To: 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room Wl2-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

From: 

Stephen Warriner 

39 Pine St. 

PO Box 1819 

Edgartown, MA 02539 

508-259-3062 

stephen@mvweb.com 

Amendment to: 

Public Docket (No. FAA-2015-0978) 

.1_ 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform 

Act") and 14 C.P.R. Part 11, Stephen Warriner, an individual, seeks exemption from 

requirements of 14 C.F.R. § 21, Subpart H; 14 C.F.R. § 43.11; 14 C.F.R. § 91.103; 14 C.F.R. 

§ 91.105; 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 

14 C.P.R.§ 91.405(a) and (d); 14 C.P.R.§ 91.407(a)(l); 14 C.F.R. § 91.409(a)(2); 14 C.P.R. 

§ 417(a) and (b) to operate an unmanned aerial vehicle (UAV) in support of commercial 

aerial photography and videography of individual commercial, public, and residential 

properties and structures with owners/operators permission and appropriate authorization. 

The request for this exemption is in the Public Interest as there are many consumer 

applications for the services that can be provided by UAV that are currently conducted by 

manned aircraft. Using a UAV for many of these applications creates an environmentally 

friendly, lower cost solution to both the operator and consumer. These aircraft can be 

operated safely, and without significant financial impact to the operator or any person or 

property on the ground in the event of the loss of an aircraft. Utilizing these UA V will create 

a safe and more productive work environment, reduce environmental pollution and have a 

positive impact on the local economy, which is in the Public Interest. 

Stephen Warriner respectfully request that the FAA grant the following requested 

exemptions: 

14 C.P.R.§ 21, Subpart H; 14 C.P.R.§ 43.11; 14 C.P.R.§ 91.103;14 C.P.R.§ 91.105; 

14 C.P.R.§ 91.109; 14 C.P.R.§ 91.119; 14 C.P.R.§ 91.121; 14 C.P.R.§ 91.151(a); 

14 C.P.R.§ 91.215; 14 C.F.R. § 91.405(a) and (d); 14 C.F.R. § 91.407(a)(1); 

14 C.F.R. § 91.409(a)(2); 14 C.F.R. § 417(a) and (b). 

14 C.P.R. 21, Subpart H: Airworthiness Certificate 

Stephen Warriner requests an exemption from 14 C.P.R. 21, Subpart i-L This Subpart 

establishes the procedures for the issuance of an airworthiness certificate. Stephen Warriner 

requests an exemption from Part 21, Subpart H because the UAV is under 50 pounds 

' ' ' i. 
(including payload) and meets an equivalent level of safety pursuant to Section 333 of the 

Reform Act due to its small size, light weight, and restricted operating environment. 

14 C.F .R 43.11: Records for Inspections 

Stephen Warriner requests an exemption from 14 C.P.R. 43.11. This part provides that 

maintenance record entries be maintained, that the inspector list discrepancies, and to affix 

placards to the aircraft. Due to its small size the UAV proposed for use, does not have room 

for placards to be placed in or on it and no inspections for UA V have been certified by FAA 

at the present time. However, as a condition to the grant of the exemption, Stephen Warriner 

will perform the inspections and time replaceable items recommended by the manufacturer 

and keep records and log books of all maintenance and repairs. 

14 C.F .R 91.103: Preflight Action 

Stephen Warriner requests an exemption from 14 C.F .R. 91.103. This regulation requires 

each pilot to take certain actions before flight to insure the safety of flight. As FAA approved 

flight manuals will not be provided for the UAV, an exemption is needed. Stephen Warriner 

will follow the manufactures preflight inspection. 

14 C.F.R 91.105: Flight Crewmembers at Stations 

Stephen Warriner requests an exemption from 14 C.F .R. 91.105. Stephen Warriner requests 

an exemption from 14 C.P.R. 91.105 since this part is not applicable due to the UAV carrying 

no flight crewmembers. An equivalent level of safety will be maintained by ensuring the pilot 

does not change inflight. 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 

Department of Transportation 

Federal Aviation Administration 

Petitioner: Stephen Warriner 

Petition of exemption from sections of; 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

Description of relief sought; 

Stephen Warriner seeks an exemption for commercial operation of an unmanned aerial 

vehicle that is under 50 pounds including payload. 

The unmanned aircraft vehicle has an onboard camera system capable of acquiring high 

resolution data. 

Proposed operations will offer real estate aerial photography, videography and aerial 

surveying services for other commercial industries.