Todd E Andrews (UAVKC) Belton, Mo – 

Section 333 Exemption Petition 

 

December 1, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 

91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Ma’am, 

 I, Todd E Andrews (UAVKC), am writing pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, 

Todd E Andrews (UAVKC), an owner and operator of small unmanned aircraft, be 

exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, Todd E 

Andrews (UAVKC), may operate my small ultra lightweight unmanned aircraft system 

(“UAS”) commercially in regulated airspace by the Federal Aviation Administration (“FAA”). 

 Following exemption and approval by the FAA, I, Todd E Andrews (UAVKC), will 

primarily use my professionally built DJI Inspire 1, DJI Phantom 3, and Custom built RSD X8 

and RSD Y6 UAS equipped with cameras for the following applications: Closed-Set Film 

Operations on Film and Television Productions, as well as Aerial Videography/ 

Cinematography to safely enhance Films and commercials; augmentation of real estate 

listing videos; and the creation of visual and topography layout videos for search and rescue 

(SAR) missions for state and local agencies, education, agricultural inspections and building 

and construction zone inspections. 

 My, Todd E Andrews (UAVKC)’s, exemption request would permit the operation of ultra 

lightweight, unmanned (i.e. piloted by remote control) UAS’s for the development of 

community and government use videos, permissible within property boundaries for 

individual homeowners and within in tightly controlled, limited airspaces predetermined in 

areas away from the general public, airports, heliports and vehicular traffic. Currently, similar 

lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists 

with no safety plan or controls in place to prevent catastrophe. Furthermore, it is my intent to 

assist future FAA safety protocols and regulations exclusive to lightweight UAS's for specific 

video and photography usage by sharing information with the FAA as I, Todd E Andrews 

(UAVKC), record flight data and other pertinent information gained through permitted flight 

operations. 

 In addition, granting my, Todd E Andrews (UAVKC)’s, exemption request will comply 

with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate 
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UAS's into the national airspace system, but to “...establish requirements for the safe 

operation of such aircraft systems [UAS's] in the national airspace system” under 

Section 333(c) of the Reform Act specific to the use of UAS's for real estate/realtor 

purposes, educational videos, Search and Rescue, land/trusts inspections, agricultural field 

monitoring, film/video productions, closed-set motion picture film operations and television, 

and structure inspections, to aid state and local agency’s. 

 Further I, Todd E Andrews (UAVKC), will conduct my operations in compliance with the

protocols described herein or as otherwise established by the FAA. For the reasons stated 

below, I, Todd E Andrews (UAVKC), respectfully request the grant of an exemption 

allowing me to operate ultra lightweight, remote controlled UAS’s to aid academic 

community awareness, to benefit/stimulate attraction to the Honolulu, Hawaii area and to 

enhance personal and public video feeds. A grant that will ultimately allow UAS’s to play a 

more positive role in our local community by increasing employment opportunities, 

heightening security measures and decreasing government expenditures by reducing the 

need for heavier manned aircraft, containing costly, combustible fuel- a potential public 

hazard in and of itself. 

I. Contact Information: 

 Todd E Andrews 

 UAVKC 

 505 East 165th Street 

 Belton, Mo 64012 

 Phone: 816-529-8374 

 todd@uavkc.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

Todd E Andrews (UAVKC) Requests Exemption are: 

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The 

size, weight and enclosed operational area of my, Todd E Andrews (UAVKC)’s, UAS’ 

permits exemption from Part 21 because my UAS meets (and exceeds) an equivalent level 

of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt 

aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 

(f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

UAS's from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. My, 

Todd E Andrews (UAVKC)’s, current and projected UAS meet or exceed each of the 

elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this 

Regulation is inapplicable. 
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14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on 

board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. 

An equivalent level of safety will be achieved by maintaining a safety/flight manual 

delineating areas of where safety can be defined. 

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS 

“geofencing” 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining any such required certifications and 

registrations by me, Todd E Andrews (UAVKC). 

B. 14 C.F.R. § 45.23: Marking of The Aircraft. 

Applicable Codes of Federal Regulation require aircraft to be marked according to certain 

specifications. My UAS can be marked with the appropriate “N” number once this “N” 

number has been given. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. 

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial 

operations. I, Todd E Andrews (UAVKC), The sUAS Pilot in Command must possess at 

least a sport pilot certificate and a driver's license. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate 

as outlined in 14 C.F.R. § 61. 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate 

at an altitude greater than 300ft AGL; safely below the standard of 400 AGL. I, Todd E 

Andrews (UAVKC), will however operate my UAS in safe areas away from public and 

traffic, providing a level of safety at least equivalent to or below those in relation to minimum 

safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an equivalent 

or higher level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft 

with an airworthiness certificate. They will not, therefore, apply to my, Todd E Andrews 

(UAVKC)'s, UAS. However, as a safety precaution I inspect my UAS before and after each 

flight. 
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III. The Extent of relief Todd E Andrews (UAVKC) Seeks and the Reason He Seeks 

Such Relief: 

 I, Todd E Andrews (UAVKC), submit this application in 

accordance with the Reform Act, 112 P.L. 95 §§ 331-334, seeking relief from any currently 

applicable FARs operating to prevent me, Todd E Andrews (UAVKC), conducting 

commercial cinematic, academic and other flight operations within the national airspace 

system. The Reform Act in Section 332 provides for such integration of civil unmanned 

aircraft systems into our national airspace system as it is in the public’s interest to do so. My, 

Todd E Andrews (UAVKC)’s, ultra lightweight UAS meets the definition of “small 

unmanned aircraft” as defined in Section 331 and therefore the integration of my ultra light 

weight UAS is expressly contemplated by the Reform Act. I would like to operate my ultra 

lightweight UAS prior to the time period by which the Reform Act requires the FAA to 

promulgate rules governing such craft. Thereby, providing direct experience and valuable 

information for formal regulation that can be administered uniformly to all related UAS aerial 

video and photography. The Reform Act guides the Secretary in determining the types of 

UAS's that may operate safely in our national airspace system. Considerations include: The 

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be operated 

near airports or heavily populated areas; and, Whether the UAS will be operated by line of 

sight. 112 P.L. 95 § 333 (a). 

Each of these items reflect in favor of an exemption for me, Todd E Andrews (UAVKC). My 

UAS’s utilize eight (8) or less rotating propellers for balance, control and stability. My UAS’s 

are equipped with the following via video and data telemetry: 

1) Altimeter 

2) Attitude indicator 

3) Ground Speed indicator 

4) Magnetic compass 

5) Heading indicator 

6) Vertical speed indicator 

7) Course deviation indicator 

8) Radio magnetic indicator 

9) GPS location 

10) Battery consumption and Battery Left with approximate time. 

11) Loiter and circle mode. 

12) Auto safety or RTL ( Return To Launch) 

13) Auto landing technology. 

Each UAS weighing less than thirty (35) pounds (far below the maximum 55 pound limit); 

Including camera(s) with or without gimbal (a camera stabilizer). I, Todd E Andrews 

(UAVKC), considers safety as foremost with each flight. My small unmanned aircrafts are 

designed to hover in place, circle in a specific place or loiter via GPS, and can be operated 

in winds up to 30.4 knots (35mph) wind. For safety, stability and fear of financial loss I will 

not fly in winds exceeding 21.7 knots (25 mph). Built in safety systems include a GPS mode 

that allows my UAS to hover/circle in place or land when radio controls are released. 

With three (3) modes to choose from, I will fly with the modes safest to complete the videos 

for aerial videography/photography and have the ability to choose the safest, most reliable 

and stable mode to prevent accident and hazard. When pilot communication from the radio 

control is lost, UAS is designed slowly descend to point of takeoff and or to land at point of 
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launch after ascending to a pre-set altitude to ensure the UAS will clear any obstacles that 

may be between the takeoff point and the current position of the UAS. This failsafe altitude 

will not be set more than 200ft and is determined before each flight. 

I, Todd E Andrews (UAVKC), will not operate my UAS near airports, hospitals nor police 

heliports, and do not operate near areas where general public is within fifty to one hundred 

(50-100) yards depending on location, conditions and weather. I am constantly on alert for 

any manned aircraft (police/medical helicopters, etc.) and 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. My UAS’s are capable 

of vertical and horizontal operations, and is flown only within my line of sight, as the remote 

control pilot. My UAS's are also flown with a second operator who aids in watching for any 

obstacles, including manned aircraft, within the flight zone of the UAS. Utilizing battery 

power rather than combustible fuels, flights generally last between three (10) to fifteen (25) 

minutes, with an altitude under one hundred fifty (150) feet. (3 )Smart Mode includes, 

position hold, self-leveling, altitude command, GPS, return home feature, and safety control 

to return home or land in the event of communication interruption between RC transmitter 

and UAS. 

I, Todd E Andrews (UAVKC), utilize a fresh fully charged battery with each flight as a 

safety precaution; full flight time limit for each battery is eight (8) to thirty (30) minutes as 

tested. I do not operate my UAS at or below manufacturer recommend minimum charge 

levels for operation; preferring to remain well within a safe operating range to insure 

adequate communication between radio control and UAS to eliminate potential for crash, 

loss of control or hazard. Reserve batteries are at hand with each exercise to insure 

replacement for sufficient safe level of operation. I do not believe in taking risk that may 

cause a crash, that could create hazard to the public/property/manned aircraft, and have no 

desire to lose an investment. I have clocked numerous practice flights in remote areas as a 

hobbyist simulating flights for future commercial use to gain familiarization with the 

characteristics of this specific UAS's performance under different temperature and weather 

conditions. I also practice computerized simulated flights to maintain adequate skills and 

response reflex time. All for the sake of safety. 

I, Todd E Andrews (UAVKC), am extremely cautious when operating of my UAS/ultra 

lightweight unmanned aircraft and will not “create a hazard to users of the national airspace 

system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it 

falls well within Congress’s contemplated safety zone when it promulgated the Reform Act 

and the corresponding directive to integrate UAS's into the national airspace system. Todd 

E Andrews (UAVKC)’s UAS, used in hobby flight, has a demonstrable safety record and 

does not pose any threat to the general public or national security. 

IV. How Todd E Andrews (UAVKC)’s Request Will Benefit the Public as a Whole: 

 Aerial videography for geographical awareness, education, search and rescue, land 

management, structure inspections and for real estate marketing has been around for a long 

time through manned fixed wing aircraft and helicopters. For small budget companies, 

average homeowners and property owners the expense of such aerial videography is cost 

prohibitive. Only large companies and high end Realtors or luxury homeowners can afford to 

absorb such expense; depriving non-luxury owners and lower budget companies from a 
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valuable marketing tool. Manned aircraft pose a threat to the public through potential 

crashes that the United States has experienced in the past with military aircraft, touring 

helicopters, and news helicopters crashes. Many of them resulting in loss of life. 

 Each aircraft has combustible fuel that burns on impact adding to the already present 

danger in the event of a crash. My, Todd E Andrews (UAVKC)'s, UAS poses no such 

threat since size and lack of combustible fuel alleviates any potential threat to the public. 

Congress has already proclaimed that it is in the public’s interest to integrate commercially 

flown UAS's into the national airspace system, hence the passing of the Reform Act. 

 Granting my, Todd E Andrews (UAVKC)’s, exemption request furthers the public 

interest through academic/visual awareness of the geographical benefits in and around the 

Honolulu area. My ultra light weight UAS is battery powered and creates no emissions that 

can harm the environment. The consequence of my ultra light weight UAS crashing is far 

less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible 

fuel and can cause devastation to the public. The public’s interest is furthered by minimizing 

ecological and crash threat by permitting aerial video/photo capture through my battery 

operated ultra lightweight UAS's. 

 Permitting me, Todd E Andrews (UAVKC), to immediately fly within national air space 

furthers economic growth. Granting my exemption request substantially furthers the 

economic impact for the Honolulu and the surrounding community for companies looking to 

relocate or build around Honolulu as well as individuals looking to relocate for career 

advancement through academic and geographical awareness. Both of which serve as a 

stimulus to the community. 

V. Reasons Why Todd E Andrews (UAVKC)’s Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To 

Existing Rule: 

 My, Todd E Andrews (UAVKC)’s, exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting me, Todd E Andrews (UAVKC), to log more 

flight time in FAA controlled airspace, with communication with the FAA, will allow me to 

contribute to the innovation and implementation of new and novel, as of yet undiscovered 

safety protocols for realtors, land, and structure owners. For development in cooperation 

with the FAA. 

 In addition I, Todd E Andrews (UAVKC), submit the following representations of 

enhancements to current aerial videography and photography: My UAS’s weigh between 6-

34 lbs. complete with batteries and cameras; I only operate my UAS below 200 feet (well 

within the 400 foot permissible ceiling set by the FAA Modernization and Reform Act of 

2012); My UAS only operate for 8-30 minutes per flight; I land my UAS prior to manufacturer 

recommended minimum level of battery power; I pilot my UAS through remote control only 

by line of sight; and have live video feed for a secondary pilot to monitor video recording; I 

receive a live telemetry feed from my UAS during all flights which include remaining battery 

voltage, distance, altitude, and any anomalies that may occur during flight; My UAS’s 

Command and Control utilizes spread spectrum 2.4Ghz-2.485Ghz frequencies in 

accordance with CFR 47, Part 15 for model aircraft use; My UAS’s camera system utilizes 

5.725Ghz-5.875Ghz frequencies in accordance with CFR 47, Part 15; My UAS’s have a 

GPS controlled flight controller- a flight safety feature whereby it hovers or circles and then 
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lands at the GPS takeoff point if communication with the remote control pilot is lost; The DJI 

Inspire 1 and DJI phantom 3 UAS feature a flight controller app that actively records and 

analyzes flight data through that can be used to update and enhance safety protocols; I only 

operate in reasonably safe environments that are strictly controlled, are away from power 

lines, elevated lights, airports and actively populated areas; I conduct extensive preflight 

inspections and protocols during which safety carries the utmost importance; I always obtain 

all necessary permissions prior to operation; and, I have procedures in place to abort flights 

in the event of safety breaches or potential danger. 

My, Todd E Andrews (UAVKC)’s, safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of commercial 

UAS into our national airspace system, helicopters are the primary means of aerial video 

and photography for community awareness real estate, structured inspections, land 

management and search and rescue. While the safety record of such helicopters is 

remarkably astounding, there have been local incidents involving loss of life as well as 

extensive property damage; it is far safer to operate a battery powered lightweight UAS. 

First, the potential loss of life is diminished because UAS's carry no people on board and I 

only operates my UAS in specific areas away from mass populations. Second, there is no 

fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, 

the small size and extreme maneuverability of my UAS allow me to remotely pilot away from 

and avoid hazards quickly and safely. Lastly, given its small size and weight, even when 

close enough to capture amazing images, my UAS need not be so close to the objects they 

are focused on through the technology and use of post editing software allowing pan and 

zoom. Accordingly, my UAS has been experimentally operated for 

familiarization/competency and will continue to operate at and above current safety levels. 

VI. A Summary The FAA May Publish in the Federal Register 

 In summary, Todd E Andrews (UAVKC) seeks an exemption from the following 

Regulations:14 C.F.R. 21, subpart H; 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. § 91.103(b); 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) and (b); 

14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, Todd E 

Andrews (UAVKC)’s, small unmanned vehicle/lightweight unmanned aircraft vehicle in 

community awareness, education, structural inspection land management, search and 

rescue and real estate operations, and to develop economic platforms for the 

aforementioned to enhance the experience of those seeking to relocate, rebuild, reevaluate 

and to find in the Honolulu area. 

VII. Additional FAA Required Operating Conditions and Limitations 

When not covered elsewhere in this Operations Manual, the following conditions and 

limitations apply: 

1. The UA must weigh less than 55 pounds (25kg), including energy source(s) and 

equipment 

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots. 
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3. Flights must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operator's manual. All altitudes 

reported to ATC must be in feet AGL. 

4. The UAS 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 state driver’s license. 

5. All operations must utilize a visual observer (VO). 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. 

6. If a discrepancy exists between these limitations and any procedure outlined elsewhere 

in this operations manual, the conditions and limitations herein take precedence and must 

be followed. 

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe 

flight. 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. The Ground Control Station, if 

utilized, must be included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records. 

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 in accordance with the operator's manual. The PIC who conducts the 

functional test flight must make an entry in the UAS aircraft records of the flight. 

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements 

must be established and identified in the operator's manual. At a minimum, the following 

must be included in the operator's manual: 

a. Actuators / Servos 

b. Transmission (single rotor) 

c. Powerplant (motors) 

d. Propellers 

e. Electronic speed controller 

f. Batteries 

g. Mechanical dynamic components (single rotor) 

h. Remote command and control 

i. Ground control station (if used) 
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j. Any other components as determined by the operator 

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a 

current state driver’s license. 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/her pilot certificate. 

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 

14CFR § 61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single 

blade or multirotor). Prior documented flight experience that was obtained in compliance 

with applicable regulations may satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under this grant of exemption to 

accomplish the required flight cycles and flight time. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 

14CFR § 61.51 (b), a minimum of five hours as UAS pilot operating the make and model of 

UAS to be utilized for operations under the exemption and three take-offs and three landings 

in the preceding 90 days. Training, proficiency, experience-building, and take-off and 

landing currency flights can be conducted under this grant of exemption to accomplish the 

required flight time and 90 day currency. During training, proficiency, experience-building, 

and take-off and landing currency flights, all persons not essential for flight operations are 

considered non-participants, and the PIC must operate the UAS with appropriate distance 

from non-participants in accordance with 14 CFR § 91.119. 

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual 

observer (VO) must have successfully completed a qualification process, as outlined in the 

operator’s manual. As this is a requirement stipulated by the operator, the test must be 

developed and implemented by a qualified person designated at the sole discretion of the 

operator. A record of completion of this qualification process must be documented and 

made available to the Administrator upon request. 

14. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified 

pilot must be successfully completed and documented. This documentation must be 

available for review upon request by the Administrator. Because the knowledge and 

airmanship test qualifications have been developed by the operator, and there are no 

established practical test standards that support a jurisdictional FAA FSDO evaluation and 

approval of company designated examiners, the petitioner will conduct these tests in 

accordance with the operator’s manual. 

15. The UAS may not be operated directly over any person, except authorized and 

consenting production personnel, below an altitude that is hazardous to persons or property 

on the surface in the event of a UAS failure or emergency. 

16. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those persons 
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must be essential to the closed-set film operations. Because these procedures are specific 

to participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is 

necessary for reductions to the distances specified in the petitioner’s manuals. This is 

consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 

Issue a Certificate of Waiver for Motion Picture and Television Filming. 

17. Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet 

if it would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of 

the filming production area to note terrain features, obstructions, buildings, safety barriers, 

etc. Such barriers may protect non-participating persons (observers, the public, news media, 

etc.) from debris in the event of an accident. This is also consistent with the same FAA 

Order 8900.1, V3, C8, S1. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual. 

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

20. Each UAS operation must be completed within 30 minutes flight time or with 25% 

 battery power remaining, whichever occurs first. 

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under this grant of 

exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) 

not more than 72 hours in advance, but not less than 48 hours prior to the operation. 

22. 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. 

23. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be added 

to the operator’s manual. 

24. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

25. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual. 
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26. The preflight inspection section in the operator’s manual must be amended to include 

the following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operator’s manual. 

27. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

28. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over 

the area of proposed filming. The 3-day notification may be waived with the concurrence of 

the FSDO. The plan of activities must include at least the following: 

a. Dates and times for all flights 

b. Name and phone number of the person responsible for the UAS filming production 

under this grant of exemption 

c. Name and phone number of the person responsible for the on-scene operation of the 

UAS. 

d. Make, model and serial or N-number of the UAS to be used 

e. Name and certificate number of the UAS PIC's involved in the filming production event 

f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission must 

be made available to the inspector upon request. 

g. Signature of exemption-holder or representative 

h. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to 

accomplish the operation 

29. The 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. 

30. The UAS must remain clear and yield the right of way to all other manned operations 

and activities at all times (including, but not limited to, ultralight vehicles, parachute activities,

parasailing activities, hang gliders, etc.). 

31. 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. 

32. The UAS cannot be operated by the PIC from any moving device or vehicle. 

33. The UAS 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. 

34. The UAS may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered 
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airport as denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement with 

the airport management must be made available to the Administrator upon request. 

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

the Federal Aviation Administration’s (FAA) 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. Further flight operations may 

not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided. 

VIII. Conclusion 

 Currently, the aforementioned aerial videography/photography relies primarily on the use 

of larger aircraft running on combustible fuel. Posing potential risk to the public. Granting 

my, Todd E Andrews (UAVKC)’s, request for exemption will reduce current 

risk levels and thereby enhance safety. My UAS craft do not contain potentially explosive 

fuel, is smaller, lighter and more maneuverable than conventional video and photographic 

aircraft with much less flight time. 

 Further, I operate at lower altitudes and in controlled airspace eliminating potential public 

risk flying to and from established airfields. I, Todd E Andrews (UAVKC), have been 

informally analyzing and recording flight information and will compile safety protocols and 

the implementation of a flight operations manual for usage that exceeds currently accepted 

means and methods for safe flight. Formal collection of information shared with the FAA will 

enhance the FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board my, Todd E 

Andrews (UAVKC)’s, UAS and therefore the likelihood of death or serious bodily injury is 

significantly diminished. My, Todd E Andrews (UAVKC)’s, operation of my UAS, weighing 

less than forty (40) pounds and traveling at lower speeds within limited areas low to the 

ground will provide an equivalent level of safety as that achieved under current FARs. 

Accordingly I, Todd E Andrews (UAVKC), respectfully request that the FAA grant my 

exemption request and am willing to cooperate in sharing information to benefit the FAA, 

safety of manned aircraft, and the general public at large. 

Respectfully submitted, 

 

Todd E Andrews 

Todd E Andrews (UAVKC) 

Todd@uavkc.com 

505 East 165th Street 

Belton, Mo 64012 
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Appendix A 

List of Aircraft

No. Make and Model Description Serial No. Registration

No.

1 DJI InspireONE Electric powered, 4 rotor, small 

unmanned multirotor helicopter 

W13DCI05

040587 

Pending 

2 DJI S1000 Electric powered, 8 rotor small 

unmanned multirotor helicopter 

Ordered, 

Awaiting 

arrival, will 

update 

Pending 

 

 

Aircraft 1: DJI INSPIRE ONE: 

The operation of the DJI INSPIRE ONE (the flight controller operation manual is NOT explained 

in this letter but can be found in Appendix C, Section 1). 

1. Build Materials 

I. Plastic 

II. Aluminum 

III. Carbon Fiber 

2. Motor Configuration 

I. The DJI Inspire ONE achieves flight in a 4 motor quadcopter setup. 

3. Payload 

I. The DJI INSPIRE ONE flies it’s own light-weight integrated camera. 

II. Maximum All-up weight- 6lbs 

4. Maintaining the DJI INSPIRE ONE 

I. Before each flight: 

1. Check all hardware to ensure it is securely tightened. 

2. Check that the motor is level and locked in place. 

3. Check the propeller to ensure it is tight and there are no visible signs of 

cracks, stress. 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for 

signs of stress or frays. 

5. Check all navigational lighting to ensure it is properly working. 
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II. After 45 hours of flight 

1. Remove and check all motors and motor mounts for signs of wear and tear. 

Replace as necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace 

as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace 

as necessary, and/or chips. Replace the propeller if questionable. 

4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix 

before flying. 

5. Check for updates to flight controller firmware. If available, install and perform 

a minimum of 15 test flights before conducting commercial work. 

Aircraft 2: DJI S1000: 

The operation of the DJI S1000 multirotor system are as follows (the flight controller operation 

manual is NOT explained in this letter but can be found in Appendix C, Section 5). 

1. Build Materials 

I. Carbon Fiber 

II. ABS Plastic 

III. Stainless Steel Hardware 

2. Motor Configuration 

I. S1000 configuration utilizing 8 motors. The motors are configured with 1 motors per 

arm, and a total of 8 arms. 

II. In this configuration the DJI S1000 can handle up to two (2) motors failing and still be 

able to fly. 

3. Payload 

I. The DJI S1000 will carry the Freefly Systems MoVI M5, M10, or M15 camera gimbal. 

II. The cameras that will be flown on the DJI S1000 include, but are not limited to, Canon 

5DMKIII, Canon 1D-C, RED Epic, RED Dragon, and Sony FS700. 

III. Maximum All-up Weight- 34lbs 

4. Maintaining the DJI S1000 

I. Before each flight: 

1. Check all hardware to ensure it is securely tightened. 

2. Check that the motor is level and locked in place. 

3. Check the propeller to ensure it is tight and there are no visible signs of 

cracks, stress. 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for 

signs of stress or frays. 
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5. Check all navigational lighting to ensure it is properly working. 

II. After 45 hours of flight 

1. Check all hardware to ensure it is securely tightened. 

2. Check that all motors are level and locked in place. 

3. Check all propellers to ensure they are tight and there are no visible signs of 

cracks, stress, and/or chips. Replace if any propeller is questionable. 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for 

signs of cuts, fraying, cracks, and/or loose/cold solder connections. Fix before 

flying. 

5. Check all navigational lighting to ensure it is properly working. 

6. Remove and check all motors and motor mounts for signs of wear and tear. 

Replace as necessary. 

7. Remove motor controllers and visually inspect and check for damage. Replace 

as necessary. 

8. Remove flight controllers and visually inspect and check for damage. Replace 

as necessary. Check for updates to flight controller firmware. If available, install 

and perform a minimum of 15 test flights before conducting commercial work. 
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Appendix B 

Personal Protocols/Controls/Flight Manual 

Protocols and Controls 

TODD E. ANDREWS (UAVKC), Belton, Missouri. 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight. Pre-Flight Protocol: 

-Check batteries with voltage meter to insure fully charged and ready for use. 

-Inspect batteries for damage or leakage that may affect proper operation. 

-Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 

-Check all GPS and Telemetry connections prior to flight. 

-Check weather forecasts for wind advisory or other conditions that my impact flight. 

-Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of 

possible air traffic. 

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information. 

Inspect flight area for 

Vicinity of public safety helipads/heliports 

Vicinity of medical helipads/heliports 

Vicinity of light poles vicinity or utility wires 

Vicinity of trees flocks of birds that may cause interference and potential flight impact 

Vicinity of any elevated obstructions that may pose potential flight hazard 

Vicinity of roadways with moderate to heavy traffic that can distract the public 

Gatherings that may attract viewers optional point of control for best visual site of UAS 

while in flight 

Emergency landing areas 

Takeoff and landing 

Inspect area for best and safest point of takeoff and landing 

If in a subdivision or area that is within 150 feet of a residential street, post warning 
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Sign(s)/stand(s) "Attention Aerial Photography In Progress, Remain Back 150 Feet " 

Flight Protocol: takeoff and land from same location have alternate landing areas in case of 

emergencies) remain alert to birds, sound or aircraft, curious public, and approaching vehicles 

do not allow anyone to engage in conversation or distract the remote control pilot restrict flight to 

minimal elevation sufficient to acquire desired results remained prepared for emergency landing 

at all times pay attention to flight time – warning meter for low voltage. 

Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut 

down propulsion immediately following landing – priority of disconnecting batteries 

Post flight: 

1. Disconnect battery to prevent accidental activation of propulsion system 

2. Secure UAS in a safe location 

3. Remove all warning signs from public access areas 

4. Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event 

Manned aircraft is heard or seen in vicinity of flight 

There is a public gathering within established safety boundary wanting to observe flight 

Pilot is being distracted from focusing on flight and safety 

Sudden change in weather (wind bursts) 

Sudden increase in vehicular traffic in vicinity of flight 

Birds enter into proximity of flight 

Any sudden unsafe event that can cause collision, distraction or interruption of control 

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative. 
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Sample Flight Log Recorded: 

Date:____________________ Time: ______________ 

Location:___________________________________________________ 

Pre-flight Inspection: ____ Yes _____ No 

Comment: _________________________________________________ 

Elements 

Proximity to airport: _______________ (attached map pinpointing approximate location of flight) 

Airport notified: ____ Yes _____ No Phone Number: _______________________ 

Contact Name:___________________________________ 

Nearest major intersection: ______________________________________________________ 

Proximity to medium traffic road: __________________________________________________ 

Proximity to heavily traveled roadway road: _________________________________________ 

Proximity to congested population: ________________________________________________ 

Approx. Local Takeoff Time: ______________ GMT: __________ 

Weather Good Fair Poor Comment: _______________________________________________ 

Visibility Good Fair Poor Comment: _______________________________________________ 

Wind Speed: ___mph ___Gusts/MPH ___avg/MPH Comment : _________________________ 

Approx. Landing Time: ______________ GMT: __________ 

Estimated Elevation Ground level: ____________ Elevation Above Sea Level: _____________ 

Safety Concerns: ______________________________________________________________ 

Additional Comments: __________________________________________________________ 
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TODD E. ANDREWS (UAVKC), Belton, Missouri. 

Appendix C

Aircraft Manuals

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and 

illustrated parts catalogs. These manuals may be attached to the docket when submitted. 

Information regarding design, aircraft performance, fail-safe features, operating limitations, 

normal and emergency procedures, and maintenance and inspection procedures is contained 

within the manuals and supplemental information documents listed below: 

1. DJI Inspire Manual V1.8 

https://www.dji.com/product/inspire-1/download 

2. Inspire 1 Maintenance Manual v1.0 

https://www.dji.com/product/inspire-1/download 

3. Intelligent Flight Battery Safety Guidelines v1.4 

https://www.dji.com/product/inspire-1/download 

4. Inspire 1 Safety Guidelines 

https://www.dji.com/product/inspire-1/download 

5. DJI S1000 Professional Manual V1.0 

 http://dl.djicdn.com/downloads/s1000/en/S1000_User_Manual_v1.10_en.pdf 

 

For more information or questions about any of the above listed information and manuals please 

contact: 

 

Todd E Andrews 

505 East 165th Street 

816-529-8374 

todd@uavkc.com