Petition for Exemption 14 CFR § 11.81 

From: 

 Michael R. Morton 

 925 Crowders Woods Dr. 

 Gastonia, NC 28052 

 (704) 460-9200 

 me@michaelrmorton.com

To:

Federal Aviation Administration 

I hereby submit a petition to receive an exemption or waiver from 14CFR § 11.81 

Section 333 UAS. 

My name is Michael Morton and I am a professional photographer specializing in real 

estate, architecture and nature/landscape images. I currently own a DJI Phantom 1 

quadcopter with a mounted GoPro Hero 3+ camera and a DJI Phantom 3 quadcopter 

with the DJI mounted camera system. 

I am seeking relief from section 333 in order to operate a Micro UAS on a commercial 

basis. The reason for this request is to take professional aerial video and photography 

for real estate agents, home builders, property development companies, and property 

owners. Since my business specifically provides these entities with professional video 

and photography, it is imperative that I provide my clients with the proper tools 

necessary to show each property they have for sale. 

These professional pictures and videos are an essential benefit in defining property 

value and assisting in the marketing and sale of property. This is a service that my 

clients are demanding because, in the sale of real estate, prospective buyers are 

requiring more and more information in order to make their decision about the property 

they are considering. As property values go up, it is necessary for prospective buyers to 

see what they are buying, and adequately assess the value of the property. In years 

past in order to get good aerial photos and video of a property, it required someone with 

a manned aircraft to fly above the property. The use of a Micro UAS to do that job 

increases the safety of the public by reducing the risk of a large aircraft crash, creating a 

safer environment by not adding toxins to the air, reducing the amount of large aircraft in 

our airspace, doesn't incite unintentional fear to animals on the ground, and allows 

closer to the ground flights without disturbing the land or plant life. The use of a Micro 

UAS will also allow prospective buyers of the property views of lower elevation terrain 

that wasn't possible with larger aircraft. 

I have many hours of flight using these Micro UAS systems as a hobbyist and believe 

that this will allow me to safely operate the quadcopter.
The following are the specifications of the Micro UAS to be used. 

Hardware: 

Size 14inches in Diameter including propellors 

Weight under 4 lbs with mounted cameras 

Transmitter operating frequency is 5.728GHz-5.8GHz. 

Range Extender that operates at 2412-2462MHz. 

Travel speed of 35.79 mph with no wind

Communication Distance of 985 Feet with Rage Extender 

Installed Software: 

Virtual Radar aircraft locator 

GPS auto-pilot system for position holding, provides altitude lock along with 

stable hovering

GPS return to take off if communication is broke or low battery is detected

No Fly Zone feature turns GPS off in no fly zones ( updated upon connection to 

internet) 

In studying the information provided in the document located here: 

https://www.faa.gov/regulations_policies/rulemaking/media/021515_sUAS_ 

Summary.pdf

I am certain that I will meet or exceed those guidelines with the following specifications 

at which I will be flying the Micro UAS. 

Based on the equipment listed above we will operate Micro UAS that weighs less 

than 4 lbs

The VLOS (Visual Line of Sight) rule for my company is limited to an up and 

down motion no more than 300-400 feet of controller and operator. 

Due to the close proximity of the flights the Micro UAS will be able to be seen at 

all times without any additional monitoring equipment other than standard human 

eye vision

Flight of the Micro UAS will be done with the permission of all parties associated 

with the property that will be filmed and at no time will I fly the Micro UAS directly 

over a person without prior knowledge and permission 

The Flight of the Micro UAS will not be performed during non-daylight hours and 

will only be flown in conditions that allow the Micro UAS to be seen by the 

operator at all times

Although a First Person view camera will be used in the aid of taking pictures it 

will not be used to guide the flight 

The limitation of the Micro UAS to be flown at no more than 35mph we find that it 

is not necessary to fly it more than 15-20mph
The Micro UAS will not be flown any higher than 300 FT above the surface it is 

being flown over or Class G operations 

The Micro UAS will be inspected prior to every flight for safe operation including 

but not limited to battery condition, operations of electric motors, gps system, IR 

Controller, propellers, and WiFi connection between Micro UAS and Controller. 

Based on Software installed the Micro UAS will not be flown within a 5mile radius 

of any commercial airstrip. 

Safety will be priority over pictures. If any flight will pose a safety hazard to 

anyone, animals, or the environment the flight will be immediately cancelled until 

such time can be deemed safe.

Operator will maintain a GPS signal with the Micro UAS at all times during the 

flight. If connection is broken the equipment's built in GPS system will return the 

Micro UAS to the initial take off point and land it safely. If that system is broken 

for any reason an emergency landing will take place lowering the Micro-UAS to 

the ground. 

Furthermore, by following the above operational limitations that I have imposed on 

flights, I will not be posing any kind of harm to the public, environment, or to wildlife. 

Since I will meet or exceed the operational requirements that are set forth to be 

enforced, I hereby request that I be granted an exemption. 

Please contact me with the above contact information if you need any further 

documentation.