April 20, 2015 

 Exemption No. 11402 

 Regulatory Docket No. FAA–2015–0149 

Mr. Thomas Ryan Drake 

28388 Maitland Lane 

Santa Clara, CA 91350 

Dear Mr. Drake: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated January 20, 2015, you petitioned the Federal Aviation Administration (FAA) 

for an exemption. The exemption would allow the petitioner to operate an unmanned aircraft 

system (UAS) to conduct video filming and photography by air for public and private use and 

to inspect land for residential, commercial, and industrial structures and property. 

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner. 

Airworthiness Certification 

The UAS proposed by the petitioner is a DJI Phantom Vision 2+. 
2 

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that the relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary. 

The Basis for Our Decision 

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest. 

Having reviewed your reasons for requesting an exemption, I find that— 

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213; 

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Thomas Ryan Drake is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below. 

Conditions and Limitations 

In this grant of exemption, Mr. Thomas Ryan Drake is hereafter referred to as the operator. 
3 

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom Vision 

2+ when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3.The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer. 

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

(AGL). Altitude must be reported in feet AGL. 

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

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

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; electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration 

of the flight. The PIC must ensure that the VO can perform the duties required of the 

VO. 

7.This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. 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 take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
4 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the 

operator must petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS−80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, 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. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property. 

9.The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

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

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

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal 

government. 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. 

14. The operator may not permit any PIC to operate 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. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
5 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

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

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

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

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may 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 with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request. 

17. The UA may not be operated 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight 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. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

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

22. All aircraft operated in accordance with this exemption must 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 must 

be as large as practicable. 
6 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

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 the aircraft is operating. These 

documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

26. All Flight operations must 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, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and 

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 

nonparticipating 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. 

28. 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. 

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply. 

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

as documented in this grant of exemption. 
7 

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must 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 

must 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. 

31. 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. 

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

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

parts 45, 47, 61, and 91. 
8 

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

John S. Duncan 

Director, Flight Standards Service 

 
Thomas	Ryan	Drake	– Section	333	Exemption	Petition

January	20,	2015

U.S.	Department	of	Transportation,	Docket	Operations	

West	Building	Ground	Floor,	Room	w12-140	

1200	New	Jersey	Ave.,	SE	Washington,	DC	20590	

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the	Federal	Aviation	

Regulations	from	14	C.F.R.	61.113(a)&(b);	91.7(a);	91.9(b)	(2);	91.109;119.121;	

91.151(a);	91.405(a);	91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)

Dear	Sir	or	Madam:	

I,	Thomas	Ryan	Drake,	am	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of	

2012	and	the	procedures	contained	within	14	C.F.R.	11,	to	request	that	I,	Thomas	Ryan	

Drake,	an	owner	and	operator	of	small	unmanned	aircraft,	be	exempted	from	the	

Federal	Aviation	Regulations	(“FARs”)	listed	below	so	that	I,	Thomas	Ryan	Drake,	may	

operate	a	small	ultra	light	weight	unmanned	aircraft	system	(“UAS”)	commercially	in	

airspace	regulated	by	the	Federal	Aviation	Administration	(“FAA”) located	in	Southern	

California	(specifically	in	Los	Angeles	and	Ventura	Counties) in	accordance	with	FAA	UAS	

Regulations	&	Policies.

This	exemption	request	is	made	based	on	information	outlined	in	this	petition,	as	well	

as	the	accompanying	DJI	Phantom	Vision	2+	Operators	Manual1 and	Personal	Protocols	

and	Controls2.	The	DJI	Phantom	Vision	2+	UAS	was	selected	because	it	has	a	proven

capability	for	controlled	flight	as	well	as	a	gyro	stabilized	flight	mode,	GPS	aided	

navigation,	a	compass,	blinking	LED’s	on	the	bottom,	a	failsafe	mode	for	returning	

home,	and	prop	guards.	These	devices	are	offered	for	general	sale	around	the	world	and	

have	often	been	used	as	Model	Aircraft	in	the	USA.	In	addition,	I,	Thomas	Ryan	Drake,	

have	flown	UAS’s	in	a	recreational	capacity	since	2013	and	have	adopted	safety	

protocols	and	controlsto	avoid	and	prevent	public	hazard,	as	well	as	manned	aircraft

hazards/catastrophe.	This	will	act	to	further	safety	protocols	exclusive	to	lightweight

UAS's	specific	to	video	and	photography	usage	as	I,	Thomas	Ryan	Drake, record	flight	

data	and	other	information	gained	through	permitted	flight	operations	to share	with	the	

FAA	through	any	required	FAA	reports	to	assist	with	future	protocol	and safety	

regulation.

I.	Contact	Information

Thomas	Ryan	Drake

DBA	six6one	Development

28388	Maitland	Ln.

																																																							 1 Appendix	A	– DJI	Phantom	2	Vision+	Operator’s	Manual 2 Appendix	B	– Personal	Protocols	and	Controls 2 Appendix	B	– Personal	Protocols	and	Controls
Thomas	Ryan	Drake	– Section	333	Exemption	Petition

Santa	Clarita,	CA

Mobile:	(661)	313-5858

Email:	drake@six6one.com

II.	Information	regarding	the	Phantom	2	Vision+	UAS

Specifically,	the	UAS	is:	

An	ultra	lightweight battery	operated	4-motor	rotorcraft	in	the	form	of	a	quadcopter	

that	takes	off	and	lands	vertically,	manufactured	by	DJI,	Model	Phantom	2 Vision+,	with	

the	following	equipment:	

• An	on-board	flight	computer	with	GPS	navigation	and	location	ability	that	

receives	signals	for	flight	controls	from	a	ground-based	transmitter/controller;	

• An	integrated	on-board	camera	capable	of	capturing	imagery	in	the	form	of	full	

color,	high	definition	still	photos	and	video;	

• An	on-board	telemetry	system	that	delivers	flight	data	from	the	on-board	flight	

computer	to	the	on-board	radio	transmitter	including	altitude	AGL,	horizontal	

and	vertical	speed,	compass	direction	of	flight	and	direction	back	to	its	launch	

site;	

• A	600mW,	5.8GHz	on-board	radio	transmitter	that	transmits	live	video	from	the	

on-board	camera	plus	all	the	flight	data	from	the	telemetry	system	described	

above;

The	Ground	Station	Includes:	

• A	Pilot	in	Command	(PIC)	in	operational	control	of	a	flight	operation	from	

beginning	to	end	and	who	controls	the	UAS	while	in	the	air;	

• A	100mW,	2.4GHz	radio	transmitter/controller	operated	by	the	PIC	to	control	

the	UAS	while	in	flight;	

• A	radio	receiver	receiving	live	video	and	flight	data	from	the	on-board	camera	

and	computer	projects	it	all	together	onto	a	screen	for	the	PIC	to	view	during	

flight;	

• A	Visual	Observer	(VO)	is	a	person	who	provides	a	second	pair	of	eyes	to	visually	

track	the	UAS	while	in	flight.	

III.	Proposed	Operations

I,	Thomas	Ryan	Drake,	intend to	use	UASs in	two	areas.	First,	I	seek an	exemption	to	

perform	video	filming	and	photographing	by	air	for	public	and	private	use. Second,	I will	

employ	UAS’s	to	inspect	land,	residential	commercial	and	industrial	structures and	

property.
Thomas	Ryan	Drake	– Section	333	Exemption	Petition

Specifically,	I will	use	UASs	which	are	equipped	with	cameras	and	sensors,	in	order	to	

engage	in	the	following	commercial	activities in	Los	Angeles	and	Ventura	Counties:	

(a)	Video	filming	by	air	and	photographing	for	public	and	private	purposes,	

including:	television,	cinematography,	advertising	or	promotions. Filming	and	

Photography	will	only	be	conducted	with	permission	and	under	contract	with	

registered	owners	or	with	any	local	government	authority	and	only	when	safe	to	

do	so.

(b)	Video	filming	by	air	and	photographing	to	support	professional	operations	in	

engineering,	land	surveying and	development,	architecture,	real	estate	and	

other	related	professional	activities.	Filming	and	Photography	will	only	be	

conducted	with	permission	and	under	contract	with	registered	owners	or	with	

any	local	government	authority	and	only	when	safe	to	do	so.

(c)	Inspection by	air	of	infrastructure	such	as	bridges,	highways,	photovoltaic	

power	stations,	and	pipelines.	These	inspections	will	only	be	done	under	

contract	and	permission	with	any	registered	owners	or	with	any	local	

government	authority	and	only	when	safe	to	do	so.

(d)	Inspection	by	air	of	land	and	residential,	commercial	and	industrial	

structures,	only	under	contract	and	permission	with	any	registered owners	or	

with	any	local	government	authority	and	only	when	safe	to	do	so.

(e)	Support	provided	to	search	and	rescue	operations	and	reconnaissance	in	

cases	of	need,	emergency	or	natural	disasters	only	when	government	authorities	

have	requested	it	by contract	or	donation	and	only	when	safe	to	do	so.

IV.	Relevant	Statutory	Authority	

This	Petition	for	Exemption	is	submitted	pursuant	to	Section	333(a)	through	(c)	of	the	

FAA	Modernization	and	Reform	Act	of	2012	("Reform	Act").	Congress	has	directed	the

FAA	"to	safely	accelerate	the	integration	of	civil	unmanned	aircraft	systems	into	the	

national	airspace	system."	Pursuant	to	Section	333	of	the	Reform	Act,	the	FAA	

Administrator	is	to	permit	unmanned	aircraft	systems	to	operate	in	the	National	Air	

Space	("NAS")	where	it	is	safe	to	do	so	based	on	the	following	considerations:	

• The	UAS’s	size,	weight,	speed	and	operational	capability;	

• Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and

• Operation	of	the	UAS	within	the	visual	line	of sight	of	the	operator.	

Additionally,	the	FAA	Administrator	has	general	authority	to	grant	exemptions	from	the	

agency's	safety	regulations	and	minimum	standards	when	the	Administrator	decides	a	

requested	exemption	is	in	the	public	interest.	See	49	U.S.C. §	106(f)	(defining	the	
Thomas	Ryan	Drake	– Section	333	Exemption	Petition

authority	of	the	Administrator);	49	U.S.C.	§	44701(f)	(permitting	exemptions	from§§	

44701(a),	(b)	and§§	44702-44716,et	seq.).	A	party	requesting	an	exemption	must	

explain	the	reasons	why	the	exemption:	(1)	would	benefit	the	public	as	a	whole,	and	(2)	

would	not	adversely	affect	safety	(or	how	it	would	provide	a	level	of	safety	at	least	

equal	to	the	existing	rules).	See	14	C.F.R.	§	11.81	(petitions	for	exemption).

V.	These	Proposed	UAS	Operations	Meet	the	Requirements	of	Section	333	of	the	

Reform	Act	

The proposed	operations	in	this	Petition	for	Exemption	qualify	for	expedited	approval	

pursuant	to	Section	333	of	the	Reform	Act	as	each	of	the	statutory	criteria	and	relevant	

factors	are	satisfied.	

VI.	Approval	is	Warranted	Based	on	the	UAS	Size,	Weight,	Speed,	and	Operational	

Capability	

I,	Thomas,	Ryan	Drake,	will	employ	the	DJI	Phantom Vision 2+	quadcopter for	the	

operations	specified	in	this	Petition	for	exemption.	

• The	Phantom	2	Vision+ UASs	have	a	maximum	take-off	weight	of	less than	5

pounds

• Flight	speed	will	not	exceed	15 miles	per	hour,	and	it	will	not	be	flown	in	

controlled	airspace	or	at	an	altitude	that	exceeds	300	feet	AGL.	

• All	flights	will	be	flown	in	such	a	manner that	they	can	be	safely	terminated	with	

a	reserve	battery	power	of	no	less	than	20%	of	the	battery's	maximum	charge.	

• The	DJI	Phantom	2	Vision+ UAS	does not	carry	any	flammable	propellant	or	fuel.	

• The	Phantom	2	Vision+ UAS	has	an	integrated	GPS	system	that	calculates	the	

UAS’s	position	and	height	and	relays	that	information	via	a	secure	connection	to	

the	operator.	

• The	Phantom	2 Vision+ UAS	contain	a	failsafe	mode	if	its	connection	to	the	

remote	control	is	lost,	and	this	system	permits	the	UAS	to	return	to	a	

predetermined	location	and land	without	injury	or	damage.

• For	additional	safety,	the	Phantom	2	Vision+ will	be	retrofitted	with	prop	guards.	

VII.	Approval	is	Warranted	Based	on	the	Operational	Restrictions	Set	Forth	in	the	

Operations	Manual.	

DJI's	operators	manual3 and	the	Personal	Protocols	and	Controls4 contain	all	of	the	

procedures	and	limitations	necessary	to	successfully	perform	the	operations	specified	in	

this	Petition	for	Exemption.	

																																																							 3 Appendix	A

4 Appendix	B
Thomas	Ryan	Drake	– Section	333	Exemption	Petition

VIII.	Public	Interest

The	public	interest	will	be	served	by	granting	Thomas	Ryan	Drake	a Petition	for	

Exemption in Los	Angeles	and	Ventura	Counties.	Congress	has	established	a	national	

policy	that	favors	early	integration	of	UASs	into	the	NAS	in	controlled,	safe	working	

environments	such	as	those	proposed	in	this	Petition.	In	addition,	the	public	also	has	an	

interest	in	reducing	the	hazards	associated	with	alternate	methods	of	conducting	similar	

operations.	Currently	operations	are	conducted	using	teams	that	physically	climb	onto	

structures	using	ladders,	using	low	flying	helicopters	or	aircraft,	are	extremely	cost	

prohibitive	or	are	simply	not	available	by	traditional	means.	By	using	UAS,	exposure	to	

physical	hazards	will	be	reduced	by conducting	the	operation	while	remaining	safely	on	

the	ground.	

Additionally,	the	intended	uses	of	the	Phantom	2	Vision+ UAS	as outlined	in	this	

document	have	identifiable	safety	benefits	that	include	reducing	the	danger	and	

emissions	associated	with	full	size	helicopters. UAS	have	no	fuel	to	ignite	or	explode,	no	

crew,	add a	greater	degree	of	flexibility,	supplement the	current	capabilities	offered	by	

manned	aircraft,	and	public	interest	for	a	ground	impact	of	a	small	lightweight	UAS	is	

further	minimized	from	an	ecological	and	safety	standpoint.	

IX.	A Summary	The	FAA	May	Publish	in	the	Federal	Register:

A.	14	C.F.R.	91:	Airworthiness	Certificates,	Manuals	and	The	Like.

14	C.F.R.	91.7(a)	I,	Thomas	Ryan	Drake,	will	ensure	the	UAS	is	in	airworthy	

condition	based	on	compliance	with	the	Phantom	2	Vision+	operating	

documents	prior	to	each	flight.

14	C.F.R.	§	91.121	Relief	is	requested	considering	the	limited	altitude	of	

proposed	operations.

B.	14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC.

Pursuant	to	14	C.F.R.	§ 61.113	(a),	The	FAA	has	previously	declared	that	

additional	manned	airship	experience	of	a	commercially	certified	pilot	would	not	

correlate	to	the	airmanship skills	necessary	for	similarly	proposed	operations	in	

previously	issued	exemptions	to	this	regulation	through	Exemption	Nos.	11062	

and	11138.

Pursuant	to	14	C.F.R.	§	61.113	(b),	The	stick	and	rudder	controls	of	the	typical	

aircraft	one	would	be	trained	on	to	achieve a	private	pilots	license	are	

completely	different	than	that	of	a	small	UAS.	Additionally, the	FAA does	not	

require	manned	ultralight	vehicle	PICs	to	meet	any	aeronautical	knowledge,	age,	

or	experience	requirements	or	to	have	airman	or	medical	certificates (as	
Thomas	Ryan	Drake	– Section	333	Exemption	Petition

outlined	in	14	C.F.R.	§	103). Ultralight	vehicles	can	weigh	more	than	500	pounds	

than	the	Phantom	2	Vision+,	can	carry	up	to	5	gallons	of	combustible	fuel,	and	fly	

at	speeds	close	to	double that	capable	by	the	Phantom	2	Vision+.	Due	to	these	

facts, and	in	the	absence	of	a	specific	UAS	Pilot	License, I	submit	that	prior	to	any	

commercial	operations	I,	Thomas	Ryan	Drake,	will	obtain	a	Student	Pilot	

Certificate	and	complete	a	basic	aviation	introduction	course, with	45 minutes	of	

logged	flight	time,	applied	by	a	certified	flight	instructor. In	addition	I	submit	32	

plus	hours	of	UAS	logged	flight	time	I	have	acquired	over	the	past	two	years5.

D.	14	C.F.R.	91.119 (c):	Minimum	Safe	Altitudes.

14	C.F.R.	§	91.119	(c)	I,	Thomas	Ryan	Drake,	will	ensure	that	all	persons	and	

objects	not	essential	to	flight	operations	must	remain	500	feet	away	from	

operations.	In	addition	to	visual	monitoring	of	the	area,	a	traffic	cone	and	

warning	sign6 alerting	persons in	the	area	will	be	placed	at	the	operation	ground	

station.	To	protect	objects	and	personnel	essential	to	flight	operations	the	

Phantom	2	Vision+	will	be	fitted	with	propeller	guards	and	safety	wire7 to	

minimize	potential	hazards.

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

14	C.F.R.	91.151	(c),	I,	Thomas	Ryan	Drake,	will	ensure	that	each	individual	flight	

will	not	begin	unless	there	is	enough	power	to	fly	to	the	first	point	of	intended	

landing	and	land	the	UA	with	30%	battery	power	remaining.	In	addition,	each	

individual	flight	will	last	no	longer	than	20	minutes,	5	minutes	less	than	the	

manufacturer	stated	25	minutes	of	flight	time.

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

The	above-cited	Regulations	require,	amongst	other	things,	aircraft	owners	and

operators	to	“have	[the]	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.	

.	.	.”

These	Regulations	only	apply	to	aircraft	with	an	airworthiness	certificate.	They	will	not,

therefore,	apply	to	my,	Thomas	Ryan	Drake’s,	UAS.	However,	as	a	safety	precaution	I	

inspect	my UAS per	operating	documents	before	and	after	each	flight.

																																																							 5 Appendix	C – Drake	UAS Flight	Logs 6 Appendix	D – Warning	Sign 7 Appendix	E – Phantom	2	Prop	Guard	Attachment	Instructions
Thomas	Ryan	Drake	– Section	333	Exemption	Petition

X.	Conclusion	

This	Petition	for	Exemption	satisfies	the	criteria	articulated	in	Section	

333	of	the	Reform	Act	of	2012	including	weight,	speed,	operating	capabilities,	proximity	

to	airports	and	populated	areas,	operation	within	visual	line	of	sight	and	national	

security.	Additionally,	the	Petition	provides	more	than	adequate	justification	for	the	

grant	of	the	requested	exemptions	to	permit	Thomas	Ryan	Drake	to	operate	a	Phantom	

Vision	2+ Plus	UAS in	Los	Angeles	and	Ventura	Counties for	the	operations	specified	

herein.	

Granting	the	exemption	will	benefit	the	public	interest	as	a	whole	in	several	ways,	

including	(1)	significantly	improving	safety	and	reducing	risk	by	alleviating	human	

exposure	to	danger,	and	(2)	improving	the	quality	of	services	and	decreasing	operating	

costs	compared	with	conventional	flight	operations.	

Very	Respectfully,	

Thomas	Ryan	Drake

28388	Maitland	Ln.

Santa	Clarita,	CA	91350

drake@six6one.com