Regulations from certain parts of the FARs. 

Dear Sir or Madame, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Jason Hoffman, photographer, hereby applies for an exemption from the listed Federal 

Aviation Regulations ("FARs") to allow him to operate a small Unmanned Aircraft System ("UAS") under 

the conditions and limitations set forth in this Petition. 

The proposed exemptions, if granted, would allow Petitioner to operate small, camera-mounted 

unmanned aircraft systems ("UAS") weighing 55 pounds or less for the purpose of aerial filming of 

motion pictures, music videos, web videos, corporate videos, television programs and commercials, and 

still photography. The requested exemption would permit the operation of small, unmanned and 

relatively inexpensive sUAS under controlled conditions in airspace that is (1) limited, (2) predetermined, 

and (3) would provide safety enhancements to the already safe photography operations presently using 

manned helicopters and airplanes in Nashville. 

Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator's 

responsibilities to " ... establish requirements for the safe operation of such aircraft systems in the 

national airspace system." Section 333(c) of the Reform Act." 

The name and address of the applicant is: Jason Hoffman P.O. Box 330526 Nashville, TN 37203 

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 
14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b) 

The Appendix describes the FARs from which an exemption is requested and summarizes the 

justification for each requested exemption. 

The Petition is submitted to fulfill Congress' goal under Section 333(a) through (c) of the Reform Act, 

which directs the Secretary of Transportation to consider whether certain unmanned aircraft systems 

may operate safely in the national airspace system (NAS) before completion ofthe rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Administrator must determine 

which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national 

security in light of the following: 

• 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 visual line of sight of the operator 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles "may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

system." ld. § 333(c) (emphasis added). 

The Secretary has delegated his aviation authority to the Administrator of the FAA. 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory 

requirements for civil aircraft, a term defined under §40101 of the Act, which includes sUASs. The 

Administrator may grant an exemption from a requirement of a regulation prescribed under subsection 

(a) or (b) of this section or any sections 44702-44716 of the Federal Aviation Act if Administrator finds 

the exemption in the public interest. 49 U.S.C. § 44701(f) See also 49 USC§ 44711(a); 49 USC§ 44704; 

14 CFR §91.203 (a) (1). 

The petitioner has over fifteen years of experience as a digital photographer, both as a profession and 

hobby, and has been a helicopter and airplane RC enthusiast without incident for over twelve years. The 

wide availability of small Unmanned Aircraft Systems, also known as "microdrones," capable of carrying 
Currently, a number of people, some professional colleagues and potential future clients, have been 

made aware of Petitioner's accomplishments and have seen the results and are requesting Petitioner to 

undertake additional microdrone photography for compensation. 

He has been advised that this is not now permitted unless he obtains special permission from the FAA. 

Many competitors of Petitioner are actively flying sUAS to conduct aerial photography for commercial 

purposes, notwithstanding the FAA's stated prohibition. He also notes and has read the congressional 

mandate in sections 332 and 333 of the FAA Revitalization and Reform Act of 2012 that the FAA move 

quickly to accommodate the economic and societal benefits that can result from widespread 

deployment of sUAS technology. Accordingly, Petitioner applies for authorization under the Federal 

Aviation Act, and the FARs rules to undertake the following activities for commercial purposes. Unless 

the Petition is granted, Petitioner will be at a significant competitive dis-advantage if he, as he prefers, 

complies with FAA policy. 

Vehicle 

The Petitioner will fly various small, camera-mounted unmanned aircraft systems ("UAS") weighing 55 

pounds or less, at a speed no greater than 50 knots. This vehicle has built in capability to limit the height 

it flies above the ground, to limit the radius of the distance it flies from the operator, and to exclude it 

from class B, C, and D airspace. The vehicle also has the built-in capability to return to the launching 

point if the wireless control link is interrupted or if the operator attempts to exceed any of the height, 

radius, or airspace limitations programmed into it. 

The vehicle weighs about five pounds empty and has a maximum gross weight of approximately twenty 

pounds. It has a top speed of about 30 knots, carry neither a pilot nor passenger, carry no explosive 

materials or flammable liquids, and operate exclusively within a predetermined area. It has four fixed 

pitch rotors, thrust from which is varied by changing RPM . It is powered by a lithium polymer battery. 

Flight Profile 

The petitioner will not fly UAS above 400 feet above ground level, or more than 1500 feet away from 

him. He will carefully preflight check the vehicle before each mission to assure that its navigation system 

are properly calibrated and that any included return-to-home features, altitude, and radius limitations 

work. 

He will operate the vehicle for aerial photography missions only in the early morning hours and other 

times when few people are out in the public. He will operate it only over largely unpopulated areas 

where the potential of uncontrolled descent to cause injury or damage is lowest. 
 Over open water in marinas, anchorages, and rivers amongst and surrounding the city of Nashville 

• Over lines of railroad and rail classification yards 

• Over metropolitan Nashville parks 

• Over nonresidential and noncommercial large-scale industrial areas 

• Over private property when he has been commissioned by the person in legal possession of the 

property to do so 

• Over public or private events petitioner is hired as photographer. 

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act 

relating to size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security. The Petition justifies grant of the requested 

exemptions allow the Petitioner to obtain aerial photography with his microdrone. 

Respectfully submitted, 

14 CFR § 45.23{b) 

14 CFR Part 21 

14 CFR § 61.3 

14 CFR § 91.7 {a) 

APPENDIX 

Requirement to display 

registration number on vehicle 

Aircraft certification 

requirements and procedures 

Requirement for pilot 

certificate 

Airworthiness requirement 

Insufficient space on vehicle 

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 

Part 61 requirements designed 

for manned aircraft, not sUAS; 

petition describes training for 

sUAS o erator 

Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 
g

altimeter 

14 CFR § 91.203 (a) & (b) Requirement for registration No one aboard to read 

and airworthiness certificates certificates 

to be onboard 

14 CFR § 91.205{b) Cockpit instruments No one aboard to read ::~:· r..- -~~·l4~~·:.:tHR•i l~1i~12:1'2~~: ~li1:1!1 i~: ~_;i~:;:?c! ( ~"'l~L.;,, I 'liTil.'1 u I II [ ·:m;o ~,~¢7i-;-.. ·:t:c3~~J; 14 CFR § 91.215 Transponder requirement Vehicle has insufficient useful 

load; will be operated below 

ATC radar coverage 

14 CFR § 91.405 (a) Inspection requirements Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 

14 CFR § 91.407{a) {1) Inspection approval Designed for manned aircraft; 

requirements not suitable for off-the-shelf 

sUAS 

14 CFR § 91.409 (a) {2) Airworthiness inspection Designed for manned aircraft; 

not suitable for off-the-shelf 

sUAS 

14 CFR § 91.417 (a) & {b) Maintenance records Designed for manned aircraft; 

requirements not suitable for off-the-shelf 

sUAS