To: 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room Wl2-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

From: 

Peter Wagner 

18 Turkey Trot Road 

New Milford, CT 06776 

860-354-9151 

wagner.peter@gmail.com 

Amendment to: 

Public Docket (No. FAA-2015-0978) 

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

"Reform Act") and 14 C.P.R. Part 11, Peter Wagner, an individual, seeks exemption 

from requirements of14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.11; 14 C.F.R. § 91.103; 

14 C.F.R. § 91.105; 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.P.R.§ 91.405(a) and (d); 14 C.P.R.§ 91.407(a)(l); 14 C.F.R. § 

91.409(a)(2); 14 C.P.R.§ 417(a) and (b) to operate an unmanned aerial vehicle 

(UAV) (a DJI Phantom 3 Pro) in support of commercial aerial photography and 

videography of individual commercial, public, and residential properties and 

structures with owners/operators permission and appropriate authorization. 

The request for this exemption is in the Public Interest as there are many consumer 

applications for the services that can be provided by UA V that are currently 

conducted by manned aircraft. Using a UAV for many of these applications creates 

an environmentally friendly, lower cost solution to both the operator and consumer. 

These aircraft can be operated safely, and without significant financial impact to the 

operator or any person or property on the ground in the event of the loss of an 

aircraft. Utilizing these UA V will create a safe and more productive work 

environment, reduce environmental pollution and have a positive impact on the 

local economy, which is in the Public Interest. 

Peter Wagner respectfully request that the FAA grant the following requested 

exemptions: 

14 C.P.R.§ 21, Subpart H; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103;14 C.P.R.§ 91.105; 14 

C.P.R.§ 91.109; 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 14 C.P.R.§ 

91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 14 C.F.R. § 

91.409(a)(2); 14 C.F.R. § 417(a) and (b). 

14 C.P.R. 21, Subpart H: Airworthiness Certificate 

Peter Wagner requests an exemption from 14 C.P.R. 21, Subpart i·L This Subpart 

establishes the procedures for the issuance of an airworthiness certificate. Peter 

Wagner requests an exemption from Part 21, Subpart H because the UAV (DJI 
Phantom 3 Pro) is under 50 pounds (including payload) and meets an equivalent 

level of safety pursuant to Section 333 of the Reform Act due to its small size, light 

weight, and restricted operating environment. 

14 C.F .R 43.11: Records for Inspections 

Peter Wagner requests an exemption from 14 C.P.R. 43.11. This part provides that 

maintenance record entries be maintained, that the inspector list discrepancies, and 

to affix placards to the aircraft. Due to its small size the UAV proposed for use, does 

not have room for placards to be placed in or on it and no inspections for UAV have 

been certified by FAA at the present time. However, as a condition to the grant of the 

exemption, Peter Wagner will perform the inspections and time replaceable items 

recommended by the manufacturer and keep records and log books of all 

maintenance and repairs. 

14 C.F .R 91.103: Preflight Action 

Peter Wagner requests an exemption from 14 C.F .R. 91.103. This regulation 

requires each pilot to take certain actions before flight to insure the safety of flight. 

As FAA approved flight manuals will not be provided for the UAV, an exemption is 

needed. Peter Wagner will follow the manufactures preflight inspection. 

14 C.F.R 91.105: Flight Crewmembers at Stations 

Peter Wagner requests an exemption from 14 C.F .R. 91.105. Peter Wagner requests 

an exemption from 14 C.P.R. 91.105 since this part is not applicable due to the UAV 

carrying no flight crewmembers. An equivalent level of safety will be maintained by 

ensuring the pilot does not change inflight. 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 

Department of Transportation 

Federal Aviation Administration 

Petitioner: Peter Wagner 

Petition of exemption from sections of; 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121,91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

Description of relief sought; 

Peter Wagner seeks an exemption for commercial operation of an unmanned aerial 

vehicle that is under 50 pounds including payload. 

The unmanned aircraft vehicle has an onboard camera system capable of acquiring 

high resolution data. 

Proposed operations will offer real estate aerial photography, videography and 

aerial surveying services for other commercial industries. 

Respectfully submitted,