Laurie L. McCord, Section 333 Exemption Request

Laurie L. McCord

2285 Rolling Hills Drive

Covington, KY 41017

July 27, 2015

Federal Aviation Administration:

I am submitting my Petition for Exemption for Unmanned Aircraft Systems operations. I have been a 

private pilot since 2006. I take the skills and education for the safe operation of UAS, very seriously. 

My request is for a waiver of the sections identified below in an effort to operate a UAS in public for 

commercial purposes. I recognize the importance of extreme privacy as I have been in situations where I 

have had to adhere to an environment, and culture that is based on such privacy. I, Laurie L. Mccord,

would like to formally submit an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 

91.9(b)2, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a) 91.119, 91.121, 91.151(a), 91.203(a) 

and (b), 91.405(a), 91.407(a) (1), 91.409 (a) (2), and 91.417 (a) and (b) of title 14 Code of Federal 

Regulations (14 CFR). This proposal exemption would allow operation of unmanned aircraft systems 

(UAS) for the purpose of Aerial Videography, Aerial Photography and Aerial Survey to augment real 

estate listings in the Greater Cincinnati and Northern Kentucky area.

Regarding the Unmanned Aircraft PIC:

I will operate a UAS, more specifically the DJI Phantom III, which is an unmanned aircraft (UA or 

PHANTOM), comprised of an attached high definition camera and a transportable ground station. I hold 

a Commercial Pilot Certificate with more than two thousand hours of flight time. Having flown 

thousands of hours in a multitude of aircraft, I am well aware of the importance of pre- flight planning 

and the significance of being safety oriented. Safety is my number one priority in aviation. As a 

Commercial Pilot I have always been required to hold at least a second class FAA Medical Certificate to 

operate under those privileges. Flying a UAS is no exception when it comes to fitness of flight and I 

intend to operate the UAS as I would any aircraft, always being in peak physical and mental condition. 

This will allow for safe operations on the ground and in the air, just as it is done in manned aircraft. 

Regarding the Operation of the Unmanned Aircraft:

With my clear understanding of FAA regulations, my experience in flying in all kinds of airspace and my 

safety first attitude, I believe that I should be granted an exemption. I am well aware of the importance 

of safe flight operations and planning flight paths that minimize any overflight of crowds or in the 

vicinity of other manned aircraft. My request for an exemption is specifically to record digital video 

data, aerial photography data and any other aerial surveying of privately owned property. These images 

will assist the real estate agent and the owner in marketing the property to the public.

Preflight and post-flight checklists and UAS examinations will help detect any abnormalities prior to 

flight and after flight. Any UAS unable to satisfy safety checklists will be removed from service until the 

issue can be resolved. The UAS will not be operated above 200 feet AGL and will not be flown in wind 

conditions greater than eight knots (8kts). The UAS will operate in temperatures between 0 degrees 
Laurie L. McCord, Section 333 Exemption Request

Celsius and 40 degrees Celsius (32 degrees Fahrenheit – 104 degrees Fahrenheit) as that is the range for 

the craft. Flights outside those temperature parameters will not be attempted. Furthermore, the UAS 

will maintain at least the Basic VFR Weather Minimums prescribed in 14 CFR 91.155 and operations will 

only commence during visual meteorological conditions. 

If a property being enhanced by videography, photography or survey is within close proximity to a 

towered airport, I will call the control tower and request permission to operate the UAS. Upon contact 

with the control tower I will alert them to the location of the property to be filmed, photographed or 

surveyed and provide the proximity of that property to the airport. I will also give a minimum of a 24 

hour notice before filming or photographing the property. If permission is not granted, operations with 

not be conducted. 

Before operating within close proximity to another structure, building or person, the owner and/or 

those who live at the aforementioned will be given notice that aerial photography, videography or 

surveying will commence. Any complaint by a neighbor or member of the public worried about their 

privacy being invaded, will be ensured that only the property being videoed will be used for marketing 

purposes. If this is not sufficient, the DJI Phantom III will immediately be brought back to the ground 

and the videography, photography or surveying will cease until the complaint is resolved. 

The UAS will only be operated with direct line of sight visual contact between the pilot in command and 

the unmanned aircraft. This will further ensure safe operational control as the pilot in command will 

always have visual line of sight on the UAS in order to scan the airspace it is operating in so as to see and 

avoid other aircraft, airborne objects or objects on the ground. Moreover, I will operate in congested 

areas with another person (spotter) in order to help spot the UAS from other angles to verify operations 

will be conducted safely. The spotter who will assist will also be another trained and certificated pilot in 

order to more safely conduct operations. 

Additionally, in order to further enhance safety, flights will end when battery reserve reaches 25

percent. The UAS has a 15.2 volt battery, allowing flight operations for up to 23 minutes. I have also 

purchased a second battery allowing for an additional 23 minutes of flight time. Operations with the 

UAS will not occur under IFR conditions. It is my understanding that granting this request would not 

adversely affect safety since operations would be in accordance with current UAS rules. Prior to 

commencing operations, I, the operator will obtain a COA from the FAA.

Suggested Public Federal Register Summary: 

“The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under the new 

FAA ‘Summary Grant’ approach, announced April 9th, 2015 that will hasten the Section 333 exemption 

approvals for many commercial UAS operators prior to finalizing the small UAS proposed rules published 

this past February.”

It is my understanding that the FAA will still review each Section 333 petition individually. However, I am 

hoping that the agency will accept my particular petition, include it in the next summary grant and issue

an exemption to myself on the presumption that the FAA has already granted a previous exemption 

similar to this request.
Laurie L. McCord, Section 333 Exemption Request

Currently, the new interim policy includes the granting of a Certificate of Waiver or Authorization (COA) 

for flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh 

less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual 

line of sight (VLOS) of the pilots, and stay certain distances away from airports or heliports such as 5 

nautical miles (NM) from an airport having an operational control tower or 3 NM from an airport with a 

published instrument flight procedure, but not an operational tower; or 2 NM from an airport without a 

published instrument flight procedure or an operational tower; or 2 NM from a heliport with a published 

instrument flight procedure. It is also understood that the “blanket” 200- foot COA allows flights 

anywhere in the country except restricted airspace and other areas, such as major cities, where the FAA 

prohibits UAS operations.

UAS Description:

I am asking for an exemption for a UAS up to 55 pounds because I will be using a craft that will be flown

operationally, weighing less than ten pounds. More specifically, I will be operating a DJI Phantom III, 

which will be qualified as a UAS. The UAS can fly for up to 23 minutes in temperatures between 0 

degrees Celsius and 40 degrees Celsius. The UAS has a Sony EXMOR camera mounted on it with a 

gimbal. The remote control allows for a smartphone or tablet to be used in order to operate the drone 

with a live feed from the Sony camera mounted on it. This permits operation with a high level of safety. 

In the event a loss of communication occurs with the UAS, it will automatically rise up vertically to a safe 

height before beginning an automatic return to home function. The control signal may be reconnected 

in flight and the pilot can take over safe operations again if communication is reestablished. However, in 

the case of a GPS failure the craft will be able to be manually flown to a safe landing by the pilot. The 

craft operates electronically, carries no flammable fuel, has an integrated GPS pilot system, location 

information along with height in AGL, speed, battery life, has programmed no-fly zones for controlled 

airports and provides direction of travel distance from the pilot.

Section 333 Compliance and Appropriateness:

Based on the size of the UAS, experience of the pilot, and operational goals, this request appears to be 

well suited for approval using the current criteria outlined in Section 333 of the FAA Modernization and 

Reform Act of 2012 (including new interim policies).

It is my hope that you find that the enhanced safety achieved using an unmanned aircraft with the 

specifications described by the petitioner which carries no passengers or crew, rather than a manned 

aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the public interest.

Sincerely,

Laurie L. McCord

Laurie L. McCord