February 22, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: 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) & (b); 14 CFR 

91.7(a); 14 CFR 91.9(b)(2); 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) 

Dear Sir or Madam:

In order to provide safe and environmentally-friendly aerial videography and photography for public 

business interests pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 

CFR Part 11, I, Stephen Rector, would like to formally submit for exemptions from the listed Federal 

Aviation Regulations (“FARs”) to serve commercial interests relating to Unmanned Aircraft Systems 

(“UAS”). The exemption request shall only be conducted under the conditions outline within requests 

and as established by the FAA as required under section 333.

My specific exemption request relates to my usage of the UAS:

1. DJI Phantom 2 (DJI Phantom 2 http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.2_en.pdf)

2. DJI Phantom 3 Professional 

(https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.p

df )

The DJI series was selected as the UAS of choice for its proven track record of safely controlled flights as 

well as many safety features to ensure the safety of my clientele, the general public, and the environment. 

The safety features with these UAS includes, return home failsafe mode, GPS navigation, and LED light 

illumination. When used in accordance with the regulations outlined by the FAA, the DJI UAS can be 

operated safely and effectively by the Pilot in Command (“PIC”). The Phantom 2 weighs 1000 grams and 

the Phantom 3 weighs 1280 g. 

The approval of this exemption would pose no regional or national security issues. As such, regulated 

and controlled environments by the operator (Stephen Rector) will ensure the safety of the environment 

and humans by strictly adhering to FAA guidelines and the requests detailed in this publication. 

Proposed Operations:

The UAS outlined previously will be operated at an altitude no greater than 400 feet above ground level 

(AGL) restricted by GPS and at speeds below 30 knots (system limitations). Inspections of the UAS will 

be conducted on a regular basis both pre and post flight. Operations will not incur within a 5 mile radius 

of any airport reference point and will only proceed during daylight and wind speeds lower than 5 mph. 

Should meteorological conditions deem flight to be unsafe, I will not fly and document all aborted 
missions. Flights will be conducted during daylight hours and all flights will be line of sight operations

with an observer present. The UAS will not fly over any unprotected persons or moving vehicles. Each 

UAS weighs less than 3 pounds respectively, and is powered by lithium ion batteries with no combustible 

fuel. No crew will board the UAS and the units will be properly transported to and from all flight 

locations in accordance with the FAA. 

The exemptions requested within this publication would allow me (Stephen Rector) to operate the DJI 

Phantom 3 and the DJI Phantom 2 UAS for commercial purposes of:

1. agricultural photography and videography, 

2. aerial videography and photography as a service to public and business interests, including: 

3. wedding and private individual photography and videography

For evidence of previous exemptions granted by the FAA for similar usage and models of UAS (DJI 

Phantom 3 professional) I will reference cases Nos. 12058 & 12045. 

Specific Sections of 14 CFR for which I seek relief and reasoning:

14 CFR Part 21: Airworthiness certificates 

In relation to the weight, speed, size, operating altitude, and closed course operating conditions of the 

UAS and its given operations, I feel an exemption of 14 CFR part 21 subpart H Airworthiness Certificates 

is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and 

Section 333 of P.L 112-95 (Section 333).

14 CFR 45.23: Display of marks: general

Due to the small nature of the DJI series and because the UAS lacks a cabin, or cockpit, I would request 

exemption from the regulation above. I will make every effort to comply with the above regulations 

given the size of the UAS and will display “Experimental” along with my license number, should it be 

granted in the largest possible font.

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

14 CFR 61.11 a&b regulate that private pilots are limited to noncommercial operations. However, given 

previous the FAAs track record of previous exemptions grated for this section (No. 12045), it should be 

noted that individuals can achieve level of airmanship and safety required in the absence of becoming a 

commercially certified pilot. Additionally, given the safety features of the UAS’s outlined in my request 

for exemption, it should be noted that the risk to the general public and environment is significantly lower 

than traditional private commercial aviation activities. 

14 CFR 91.7: civil aircraft airworthiness

Currently there are no certifications that are applicable to my requested UAS’s. I, Stephen Rector, will 

take full responsibility for certifying that the UAS is airworthy in accordance with recommendations from 

the manufacture and personal judgment. Accurate maintenance records will be kept for the aircraft on 

hand and note of any damages to the UAS will be documented and addressed pre and post flight. Flight 

records including operating time and any issues experienced during flight will be kept.

14 CFR 91.9 (b) 2: Civil aircraft flight manual, marking, and placard requirements
In reference to previous exemptions (No. 12045) there are “no pilots or passengers on board the aircraft, 

and given its size, the regulation is inapplicable.” I, Stephen Rector, will maintain a safety/flight manual 

with to achieve an equivalent level of safety.

14 CFR 91.119C: Minimum safe altitudes

The FAA mandates that UAS shall not exceed an operating altitude of 400 feet above ground level. I will 

ensure that the DJI is calibrated properly to never exceed 400 feet AGL. These calibrations will be part of 

the preflight inspections. I will ensure that the UAS will not fly in congested areas or over unprotected 

individuals/animals or moving vehicles. 

14 CFR 91.121: Altimeter settings

The DJI series is equipped with GPS/Glonass technology that can be transmitted to a nearby tablet and 

spotter. These technologies will ensure an equivalent level of safety and range of operation. 

14 CFR 91.151 (a)(1): Fuel Requirements for flight in VFR conditions

The DJI is powered by lithium ion batteries which are made specifically for this UAS. The batteries are 

not rated for flight time longer than 25 minutes. Because of these restrictions, the UAS will be unable to 

comply with this requirement. Exemption is requested

14 CFR 91.203 (a) and (b): Civil aircraft: Certification

There are currently no provisions or procedures for regulations of airworthiness certificates for the 

previously mentioned UAS. By adhering to the FAA regulations stated within this document, it can be 

safely determined that an equivalent level of safety will be achieved through fail safe mechanisms aboard 

the UAS and self-regulation. 

14 CFR 91.405(a) Maintenance required, 14 CFR 91.407(a)(1): Operation after maintenance, Preventive 

maintenance, rebuilding, or alteration, 14 CFR 91.409(a)(1) and (2): Inspections & 14 CFR 91.417 (a) & 

(b): Maintenance records

In accordance with the operating manual and requirements by the manufacture, I, Stephen Rector, will 

ensure that all maintenance inspections of the UAS be performed both pre and post flight for the UAS’s 

outlined previously. 

Public interest and Public Safety:

Given the traditional mechanisms of areal and vehicular crop inspections, drone inspection of agricultural 

products in Oklahoma will allow for less impact on the environment as opposed to vehicular and 

pedestrian impacts in sensitive crop fields (the primary focus of my endeavors). Additionally, reduced 

greenhouse emissions, noise emissions, and public safety will increase with the reduction of helicopter 

inspections. Additional safety incidences will be mitigated by the DJI’s ability to distinguish “no fly 

zones” in major cities. The DJI series was selected because of its many inherent safety mechanisms as 

well as flight integrity that can be controlled by me, Stephen Rector.

Summary:

In summary, I, Stephen Rector, am seeking exemption from the following rules: 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) & (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 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). By granting exceptions to the above mentioned rules, I, 

Stephen Rector will be seeing to make my UAS services available to public and commercial interests. 

The FAA has authorized similar exemptions under no. 12045 and 12053. By granting the exception, I, 

Stephen Rector, will be able to provide services to interested clientele at reduced costs and increased 

safety in comparison to traditional manned helicopter services. My UAS meet and exceed all safety 

regulations outlined by the FAA. In addition to the safety measured outline in the exemption request, I, 

Stephen Rector, will additionally adhere to the below FAA mandates:

 Flying the DJI Phantom 2 & 3 safely in accordance with its operating manual

 Never exceeding 400 feet altitude AGL or exceeding speeds of 87 knots

 Craft will never exceed 30 knots (horizontal UAS limitations)

 Never fly within 5 nautical miles from an airport having an operation control tower

 Never fly within 2 nautical miles from a heliport with a published instrument flight procedure

 Crafts will never exceed 55 lbs including payload

 UAS will be inspected both pre and post flight in accordance with manufacture 

 The UAS will always be in visual line of sight of PIC (ONLY Stephen Rector) with an observer 

(VO)

 Not flying directly over unprotected persons or moving vehicles

 Not flying in weather conditions that will impair visibility, high winds, rain

 Not flying under the influence of drugs or alcohol

 Pre inspecting proposed flight area to ensure safety of the environment and human life

 Not flying over sensitive environments such as water treatment facilities, power stations, 

correctional facilities, etc.

 Adhering to and confirming local laws and regulations prior to flying over private property

 Never filming persons without explicit consent from all parties without invasion of privacy

 The PIC will ONLY be Stephen Rector

 Written or verbal consent will be obtained from all persons within 100 feet of flight operation 

 Written or verbal permits will be obtained from all territorial, state, or city jurisdictions including 

local law enforcement or other appropriate agencies when needed

 Should GPS be lost, craft will always return home autonomously

Thank you for your time in reviewing my application and I look forward to supporting and cooperating 

with the FAA in safe UAS operations. 

Sincerely,

Stephen Rector

217 NW 160th Ter.

Edmond, OK 73013

405-210-1743

rectorstephen@gmail.com