Robert Samuels 

Two Rivers Aerial Photography 

313 Dartmouth Avenue 

Fair Haven, NJ 07704 

Robbiesamuels5@gmail.com 

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H 

14 CFR 45.23(b) 

14 CFR 61.113(a) and (b) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a)(1) and (2) 

14 CFR 91.417(a) and (b) 

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

CFR Part 11, Robert Samuels, operator of Unmanned Aircraft Systems (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of 

designated UAS, provided such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, 

would provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including public events, 

cinematography and newsgathering. 

As described fully below, the requested exemption would permit the operation of designated 

UAS as set forth in this document under controlled conditions in the NAS that would be a) limited b) 

controlled c) predetermined and d) safe. Approval of this exemption would increase public awareness of 

UAS operations and enhance safety to aid in fulfilling the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft 

systems in the national airspace system.” 

I plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned aircraft 

(UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a quad-copter 
with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by 

electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. 

Also, given the small size of the UAS involved and the restricted controlled environment within which it 

operates, the applicant fits within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence 

immediately. Also due to the size of the UASs and the controlled areas in which the relevant UASs will 

operate, approval of the application presents no national security issue. Given the following, the grant 

of the requested exemptions is clearly in the public interest: 

Robert Samuels proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for an 

exceptional level of safety to operations. These limitations and conditions to which Robert Samuels 

agrees to be bound when conducting commercial operations under an FAA issued exemption including: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

4. Flights will be terminated at 20% battery power reserve. 

4. Flights will be operated at an altitude of no more than 400 feet AGL 

5. UAS operator will be trained and certified in the proper safety and operations of the UAS. 

6. The UAS will only operate within a controlled area as defined in the Procedures. 

7. The operator will post advisor notice around the controlled area. 

8. The operator will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated as required. 

9. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a predetermined location within the Security Perimeter and land. 

10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and is 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. I look forward to working with your office. Please contact me at any time if additional 

information or clarifications are needed. 

Sincerely, 

Robert Samuels