

Transmitter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm

Working Voltage 1.2 A @7.4 V

Battery Charger Specifications: 

Battery Charger Voltage 17.4 V

Rated Power 100 Watts

Intelligent Flight Battery Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g (per battery)

Max Flight Time Approximately 23 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W

Mobile Viewing Device Specifications: 

App / Live View Mobile App

DJI Pilot Eirp 100mW

Live View Working Frequency 2.4GHz ISM

Live View Quality 720P @ 30fps (depending on conditions and

mobile device)

Latency 220ms (depending on conditions and mobile

device)

Required Operating Systems iOS 8.0 or later, Android 4.1.2 or later

Recommended Devices

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2,

iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad

mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus

 Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, 

Nubia Z7 mini
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Operations and Regulatory Compliance Specifications

The UAS will be operated in full compliance with all manufacturer guidelines, but not to exceed

any limitations or restrictions as defined by approved operating documents or Federal Aviation

Regulations. The mobile viewing device used with the controller shall be of a type that is 

specifically recommended for use by the manufacturer. Software and/or firmware updates will

also be completed as required to ensure optimal operation of the system. 

Due to the small size of my UAS aircraft and the restricted environment within which they will 

operate, my UAS operations will remain well within the Reform Act’s safety requirements. 

Secondly, due to the small size of the UAS platform and the predetermined areas in which it will 

operate, approval of this application presents no national security issues. Based upon the 

elevated level of safety surrounding the proposed operations, the significant public benefit of 

these enhanced safety procedures, and the reduction in environmental impacts (reduced 

emissions and noise), the grant of the requested exemption is believed to be in the public interest. 

Accordingly, I respectfully request that the FAA grant the requested 333 exemption. 

The applicant proposes that the exemption requested apply to UAS that have the characteristics 

and that operate with the limitations listed. These limitations provide for at least an equivalent or 

higher level of safety to operations under the current regulatory structure because the proposed

operations represent a safety enhancement to the existing aerial photography and aerial filming

for movie and television filming operations conducted with conventional aircraft. 

These limitations and conditions to which I agree to be bound when conducting 

commercial operations under an FAA issued 333 exemption include, but are not limited 

to: 

1. Operations authorized by this grant of exemption will be limited to the DJI Phantom 3 series 

and a ramp weight of less than 55 pounds, including payload. Proposed commercial 

operations of any other UAS type by myself will require a new petition or an amendment to this 

exemption. 

2. The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour). The pilot

may use either groundspeed or calibrated airspeed (as presented via telemetry data on the

mobile viewing device) to determine compliance with the 87 knot speed restriction. In no case

will the Phantom 3 be operated at airspeeds greater than the maximum operating air speed

recommended by the aircraft manufacturer. 

3. The UAS must be operated at an altitude of no more than 400 feet above ground level 

(AGL).Altitude must be reported in feet AGL (as presented via telemetry data on the mobile 

viewing device) . 

4. The UA will be operated within visual line of sight (VLOS) of the PIC at all times. 

5. All operations will utilize a visual observer (VO). The UAS will be operated within visual line of

sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be

able to communicate verbally at all times. The PIC must ensure that the VO is qualified to

perform the duties required of the VO. 

6. This exemption and the operating documents needed to operate this UAS must be accessible
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during all operations, and if a discrepancy exists between the conditions and limitations in this 

exemption and the procedures outlined in the operating documents, the conditions and

limitations herein will take precedence. 

7. If the approved UAS has undergone maintenance or alterations that affect the UAS operation

or flight characteristics, e.g., replacement of a flight component, it must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights 

may only be conducted by a PIC with a VO and must remain at least 500 feet from other 

people or structures. The test flight must be conducted in such a manner so as to not pose a 

hazard to persons and property. 

8. The operator will be responsible for maintaining and inspecting the UAS to ensure that it is in

an airworthy condition for safe operation. 

9. Prior to each flight, the PIC will conduct a pre-flight inspection and determine the UAS is in a

condition for safe flight. The pre-flight inspection will be used to determine if any potential

discrepancies, e.g., inoperable components, items, or equipment exists. If the inspection 

reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance and/or corrective action has been performed and 

the UAS is determined to be in a condition for safe flight. 

10. I will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life 

limit requirements for the aircraft and aircraft components. 

11. Each UAS operated under this exemption will comply with all manufacturer safety bulletins. 

12. The PIC must hold at least a private pilot certificate or FAA recognized equivalent. The PIC 

must also hold a current FAA airman medical certificate or a valid U.S. driver’s license. The 

PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in 

which the PIC is rated on his or her pilot certificate.

13. I will not permit any PIC to commence operations unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. 

14. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR

§ 61.51(b). During training, proficiency, and experience-building flights, all persons not

essential for flight operations are considered nonparticipants, and the PIC will operate the 

UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations will not be conducted during night as part of this exemption, as defined in14

CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC). 

16. My UAS will not operate within 5 nautical miles of an airport reference point (ARP) as denoted 

in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, 

unless a letter of agreement (LOA) with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. 

17. The UAS will not operate less than 500 feet below or less than 2,000 feet horizontally from a

cloud or when visibility is less than 3 statute miles from the PIC and VO. 

18. If the UAS loses communications or loses its GPS signal, the PIC will initiate a Return to

Home (RTH) to its known takeoff point. Further, the UAS will utilize the manufacturer’s fail

safe flight profile that requires the UAS to initiate a climb to the maximum altitude (400 feet 
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AGL),then proceed to the pre-determined home point, and then initiate a vertical descent to 

landing to avoid potential obstacles along its return path. 

19. The PIC will immediately abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC will not operate the UAS unless (considering wind and forecast weather conditions) 

there is enough available power for the UA to conduct the intended operation and to operate

after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. Low power warning will be set to 25% (termination of operations and 

an immediate return to the takeoff point), and critical power will be 10% (automatic auto land 

sequence is initiated). 

21. All operations shall be conducted in accordance with an ATO (air traffic organization)-issued

COA (certificate of waiver or authorization). I will apply for a new or amended COA if I intend to 

conduct operations that cannot be conducted under the terms of the attached COA. 

22. All UAS operated in accordance with this exemption will be identified by serial number,

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings 

in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

23. All documents and manuals used to ensure the safe operation and flight of the UAS as well as 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time it is operating. These documents and manuals 

will be presented to the Administrator or any law enforcement official upon request. 

24. The UAS will remain clear and give way to all manned aviation operations and activities at all 

times. 

25. The UAS will not be operated by the PIC from any moving device or vehicle. 

26. All flight operations will be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures unless: 

A. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator must ensure that

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, light

operations will cease immediately to ensure the safety of nonparticipating persons.

B. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present an undue 

hazard. The PIC, VO, operator trainees or essential persons are not considered non

participating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted.

Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of

the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web 

site:www.ntsb.gov. 

28. If operations for television filming and production are approved, the following additional

conditions and limitations will apply. 
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29. I must have exemption permits for operations for the purpose of closed-set motion picture and 

television filming. 

30. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption. 

31. At least 3 days before aerial filming, I will submit a written Plan of Activities to the local Flight 

Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities will 

include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted under this 

grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission must be 

made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to

accomplish the operation. 

32. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the

exemption holder’s MPTOM. 

33. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 

45,47, 61, and 91. 

34. The UAS will only operate within a defined boundary area throughout all phases of flight.

Security will be monitored by the operator and designated security personnel. 

35. A preflight briefing will be conducted in regard to the day’s planned UAS operations. All

personnel who will be performing duties within the boundaries of the safety perimeter be 

present for this briefing. Preflight briefing items will include, but are not limited to: 

a. Authorized UAS flight operations, mission plan of activities, and special provisions issued 

by the Flight Standards District Office having jurisdiction over the photo / filming area.

b. Radio communications (if required for operations permitted within 5 miles of an airport).

c. Takeoff procedures.

d. Maneuvering of the UAS to be conducted during the event.

e. Approach and landing procedures.

f. Alternate landing zone in the event of emergency or security breach.

g. Weather and special considerations.

h. Emergency procedures.

i. Safety briefing for participating personnel. 

j. Safety procedures of non-participating persons.

k. Definition of operational boundaries.

l. Regulatory requirements: local, state, or federal.
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m. Any additional limitations or procedures unique to the operations. 

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

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

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b) 

4 C.F.R. Part 21, Subpart H: 

Airworthiness Certificates 14 C.F.R. 

§91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and

limited operating area associated with the aircraft to be utilized by the Applicant, an exemption

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section333 of 

the Reform Act both authorize the FAA to exempt aircraft from the requirement for an

airworthiness certificate, upon consideration of the size, weight, speed, operational capability,

and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the

restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without 

the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. 

including payload, carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored 

by both the operator, pursuant to the Manual’s requirements, and under the requirements and in 

compliance with local public safety requirements, to provide security for the area of operation as is 

now done with conventional filming. The FAA will have advance notice of all operations. These 

safety enhancements, which already apply to civil aircraft operated in connection with motion 

picture and television production, provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates issued under 14 

C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, location 

of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 
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substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or 

pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited,"

"restricted," "light-sport," "experimental," or "provisional," as applicable. 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 sUAV, two-inch 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 sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and 

others working with the sUAV will see the identification of the UAS as “Experimental.” The FAA 

has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the UAS will 

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety 

of current operations by requiring the PIC operating the aircraft to have a private pilot’s license 

rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft 

that carries the pilot and passengers, the UAS is remotely controlled with no souls on board. The 

area of operation is controlled and restricted, and all flights are planned and coordinated in 

advance as set forth in the Manual. The level of safety provided exceeds that provided by a single 

individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks 

associated with the operation of the UAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the 

UAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 

14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining air worthiness.

Given the size of the aircraft and the requirements contained in the Manufacturers Operating

Manual for maintenance and use of safety check lists prior to each flight, an equivalent level of

safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual,

approved manual material, markings, and placards, or any combination thereof. The UAS, given 

its size and configuration has no ability or place to carry such a flight manual on the aircraft, not 

only because there is no pilot on board, but because there is no room or capacity to carry such an 

item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual 

at the ground control point where the pilot flying the sUAS will have immediate access to it. The 
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FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827,and 10700. 

14 C.F.R. § 91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the

safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an

exemption will be needed. The PIC will take all actions including reviewing current weather 

conditions and forecasts, flight time and battery requirements, establishing a clear takeoff and

landing zone, and aircraft performance data before initiating flight. 

14 C.F.R. §91.109: Flight instruction

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. UASs and remotely piloted aircraft, by their design do not have fully functional dual

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

the aircraft via radio communications. The FAA has approved exemptions for flight training

without fully functional dual controls for a number of aircraft and for flight instruction in

experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety can be

achieved as neither a pilot nor passengers will be carried in the aircraft in addition to the small size 

and low speed of the aircraft. 

14 C.F.R. §91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a UAS that is not a helicopter and the exemption requests authority to operate at 

altitudes up to 400 AGL, or not more than 200 above an elevated platform from which filming is 

planned, an exemption may be needed to allow such operations. As set forth herein, except for 

the limited conditions stated in the Manual, the UAS will never operate at higher than 400AGL. It 

will however be operated in a restricted area with security perimeter, where buildings and people 

will not be exposed to operations without their pre-obtained consent. The equivalent level of 

safety will be achieved given the size, weight, speed of the UAS as well as the location where it is 

operated. No flight will be taken without the permission of the property owner or local officials. 

Because of the advance notice to the property owner and participants in the filming activity, all 

affected individuals will be aware of the planned flight operations. Compared to flight operations 

with aircraft or rotorcraft weighing more than the maximum 55lbs.proposed herein and the lack of 

a flammable fuel source, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these small-UAS operations and the 

operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate

altimeter setting available before departure.” As the UAS may not have a barometric altimeter, but 

instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will 

be achieved by the operator, pursuant to the Manual and Safety Check list, by receiving altitude 

information via a digitally encoded telemetric data feed, which downlinks from the aircraft to a 

ground-based on-screen display. This altitude information will be generated by equipment 
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installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, 

or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will 

be established and confirmed for accuracy by the pilot. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly 

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”The battery 

powering a small UAS provides approximately 23 minutes of powered flight. To meet the 30 

minute reserve requirement in 14 CFR §91.151, UAS flights of this type would not be possible. 

Given the limitations on the UAS’s proposed flight area and the location of its proposed operations 

within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable. I believe that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, 

with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed of the small UAS. I believe that an 

equivalent level of safety can be achieved by limiting flights to 23 minutes or 25% of battery 

power, whichever happens first. This restriction would be more than adequate to return the UAS 

to its planned landing zone from anywhere in its limited operating area. Similar exemptions have

been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 

14 C.F.R. §91.203 (a) and (b): Civil Aircraft: Certificates Required

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. A small UAS fully loaded 

weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability 

or place to carry certification and registration documents or to display them on a sUAS. An 

equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the UAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665,9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Requirements and

Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.Given that 

these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will 

not apply to a UAS operated by myself. Maintenance will be accomplished by the operator 

pursuant to the flight manual and operating handbook. As the manufacturer does not provide 
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specific maintenance instructions, maintenance will be “on condition” for all aircraft and each 

aircraft will have a maintenance log. An equivalent level of safety will be maintained because 

small UASs are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will 

be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will 

ensure that the UAS is in working order prior to initiating flight as part of a detailed preflight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator will be the individual most familiar with the aircraft and best suited to maintain the aircraft 

in an airworthy condition to provide the equivalent level of safety. If the operator encounters a 

maintenance issue which cannot be addressed, the UAS will be returned to the manufacturer or a 

qualified repair facility where such repairs or maintenance can be performed. These repairs will 

also be noted in the aircraft maintenance log. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register, should it be determined that publication is needed: 

Applicant (Robert Kennon Williamson) seeks an exemption from the following rules:14 C.F.R. 

§21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) 

(2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1);

91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to commercially operate a small unmanned

aerial system (55lbs or less) in aerial photography and aerial filming operations. Approval of 

exemptions allowing commercial operations of sUASs in the aerial photo and film industry will 

enhance safety by reducing risk. Conventional film operations, using jet or piston power aircraft, 

operate at extremely low altitudes close to the subject being filmed and in near proximity to people 

and structures and present the risks associated with vehicles that weigh in excess of 3000 pounds 

and carry large amounts of fuel. Such aircraft must fly to and from the film location. In contrast, a 

small UAS weighing less than 55 lbs. and powered by batteries eliminates virtually all of that risk 

given the reduced mass and lack of combustible fuel carried on board. The UAS is carried to the 

film set or location and not flown. The small UAS will also carry no passengers or crew and, 

therefore, will not expose them to the risks associated with manned aircraft flights. The operation 

of a small UAS weighing less than 55 pounds, conducted in the strict conditions outlined above, 

will provide an equivalent or increased level of safety supporting the grant of the exemptions 

requested herein, including the exemption of the applicant from the requirements of Part 21 and 

allowing commercial operations. These small, unmanned aircraft operate at slow speeds in close 

proximity to the ground, as well as in a restricted environment. As a result, a small UAS in 

commercial operations is far safer than operations conducted with conventional helicopters or 

aircraft operating in similarly close proximity to structures and personnel. 

In the matter of privacy, all flights will occur over private or controlled access property with the

property owner’s prior consent and knowledge. Filming will be of people who have also

consented to being filmed or otherwise have agreed to be in the area where filming will take

place. 
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In closing, I will ensure that all regulatory requirements are met and/or exceeded in the best 

interests of professionalism and safety. I am committed to this philosophy, and will gladly 

provide feedback and additional data to further the development of this emerging industry. 

If you have any questions or require any additional information, please contact the undersigned

at (731) 609-4432 or bobwill0817@gmail.com. 

Sincerely yours, 

Robert Kennon Williamson (Pilot Certificate 3477943)