Todd W. Brown

1006 Englewood Road

Cleveland Heights, Ohio, 44121

(216)469-0444

tbrown@audica.us

Website: www.ToddWBrown.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, Todd W. Brown, 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 public 

events and promotional material.

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 PHANTOM 2 VISION+ which is comprised of an 

unmanned aircraft (UA or Phantom 2 Vision+) and a transportable ground 

station. The Phantom 2 Vision+ is referred to as a quad-copter with a maximum 

gross weight of about 3 pounds. It is equipped with four rotors that are driven by 

electric motors powered by batteries. The UA has a maximum airspeed of 16 

m/s.

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 UAS and the controlled areas in which 

the relevant UAS will operate, approval of the application presents no national 

security issue. Given the following, the grant of the requested exemptions is 

clearly in the public interest: Todd W. Brown 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 operations. These limitations and conditions to 

which Todd W. Brown 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 15% battery power reserve.

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

5. UAS operator will be trained 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 pre-determined 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 working with 

your office. Many thanks in advance for your consideration. Please contact me 

directly at any time if additional information is needed.

Sincerely,

Todd W. Brown