By letter dated July 1, 2015, Mr. Joseph, Wilkins, 18865 State Rd 54 Lutz Fl. 33558 petitioned the 

Federal Aviation Administration (FAA) for an exemption from part 21, subpart H; and Sections 

45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 

91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code 

of Federal Regulations (14 CFR). The proposed exemption would allow Mr. Wilkins to operate 

the PHANTOM 3 Professional quad-copter unmanned aircraft system (UAS) to conduct 

aerial videography and cinematography to enhance academic community awareness for 

those individuals and companies unfamiliar with the geographical layout of the Tampa Bay area and 

augment real estate listing videos. As well to provide Arial photography of construction, Jobs, 

Roofing Inspections, before and after photography,and outdoor activity videos and photography.

The petitioner supports his request with the following information:

The petitioner has provided the following information – contained in his petition and supporting 

documentation including: 1) Supplemental Response for Petition, 2) PHANTOM Flying Flow Chart 

V1.0 (Simplified Version), PHANTOM Quick Start Manual v1.7, PHANTOM Advanced Manual v.1.4, 

3) PHANTOM 3 Professional User Manual 4) restricted areas map, 5) personal protocols and 

controls, and 6) Safety/Flight Manual (all hereinafter referred to as operating documents).

The FAA has organized the petitioner’s information into four sections: 1) the unmanned aircraft 

system (UAS), 2) the UAS Pilot In Command (PIC), 3) the UAS operating parameters and 4) Public 

Interest.

Unmanned Aircraft System

The petitioner states he plans to operate a UAS, the PHANTOM 3 Professional, which is comprised 

of an unmanned aircraft (UA or PHANTOM) and a transportable ground station.

The PHANTOM 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 30 knots. The Phantom # Professional comes affixed with a small HD camera 

Petitioner plans to operate the UA over various areas near Tampa Bay Area to enhance academic 

community awareness and augment real estate listing videos as well to provide digital photography 

and Video.

Petitioner makes the following representations of operational enhancements which he proposes to 

abide by to ensure this exemption will provide a level of safety at least equal to existing rules:

• He will only operate in reasonably safe environments that are strictly controlled, are away from

power lines, elevated lights, airports and actively populated areas; and

• He will conduct extensive preflight inspections and protocols, during which safety carries primary 

importance.

The petitioner states that given the size, weight, speed, and limited operating area associated with 

the aircraft to be utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness 

Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions and 

limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR 

part 11 and Section 333 of P.L. 112-95 (Section 333).
Petitioner requests an exemption from § 45.23 Marking of the aircraft because his UA will not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he states that twoinch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal 

lettering requirement. Regardless of this, petitioner states that he will mark his UAS in the largest 

possible lettering by placing the word “Experimental” on its fuselage as required by § 45.29(f) so that 

he or anyone assisting him as a spotter will see the markings.

The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) 

and (b) Maintenance inspections may be required and should be granted since they only apply to 

aircraft with an airworthiness certificate. However, the petitioner states as a safety precaution he will 

perform a preflight inspection of his UAS before each flight as outlined in his operating documents.

UAS Pilot in Command (PIC)

The petitioner asserts that under § 61.113 (a) and (b) private pilots are limited to non-commercial

operations, however he can achieve an equivalent level of safety as achieved by current regulations 

because his UAS does not carry any pilots or passengers. Further, he states that, while helpful, a 

pilot license will not ensure remote control piloting skills. He further indicates that the risks of 

operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 

CFR part 61, et seq., thus he requests an exemption from § 61.113 Private Pilot Privileges and 

Limitations: Pilot in command.

Regarding UAS operational training, the petitioner states he has flown numerous practice flights in 

remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with 

the characteristics of his UAS’ performance under different temperature and weather conditions. He 

further states that he practices computerized simulated flights to maintain adequate skills and 

response reflex time.

In a supplemental request to the FAA, the petitioner requests consideration of a 120 day temporary 

airman certificate in accordance with § 63.13, to allow him time to obtain a private pilot certificate or 

to allow the FAA time to establish minimum UAS airman certification standards.