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May 24, 2015 

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR part 21, subpart H; 14 C.F.R. 45.23(b); 14 CFR 61.113(a) & (b); 91.7(a); 

91.9(b) (2); 91.103(b); 91.109; 91.119; 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: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 

C.F.R. Part 11, Kenneth A Stephens, hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its Small Unmanned Aircraft 

Systems (“sUAS’”) for aerial photography and videography, inspections of bridges, utilities, 

construction industries and real estate properties and other flight operations that could be 

performed safely and more cost effectively with the use of small UAS at low altitude within the U.S. 

National Airspace System as compared to manned aircraft. Operations would be performed only at 

the request of and with the authorization and permission of clients or their authorized agents in 

order to facilitate commerce and raise awareness of the beneficial uses of sUAS’s so long as such 

operations are conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333. 

The FAA has granted Exemption No. 11158 & 11694 that uses the same UAS as Kenneth A. 

Stephens The DJI S1000 is a stable lightweight battery operated octocopter

The requested exemption would permit the operation of sUAS under controlled conditions in 

airspace that is a.) limited b.) predetermined c.) controlled to access and d.) would provide safety 

enhancements to the already regulated safety practices presently followed by manned aircraft as 

governed by the FAA. Approval of this exemption would thereby enhance safety and fulfill the 

Secretary of Transportation’s (the FAA Administrator’s) responsibility to “...establish requirements 

for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of 

the Reform Act. 

Applicant Contact Information: 

Kenneth A Stephens 

224 4th st

Juneau Alaska 99801

PH: 907-723-6399

Email: stephens@gci.net
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I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level 

of safety. I would look forward to working with your office. Please contact me at 907-723-6399 or 

via email stephens@gci.net at any time if you require additional information or clarification.

BASIS FOR PETITION 

I. UAS

The S1000 has already been approved by the FAA to be used in aerial photography in 

exemption No. 11158 & 11694. Kenneth A Stephens intends to use DJI S1000 in a similar 

manner. The S1000 is an octocopter with retractable landing gear. The aircraft is designed to 

be stable even with the loss of a rotor. The S1000 has a maximum thrust of 2.5kg. It weighs 

approximately 9.7 pounds and has a maximum takeoff weight is approximately 24 lbs. The 

S1000 uses a 6S LiPo battery that allows flight times in excess of 25 minutes. The S1000 

has a maximum speed of 45 mph. It can hover and simultaneously move vertically and 

horizontally. The S1000 can operate in temperatures between -10 C to plus 40 C. The 

propeller is made out of high strength performance engineered plastics and is approximately

15 X5.2 inches. The S1000 is not water-proof and is prohibited from flying in the rain and 

snow. 

Further, the S1000 is programmed to return to its launch site in the event of either 

communications failure, loss of the Global Positioning System (GPS), or low battery. 

II. Operations 

Kenneth A. Stephens has a Flight Operations Manual (“FOM”) which is intended to provide 

an equivalent or higher level of safety for flight operations for the FAR’s. Kenneth A 

Stephens will provide a hard or electronic copy to each Pilot and Observer. The Pilot in 

Command (“PIC”) will ensure that each flight is in compliance with the FOM, DJI S1000 

Operations Manual (“Operations Manual”, which is electronically available at 

http://www.dji.com/product/spreading-wings-s1000-plus/download), applicable FAR’s and 

any conditions or limitations specified in grant of Exemption. 

As set forth in the FOM, some requirements, limitations and conditions include: 

1.) Minimum crew for each operation will consist of a PIC and the Observer. The 

PIC may deem other crew essential to the safe operation of the aircraft to include: a 

camera operator, instructor, trainee, or other persons necessary for the safe 

operation of the flight. 

2.) The PIC and Observer will be able to communicate verbally at all times. 

3.) Flights will only be conducted during daylight hours.

4.) Visibility will be adequate to ensure that the PIC and/or Observer can maintain 

visual contact with the aircraft at all times and ensure that the aircraft will remain 

clear of obstructions and people.

5.) The aircraft will remain clear of clouds at all times.

6.) Flights will be operated within the line of sight of the PIC and/or Observer.

7.) Flights will not go beyond 3⁄4 statute miles from point of intended landing.

8.) Flights will be terminated at or before 30% battery power reserve.
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9.) Flights will not be conducted at speeds greater than 25 mph.

10.) Flights will operate at an altitude of no more than 400 feet AGL.

11.) Flights will remain in Class G airspace.

12.) Flights will not operate within 5 nautical miles of an airport or heliport unless a 

letter of agreement with airport management is obtained 

13.) Flights that fly over private or controlled-access property will be conducted 

with landowner’s/controller’s permission.

14.) Flights will not be operated over densely populated areas.

15.) The PIC will ensure that an adequate preflight inspection of the aircraft has 

been completed in accordance with the Operations Manual and the FOM.

16.) The PIC will conduct a briefing before each flight with the Observer and any

other essential crew as to the plan for the flight including: flight area, weather, 

potential obstacles and hazards, flight time, battery time and any other information 

affecting the safety of flight.

A. STATUTORY AUTHORITY FOR EXEMPTIONS 

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory 

authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

including sUASs, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702 – 44716 of this title if the Administrator 

finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC 

§44704; CFR §91.203(a)(1). 

Section 333(b) of the Reform Act assists the Secretary in determining whether sUASs may operate 

in the National Airspace System without creating a hazard to the user, the public, or a threat to 

national security. In making this determination, the Secretary must consider: 

a.) The sUAS’s size, weight, speed and operational capability

b.) Whether the sUAS operates within the visual line of sight of the operator

c.) Whether the sUAS operates outside of highly populated areas and away from close proximity to 

airports

Reform Act §333(a). If the Secretary determines that a sUAS “may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in 

the national airspace system.” Id. §333(c). 
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Kenneth A Stephens will be using a octocopter manufactured by DJI. The model being used is the S1000 

The S1000 weighs less than 25 pounds, including payload. The S1000, operating under normal 

conditions, (no wind) travels at a maximum speed of 45 MPH and has the capability to hover and move 

in the vertical and horizontal plane simultaneously. The S1000 will operate only in the pilot’s visual line 

of sight at all times and will operate only within the limits of the area required to be videoed or 

photographed. Such operations will insure that the S1000 will “not to create a hazard to users of the 

national airspace system or the public.” Reform Act Section 333(b). 

Given the small size of the S1000 and the restricted and predetermined environment within which 

it will operate, this application falls squarely within the zone of safety (an equivalent level of safety) 

in which Congress envisioned that the FAA must, by exemption, allow commercial operations of 

sUAS to commence immediately. 

Also due to the small size of the S1000 and the low altitudes and restricted areas in which it will 

operate, approval of the application presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, including enhanced safety, grant of the requested 

exemptions is in the public interest. Accordingly, Kenneth A Stephens respectfully requests that the 

FAA grant the requested exemption without delay. 

B. PUBLIC INTEREST 

This exemption application is expressly submitted to fulfill Congress’s goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the National Airspace System before 

completion of the rulemaking required under Section 332 of the Reform Act. By granting an 

exemption the FAA will fulfill Congress’s intent of allowing UAS to operate with significant safety 

precautions in low risk environments. 

The use of sUAS for videoing or photographing drainage ways, bridges and survey mapping can 

reduce the risk of injuries to workers attempting to walk in very dangerous/difficult terrain found in 

waterways, detention ponds and surveying areas as well as reduce environmental impacts to 

wetland areas that are very sensitive for wildlife. Use of sUASs on construction sites can 

significantly reduce the risk to workers of falls while inspecting, surveying or monitoring site 

progress. sUASs can inspect, photograph and collect data on hard to get to areas that otherwise 

would require worker inspection. Falls are the leading source of workplace could save workers 

lives. Aerial videography for real estate marketing has been around for years through manned fixed 

wing aircraft and helicopters. 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 expense, depriving non-luxury homeowners and 

lower budget realtors from a valuable marketing tool. Manned aircraft pose a threat to the public 

through potential catastrophic crashes resulting in loss of life due to the potential combustible 

fuel that can explode and burn on impact. sUASs pose no such threat since size and lack of 

combustible fuel alleviates any potential threat to the public. 

 
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Finally, sUASs reduce the environmental impact by dramatically decreasing the energy used for 

aerial imaging. The S1000 uses rechargeable lithium ion batteries, as opposed to fossil fuels burned 

in operation of small aircraft and helicopters that are hundreds or thousands of times heavier. 

C. EQUUIVALENT LEVEL OF SAFETY 

Kenneth A Stephens 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 

at least an equivalent or even higher level of safety to operations under the current regulatory 

structure because the proposed operations represent a safety enhancement to the already safe 

operations conducted with helicopters and other conventional aircraft. 

Kenneth A Stephens will be bound by the following limitations when conducting its sUAS 

operations under an FAA issued exemption: 

1.) The sUAS will be less than 25 pounds. 

2.) Flights will be operated within visual line of sight of the pilot. 

3.) Maximum total flight time for each operational flight will be 15 minutes. The S1000 calculates 

battery reserve in real time, and will return to its ground station with at least 30% battery reserve 

should that occur prior to the 15 minute limit. 

4.) Flights will be operated normally at approximately 150 feet AGL, never exceeding 400 

feet AGL. 

5.) Horizontal flight speed will not exceed 45 MPH. 

6.) Crew for each operation will consist of the sUAS Pilot who will keep the sUAS within his/her 

visual line of sight at all times and a Visual Observer who will also keep the aircraft within 

line of sight as well as watch for other aircraft or personnel that might enter the operation area. 

7.) Pilot and Visual Observer will keep in constant verbal contact throughout the duration of each 

flight. If conventional aircraft or unauthorized personnel enter the flight operations 

area unexpectantly the flight will be terminated immediately. 

8.) The sUAS pilot will be trained in flight, operations, checklists and safety procedures with 25 

hours of flight time and 100 landings and takeoff with the S1000 

9.) The sUAS will only operate in a confined predetermined area around which a security 

perimeter will be established for flight operations. 

10.) Warning signs will be posted in the flight operations area indicating to remain clear of 

the area. 

11.) A briefing will be conducted in regard to the planned sUAS operations prior 

to each flight. It will be mandatory that all personnel who will be present within the

boundaries of the safety perimeter be present for this briefing. 

12. ) All personnel will consent to the UAS flyover on site by waiver, and the operator will obtain

additional verbal or written consent of all persons who will be allowed within 100 feet of the 

flight operation. 

13.)Written and/or oral permission from the relevant property holders will be obtained

14.)All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate governmental agencies 

when required. 

15.)The pilot will take all actions including reviewing weather, flight battery requirements, landing 

and takeoff distances and aircraft performance data before initiation of flight. 

16.) The observer will be required to complete training as outlined in the FOM
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17.)The pilot will have a Pilot’s license and a Class III medical.

18.)The pilot will perform a minimum of 3 takeoffs and landings within the preceding 5 days with 

the S1000 sUAS.

19.)If the S1000 loses communications or loses its GPS signal, it will automatically return to a predetermined location within the security perimeter and land. 

20.)The pilot will abort a flight (return to home) in case of unpredicted obstacles or emergencies 

with the push of a button..

21.)Single family residential and commercial properties to be videoed will be limited to a minimum 

of one acre parcels, in size, which would allow the sUAS to be maneuvered around the perimeter of 

the structure without over flying the structure being videoed as well as any structures on adjacent 

properties thus allowing an emergency landing, if a power failure occurs, without any undue hazard 

to persons or property on the surface. 

22.)sUAS will not be flown within 5 miles of airports as shown on current FAA-published 

aeronautical charts unless authorization has been granted by the controlling ATC facility governing 

that airport. 

23.)Pilot will preflight/inspect sUAS for airworthiness prior to each flight including the Ground 

Control station. 

24.)Pilot will maintain the S1000 and properly document all maintenance and alterations in the 

S1000 records. 

25.)Pilot will conduct a functional test flight after all maintenance prior to the next operational 

flight and record this flight in the S1000 records/ flight log. 

26.)All flights will be flown only during daylight hours under visual meteorological conditions 

(VMC). 

D. DESCRIPTION OF SPECIFIC REGULATIONS REQUESTING EXEMPTION FROM: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203(a)(1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited 

operating area associated with the aircraft to be utilized by Kenneth A. Stephens an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 V.S.C.§44701 (t) and Section 333 of 

the Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular sUAS. Our small UAS will be operated at 

low speed in a controlled environment, at least five miles from an airport and more than three 

miles from any densely populated area. An analysis of these criteria demonstrates that the sUAS 

operated without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

helicopter) operating with an airworthiness certificate without the restrictions and conditions 

proposed. 

The DJI S1000 to be operated hereunder is less than 25 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within 
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a secured area. Like other civil aircraft, operations under this exemption will be tightly controlled 

and monitored by the operator and under the requirements and in compliance with local public 

safety requirements, to provide security for the area of operation. 

These safety enhancements provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 

21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the sUAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels.

14 C.F.R. 45.23(b): Marking of the Aircraft 

This regulation requires certain experimental, provisionally certificated aircraft, or lightsport

category aircraft to be marked with letters between 2 inches and 6 inches high “limited,” 

“restricted,” “light-sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit, 

or pilot station. 

Even though the sUAS will have no airworthiness certificate, an exemption would be needed as the 

sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” 

can be placed. Given the size of the sUAS, two-inch lettering would be impossible.

The FAA has issued an exemption to this regulation: Exemption No. 11109. 

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in Command 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will 

not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety 

of current operations by requiring the pilot operating the sUAS to have completed sUAS flight 

training by reviewing each of the three DJI Inspire 1 manuals (attached to this document), The pilot 

would also perform a minimum of 200 flight cycles, 25 hours of total time as a sUAS rotocraft pilot 

and a minimum of 100 landing and take off before performing the first “operational flight” under 

this exemption. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is 

remotely controlled with no living thing or cargo on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance. The risks associated with the 

operation of the sUAS are so diminished from the level of risk associated with commercial 

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as 

requested with a pilot who has met the minimum requirements stated above exceeds the present 

level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. 91.7(a): Civil aircraft airworthiness

 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption 

be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of 

the aircraft and the requirements contained in the DJI S1000 Manuals, FOM and the use of a 

preflight checklist prior to each flight an equivalent level of safety will be provided. 

14 C.F.R. 91.9(b)(2): Civil aircraft flight manual, marking and placard requirements 
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The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to 

carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation: Exemption Nos. 11062, 11109, 11112, 11213, 11694, 

11158, 

14 C.F.R. 91.103(b): Preflight Action 

This regulation requires each pilot in command take certain actions before flight to ensure the 

safety of flight. An exemption is needed from this requirement as the pilot will take separate 

preflight actions, including checking for weather conditions, checking flight battery requirements, 

checking takeoff and landing distances, and all other actions in the Preflight Checklist in the DJI 

S1000 Manuals. These actions will provide an equivalent level of safety. 

14 C.F.R. 91.109: Flight Instruction 

Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully functioning dual controls.

By design, sUASs and remotely piloted aircraft do not have fully functional dual controls. Flight 

control is accomplished through the use of a control box that communicates with the aircraft via 

radio communications. The FAA has previously approved exemptions for aircraft without fully 

functional dual controls. See Exemption Nos.5778K & 9862A. The equivalent level of safety 

provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to 

control the sUAS via radio signals from the controller, and by the size and speed of the aircraft. 

 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating 

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This 

exemption is for a multirotor craft that flies similarly to a helicopter, with vertical takeoff and 

vertical landing, which will typically operate at altitudes of 150 AGL, so an exemption may be 

needed to allow such operations. The sUAS will never operate at altitude higher than 400 AGL and 

will be in a restricted area with security perimeter, where buildings and people will not be exposed 

to operations without their pre-obtained consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as 

the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and any onsite 

personnel all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighing far more than the maximum 25 lbs. proposed herein 

and carrying flammable fuel, any risk associated with our operations is far less than those presently 
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presented with helicopters and other conventional aircraft operating at or below 500 AGL. In 

addition, the low-altitude operations of the sUAS will ensure separation between these sUAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 

14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions 

Section 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. The S1000 is 

limited to operations in predetermined and controlled environments, and has a limited range and 

flight time which require an exemption from 14 CFR 91.151(a). 

The battery powering the S1000 provides approximately 15 minutes of powered flight. To meet the 

30 minute reserve requirement in 14 CFR §91.151, DJI S1000 flights would not be possible. Given 

the limitations on the DJI S1000 proposed flight area and the location of its proposed operations 

within a predetermined area, a time frame of 15 minutes for flight in daylight VFR conditions is 

reasonable. 

Kenneth A. Stephens believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the DJI S1000, in a tightly controlled area where only 

people and property owners or official representatives who have signed waivers will be allowed, 

with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 

91.151(a) was intended to alleviate given the size and speed of the S1000. Additionally, limiting 

S1000 flights to less than 15 minutes would greatly reduce the utility for which the exemption will 

be granted. 

 

An equivalent level of safety can be achieved by limiting flights to 15 minutes, or enough battery 

reserve to ensure that the S1000 lands at the ground station with at least 30% of battery power (as 

determined by the onboard monitoring system and the pilot), whichever happens first. This 

restriction would be more than adequate to return the S1000 to its planned landing zone from 

anywhere in its limited operating area. 

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 

10673, and 10808. 

14 CFR 91.203 (a) & (b): Carrying civil aircraft certification and registration 

The regulation provides in part: 

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the 

following: 

(1) An appropriate and current airworthiness certificate.... 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at 

the cabin or cockpit entrance so that it is legible to passengers or crew. 
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The DJI S1000 fully loaded weighs no more than 25 lbs. and is operated without an onboard pilot. 

Therefore there is no ability or place to carry certification and registration documents or to display 

them on the DJI S1000. 

An equivalent level of safety will be achieved by keeping these documents at the ground flight 

control point where the pilot flying the sUAS will have immediate access to them; to the extent 

they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A 

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 

9797, 9797A, 9816A, and 10700. 

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

These regulations require that an aircraft operator or owner “shall have that 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 ... 

,” and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to Kenneth A, Stephens. Maintenance will be accomplished by the operator. 

An equivalent level of safety will be achieved because the DJI S1000 is very limited in size and will 

carry a small payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise the DJI S1000 can land immediately and will be operating from no higher than 400 feet 

AGL. The operator will ensure that the DJI S1000 is in working order prior to initiating flight, 

perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety. 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 

45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7(a); 91.9 (b) (2);91.103(b);91.109; 91.119; 

91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate 

commercially a small unmanned vehicle (25 lbs. or less) in aerial photography and videography for 

mapping, inspections of drainage ways, , utilities, construction industries, bridges and real estate 

properties and other flight operations that could be performed safely and more cost effectively 

with the use of small UAS at low altitude within the U.S. National Airspace System as compared to 

manned aircraft. 

Approval of exemptions allowing commercial operations of sUASs enhances safety while reducing 

risk. Manned aircraft create a greater risk because the craft are much larger, have combustible fuel, 

and carry an onboard human pilot. In contrast, a sUAS weighing fewer than 25 lbs. and powered by 

batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel 
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carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to 

the risks associated with manned aircraft flights. 

The operation of small UASs, weighing less than 25 lbs., conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing 

commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and 

in a sterile environment and, as a result, are far safer than conventional operations conducted with 

turbine helicopters operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property owner's prior 

consent and knowledge. Images taken will be of individuals who have also consented to being 

filmed or otherwise have agreed to be in the area where aerial photography will take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of 

sight and national security – provide more than adequate justification for the grant of the 

requested exemptions allowing commercial operation of Kenneth A. Stephens sUAS in above 

referenced services pursuant to the DJI Manuals 

Thank you for considering this exemption request.

Sincerely, 

Kenneth A. Stephens