Texas State Drone

William Clay Thompson

12225 Greenville Ave. #700

Dallas, TX 75243

June 25, 2015

US Department of Transportation

Federal Aviation Administration

800 Independence Ave. SW

Washington, DC 20591

PETITION FOR EXEMPTION, Requesting relief from the FAA 

modernization and Reform Act OF 2012, public law 112-95 Feb. 14, 2012, 

section 333.

Exemptions Requested for: 

14CFR 21, Subpart H

14 CFR 45.23(b) 

14CFR 61.113(a)&(b)

14CFR 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a) 

91.203(a)&(b), 91.405(a), 91.407(a)(1), 91.409(a)&(b), 91.417(a)&(b)

14CFR, Title 14 Chapter 1 Subchapter D parts 60 thru 67, specifically 61.1 

to 61.429.

Contact Information:

William Clay Thompson

Owner/UAS Pilot

Texas State Drone

12225 Greenville Ave. #700

Dallas, TX 75243

Phone: 214-679-8471

TX Driver’s License: 08663130

clay.thompson@yahoo.com

DJI Phantom 2 Vision Plus

DJI Inspire 1
William Clay Thompson/Texas State Drone, Dallas, TX - Section 333 Exemption Petition 2

Dear Sir or Madam,

I, William Clay Thompson, am writing pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 and 14 CFR Part 11, to request that I, 

William Clay Thompson, owner and operator of Texas State Drone (TSD), and

owner and Pilot in Charge of small unmanned aircraft systems (UAS), specifically 

the DJI Phantom 2 Vision Plus and the DJI Inspire 1, be exempt from the Federal 

Aviation Regulations (FARs) listed above so that Texas State Drone may operate its

small UAS’s commercially in airspace regulated by the Federal Aviation 

Administration (FAA).

I, William Clay Thompson, Pilot in Charge (PIC) and Owner of Texas State Drone 

(TSD) request this exemption under the guidelines of Section 333 specifically as it 

relates to aerial videography and photography (commercial and private real estate, 

community awareness, and nature). Under the terms of this exemption TSD agrees 

to safely fly its UAS's in a safe and lawful manner as it relates to Local, State and 

Federal guidelines as stated within the exemption grant. All UAS's piloted by TSD 

weight less than 55 lbs and fly at speeds below 58 mph (50 knots). TSD agrees to 

operate under any and all guidelines set forth by the FAA now and in the future.

TSD follows current FAA regulations, 400 ft. altitude maximum, line of sight 

(VLOS), daylight only, and airport 5-mile restrictions. In addition TSD uses a 

spotter (VO) and 2-way communication between PIC and visual observer (VO) at all 

times during the flight. All UAS's owned by TSD are equipped with numerous safety 

features including auto return to home and low battery functions that return the 

UAS back to the ground station point of take off. All systems are displayed on 10 

inch monitors (battery levels and performance) in addition to altitude, distance, 

speed and current GPS location on overlay map. All UAS are maintained according 

to manufacturer suggested maintenance schedules by an authorized dealer.

TSD considers air safety one of our paramount duties to the public. TSD performs a 

routine pre-flight inspection before every flight on every UAS before a launch into 

the National Airspace System (NAS). These pre-flight inspections include 

propellers, motors, battery levels, battery history, compass re-calibrations, GPS 

satellite evaluation, electromagnetic conditions, weather and environmental 

surroundings (structures, power lines, population etc.). All of these pre-flight 

inspections are performed according to the published manufacturer guidelines as it 

pertains to the individual UAS.

As the PIC and owner of TSD, I have multiple years and hours flying Remote 

Controlled Helicopters and Quad Copters. I also agree, if exemption is granted, to 

keep a complete flight log (as I currently do) to include all required information as 

laid out in the FAA exemption (time, date, place, conditions, PIC, VO, etc.). As 

owner and PIC at TSD, I will also agree to any required course of study or flight 

evaluations including fees required if any. I also hold a US passport and have been 

vetted and accepted by Transportation Security Administration (TSA), Department 
William Clay Thompson/Texas State Drone, Dallas, TX - Section 333 Exemption Petition 3

of Homeland Security (DHS), and US Department of Immigration and Customs for 

participation in the Global Online Enrollment System (GOES).

The use of TSD’s UAS’s for aerial real estate videography is less costly than a 

helicopter or fixed wing aircraft. For small budget real estate companies and 

average homeowners, the expense of such aerial photography and videography is 

cost prohibitive. It is my objective to provide this valuable marketing tool to better 

enhance the sale of real estate at an affordable price by a trained professional with 

a safety-first mindset. 

Granting Texas State Drone an exemption will not adversely affect safety. The 

public's interest is furthered by minimizing ecological and crash threat by permitting 

aerial video/photo capture through my battery operated UAS's. The consequence 

of my UAS crashing is far less than a full sized helicopter or fixed wing aircraft,

which are heavy, contain combustible fuel and can cause catastrophic devastation 

to the public. TSD’s UAS’s utilize battery power and have no negative impact on 

the environment. 

TSD operates only in reasonably safe environments that are strictly controlled, are 

away from power lines, elevated lights, airports, and actively populated areas. I 

conduct extensive pre-flight inspections and protocols, during which safety is of 

primary importance. I always obtain all necessary permissions prior to operation. I 

have procedures in place to abort flights in the event of safety breaches or potential 

danger. TSD’s safety protocols provide a level of safety equal to or exceeding 

existing rules.

When pilot communication is lost, TSD’s UAS’s are designed to return to the point 

of takeoff, slowly descend, land, and disengage the electric motors (return to home

feature). I and TSD will not operate our UAS’s near airports, hospitals, military 

installations, or police heliports. I am constantly on alert for any manned aircraft 

(personal crafts, police/medical helicopters, etc.) and am prepared to land/abort

immediately to the nearest and safest ground point should a manned aircraft 

approach my location or I suspect manned aircraft may approach near my location.

TSD’s UAS’s are capable of vertical and horizontal operations, and are flown only 

within PIC’s line of sight.

Regarding pilot certification (14CFR, Title 14 Chapter 1 Subchapter D parts 60 thru 

67, specifically 61.1 to 61.429), I, William Clay Thompson, respectfully request the 

FAA grant exemptions from regulations that address general flight rules, pilot 

certificate requirements, manuals, maintenance and equipment mandates. I 

believe that these requirements are unnecessary for pilot controlled drone flight.

Additionally, current FAA proposals have omitted this as a future requirement for 

small UAS's.

In Conclusion: Texas State Drone and William Clay Thompson submit that given 

the size and safeguards of the aforementioned UAS's, TSD would be able to 

perform safe operations greater than envisioned by Congress for the FAA to 
William Clay Thompson/Texas State Drone, Dallas, TX - Section 333 Exemption Petition 4

establish. This exemption would allow TSD to perform safe commercial operations, 

and in doing so benefiting the greater public interest. William Clay Thompson and 

TSD wishes you to consider that as to the size of our UAS's, area and altitudes that 

we fly, this exception would present no risk to our National Security or FAA 

regulated commercial air space. The strict regulation and operating conditions as 

provided in Section 333 of the Reform Act gives the FAA the authority to grant this 

exemption. TSD hopes for a timely consideration as we have made a considerable 

investment in our time and committed finances.

Kindest Regards,

William Clay Thompson

Owner

Texas State Drone

12225 Greenville Ave. #700

Dallas, TX 75243

Phone: 214-679-8471

TX Driver’s License: 08663130

clay.thompson@yahoo.com