U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12B140 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Petition for Exemption Under 14 CFR § 11.81. to Allow Commercial 

Use of Unmanned Aircraft Systems 

Petitioner: 

Michael Robbins 

4450 El Centro Road #416 

Sacramento, CA 95834 

310-866-0318 

mostey@gmail.com 

To Whom It May Concern, 

Prepared By: 

Sam Estrin 

Drone Universities 

10444 Cheviot Court 

San Diego, CA 92126 

310-613-0562 

sam.estrin@droneuniversities.com 

http:/ fdroneuniversities.com 

This application is substantially based on the FAA's findings in Exemption No. 

11351 granted to Corp on April17, 2015, and in reliance on the analysis provided 

therein. 

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

exemption from: 

a. FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, 

Section 333 

b. 14 CFR Part 21, subpart H 

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

d. 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 

©Copyright 2015, Drone Universities, All Rights Reserved. Revision 1 July 9 th, 2015 
X. 91.417 

2. Relief sought: 

a. Michael Robbins wishes to operate small Unmanned Aircraft Systems 

(sUAS) for commercial purposes to include (but not be limited to) 

videography, cinematography, photogrammetry, industrial 

inspections and analyses. This relief is sought because law currently 

prohibits commercial use of sUAS unless performed under an 

exemption. 

b. This exemption will cover use of the following airframes, all of which 

will weigh less than 55 pounds including payload and energy sources: 

i. DJI Phantom FC40 

ii. D JI Phantom 2 

iii. D JI Phantom 3 

iv. Other models to be added by future amendment to this 

exemption. 

3. Public benefit: 

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., power line 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. Reduces environmental impact by eliminating sources of 

hydrocarbon emissions from manned aircraft. 

4. Safety not adversely affected: 

a. 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 

Robotic Skies (or 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 flight operations will be conducted by at least two individuals (PIC 

and observer) who will maintain verbal communication capability 

with each other at all times during the flight, and who will remain 

stationary on the ground during the flight operations: 

i. A Pilot In Command (PIC) who possess the following 

credentials: 

1. An Airman Certificate issued under 14 CFR 61 (private 

pilot license) screened by the TSA 

2. A Third Class medical certificate issued under 14 CFR 

67 

©Copyright 2015, Drone Universities, All Rights Reserved. Revision 1 July 9 th, 2015 
3. A bi-annual flight review under 14 CFR 61.56 

4. A certificate of competency for UAS issued by Drone 

Universities, UMEX or equivalent certification 

5. At least 200 cycles and 25 hours of flight experience in a 

UAS rotorcraft (or UAS fixed-wing in the case of fixedwing flight operations under this exemption). Such 

cycles and hours may be gained during flights under 

this exemption if a safe distance is maintained from 

persons in accordance with 14 CFR 91.119 

6. At least 5 hours of flight experience and 3 takeoffs and 

landings in make and model being flown in the prior 90 

days. Such cycles and hours may be gained during 

flights under this exemption if a safe distance is 

maintained from persons in accordance with 14 CFR 

91.119 

ii. A Visual Observer 

m. A Sensor Operator (whenever necessary) 

d. All flight operations will be conducted in accordance with valid 

Certificates of Authorization 

e. All flight operations will comply with the following: 

i. The manufacturers' Aircraft Flight Manuals and Operation 

Guidelines 

ii. Michael Robbins flight operations policies including lost 

communication and other emergency and safety procedures. 

iii. Conducted in VMC conditions during daylight hours. 

iv. PIC and VO will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any) 

and safety risk assessments will be conducted prior to each 

flight. 

vi. Flight altitudes will remain below 400 feet above ground level. 

vii. Flight ground speeds will not exceed 50 knots. 

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

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

ix. Not be made near persons as required in 14 CFR 91.119 and 

not over persons on the ground without their prior permission. 

x. Each flight will be logged in both the PIC's logbook and the 

aircraft logbook 

xi. Not exceed 7 5% of the battery or fuel capacity of the aircraft, 

or 30 minutes, whichever occurs first. 

xii. Any incidents will be reported to NTSB within 24 hours of 

occurrence. 

xiii. Michael Robbins will maintain liability insurance of at least 

$1,000,000 issued by a major aviation insurance underwriter. 

xiv. Any applicable local FSDO requirements. 

©Copyright 2015, Drone Universities, All Rights Reserved. Revision 1 July 9 th, 2015 
xv. All other applicable regulations concerned with the operation 

of aircraft. 

f. Aircraft will use 2.4 GHz for control of the aircraft, and 5.8 GHz for 

sending data with well-defined and tested lost link procedures. 

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

Sincerely, 

Michael Robbins 

07/09/2015 

©Copyright 2015, Drone Universities, All Rights Reserved. Revision 1 July 9th, 2015