February 15, 2016

Jeff Rasco

22 Knight Ave

Sequim WA 98382

360-809-0793

rasco@olypen.com

Federal Aviation Administration:

I, Jeff Rasco, am writing pursuant to Section 333 of the FAA Modernization and 

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

that I, Jeff Rasco, an owner and operator of small unmanned aircraft, be 

exempted from the Federal Aviation Regulations (FAR) listed below that I may 

operate a small ultra light weight unmanned aircraft system (UAS) commercially 

in airspace regulated by the Federal Aviation Administration (FAA) in accordance 

with FAA UAS Regulations & Policies. I currently hold a commercial, instrument 

fixed wing and commercial rotorcraft license. 

The requested exemption would permit me, Jeff Rasco, to conduct commercial 

operations of the UAS meeting or exceeding the operational safety requirements 

set forth in Section 333. Commercial operation of the UAS equipped with a 

camera would be used for the following: Aerial photography and/or video for print 

publication, insurance, real estate, utility inspection, land surveying, engineering, 

television, public events, cinematography, news gathering, advertising, utility 

inspections, search and rescue, security, aerial mapping and training .

Traditional methods of aerial photography and video are not viable options for the 

average consumer as they are not cost effective and involve risks to everyone 

involved. A UAS operation is more affordable and safer for the community and 

better for the environment than airplanes or helicopters. A UAS does not carry 

flammable fuel, emit carbon dioxide or hold a pilot, crew or passengers.

This proposed exemption would allow me operation of the UAS for the purpose 

of aerial photography and video as a service to the public/business interests. 

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

Exemption Nos. 11062, 11109, 11112, 11213 and 12645.
UAS to be utilized will include the Quanum Nova, Cheerson CX-20, DJI Phantom 

2 and DJI Phantom 3. These UAS will be equipped with detachable camera and 

will be transported in proper storage. These UAS are selected because they 

have proven reliable flying capabilities managed by gyro stabilized flight, GPS 

aided navigation, a compass, blinking LEDs and failsafe mode for returning 

home. This will act to further safety protocols exclusive to lightweight UAS 

specific to video and photography usage as I, Jeff Rasco, record flight data and 

other information gained through permitted flight operations to share with the 

FAA through any required FAA reports to assists with future protocol and safety

regulations.

I am submitting a request for an exemption from the following regulations: 

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.23(a) & (c)

14 C.F.R. 61.101(e) (4) & (5)

14 C.F.R. 61.113(a)

14 C.F.R. 61.315(a)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151(a)(1)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409(a)(1) & (2)

14 C.F.R. 91.417(a) & (b)

Specific section or sections of 14 CFR which I seek relief and the reason I

seek relief:

14 C.F.R. Part 21: Airworthiness Certificates

I am requesting relief base on the given size, weight, speed and limited operating 

area associated with the UAS to be utilized. A UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than conventional aircraft operating 

with an airworthiness certificate.

14 C.F.R. 45.23(b): Display of marks: general

The UA does not have a cabin, cockpit, pilot station, fuselage, boom, or tail on 

which to mark certain words or phrases. Further, the two inch lettering is not 

practical to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. An equivalent level of safety will be maintained by 

making the lettering as large as practical.
14 CFR 61.23(a) & (c): Operations requiring a medical certificate

This regulation is intended for a pilot in command of an aircraft and not a UAS.

An equivalent level of safety will be maintained by insuring the PIC has a valid 

driver’s license.

14 CFR 61.101(e) (4) & (5): Recreational pilot privileges and limitations.

I request relief to the extent necessary to allow a PIC holding a recreational pilot 

certificate to conduct the proposed UAS flight operations for compensation or 

hire. An equivalent level of safety will be maintained because the PIC of the UAS 

will be proficient and abide by all rules specified in the requested exemption.

14 C.F.R. 61.113(a): Private pilot privileges and limitations: Pilot in command

I request relief to the extent necessary to allow a PIC holding a private pilot 

certificate to conduct the proposed UAS flight operations for compensation or 

hire. An equivalent level of safety will be maintained because the PIC of the UAS 

will be proficient and abide by all rules specified in the requested exemption.

14 C.F.R 61.315(a) Privileges and limits of my sport pilot certificate

I request relief to the extent necessary to allow a PIC holding a sport pilot 

certificate to conduct the proposed UAS flight operations for compensation or 

hire. An equivalent level of safety will be maintained because the PIC of the UAS 

will be proficient and abide by all rules specified in the requested exemption.

14 C.F.R 91.7 (a): Civil aircraft airworthiness

Currently there is no airworthiness certificate applicable for the UAS in question.

The use of safety check lists to conduct inspections prior to each flight will 

provide an equivalent level of safety.

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard 

requirements

I am requesting relief from this regulation because there is no pilot on board this 

aircraft to read a flight manual. Given the size of the UAS, this regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a 

safety/flight manual with the operator.

14 C.F.R. 91.119(c): Minimum safe altitudes

I will ensure that UAS do not operate any higher than 400 feet above ground 

level. I will not fly over congested areas. I will plan operations before hand, for 

proper flight safety, and proper height analysis as to avoid collisions.

14 C.F.R. 91.121: Altimeter settings

The UAS is too small to accommodate an altimeter and there is no pilot onboard 

to read one. An equivalent lever of safety will be maintained by using GPS to 

determine altitude.
14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions

The UAS that I will fly are powered by electricity, using lithium polymer batteries 

that currently have a flight limit of approximately no more than 20 minutes. 

Therefore, due to the limitations of the batteries, it is not possible to comply with 

this regulation. Safety will be maintained by insuring that before each flight there 

is enough power for the UAS to conduct the flight and to operate after that for at 

least five minutes or greater if recommended by the manufacturer. 

14 C.F.R. 91.405(a): Maintenance Required, 14 C.F.R. 91.407(a)(1): Operation

after maintenance, preventive maintenance, rebuilding, or alteration, 14 C.F.R. 

91.409(a)(1) and (2): Inspections &14 C.F.R. 91.417 (a) and (b):

Relief is requested from these regulations because the UAS does not have an 

airworthiness certificate. Trained technicians will be utilized to perform 

maintenance or alterations. Preflight inspections of the UAS before each flight as 

outlined in the operating documents will be conducted and I will also follow 

manufacturer recommendations from said operating documents to maintain 

safety.

Public Interest

Aerial video and photography as an available service to the public allows for a

less expensive method to capturing imagery than aircraft and helicopters. Aircraft 

and helicopters are expensive, create lots of noise, and are much more 

hazardous due to size and combustible fuel.

Summary

I am seeking exemption from the following rules:

14 C.F.R. Part 21 

14 C.F.R. 45.23(b)

14 C.F.R. 61.23(a) & (c)

14 C.F.R. 61.101(e) (4) & (5)

14 C.F.R. 61.113(a) 

14 C.F.R. 61.315(a)

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b)(2)

14 C.F.R. 91.119(c)

14 C.F.R. 91.121

14 C.F.R. 91.151(a)(1)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

14 C.F.R. 91.409(a)(1) & (2)

14 C.F.R. 91.417(a) & (b)

With the exemptions of the mentioned rules I, Jeff Rasco, will be seeking to make 

my drone photography and video services available to the public. I will operate 

the UAS in a safe manor, including but are not limited to: 
● UAS weighing less than 55 lbs.

● Not operating at night

● Flying below 400 feet AGL

● Conducting a pre-flight inspection prior to each flight

● Keeping UAS in visual line of sight at all times when in operation 

● Using an observer to assist 

● Remaining well clear of and not interfering with manned aircraft 

operations, and avoiding other aircraft and obstacles at all times 

● Not intentionally fly over unprotected persons or moving vehicles 

● Contacting the airport and control tower before flying within 5 miles of 

an airport

● Not flying in adverse weather conditions such as high winds or reduced 

visibility 

● Not flying under the influence of alcohol or drugs 

● Ensuring the operating environment is safe 

● Not flying over sensitive infrastructure or property such as power 

stations, water treatment facilities, correctional facilities, etc. 

● Checking and following all local laws and ordinances before flying over 

private property 

● Not conducting surveillance or photograph of persons in areas where 

there is an expectation of privacy without the individual's permission. 

Thank you for your consideration. 

Respectfully,

Jeff Rasco

22 Knight Ave

Sequim WA 98382

360-809-0793

rasco@olypen.com