August 3, 2015

Exemption No. 12288

Regulatory Docket No. FAA–2015–2124

Mr. Bronson Cheeks

House Fly, LLC

561 Hunt Road

Tarpon Springs, FL 34688

Dear Mr. Cheeks:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated May 21, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of House Fly, LLC (hereinafter petitioner or operator) for an exemption. The

petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial 

videography and cinematography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are a DJI Inspire 1 and DJI Phantom 3.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
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aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1

. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying 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.

Having reviewed your reasons for requesting an exemption, I find that—

• They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

• The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

• A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Bronson Cheeks dba House Fly, LLC is granted an 

exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 

91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 

91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform 

aerial data collection. This exemption is subject to the conditions and limitations listed 

below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Mr. Bronson Cheeks dba House Fly LLC is hereafter referred to as 

the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 and 

DJI Phantom 3 when weighing less than 55 pounds including payload. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this 

exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 
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limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.
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14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.
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22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.
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If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on August 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

May 21, 2015 

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, S.E.

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14

C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109;

119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam, 

I, Bronson Cheeks dba “House Fly, LLC”, am writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained within 14 C.F.R. 

11, to request that I, Bronson Cheeks, an owner and operator of small unmanned aircraft, 

be exempted from the Federal Aviation Regulations (“FARs”) listed below so that I, 

Bronson Cheeks, may operate my unmanned aircraft system (“UAS”) commercially in 

airspace regulated by the Federal Aviation Administration (“FAA”). 

As described herein I, Bronson Cheeks, an insured member of the AMA (Academy of 

Model Aeronautics) am experienced in flying hobby helicopters/planes for recreational

purposes. Currently using a DJI Inspire 1 Quadcopter1 and the DJI Phantom 3 

Quadcopter2 with intent for aerial videography/cinematography to enhance academic 

community awareness for individuals and companies unfamiliar with the geographical 

layout of the West Florida area, and augment real estate listing videos; following 

exemption and approval by the FAA. Thereby enhancing their academic research 

experience for the West Florida Area. I have flown RC Helicopters/Planes/Quadcopters 

for over three (3) years without incident. Committed to safety with each flight. My 

exemption request would permit operation of ultra light weight, UAS(s) in tightly 

controlled and limited airspace. 3 Predetermined in areas away from general public, 

airports, heliports and vehicular traffic for community videos, and within property 

boundaries for individual homeowner real estate listing videos/photos. Currently, similar 

lightweight, remote controlled UAS's are legally operated by unmonitored amateur 

hobbyists with no safety plan or controls in place to prevent catastrophe. I, Bronson 

Cheeks, have personally instilled safety protocols and 

1 Appendix A – DJI Inspire 1 Operator Manual 

2 Appendix B – DJI Phantom 3 Operator Manual 

3 Appendix C – Tampa — Tampa Florida area VFR radius maps Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption 

Petition

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

controls4 to avoid and prevent public hazard, as well as manned aircraft

hazards/catastrophe. This will act to further safety protocols exclusive to lightweight

UAS's specific to real estate video and photography usage as I, Bronson Cheeks, 

record flight data and other information gained through permitted flight operations to 

share with the FAA through any required FAA reports to assist with future protocol and 

safety regulation. 

Granting my request comports with the Secretary of Transportation’s (FAA 

Administrator’s) responsibilities and authority to not only integrate UAS's into the

national airspace system, but to “...establish requirements for the safe operation of such 

aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the

Reform Act specific to the use of UAS's for Cinematography/Photo purposes. Further I, 

Bronson Cheeks, will conduct my operations in compliance with the protocols described 

herein or as otherwise established by the FAA. 

For the reasons stated below I, Bronson Cheeks, respectfully request the grant of an 

exemption allowing me to operate ultra lightweight, remote controlled UAS’s for 

academic community awareness to benefit/stimulate attraction to the West Florida

area and to enhance real estate listing videos for homeowners who cannot afford 

expensive manned aircraft for the same purpose. Both of which will promote local

economic growth through increased employment and increased tax base. Both with 

public safety in mind by keeping heavier manned aircraft containing combustible fuel

that that poses potential public hazard. 

Name and Address of the Petitioner

Bronson Cheeks dba “House Fly LLC” 

561 Hunt Road Suite B 

Tarpon Springs, FL 34688 

Mobile: (727) 412-2689 

Email: HouseFlyFlorida@gmail.com

Regulations Petitioner Petitions for Exemption, If Such Regulations Apply to

SUAVs

14 CFR Part 21 14 C.F.R. 91.109 14 CFR 91.405 (a)

14 C.F.R. 45.23(b) 14 C.F. R. 91.119 14 CFR 407 (a) (1)

14 CFR 61.113 (a) & (b) 14 C.F.R. 91.121 14 CFR 409 (a) (2) 

14 C.F.R. 91.7 (a) 14 CFR 91.151 (a) 14 CFR 417 (a) & (b) 

14 CFR 91.9 (b) (2) 14 CFR 91.203 (a) & (b) 

14 C.F.R. 91.103

_________________________

4 Appendix D - Personal Protocols and Controls 

Bronson Cheeks, Cinematographer Tarpon Springs, FL - Section 333 Exemption Petition

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

The Extent of relief sought and the Reason He Seeks Such Relief:

I, Bronson Cheeks, submit this application in accordance with the Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any currently applicable FARs operating to prevent

me, Bronson Cheeks, to pursue commercial--cinematic, academic and other flight

operations within the national airspace system. The Reform Act in Section 332 provides 

for such integration of civil unmanned aircraft systems into our national airspace system

as it is in the public’s interest to do so. My, Bronson Cheeks’, ultra light weight UAS 

meets the definition of “small unmanned aircraft” as defined in Section 331 and 

therefore the integration of my ultra light weight UAS is expressly contemplated by the 

Reform Act. I would like to operate my ultra lightweight UAS prior to the time period by 

which the Reform Act requires the FAA to promulgate rules governing such craft. 

Thereby, providing direct experience and valuable information for formal regulation that

can be administered uniformly to all real estate related UAS aerial video and 

photography. The Reform Act guides the Secretary in determining the types of UAS's 

that may operate safely in our national airspace system. Considerations include: The

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will be

operated near airports or heavily populated areas; and, Whether the UAS will be

operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items reflect in favor of an 

exemption for me, Bronson Cheeks. My UAS utilizes four (4) counter-rotating 

propellers for balance, control and stability. My UAS is equipped with GPS and auto 

return safety technology. Weighing less than ten (10) pounds (far below the maximum 

55 pound limit); including camera with gimbal. 

I, Bronson Cheeks, considers safety as foremost with each flight. My small unmanned 

aircraft is designed to hover in place via GPS and operate in less than a 24 knot (15 

mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 

16 kph (10 mph). Built in safety systems include a GPS mode that allows my UAS to 

hover in place when radio control inputs are released. With three modes to choose from, I 

utilize the Smart Mode5 for aerial videography/photography. This is the safest, most 

reliable and stable mode to prevent accident and hazard. When pilot communication is 

lost UAS is designed slowly descend to point of take off. I do not operate my UAS near 

airports, Hospitals nor Police heliports, and do not operate near areas where general

public is within fifty to one hundred (50-100) yards depending on location, conditions 

and weather. I am constantly on alert for any manned aircraft (Police/Medical

helicopters, etc.) and prepared to land/abort immediately to the nearest and safest

ground point should a manned aircraft approach my location or I suspect manned 

aircraft may approach near my location. My UAS is capable of vertical and horizontal

operations, and are flown only within my line of sight of me, as the remote control pilot. 

Utilizing battery power rather than combustible fuels, flights generally last between 

eighteen (18) to twenty (20) minutes, with an altitude under one hundred fifty (150) feet. 

5Smart Mode includes GPS Geofence radius for operation, position hold, self-leveling, altitude command, return home feature or land

in the event of communication interruption between RC transmitter and UAS. See Appendix A 

Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption Petition

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

I, Bronson Cheeks, utilize a fresh fully charged battery with each flight as a safety 

precaution; full flight time limit for each battery is eighteen (18) to twenty (20) minutes 

as tested. I do not operate my UAS at or below manufacturer recommended minimum

charge levels for operation; preferring to remain well within a safe operating range to 

insure adequate communication between radio control and UAS to eliminate potential for 

crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure

replacement for sufficient safe level of operation. I do not believe in taking risk that may 

cause a crash, that could create hazard to the public/property/manned aircraft. I have

clocked over 180+ hours of hobby level flights for future commercial use to gain 

familiarization with the characteristics of this specific UAS's performance under different

temperature and weather conditions. I also practice computerized simulated flights to 

maintain adequate skills and response reflex time. I, Bronson Cheeks, am extremely 

cautious when operating of my UAS/ultra light weight unmanned aircraft and will not

“create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 

(b). Given the small size and weight of my UAS it falls well within Congress’s 

contemplated safety zone when it promulgated the Reform Act and the corresponding

directive to integrate UAS's into the national airspace system. The UAS, used in hobby 

flight, has a demonstrable safety record and does not pose any threat to the general public

or national security. 

How Bronson Cheeks’ Request Will Benefit the General Public:

Aerial videography for geographical awareness and for real estate marketing has been 

around for a long time through manned fixed wing aircraft and helicopters. However, For 

small budget real estate companies and average homeowners the expense of such aerial

videography is cost prohibitive. Only large companies and high end Realtors or luxury 

homeowners can afford to absorb such expenses. Depriving non-luxury homeowners 

and lower budget Realtors from a valuable marketing tool. Manned aircraft pose a threat

to the public through potential catastrophic crash that the community has experienced in 

the past with military, medical and news/tourism helicopter crashes within the city of 

Tampa and Tarpon Springs. Each resulting in loss of life. Each with combustible fuel that 

exploded and burned on impact. Police helicopters have made emergency hard landings 

within city limits. My UAS pose no such threat since size and lack of combustible fuel 

alleviates any potential threat to the public. 

Congress has already proclaimed that it is in the public’s interest to integrate

commercially flown UAS's into the national airspace system, hence the passing of the

Reform Act. Granting my, Bronson Cheeks, exemption request furthers the public 

interest through academic/visual awareness of the geographical benefits in and around 

the West Florida area. My ultra lightweight UAS is battery powered and creates no 

emissions that can harm the environment. The consequence of my ultra light weight UAS 

crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, 

contain combustible fuel and can cause catastrophic devastation to the public 

Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption Petition

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

The public’s interest is furthered by minimizing ecological and crash threat by permitting 

aerial video/photo capture through my battery operated ultra lightweight UAS's. 

Permitting me, Bronson Cheeks, to immediately fly within national air space furthers 

economic growth. Granting my exemption request substantially furthers the economic

impact for the West Florida community for companies looking to relocate or build in the

West Florida area as well as individuals looking to relocate for career advancement 

through academic and geographical awareness. Both of which serve as a stimulus to 

the community. 

Reasons Why Bronson Cheeks’ Exemption Will Not Adversely Affect Safety 

And How The Exemption Will Provide a Level of Safety At Least Equal To 

Existing Rule:

My, Bronson Cheeks, exemption will not adversely affect safety. Quite the contrary, 

for the reasons stated permitting me, Bronson Cheeks, to log more flight time in 

FAA controlled airspace, with communication with the FAA, will allow me to 

contribute to the innovation and implementation of new and novel, as of yet 

undiscovered safety protocols for UAS Pilots that can be embraced for development 

in cooperation with the FAA. In addition I, Bronson Cheeks, submit the following 

representations of enhancements to current aerial videography and photography: 

• My UAS weighs less than 10 pounds complete with a small ultra light weight

high camera 

• I only operate my UAS below 200 feet (well within the 400 foot permissible

ceiling set by the FAA Modernization and Reform Act of 2012); 

• my UAS only operate for 18-20 minutes per flight; 

• I land my UAS prior to manufacturer recommended minimum level of battery 

power; 

• I pilot my UAS through remote control only by line of sight; 

• My UAS has GPS a flight safety feature whereby it hovers and then slowly lands 

if communication with the remote control pilot is lost; 

• I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols; 

• I only operate in reasonably safe environment that are strictly controlled, are

away from power lines, elevated lights, airports and actively populated areas; 

• I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance; 

• I always obtains all necessary permissions prior to operation; and, 

• I have procedures in place to abort flights in the event of safety breaches or 

potential danger. 

Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption Petition 

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

My, Bronson Cheeks’, safety protocols provide a level of safety equal to or exceeding 

existing rules. It is important to note that absent the integration of commercial UAS into 

our national airspace system, helicopters are the primary means of aerial video and 

photography for community awareness and real estate. While the safety record of such 

helicopters is remarkably astounding, there has been local incident involving loss of life

as well as extensive property damage; it is far safer to operate a battery powered ultra

light weight UAS. 

• First, the potential loss of life is diminished because UAS's carry no people on 

board and only operated in specific areas away from mass populations. 

• Second, there is no fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished. 

• Third, the small size and extreme maneuverability of my UAS allow me to 

remotely pilot away from and avoid hazards quickly and safely. 

• Lastly, given its small size and weight, even when close enough to capture

amazing images, my UAS need not be so close to the objects they are focused 

on through the technology and use of post editing software allowing pan and 

zoom. 

Accordingly, my UAS has been experimentally operated for familiarization/competency 

and will continue to operate at and above current safety levels. 

A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 & 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation to 

FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, 

Bronson Cheeks’, UAS permits exemption from Part 21 because my UAS meets 

(and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform 

Act. The FAA is authorized to exempt aircraft from the airworthiness certificate

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. 

My, Bronson Cheeks, current and projected UAS's meet or exceed each of the

elements. 

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable. 

Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption Petition

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

on board pilots or passengers, and given the size of the UAS's, this Regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight 

manual delineating areas of where safety can be defined.6 The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, 10167A, 

10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS 

utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications 

and registrations. They are inapplicable for the same reasons described above. The 

equivalent level of safety will be achieved by maintaining any such required 

certifications and registrations by me, Bronson Cheeks.

B. 14 C.F.R. § 45.23: Marking of The Aircraft.

Applicable Codes of Federal Regulation require aircraft to be marked according to

certain specifications. My UAS are, by definition, unmanned. They therefore do not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. 

Further, two-inch lettering is difficult to place on such small aircraft with dimensions 

smaller that minimal lettering requirement. Regardless, I will mark its UASs in the 

largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as 

required by 14

C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the 

UAV will see the markings. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. I, Bronson Cheeks, can achieve an equivalent level of safety 

as achieved by current Regulations because my UAS does not carry any pilots or 

passengers. Further, while helpful, a pilot license will not ensure remote control 

piloting skills. The risks attended to the operation of my UAS is far less than the risk 

levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. Thus, 

allowing me, Bronson Cheeks, to operate my UAS meet and exceed current safety 

levels in relation to 14 C.F.R. §61.113 (a) & (b).

D. 14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. 

It allows

_______________________

6Appendix E - Safety/Flight Manual 

Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption Petition

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

helicopters to be operated at lower altitudes in certain conditions. My UAS 

will never operate at an altitude greater than 200 AGL; safely below the 

standard of 400 AGL. I, Bronson Cheeks, will however operate my UAS in 

safe areas away from public and traffic, providing a level of safety at least 

equivalent to or below those in relation to minimum safe altitudes. Given the 

size, weight, maneuverability and speed of my UAS, an equivalent or higher 

level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections.

The above-cited Regulations require, amongst other things, aircraft owners 

and operators to “have [the] aircraft inspected as prescribed in subpart E of 

this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in 

part 43 of this chapter. . . .”

These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to my, Bronson Cheeks, UAS. However, as a safety 

precaution I inspect my UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 

C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, 

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and 

enclosed operational area of my UAS permits exemption from Part 21 because my, 

Bronson Cheeks’, UAS meets an equivalent level of safety pursuant to Section 333 of 

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My 

UAS meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation 

of an aircraft without an airworthiness certificate. As no such certificate will be

applicable in the form contemplated by the FARs, this Regulation is inapplicable. 14 

C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual. The FAA has 

previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software

updates and curative measures for any damaged hardware. Therefore, an equivalent

level of safety will be achieved. 

Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption Petition

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Bronson Cheeks, House Fly, LLC, Tarpon Springs FL – Section 333 Exemption Petition

In summary, Bronson Cheeks seeks an exemption from the following 

Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 

91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 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.F.R. §§ 91.203(a) and (b); 14 

C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 

91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my small

unmanned vehicle/lightweight unmanned aircraft vehicle in community 

awareness, Cinematography, and to develop economic platforms for real estate to 

enhance the experience of those seeking to relocate to the West Florida 

area. Currently, area awareness and real estate aerial videography/photography relies 

primarily on the use of larger aircraft running on combustible fuel. Posing potential risk 

to the public. Granting my request for exemption will reduce current 

risk levels and thereby enhance safety. My UAS craft does not contain potentially 

explosive fuel, is smaller, lighter and more maneuverable than conventional video and 

photographic aircraft with much less flight time. Further, I operate at lower 

altitudes and in controlled airspace eliminating potential public risk flying to and from 

established air fields. I, Bronson Cheeks, have been informally analyzing flight

information and have compiled safety protocols and the implementation of a flight

operations manual for UAS usage that exceeds currently accepted means and 

methods for safe flight. Formal collection of information shared with the FAA will

enhance the FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board my UAS and 

therefore the likelihood of death or serious bodily injury is significantly diminished. 

Operation of my UAS, weighing less than 10 pounds and travelling at lower speeds 

within limited areas will provide an equivalent level of safety as that achieved under 

current FARs. Accordingly I, Bronson Cheeks, respectfully request that the FAA grant 

my exemption request and am willing to cooperate in sharing information to benefit the 

FAA, safety of manned aircraft, and the general public at large. 

Respectfully submitted, 

Bronson Cheeks, 

House Fly, LLC 

561 Hunt Road Suite B 

Tarpon Springs, FL 34688 

Bronson Cheeks, House Fly, LLC Tarpon Springs, FL - Section 333 Exemption Petition 
Page 9 of 9 

Appendix A 

DJI Inspire 1

Operator Manual 






















Appendix B 

DJI Phantom 3

Operator Manual 

(Uploaded in Separate Attachment 58 page Document) 
Appendix C 

Tampa/Orlando --VFR Aeronautical Chart 

Appendix D 

Bronson Cheeks 

Personal Protocols and Controls 
Protocols and Controls

Aerial Community and Real Estate Videos

Safety for public on the ground as well as manned aircraft above is an essential and utmost

consideration for aerial videos and photography. As such, safety protocols and controls must be

implemented through pre-flight preparation and during flight.

Pre-Flight Protocol:

• Check batteries with voltage meter to insure fully charged and ready for use.

• Inspect batteries for damage or leakage that may affect proper operation.

• Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion

or

• unmanageable/uncontrolled flight.

• Check weather forecasts for wind advisory or other conditions that my impact flight.

• Consult five (5) mile radius map for airport vicinity.

o Contact respective airport to advise of estimated flight time, estimated flight

duration, estimated elevation of flight, and any other pertinent information.

• Inspect flight area for

o vicinity of public safety helipads/heliports

o vicinity of medical helipads/heliports

o vicinity of light poles

o vicinity or utility wires

o vicinity of trees

o flocks of birds that may cause interference and potential flight impact

o vicinity of any elevated obstructions that may pose potential flight hazard

o vicinity of roadways with moderate to heavy traffic that can be distracted

o public gatherings that may attract viewers

o optional point of control for best visual site of UAS while in flight

• Takeoff and landing

o inspect area for best and safest point of takeoff and landing

o if in a subdivision or area that is within 150 feet of a residential street, post

warning sign(s)/stand(s) "Attention Aerial Photography In Progress - Remain

Back 150 Feet"

Flight Protocol:

• Takeoff and land from same location

• Remain alert to birds, sound or aircraft, curious public, and approaching vehicles

• Do not allow anyone to engage in conversation or distract the remote control pilot

• Restrict flight to minimal elevation sufficient to acquire desired results

• Remain prepared for emergency landing at all times

• Pay attention to flight time

o If possible set a timer as a safety alert

• Land UAS and shut down propulsion immediately following landing
Protocols and Controls

Post flight:

a. Disconnect battery to prevent accidental activation of propulsion system

b. Secure UAS in a safe location

c. Remove all warning signs from public access areas

Emergency or Suspected Hazard:

• Immediate land UAS at safest and closet ground location in the event

o Manned aircraft is heard or seen in vicinity of flight

o There is a public gathering within established safety boundary wanting to observe

flight

o Pilot is being distracted from focusing on flight and safety

o Sudden change in weather (wind bursts)

o Sudden increase in vehicular traffic in vicinity of flight

o Birds enter into proximity of flight

o Any sudden unsafe event that can cause collision, distraction or interruption of

control
Appendix E 

Bronson Cheeks 

Safety/Flight Manual