Bobby G. Craft II

3273 Mandrake Blvd

Commerce Michigan 48382

bobby_craft@comcast.net

Summary

Bobby G. Craft II, pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA), hereby petitions exemption from certain requirements of 14 CFR. The exemption will

permit Bobby G. Craft II to operate a small professional Unmanned Aircraft System (UAS) (3DR

SOLO, or an equivalent or smaller UAS, under 55 lbs.), for the commercial purpose of conducting

aerial video and photography of construction sites, residential and commercial real estate,

agricultural areas, public landscapes (unless prohibited) and special events within the United

States. 

Sections of 14 CFR from which I seek exemption:

Part 21, Subpart H Airworthiness Certificates

45.23 Display of marks; general.

61.113 (a) and (b) Private pilot privileges and limitations: Pilot in command

91.7 (a) Civil aircraft airworthiness

91.9 (b) (2) Civil aircraft flight manual, marking, and placard requirements

91.103 Preflight action

91.109 Flight instruction; Simulated instrument flight and certain flight tests

91.119 Minimum safe altitudes: General

91.121 Altimeter settings

91.151 Fuel requirements for flight in VFR conditions

91.203 (a) & (b) Civil aircraft: Certifications required

91.205 (b) Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument

and equipment requirements.

91.215 ATC transponder and altitude reporting equipment and use

91.405-91.417 Maintenance & Inspections

In consideration of the speed, weight, size, and limited operating time spans and geography, the

UAS meets the conditions of Section 333 (FMRA) and will not require an airworthiness certificate,

markings, nor the maintenance and inspections associated with manned aircraft. Being a battery

powered aircraft, flight times are severely limited to less than 30 minutes and will only be flown

within the line of sight during stable weather conditions. Any repairs to the UAS will be done by the

manufacturer or authorized professionals. The UAS will be used as part of my employment with

great potential for economic improvement of my situation. Flights will not involve the carrying of

passengers or property.

An equivalent level of safety will be met by strict adherence to preflight checklists, regular

inspections and maintenance, flight practice and safe flight techniques. Bobby G. Craft will ensure

that the aircraft is in an airworthy condition prior to every flight and that weather, environmental,

structural, and human conditions are such that a safe flight can be successful. Additionally, the

UAS that I intend to fly has built-in safety features including GPS, barometric pressure sensors,

return-to-home, limits on flight altitude of 400 feet, real time flight video to smartphone or tablet in

the app which includes detailed flight information and battery life indicators and warnings, on

screen map, and flight logs. The app also includes flight training simulators to help in gaining

confidence and experience.

The public interest is served in that aerial video, photography, and surveying can be achieved

safely, efficiently, and economically. UAS flights within authorized air pace, rather than airplane or
safely, efficiently, and economically. UAS flights within authorized air pace, rather than airplane or

helicopter flights, reduce congested air space, are much more economical, and use minimal

amounts of energy and no fossil fuels. UAS flights cause less noise and air pollution.

Privacy rights of private citizens, companies, and government agents and facilities will be

respected. Conditions of Section 333 will be strictly observed.