Drake Evans

3103 W Meadow Springs Dr

Apartment 2

Holland, MI 49424

231.343.2804

talk@drake-evans.com

drake-evans.com

Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 

14 CFR 21 subpart H 

14 CFR 45.23(b) 

14 CFR 61.113(a) and (b) 

14 CFR 91.7(a) 

14 CFR 91.9(b)(2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119(c) 

14 CFR 91.121 

14 CFR 91.151(a) 

14 CFR 91.203 (a) and (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a)(1) and (2) 

14 CFR 91.417(a) and (b) 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 

11, Drake Evans, operator of Unmanned Aircraft Systems (UAS), hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of designated UAS, provided such operations 

are conducted within and under the conditions outlined herein or as may be established by the FAA as required 

by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would 

provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and news gathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local 

government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to 

electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of 

an emergency or natural disaster only when the local authorities or government has requested it by contract or 

donation. 

6. Training to persons individually or belonging to both private and/or public organizations to increase 

awareness and improve safety for current and future UAS operations within the NAS. 

As described fully below, the requested exemption would permit the operation of designated UAS as set forth 

in this document under controlled conditions in the NAS that would be a) limited b) controlled c) predetermined 
and d) safe. Approval of this exemption would increase public awareness of UAS operations and enhance safety 

to aid in fulfilling the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national airspace system.” 

I plan to operate a UAS, the DJI Inspire 1 which is comprised of an unmanned aircraft (UA or Inspire 1) and a 

transportable ground station. The Inspire 1 is referred to as a quad-copter with a maximum gross weight of about 

6.5 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has 

a maximum airspeed of 22 m/s (ATTI mode, no wind). The Inspire 1 includes many features to maximize both 

safety and failsafe mechanisms including but not limited to GPS “return to home” in the case of signal loss and 

additional camera sensors that maintain orientation and relative location when and if GPS signal is lost (A full 

up-to-date manual for the DJI Inspire 1 as well as listing of all it’s saftey features can be found at http://download.

dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf).

Flights will always be conducted with the UAS Pilot (Drake Evans), a camera operator, and spotter to ensure safety 

is the number one priority. By adding a camera operator and spotter, there is always 2 people maintaining line of 

sight and allows the pilot full attention on the flight path and ensuring all FAA conditions are met.

Also, given the small size of the UAS’s involved and the restricted controlled environment within which they will 

operate, the applicant fits within that zone of safety (an equivalent level of safety) in which Congress envisioned 

that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to 

the size of the UASs and the controlled areas in which the relevant UASs will operate, approval of the application 

presents no national security issue.

By conducting safe operation of the UAS, and spreading both accurate knowledge and information of FAA 

regulations and requirements as well as general safety information on UAS operation, I believe there is benefit 

for all parties (Drake Evans, the FAA, and the general public).

Drake Evans proposes that the exemption requested herein apply to civil aircraft that have the characteristics 

and that operate with the limitations listed herein. These limitations provide for an exceptional level of safety 

to operation. These limitations and conditions to which Drake Evans agrees to be bound when conducting 

commercial operations under an FAA issued exemption including: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. Maximum total flight time for each operational flight will be 30 minutes. 

4. Flights will be terminated at 25% battery power reserve. 

4. Flights will be operated at an altitude of no more than 200 feet AGL

5. UAS operator will be trained and certified in the proper safety and operations of the UAS. 

6. The UAS will only operate within a controlled area as defined in the Procedures. 

7. The operator will post advisor notice around the controlled area. 

8. The operator will have been trained in operation of UAS generally and received up-to-date information on the 

particular UAS to be operated as required. 

9. If the UAS loses communications or loses its GPS signal, the UAS will have capability to return to a predetermined location within the Security Perimeter and land. 

10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are prepared 

to modify or amend any part of this request to satisfy the need for an equivalent level of safety. I look forward to 

hearing from your office. Please contact me at any time if additional information or clarifications are needed. 

Sincerely, 

Drake Evans