August 19, 2015

Exemption No. 12532

Regulatory Docket No. FAA–2015–1921

Mr. Philip Madison

208 Anita Drive

Paducah, KY 42003

Dear Mr. Madison:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letters dated May 13 and July 30, 2015, you petitioned the Federal Aviation 

Administration (FAA) for an exemption. The petitioner requested to operate an unmanned 

aircraft system (UAS) to conduct aerial data collection for aerial videography and 

cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom and DJI Phantom 3.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 
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finds that the relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Philip Madison is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Philip Madison is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom and 

DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. 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; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 
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documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. 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 or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

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.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any 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.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

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

to the FAA's 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (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 operator for the UAS aerial filming conducted 

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 UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

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; and

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.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Philip	Madison

208	Anita	Drive

Paducah,	KY	42003

270.392.1952

May	13,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Exemption	Pursuant	to	Section	333

To	whom	it	may	concern;

I	am	seeking	relief	from	the	following	portions	of	14	CFR’s:

91.7(a)

91.119(c)	

91.121

91.151(a)

91.405(a)

91.407(a)(1)

91.409(a)(1)&(2)

91.417(a)&(b)

I	intend	to	operate	the	DJI	Phantom	1	and	DJI	Phantom	3	Professional	“quad-copter	

style” unmanned	aircraft	systems (UAS)	in	the	western	Kentucky	region	for	the	purpose	

of	aerial	data	collection to	produce	images/video	for	use	in aerial	

videography/cinematography	and	augmenting	real	estate	listing	videos	(or	similar	

operations),	commercial advertisings,	educational	videos,	industrial	training/safety	

programs	and	educational	products.

As	for	my	accreditations with	model	aircraft,	I	am	a	current	and active	member	in	the	

Academy	of	Model	Aeronautics	(AMA)	since March	9,	2005	and	hold	a	AMA	Turbine

Waiver	(#FW	9880)	for	fixed	wing	turbine	powered	aircraft	since	September	12,	2008.		

Over	the	past	several	years	I	have	also	earned	the	status	of	Contest	Director	for	the	

AMA	and	held	the	responsibility	of	numerous	model	aircraft	events	with	zero	incidents.

I	am	currently	employed	in	the	video	production	industry,	with	over	16	years	on	the	job	

experience	in	all	aspects	of	video	production.		It	is	my	intent to	include	the	products	of	

aerial	videography	and	cinematography	from	the	UAS	platform	into	current	production	

work.		Throughout	the	past	two	years	I	have	practiced	at	the	hobby/recreation	level	UAS	
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activities	with	the	DJI	Phantom	1	platform	and	have	accumulated	more	than	40+	hours	

of	flight	time,	WITHOUT	INCIDENT.

Following	are	the	justifications	as	to why	I	am	seeking	relief	from	each	section:

91.7(a)	– It	is	my	understanding	that	no	FAA	regulation	standard	exists	for	determining	

the	airworthiness	of	the	UAS	I	intend	to	operate,	the	regulation	is	inapplicable.

91.119(c)	– The	intended	operations	under	this	exemption	would	need	to	occur	at	

altitudes	fewer	than	400	feet	and	closer	than	500	feet	to	person,	objects	or	structures.

91.121	– The	manufactured	platform	intended	uses	a	barometric	altimeter,	GPS	derived	

altitude	and	ultrasonic	reference	relative	to	ground	capabilities	to	establish	altitude	

while	the	FAA	requires	any	altitude	reported	to	be	in	feet	AGL.

91.151(a)	– The	manufactured	system	does	not	have	the	ability	to	adhere	to	this	

regulation.

91.405(a)	– This	section	does	not	apply	to	UAS.

91.407(a)(1)	– This	section	does	not	apply	to	UAS.

91.409(a)(1)&(2)	- This	section	does	not	apply	to	UAS.

91.417(a)&(b)	- This	section	does	not	apply	to	UAS,	however	it	is	my	intent	to	keep	a	

flight	log	with	basic	information	about	each	activity/flight	of	the	UAS	involved.

It	is	my	intent	to	comply	with	the	following	conditions	of	UAS	operations	for	the	

purpose:

1.		All	operations	authorized	by	this	grant of exemption	are	limited	to	the	platform	

aircraft	as	described in	their	respective	operating	guidelines	and	documents	from	the	

manufacturers for	the	DJI	Phantom	1	and	DJI	Phantom	3	Professional.

2.		Each	aircraft	will	NOT	exceed	55	pounds	in	weight.	(Estimated	approximate	weight	

for	each individual aircraft	is	less	than	4.5	pounds.)

3.		The	UAS	will	not	fly	in	excess	of	an	indicated	airspeed	of	35	knots.

4.		The	UAS	will	be	operated	at	an	altitude	of	no	more	than	400	feet	above	ground	level	

(AGL),	as	indicated by	the	procedures	specified	in	the	operating	documents.

5.		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).	All	UAS	
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operations	will	be	conducted	during	a	minimum	of		“fair”	weather	situations	deemed	

safe by	the	operator.

6.		The	UAS	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the	Pilot	In	Command	

(PIC)	at	all	times.		This	requires	the	PIC	to	be	able	to	use	human	unaided	vision	by	any	

device	other	than	corrective	lenses.

7.		ALL	operations	must utilize	a	visual	observer	(VO).		The	UAS	will	be	operated	within	

the	VLOS	of	the	VO	at	all	times.		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.		The	PIC	must	be	designated	before	the	flight	and	

cannot	transfer	the	designation	for	the	duration	of	the	operation.		The	PIC	must	ensure	

that	the	VO	is	capable	to	perform	the	functions	prescribed.

8.		The	operating	documents	and	this	grant of	exemption	must	be	accessible	during	UAS	

operations	and	made	available	to	the	Administrator	upon	request.	lf	a	discrepancy	exists	

between	the	conditions	and	limitations	in	this	exemption	and	the	procedures	outlined	in	

the	operating	documents,	the	conditions	and	limitations	herein	take	precedence	and	

must	be	followed.	Otherwise,	the	operator	must	follow	the	procedures	as	outlined	in	its	

operating	documents.	The	operator	may	update	or	revise	its	operating	documents.	lt	is	

the	operator's	responsibility	to	track	such	revisions	and	present	updated	and	revised	

documents to	the	Administrator	upon	request.	The	operator	must	also	present	updated	

and	revised	documents	if	he	petitions	for	extension	or	amendment	to	this	grant	of	

exemption.	lf	the	operator	determines	that	any	update	or	revision	would	affect	the	

basis	upon	which	the	FAA	granted	this	exemption,	then	the	operator	must	petition	for	

amendment	to	its	grant	of	exemption.	The	FAA's	UAS	lntegration	Office	(AFS-80)	may	be	

contacted	if	questions	arise	regarding	updates	or	revisions	to	the	operating	documents.	

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

flight.	lf	the	inspection	reveals	a	condition	that	affects	the	safe	operation	of	the	UAS,	the	

UAS	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	

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

properly	documented	in	the	aircraft	records.	

10.		Any	UAS	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.	The	PIC	who	conducts	the	functional test	flight	must	make	an	entry	

in	the	aircraft	records.	

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

maintenance,	overhaul,	replacement,	inspection,	and	life	limit	requirements.

12.		The	operator	must	carry	out	its	maintenance,	inspections,	and	record	keeping	

requirements,	in	accordance	with	the	operating	documents.	Maintenance,	inspection,	
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and	alterations	must	be	noted	in	the	aircraft	records,	including	total	flight	hours,	

description	of	work	accomplished,	and	the	signature	of	the	authorized	person	returning	

the	UAS	to	service.	

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

Bulletins.	

14.		The	UAS may	not	operate	within	5	nautical	miles	of	an	airport	reference	point	as	

denoted	on	a	current	FAA-published	aeronautical	chart.

15.		The	UAS	may	not	be	operated	less	than	500	feet	below,	or	less	than	2,000	

horizontally	from	a	cloud	or	when	visibility	is	less	than	3	statute	miles	from	the	PIC.

16.		If	the	UAS loses	communications	or	loses	its	GPS	signal,	it	must be	designed	to

return	to	a	pre-determined	location	within	the	planned	operating	area	and	land	or	be	

recovered	in	accordance	with	the	operating	documents.	

17.		The	PIC	must	abort	the	flight	in	the	event	of	unpredicted	obstacles	or	emergencies	

in	accordance	with	the	operating	documents.	

18.		The	PIC	is	prohibited	from	beginning	a	flight	unless	(considering	wind	and	forecast	

weather	conditions)	there	is	enough	power	to	fly	at	normal	cruising	speed	to	the	

intended	landing	point	and	land	the	UAS with	25%	battery	power	remaining.	

19.		All	aircraft	operated	in	accordance	with	this	exemption	must	be	identified	by	

manufacturers	applied	and	recorded	serial	number.

20.		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.	

21.		Documents	relating	to	the	manufactures	operating	manual,	usage	guide,	

maintenance	recommendations	and	granted	exemption	notice	must	be	available	to	the	

PIC	at	all	times.		These	documents	must	be	made	available	to	the	Administrator	or	any	

law	enforcement	official	upon	request.

22.		The	UAS	must	remain	clear	and	yield	the	right	of	way	to	all	manned	aviation	

operations	and	activities	at	all	times.	

23.		The	UAS	may	not	be	operated	by	the	PIC	from	any	moving	device	or	vehicle.	

24.		The	UA	may	not	be	operated	over	congested	or	densely	populated	areas	without	

prior	notice	of	activity	and	purpose	to	responsible	party	involved.

25.		All	operations	shall	be	conducted	over	private	or	controlled-access	property	with	

permission	from	the	land	owner/controller	or	authorized	representative.	Permission	
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from	land	owner/controller	or	authorized	representative	will	be	obtained	for	each	

operation to	be	conducted.	

26.		The	operator	must	have	a	motion	picture	and	television	operations	manual	

(MPTOM)	as	documented	in	this	grant	of	exemption.

27.		At	least	3	days	before	aerial	filming,	the	operator	of	the	UAS	affected	by	this	

exemption	must	submit	a	written	Plan	of	Activities	to	the	local	Flight	Standards	District	

Office	(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:	

1. Dates	and	times	for	all	flights;	

2. Name	and	phone	number	of	the	operator	for	the	UAS	aerial	filming	conducted	

under	this	grant	of	exemption;	

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

of	the	UAS;	

4. Make,	model,	and	serial	or	N−Number	of	UAS	to	be	used;	

5. Name	of	UAS	PICs	involved	in	the	aerial	filming;	

6. 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;	

7. Signature	of	exemption	holder	or	representative;	and	

8. 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.	

28.		Flight	operations	may	be	conducted	closer	than	500	feet	from	participating	persons	

consenting	to	be	involved	and	necessary	for	the	filming	production,	as	specified	in	the	

exemption	holder’s	MPTOM.	

28.		Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical	

boundaries	of	the	operational	area	as	defined	by	the	within	this	operational	exemption	

must	be	reported	to	the	FAA's	UAS	lntegration	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.	
6

Along	with	this	petition,	I	submit	the	following	for	review	as	indicators	for	operation	of	

the	UAS	prescribed	for	approval	in	this	exemption:

-DJI Phantom	Flying	Flow	Chart

-DJI	Phantom	Quick	Start	Manual

-DJI	Phantom	User	Manual

-DJI	Phantom	3	Professional	Quick	Start	Guide

-DJI	Phantom	3	Professional User	Manual

-Proposed	Motion	Picture	and	Television	Flight	Operation	Manual

If	more	information	or	documentation	is	needed	to	approve	this	exemption for	the	

intended	use	of	the	UAS,	please	contact	me	at	270.392.1952.

Thank	you,

Philip	Madison
Philip	Madison

208	Anita	Drive

Paducah,	KY	42003

270.392.1952

July	30,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Additional	Information	Requested	for	Docket	FAA-2015-1921

To	whom	it	may	concern;

Pursuant	to	the	FAA	Modernization	and	Reform	Act	of	2012	I	am	writing in	request	for	

an	exemptions	from	the	current	Federal	Aviation	Regulations	(“FARs”)	listed	below	so	

that	I	may	operate	small	ultra	light	weight	unmanned	aircraft	system	(“UAS”)	

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

believe	that	such	activity	is	already	occurring	by	“unauthorized”	operators	and	it	is	my	

goal	to	work	with	the FAA	through	this	exemption request	to	operate	within	the

constraints	of	the	current	FAR.		

I	have	over	15+	years	experience	in	television/film	production	as	well	as	10+	years	

experience	in	remote	control	models,	all	without	incident.		The	opportunity	to	integrate

such	UAS aerial	platforms	in	a	safe	and	controlled	manor	through	this	exemption,	if	

approved,	will aid	in	the	development	of	an	already	“booming” media	industry.

Data	collected	by	the	operation	of	this	exemption	is	intended	for	use	as	images/video	

for	videography/cinematography,	real	estate,	web-based	videos/websites,	commercial	

advertisings,	educational	videos,	training/safety	videos and	potentially	search	and	

rescue	operations	if	necessary	and	requested	by	local	area	agencies.

PUBLIC	GOOD

With	this	exemption	I	plan	to	provide	a	platform	for	aerial	data/imaging	in	a	manor	that	

is	not	cost	prohibitive	as	has	been	historically	with	manned	aircraft.		Congress	has	

already	decided	that	it	is	in	the	public’s	interest	to	integrate	commercially	flown	UAS	

into	the	national	airspace	system	and	passed	the	Reform	Act.

Aerial	videography	for	geographical	awareness,	real	estate	marketing	and	video	

production has	been	around	for	a	long	time	through	manned	fixed	wing	aircraft	and	

helicopters.	But	for	small	business	owners,	its	expense	has	been	cost-prohibitive.		

Granting	this	exemption	will allow	me to	provide	this	service	at	a	much	lower	cost.	
Further,	the	small	UAS	being	utilized	in	this	application	will	pose	no	threat	to	the	public	

given	its	small	size	and	lack	of	combustible	fuel	when	compared	to	larger	manned	

aircraft.	The	UAS	is	battery	powered	and	creates	no	emissions	that	can	harm	the	

environment.		The	operation	of	this	UAS	will	minimize	ecological	damage	and	promote	

economic	growth	by	providing video	based information	to	businesses	&	individuals	in	

the	area.	

This	exemption,	if	granted,	will	also	further	economic impact	for	the	area	by	providing	

an	opportunity	for	companies	looking	to	build	and	individuals	looking	to	relocate	for	

careers	to	have	information	available	to	them	through	academic	and geographical	

awareness.		These	serve	as	a	stimulus	to	the	community.

CONCLUSION

Finally,	I	am	requesting	this	exemption	to	perform	safe	operations	of	the	listed	UAS	at	

low-level	altitudes	and	only	around	those	completely	informed	and	agreed	upon	the	

operation,	thus	virtually	eliminating	the	potential	risk	to	the	public.		The	systems	that	I	

operate	keep	very	accurate	data	logs	that	will	also	allow	me	to	constantly	evolve	my	

personal	guidelines	under	this	exemption	and	be	information	that	can	eventually	be	

transferred	along	to	the	FAA	for	review	in	efforts	to	enhance	the	efforts	on	future	

protocols	in	complying	with	the	FAA	Modernization	and	Reform	Act	of	2012.	

The	UAS	platforms	I	intend	to	operate	have	no	personnel	on	board,	and	therefore	any	

likelihood of	death	or	serious	injury	is	significantly diminished.		

All	UAS	used	are	very	lightweight	and	operated	at	very	low	speeds	within	limited	areas,	

which	again	provides	a	great	level	of	safety.		

I	hope	to	operate	the	UAS	in	a	safe	manor	and	to	utilize	such	a	platform	in	the	

advancement	of	aerial	data	collection. If	more	information	or	documentation	is	needed	

to	approve	this	exemption for	the intended	use	of	the	UAS,	please	contact	me	at	

270.392.1952.

Thank	you,

Philip	Madison