Collins B. Case

9980 Rail Circle

Pensacola, FL 32507

601 757 0873

Cbc0873@gmail.com

Dear Sir or Madam:

This petition is being submitted on my behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), 

and 14 C.F.R. Part 11, Collins B. Case, a freelance aerial photographer and videographer, applies 

for an exemption from the Federal Aviation Regulations (FARs) listed below to allow for the 

operation of a Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by

the Federal Aviation Administration (FAA) so long as such operations are conducted with and 

under the conditions outlined herein or as may be established by the FAA as required by Section 

333. The requested exemption would permit Collins B. Case to pursue his commercial interests 

in providing services using a small advanced sUAV in the following areas: Education, Land 

Development and Erosion, Construction, Farming, Real Estate, Marketing, 

Management/Surveying, Private and Public Events, Business Promotion, and related Economic 

Development. Collins B. Case has demonstrated the ability to safely and effectively fly the sUAS 

DJI Phantom 3 Standard which will be used for all commercial and private purposes. Collins B. 

Case complies with local ordinances and laws regarding the operation of sUAS and adheres to all 

weather and environmental restrictions or limitations in reference to the operations of sUAS. As 

a certified Federal Aviation Safety Officer, Collins B. Case possesses and utilizes skills

necessary for the safe operations of aircraft such as decision making, assertiveness, mission 

analysis, communication, leadership, adaptability/flexibility, and situational awareness. 

Additionally, Collins B. Case has exemplified the highest standards of aviation safety while

serving in the military as a Naval Flight Officer since 2008.

All flights will occur in compliance with any state or local ordinances or laws regarding privacy.

I, Collins B. Case, am seeking the exemption because I am committed to complying with all of 

the rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate 

the sUAS in the manner that I have described, and for the purposes that I have described. 

Without the exemptions request granted, I would be unable to safely and effectively explore the 

listed sUAS commercial opportunities, and it is my intention to comply with the FAA and obtain

an exemption of the regulations listed below.

The following contains a list of regulations from which I am seeking exemption, and an 

extensive list of responsibilities I assume as operator; it also contains information regarding the 

aircraft, public benefit and safety features, and similar petitions requests granted.

Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a) & (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)
14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 – 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING CONDITIONS, LIMITATIONS, 

AND RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 Standard 

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 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 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 Columbia, 

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 (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. For tethered UAS operations, the tether line must have colored pennants or streamers 

attached at not more than 50 foot intervals beginning at 150 feet above the surface of the earth 

and visible from at least one mile. This requirement for pennants or streamers is not applicable 

when operating exclusively below the top of and within 250 feet of any structure, so long as the 

UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

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

21. 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 5 minutes or with the reserve power recommended by the 

manufacturer if greater.

22. 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 enclosed COA.

23. 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.

24. 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.

25. The UA must remain clear and give way to all manned aviation operations and activities at 

all times.

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

27. 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.

28. 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.
29. 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.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of 

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

14 CFR 21 H: Airworthiness Certificates

Certification Procedures for Products and Parts

Reason for Exception

It has been determined that similar UAS's do not require an airworthiness certificate as granted in 

Exemption No. 11623, 11650, 11664, 12701 and 11734.

14 CFR 45.23 (b): Marking of the Aircraft

These regulations provide that each aircraft must display "N" and the aircraft's registration 

number in letters at least 3 inches high. Additionally, the aircraft must display the word 

"EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or 

pilot station.

Reason for Exception

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the 

UAS will have not entrance to the cabin, cockpit or pilot station on which the work 

"EXPERIMENTAL" can be placed. Given the size of the UAS, two-inch lettering will be 

impossible. The word "EXPERIMENTAL" will be placed on the fuselage in compliance with 

45.29 (f). The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167A.

14 CFR 61.113 (A) 7 {b): Private Pilot Privileges and Limitations

The regulation provides that no person may serve as a required pilot flight crewmember of a civil 

aircraft of the United States, unless that person: (1) has a pilot certificate or special purpose 

authorization issued under this part in that person's physical possession or readily accessible. (2) 

The flight is only incidental to that business or employment. (3) The aircraft does not carry 

passengers or property for compensation or hire.

Reason for Exception

The Petitioner will follow all manufacturers' current training programs and safety manuals. 

Current FAA proposals have omitted this as a requirement for sUAS. These requirements are 

unnecessary for small-sized ground station pilot controlled sUAS flights. PIC will ensure every

aspect of this petition is followed, maintained, and documented in depth across all sUAS 

operations if granted exemption.

Public Benefit and Safety

Each year many people throughout the country waste critical time and resources on inaccurate 

construction, building repair, farming, and land development estimates and bids. The intention 

of this exemption is to gather well documented imagery and photographic analytical data of 

buildings and land in order to more efficiently provide services made possible by sUAS 

technology which requires less risk of injury or death on behalf of construction and land 

surveyors and associate purveyors therein. As a certified Federal Aviation Safety Officer, Collins 
B. Case understands the vital importance of safety as it applies to the aviation environment.

Collins B. Case is petitioning for an exemption to operate a DJI Phantom 3 Standard with GPS 

safety features which limit the height it flies above ground level (AGL), the radius of the 

distance it flies from the operator, and to exclude it from operations within designated Class B, C 

and D airspace including a no-fly zone feature. The DJI Phantom 3 Standard also has a failsafe 

function that is triggered in the event communication is lost between the sUAS and the main 

controller transmitter. At that time, the sUAS will return to its point of takeoff and land safely. If 

the connection is restored, the PIC can regain control of flight and land manually. These 

specifications meet with the Model Aircraft Operating Standards as set below:

 The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and 

will operate at sites that are `sufficient distance' from populated areas within the sterile 

area described in the FOPM. Such operations will ensure that the sUAS will "not create a 

hazard to users of the national airspace system or the public."

 When flying the sUAS within three (3) miles of an airport, airport operators will be

notified and the operator will give the right-of-way to avoid flying in the proximity of 

full-scale aircraft. Maximum flight time for each operation will be 25 minutes.

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserve 

flight time to safely land the sUAS.

 The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 

feet AGL, and not more than 200 feet above an elevated platform from which 

videography is planned.

 Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, 

and the camera operator.

 The sUAS operated by the petitioner weighs less than 3 pounds, including all payloads 

(i.e. camera, lens, and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally.

 Given the small size of the sUAS and the restricted sterile environment, within which it 

will operate, the stated operations adhere to the Reform Act's safety requirements.

Sincerely,

Collins B. Case