Petition for exemption section 333

Greg Priest

3874 Camellia Drive

Mobile Al, 36693

(251)680-6830

Gpriest65@gmail.com

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR 61.113 (a) & (b) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F. R. 91.119 14 C.F.R. 

91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

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

C.F.R. Part 11, Mobile Drones “Greg Priest”., operator of Small Unmanned Aircraft Systems (“sUASs”) 

equipped to conduct aerial photography and videography for the real estate industry, hereby applies for 

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

sUASs, so long as such operations are conducted within and under the conditions outlined herein or as 

may be established by the FAA as required by Section 333.1

I would like to use a small hex copter, in my startup business for Aerial real estate photography and land 

survey. In the course of operating my hex copter I have been contacted by individuals inquiring the 

availability of my equipment to video property or properties they have listed on various real estate sites.

I see the future of UAS based businesses growing rapidly, and would like to be a part of this growing 

aviation sector.

Current aerial video and photography projects require the hire of full size aircraft at a considerably 

higher level of risk and cost. The equipment I will be using weighs less than 5lbs and has various safety 

systems and overrides that in the event of loss of signal, guarantee that the aircraft return to the point 

of launch and safely land. Also, the equipment weighs considerably less than traditional aircraft and 

crew.

As a former student pilot who worked toward my private pilot license, this allows me to get back into 

aviation in a new technology that I also hope will led to my eventual private pilot certification. As a 

student pilot I logged more than forty hours in small single engine aircraft. I understand the safety 

procedures and how important check lists and well maintained aircraft are for public safety. When I fly 

my UAS I always abide by all FAA regulations. I take this as a future business very seriously. 

The equipment I am using is maintained to the highest standards. I do preflight checks on batteries,

airframe, motors and all equipment associated with my aircraft. I do limit my flights to below 400 feet 

AGL and within line of sight. My UAS is equipped with an auto pilot system in the event of loss of signal 

or loss of sight. The UAS is also equipped with an FPV camera that can be used in the event there is an 

emergency situation or disorientation. Please consider granting this exemption I would greatly 

appreciate the consideration.

Sincerely

Greg Priest
Regulations from which the exemption is requested: 14 CFR 61.113 (a) & (b) 14 CFR 91.9 (b) (2) 14 C.F.R. 

91.103 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 

409 (a) (2) 14 CFR 417 (a) & (b)

sUASs operated by Mobile Drones “Greg Priest” weigh less than 10 pounds, including the payload (i.e. 

camera, lens, and gimbal). They operate at speeds of no more than 35 knots, can hover, and can 

simultaneously move vertically and horizontally. Mobile Drones “Greg Priest” will only operate its sUASs 

in line of sight and will operate only within the secure area described in the FOPM. Such operations will 

insure that the sUAS will “not create a hazard to users of the national airspace system or the public.”

The small size of UASs and the restricted secure environment within which they will operate, Mobile 

Drons UAS operations adhere to the Reform Act’s safety requirements. Additionally, due to the size of 

the UASs, permission from relevant property owners or other applicable parties, and the limited areas in 

which they will operate, approval of this application presents no national security issues.

Based on the substantial level of safety surrounding the proposed operations, and the significant public 

benefit (enhanced safety), reduction in environmental impacts, the grant of the requested exemption is 

in the public interest. Accordingly, Mobile Drones “Greg Priest” respectfully requests that the FAA grant 

the requested exemption. 

Aircraft And Equivalent Level Of Safety 

The operating limitations proposed by Mobile Drones “Greg Priest” provide for at least an equivalent or 

higher level of safety because operations further enhance safety of aerial image collection using 

conventional aircraft. 

The limitations and conditions include:

• The sUASs will weigh less than 10 pounds DJI F550.

• Flights will be operated within line of sight of a pilot and/or observer. 

• Maximum flight time for each operational flight will be no more than 20 minutes. Flights will be 

terminated at no less than 30% battery power reserve should that occur prior to the 20 minute limit.

• Flights will be operated at an altitude below 400 feet AGL, and not more than 200 feet above an 

elevated platform from which filming is planned. 

• Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observer. 

• A sUAS pilot will be Pilot in Command (PIC). 

• The sUAS will only operate within a confined secure area as defined in the FOPM. Page 2 of 6 

• A briefing will be conducted for planned sUAS operations prior to each day’s flight. All personnel 

performing duties within the boundaries of the safety perimeter are required to attend. 

• The operator will obtain consent of all persons involved in the filming and ensure that only consenting 

persons will be allowed within 500 feet of the flight operation. 

• The Pilot and observer must be trained in sUAS operations and have received current information on 

the particular sUAS to be operated as required by the FOPM DJI F500 with NAZA M V2. 

• The Observer and pilot will be able to communicate by two way radio at all times 
• Written and/or oral permission from the relevant property holders will be obtained prior to flight 

operations. 

• If the sUAS loses communications or loses its GPS signal, the sUAS will have the capability to return to 

the point of launch using the RTL safety future of the flight controller

14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: 

Pilot in Command Sections 61.113 (a) and (b) limit private pilots to non-commercial operations. Because 

the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level 

of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license 

rather than a commercial pilot’s license to operate a sUAS. Unlike a conventional manned aircraft, a 

sUAS is remotely controlled by a ground-based operator. The operational area is controlled and 

restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that 

provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. 

The risks associated with the use of a sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 allowing sUAS use by a sport pilot as the PIC exceeds 

the present level of safety sought by 14 C.F.R. §61.113 (a) and (b).

14 C.F.R. § 91.103:

Preflight Action Section 91.103 requires each pilot to preflight an aircraft before flight Page 3 of 6 to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be used, an exemption is 

requested. However, an equivalent level of safety will be provided. The PIC will take all actions, including 

reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance 

data before commencement of flight. 

14 C.F.R. §91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 provides, in 

pertinent part, that: “except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: .....

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure.”

Because Mobile Drones “Greg Priest” requests authority to operate at altitudes no higher than 400 AGL, 

and not more than 200 above an elevated platform from which filming is planned, an exemption is 

needed to allow such operations. Except for the limited conditions stated in the FOPM, the sUAS will 

never operate higher than 400 AGL. It will, however, be operated in a restricted area within a security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent.

The equivalent level of safety will be achieved given the size, weight, and speed of the sUAS as well as 

the location where it is operated. No flight will be taken without the permission of property owners or 

local officials. Because of the advance notice to the property owners and participants in the filming 

activity, all affected individuals will be informed of the planned flight operations. Compared to flight 

operations for conventional aircraft, any risk associated with the proposed sUAS operations is far less 

than conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations and 

lite weight of the DJI F550 will ensure separation between a sUAS and conventional aircraft. 
14 C.F.R. §91.121: Altimeter Settings

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As a sUAS may not have a barometric altimeter, but instead a GPS altitude 

data, an exemption is needed.

An equivalent level of safety will be achieved by the operator, pursuant to the FOPM and Safety Check 

list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. §91.151(a): Fuel Requirements for Flight in VFR Conditions

Page 4 of 6 Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that 

for at least 30 minutes . . . .” The typical battery powering the Mobile Drones “Greg Priest” sUASs 

provides less than 20 minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR 

§91.151, sUAS flight would not be possible. Given the limitations on the sUAS’s proposed flight area and 

its proposed operations within a predetermined location, a longer time frame for flight in daylight VFR 

conditions is reasonable. Furthermore, operating the sUASs in a tightly controlled area where only 

people, property owners, or official representatives who have signed waivers will be allowed, less than 

30 minutes of reserve fuel does not engender the type of risk that §91.151(a) was intended to address. 

Mobile Drones “Greg Priest” believes that safety can be achieved by limiting flights to 15 minutes or 30% 

of battery power, whichever occurs first. This restriction would be more than adequate to return the 

sUAS to the point of launch from anywhere in its limited operating area.

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

These regulations require that an aircraft operator or owner shall “have that 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...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Mobile 

Drones “Greg Priest” operations. 

Maintenance will be accomplished by the operator. An equivalent level of safety will be achieved 

because the DJI F550s are limited in size, will carry a small payload and operate only in restricted areas 

for limited periods of time. If mechanical issues arise, the sUAS can land immediately and will be 

operating from no higher than 400 feet AGL. As provided in the FOPM, the operator will ensure that the 

sUAS is in working order prior to flight, perform any required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the sUAS and best 

suited to maintain it in an airworthy condition. 

Summary for Publication Pursuant to 14 C.F.R. Part 11,

The following summary is provided for publication in the Federal Register, should it be determined that 

publication is needed: Mobile Drones “Greg Priest” seeks an exemption from the following rules:

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 

91.409(a)(2); and 91.417(a) and (b) to operate Page 5 of 6 commercially a small unmanned vehicle (55 

pounds or less) in commercial image acquisition operations. 
As established by the sUAS exemptions already granted by the FAA, allowing commercial operations of 

sUASs in agriculture, real estate, inspection, S & R, and film industries will enhance safety by reducing 

risk. Conventional survey, agricultural, mapping, inspection, and film operations, using turbine aircraft, 

operate at low altitudes and present the risks associated with aircraft that weigh around 4,000 pounds, 

and which carry large amounts of Jet A fuel. Such aircraft must also fly to and from the target location. 

In contrast, a sUAS weighing fewer than 55 pounds and powered by batteries eliminates virtually all of 

that risk given the small size and lack of combustible fuel. The sUAS is carried, and not flown, to target 

site. The DJI F550 sUAS carries no passengers or crew and, therefore, will not expose them to the risks 

associated with manned flights. 

The operation of sUASs conducted in the strict conditions outlined in the FOPM will provide an 

equivalent level of safety supporting the grant of the exemption requested herein. The sUASs operate at 

slow speeds, close to the ground, and in a secure environment. As a result, they are far safer than 

conventional operations conducted with turbine helicopters flying near the ground and people. 

Privacy

All flights will occur over private or controlled access areas with the property owner’s prior consent and 

knowledge. Recognizable images will only be recorded of people who have given their consent or 

otherwise have agreed to be in the area where active image acquisition will take place.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 (size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security) provide more than adequate justification to grant Mobile Drones “Greg Priest” 

requested exemption, allowing for Mobile Drones “Greg Priest” sUAS commercial operations for the 

listed industries pursuant to the included FOPM. 

I can be reached at (251)680-6830 or gpriest65@gmail.com if further information is needed.

Thank you.