Ryan	Roberts	Videography

3616	CR	192	East

Kilgore,	TX	75662

903/746-2942

Email- RRobertsvideo@gmail.com

Docket Management Facility 

c/o US Department of Transportation

1200 New Jersey Avenue,

SE West Building Ground Floor Room W12-140

Washington, DC 20590

Petition	of	Ryan Roberts	Videography,	

For Exemption	Pursuant	to	Section	333

Of the	FAA	Modernization	and	Reform	Act	of	2012

Sir	or	Madam,

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

CFR	Part	11,	Ryan	Roberts	Videography	is	hereby	requesting	an	exemption	from	the	

listed	Federal	Aviation	Regulations	to	operate	a	small	Unmanned	Aircraft System	for	

the	purpose	of	recording	photography	and	videography	for	compensation	or	hire.

This	exemption	would	permit	commercial	operation	by	Ryan	Roberts	Videography,	

using	a	DJI	Phantom	3	Advanced	UAS	in	order	to	provide	the	following	services:

•	Real estate	advertising

•	Land surveying

•	Agricultural surveying

•	Commercial advertisement

•	Personal event	photography	and	videography

•	Commercial event	photography	and	videography	

Ryan	Roberts	Videography’s	operation	under	the	exemption	will	be	subject	to	strict	

operating	requirements	and	conditions	to	ensure	an	equivalent	level	of	safety	to	

currently	authorized	operations	using	manned	aircraft and	under	conditions	as	may	

be	modified	by	the	FAA	as	required	by	Section	333.

Ryan	Roberts	Videography	respectfully	submits	this	request	for	an	exemption	due	

to	its	use	of	sUASs/UASs.	Approval	of	this	exemption	would	enhance	safety	and	

fulfill	the	Secretary	of	Transportation’s	responsibilities	under	Section	333(c)	of	the	

Reform	Act	to	“establish	requirements	for	the	safe	operation	of	such	aircraft

systems	in	the	national	airspace	system.”

Ryan	Roberts	Videography	has	organized	this	exemption	request	as	follows:
I.	Petitioner’s	Description

II.	Relevant	Statutory	Authority

III.	Qualifications	for	Approval	Under	Section	333	of	the	Reform	Act

IV.	Description	of	Proposed	Operations

V.	Regulations	from	which Exemption	is	requested

VI.	Public	Interest

VII.	Privacy

VIII.	Federal	Registry	Summary	

IX.	Conclusion

I.	Petitioner’s	Description

Ryan	Roberts	Videography,	located	in	Kilgore,	TX,	is	a	company	that	provides	aerial	

drone	footage	for	consumers	and	businesses	alike.	The	services	we	provide	include	

but	are	not	limited	to:

•	Real estate	advertising

•	Land surveying

•	Commercial advertisement

•	Personal event	photography	and	videography

•	Commercial event	photography	and	videography

Ryan	Roberts	Videography’s	goal	is	to	operate	in	an	accident-free	environment	

while	serving	our	community.

Ryan	Roberts	Videography	is	owned	&	operated	by	myself	with	over	5	years	of	

combined	UAS/UAV/Drone	experience:

Ryan	Roberts

3616	CR	192	East

Kilgore,	TX	75662

(903)	746-2942

rrobertsvideo@gmail.com

II.	Relevant	Statutory	Authority

This	petition	for	exemption	is	submitted	to	fulfill	Congress’	goal	in	passing	Section	

333(a)	through	(c)	of	the	Reform	Act.	Congress	has	directed	the	FAA	“to	safely	

accelerate	the	integration	of	civil	unmanned	aircraft systems	into	the	national	

airspace	system.”	Pursuant	to	Section	333	of	the	Reform	Act,	the	FAA	Administrator	

is	to	consider	whether	certain	unmanned	aircraft systems	may	operate	safely	in the	

National	Airspace	(“NAS”)	before	completion	of	formal	UAS	legislation,	based	on	the	

following	considerations:

•	The	UAS’s	size,	weight,	speed,	and	operational	capability;

•	Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas	

•	Operation	of	the	UAS	within	the	visual	line	of	sight	of	the	operator.

If	the	Secretary	determines	that	such	vehicles	“may	operate	safely	in	the	National	

Airspace	System,	the	Secretary	shall	establish	requirements	for	the	safe	operation	of	

such	aircraft in	the National	Airspace	System.”
Additionally,	the	FAA	Administrator	has	general	authority	to	grant	exemptions	from	

its	safety	regulations	and	minimum	standards,	and	has	done	so	on	numerous	

occasions,	when	the

Administrator	decides	a	requested	exemption	is	in	the	public	interest.	A	party	

requesting	an	exemption	must	explain	the	reasons	why	the	exemption:	(1)	would	

benefit	the	public	as	a	whole,	and	(2)	would	not	adversely	affect	safety	(or	how	it	

would	provide	a	level	of	safety	at	least	equal	to	the	existing	rules).

The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue	

exemptions.	This	statutory	authority,	by	its	terms,	includes	exempting	civil	aircraft,	

as	the	term	is	defined	under	40101	of	the	Act,	from	the	requirement	that	all	civil	

aircraft must	have	a	current	airworthiness	certificate	and	those	regulations	

requiring	commercial	pilots	to	operate	aircraft in	commercial	service:

The	Administrator	may	grant	an	exemption	from	a	requirement	of	a	regulation	

prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any	of	sections.

III.	Qualifications	for	Approval	Under	Section	333	of	the	Reform	Act

The	proposed	operations	in	this	petition	for	exemption	qualify	for	expedited	

approval	under	Section	333	of	the	Reform	Act.	Each	of	the	statutory	criteria	and	

other	relevant	factors	are	satisfied.

The	proposed	operations	would	permit	Ryan	Roberts	Videography	the	use	of	small	

unmanned	aircraft systems	under	controlled	conditions	in	airspace	that	is:	(1)	

predetermined;	(2)	access	controlled;	(3)	enhanced	with	an	increased	level	of	safety	

beyond	that	existing	when	fixed	or	rotor	wing	aircraft are	used	to	accomplish	the	

same	purpose.

Ryan	Roberts	Videography uses	a	UAS	(DJI	Phantom	3	Advanced)	that	is	multi-rotor,	

weighing	less	than	55	pounds,	including	payload.	Under	normal	conditions,	it	

operates	at	speeds	less	than	50	mph	and	has	the	capability	to	fly,	hover,	and	move	in	

the	vertical	and	horizontal	plane.	Ryan	Roberts	Videography’s UASs	will	operate	in	

line	of	sight,	during	daylight	hours,	and	will	only	operate	within	a	sterile	area.	Ryan	

Roberts	Videography will	operate	at	or	below	400	feet	above	ground	and	will	file	a	

NOTAM	for	each	flight	operated	in	controlled	airspace.	All	required	permissions	and	

permits	would	be	obtained	from	territorial,	state,	county,	or	city	jurisdictions,	

including	local	law	enforcement,	fire,	or	other	appropriate	governmental	agencies	

prior	to	operating	a	UAS.

Given	the	small	size	of	the	UAS’s	involved	and	the	restricted	sterile	environment	

within	which	they	will	operate,	Ryan	Roberts	Videography’s	exemption	falls	within	

the	zone	of	safety	and	demonstrates	an	equivalent	level	of	safety,	in	which	Congress	

desired	the	FAA	to	permit	commercial	UAS	operations	by	exemption	pending	the	

completion	of	formal	legislation.	Also,	due	to	the	size	of	the	UASs	and	the	confined	

area	in	which	they	will	operate,	approval	of	the	exemption	presents	no	hazard	in	the	

National	Airspace	System.

Considering	the	clear	direction	in	Section	333	of	the	Reform	Act,	the	authority	

contained	in	the	Federal	Aviation Act,	as	amended,	the	equivalent	level	of	safety	

surrounding	the	proposed	operations,	and	the	significant	public	benefit,	the	grant	of	

the	requested	exemptions	is	also	in	the	public	interest.
IV.	Description	of	Proposed	Operations

To	assist	the	FAA	in	its safety	assessment	of	Ryan	Roberts	Videography,	’s	proposed	

UAS	operations,	below	is	a	summary	of	operational	limitations	and	conditions	that	

will	ensure	an	equivalent	or	higher	level	of	safety	to	operations	conducted	under	

current	regulatory	guidelines:

1.	The UAS will weigh less than 55 pounds,

2.	Flights will be operated within line of sight of the PIC and observer.

3.	Maximum total flight time for	each operational flight will be limited to the amount

of time	the	UAS	can	be	flown	and	still	maintain	a	reserve	battery	power	of	no	less	

than	25%.

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

5.	Minimum crew for each operation will	consist of the UAS Pilot in Command and a

Visual Observer.

6.	Prior to the operations	at a particular location, a site inspection will have been

conducted.

7.	All	UAS’s	will	be	maintained	in	accordance	with	inspection	programs	specified	in	

the	manufacturer’s	guidelines.

8.	The	PIC	and	VO	will	at	all	times	be	able	to	communicate	by	voice.

9.	The PIC,VO,&	any other operational personnel will have been fully trained prior to

having any	operational	responsibilities.

10.	All	required	permissions	and	permits	would	be	obtained	from	territorial,	state,	

county	or city	jurisdictions,	including	local	law	enforcement,	fire	or other	

appropriate	governmental	agencies.

11.	If	the	UAS	loses	communication	signal,	the	UAS	will	have	the	capability	to	return	

to	a	pre-determined	location	with	the	sterile	area	and	land.

12.	The	UAS	PIC	has	the	capability	to	abort	a	flight in	case	of	unpredicted	obstacles	

or	emergencies.

13.	Ryan	Roberts	Videography, by	following	FAA,	NTSB,	and	AFS-80	best	practices,	

will	assure	no individuals’	privacy	is	violated.

14.	Procedures	have	been	established	by	Ryan	Roberts	Videography	to	contact	ATC	

prior	to operating	in	airspace	other	than	G.

V.	Regulations	from	which	Exemption	is	requested:	

To	use	a	UAS	for	data	collection,	Ryan	Roberts	Videography	requests	relief	from	the	

following	sections	of	Title	14	of	the	Code	of	Federal	Regulations:

•	§61.101(e)(4)	and	(5)	and	§61.113(a)	Private	Pilot	Limitations:	Pilot	in	Command

Sections	61.101(e)(4)	and	(5)	and	61.113(a)	limits	private	pilots	to	non-commercial	

operations.	However,	because	the	aircraft will	not	carry	pilots	or	passengers	and	is	

limited	in	the	type	of	operation	and	the	area	of	operation,	a	private	pilot	can	achieve	

the	equivalent	level	of	safety	for	the	proposed	operations	as	a	commercial	pilot.	

First,	unlike	conventional	manned	aircraft,	UASs	are	remotely	controlled	by	a	

ground	based	pilot	operator	in	a	controlled	and	restricted	area.	Second,	the	aircraft

is	much	smaller	than	a	manned	aircraft that	the	level	of	risk	associated	with	its’	

operation	is	diminished	from	the	level	of	risk	associated	with	commercial	

operations	contemplated	by	part	61.	Therefore,	allowing	aircraft use	by	a	private	
pilot	as	the	PIC	meets	or	exceeds	the	present	level	of	safety	sought	by	14	CFR	

61.101(e)(4)&(5)	and	61.113(a).

•	§61.315(a)	Sport	Pilot	Limitations

Section	61.315(a)	limits	sport	pilots	to	non-commercial operations.	However,	

because	the	aircraft will	not	carry	pilots	or	passengers	and	is	limited	in	the	type	of	

operation	and	the	area	of	operation,	a	private	pilot	can	achieve	the	equivalent	level	

of	safety	for	the	proposed	operations	as	a	commercial	pilot.	First,	unlike	

conventional	manned	aircraft,	UASs	are	remotely	controlled	by	a	ground	based	pilot	

operator	in	a	controlled	and	restricted	area.	Second,	the	aircraft is	much	smaller	

than	a	manned	aircraft that	the	level	of	risk	associated	with	its’	operation is	

diminished	from	the	level	of	risk	associated	with	commercial	operations	

contemplated	by	part	61.	Therefore,	allowing	aircraft use	by	a	private	pilot	as	the	

PIC	meets	or	exceeds	the	present	level	of	safety	sought	by	14	CFR	61.315(a).

•	§91.7(a)	Civil	Aircraft Worthiness

Section	91.7(a)	requires	a	civil	aircraft to	be	in	an	airworthy	condition	for	operation,	

which	accordingly	includes	an	airworthiness	certificate	in	accordance	with	14	CFR	

part	21,	Subpart	H.	To	maintain	an	equivalent	level	of	safety,	the	PIC	will	ensure	that	

the	aircraft is	in	compliance	with	the	Operating	Manual	and	the	FOPM	prior	to	each	

flight.	Additionally,	the	Pilot	will	still	comply	with	91.7(b)	and	ensure	that	the	

aircraft is	in	condition	for	a	safe	flight.

•	§91.119(c)	Minimum	Safe Altitudes

Section	91.119(c)	establishes	safe	altitudes	for	operation	of	civil	aircraft over	other	

than	congested	areas.	Ryan	Roberts	Videography	requests	authority	to	operate	up	

to	400	AGL	over	uncontested	areas.	The	aircraft will	operate	in	a	limited	area	within	

pre-defined	boundaries	with	the	consent	of	the	landowner/controller	and	require	

that	all	non-essential	persons	remain	clear	of	the	flight	area	during	operations.	The	

PIC	will	make	a	safety	assessment	of	the	risk	of	operating	the	aircraft and	ensure	no	

undue	hazard	is	present	for	persons	or	property.	Considering	the	size,	weight	and	

speed	of	the	aircraft,	these	protections	will	ensure	the	equivalent	level	of	safety	of	

minimum	safe	altitudes.	Compared	to	flight	operations	for	manned	aircraft and	the	

lack	of	flammable	fuel,	any	risk	associated	with	the	proposed	aircraft operations	is	

far	less	than	conventional	aircraft operating	at	or	below	500	ft. AGL.	In	addition,	the	

low-altitude	operations	of	the	aircraft will	ensure	separation	with	conventional	

aircraft.

•	§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.”	The	DJI	

Phantom	3	Advanced does	not	have	a	barometric	altimeter,	but	instead	uses	GPS	

altitude	data.	Ryan	Roberts	Videography	establishes	an	equivalent	level	of	safety	by	

requiring	the	pilot	to	confirm	that	the	GPS	altitude	is	set	to	zero before	every	flight.

•	§91.151(a)(1)	Fuel	Requirements	for	Flight	in	VFR	Conditions

Section	91.151(a)(1)	requires	all	day	VFR	flights	to	operate	with	enough	fuel	to	fly	

to	first	point	of	intended	landing	and	then	for	at	least	an	additional	thirty	minutes.

The	batteries	that	power	Ryan	Roberts	Videography	unmanned	aircraft systems	

provide	approximately	23	minutes	of	powered	flight	time	and	therefore	unable	to	
meet	this	requirement.	However,	the	DJI	Phantom	3	Advanced has	a	low	battery	

alarm	along	with	a	critical	battery	limit	that	automatically	sends	the	aircraft back	to	

its	departure	point.	Also,	because	the	aircraft will	be	flying	in	a	confined	area	

without	the	presence	of	non-essential	persons	and	with	landowner/controller	

permissions,	an	equivalent	level of	safety	can	be	achieved	by	flight	planning	all	

flights	to	return	to	intended	landing	site	with	a	minimum	of	25%	reserve	power	in	

accordance	with	the	FOPM.

•	§91.405(a),	§91.407(a)(1),	§91.409(a)(1)	and	(2),	§91.417(a)	and	(b)	Maintenance	

Inspections

Sections	§91.405(a),	§91.407(a)(1),	§91.409(a)(1)	and	(2),	§91.417(a)	and	(b)	

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	Ryan	Roberts	Videography	operations.	

Ryan	Roberts	Videography	will	accomplish	maintenance	in	accordance	with	the	

operations	manual	and	FOPM.	The	Pilot	in	Command	will	ensure	that	the	aircraft is	

in	working	order	prior	to	flight	and	will	perform	some	maintenance	and	inspection	

of	the	aircraft and	“be	authorized	to	approve	the	aircraft for	return	to	service.”	

Additionally,	the	Pilot	in	Command	will	conduct	detailed	inspections	of	the	aircraft

every	10	hours	of	flight.	Maintenance	performed	by	the	PIC	is	limited	to	repairing

small	cracks	replacing	propellers,	and	updating	software	and	firmware.	The	

manufacturer	will	perform	all	other	maintenance. Ryan	Roberts	Videography will	

keep	a	log	of	maintenance	performed.	Moreover,	Ryan	Roberts	Videography	and	the	

PIC	are	most	familiar	with	the	aircraft and	best	suited	to	maintain	it	in	an	airworthy	

condition.

An	equivalent	level	of	safety	will	be	achieved	because	the	DJI	Phantom	3	

Professional	is	limited	in	size,	will	carry	a	small	payload	and	operate	only	in	

restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	arise,	the	aircraft

can	land	immediately	and	will	be	operating	no	higher	than	400	feet	AGL.

VI.	Privacy

There	is	little	concern	that	the	proposed	flights	will	cause	invasions	of	privacy	

because	flights	will	occur	over	private	or	controlled	access	property	with	the	

landowner’s	prior	consent	and	knowledge.

VII.	Public	Interest

Use	of	the	DJI	Phantom	3	Advanced drone	is	in	the	public	interest	because	it	is	safer	

for	people	and	structures	than	conventional	manned	aircraft.	First,	risk	to	the	flight	

crew	is	virtually	eliminated	by	using	an	unmanned	aircraft.	Second,	by	flying	a	small	
aircraft weighing	less	than	55	pounds	and	carrying	no	fuel,	risk to	persons	and	

structures	on	the	ground	is greatly	reduced.	Finally,	use	of	the	DJI	Phantom	3	

Advanced benefits	the	public	because	it	is	better	for	the	environment	through	

reduction	in	noise	and	environmental	pollution.

VIII.	Federal	Registry	Summary

Ryan	Roberts	Videography	seeks	an	exemption	from	the	following	sections	of	Title	

14	of	the	Code	of	Federal	Regulation:	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	commercially	operate	an	unmanned	aircraft system	for	

commercial	purposes	including	but	not	limited	to:	aerial	photography,	aerial	

videography,	land	surveying,	and	industrial	inspections.

As	established	by	the	UAS	exemptions	already	granted	by	the	FAA,	allowing	

commercial	operations	of	UASs	for	aerial	photography	and	videography	will	

enhance	safety	by	reducing	risk.	Conventional	aerial	photography,	aerial	

videography,	aerial	surveying,	and	aerial	inspections	using	manned	aircraft present	

avoidable	risks	to	flight	crew	and	persons	and	structures	on	the	ground	because	the	

aircraft is	flying	at	low	altitudes	with	large	amounts	of	fuel.	In	contrast,	a	UAS	

weighing	less	than	55	pounds	and	powered	by	batteries	eliminates	virtually	all	of	

that	risk given	the	small	size	and	lack	of	combustible	fuel.	Using	an	aircraft that	does	

not	have	emissions	also	eliminates	environmental	risks.	Therefore,	by	using	an	UAS	

for	the	purposes	outlined	by	Ryan	Roberts	Videography,	the	risk	to	persons	and	

structures	will	be	significantly	reduced.

IX.	Conclusion

Ryan	Roberts	Videography	requests	an	exemption	from	the	aforementioned	

sections	of	14	CFR.	The	exemption	is	in	the	public	interest	because	it	will	increase	

safety	for	persons	and	structures	and	Ryan	Roberts	Videography	will	provide	an	

equivalent	or	greater	level	of	safety	as	provided	for	in	the	applicable	14	CFR	

sections.