January 8th, 2016

PETITION FOR EXEMPTION

Robert Mahaffie

dba Bobcat Creative LLC

U.S. Department of Transportation

Federal Aviation Administration

800 Independence Avenue, SW

Washington, D.C. 20591

Re: Exemption Request seeking relief from the requirements of Title 14 of the code of Federal 

Aviation Regulations: Part 21 Subpart H; 61.113(a) & (b); 91.7(a); 91.9(b); 91.103; 91.119; 

91.121; 91.151(b); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417(a) & (b) 

concerning commercial operations of an Unmanned Aircraft Systems Pursuant to Section 333 of 

the Federal Aviation Administration (“FAA”) Modernization and Reform Act of 2012.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act, I, Robert Mahaffie, operator 

of an Unmanned Aircraft System (UAS), hereafter referred to as the Petitioner, hereby apply, on 

behalf of Bobcat Creative LLC, for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its UAS, 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.

I would like to formally submit for an exemption from part 21, subpart H; 61.113(a) & (b), 

91.7(a), 91.9(b)(2), 91.119, 91.121, 91.151(a)(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 

91.409(a) (1) & (2), and 91.417(a) & (b) of Title 14, Code of Federal Regulations (14 CFR); 

In order to operate small UAS commercially in airspace regulated by the Federal Aviation 

Administration (FAA) for the purposes of aerial photography, cinematography, videography, 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 a manned 

aircraft.

Applicant:

Robert Mahaffie

Owner

Bobcat Creative LLC

304 E. Monument St. #6

Colorado Springs, CO 80903

rob.mahaffie@gmail.com

202-487-5624

UAS Registration #: FA3FFAYPRM
Commercial operation of an UAS, as described herein, which are equipped with camera and 

sensors would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate, 

marketing and other related professional activities

• Aerial video and/or photography for public and/or private use including public and 

private event promotion

As described fully below, the requested exemption would permit the operation of a UAS under 

controlled conditions in the national airspace system (NAS) that would be a) limited, b) 

controlled, c) predetermined, and d) will provide safety enhancements to the already safe 

operations in the industry presently using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation responsibilities to 

“....establish requirements for the safe operation of such aircraft systems in the national 

airspace system.”

The UAS:

The UAS is visibly marked with it’s UAS Registration #: FA3FFAYPRM in accordance with new 

UAS registration procedures.

As found in Exemption No. FAA–2015–3709 (Harrison), the FAA recently approved similar use 

of a DJI PHANTOM 3 ADVANCED. I will operate a UAS, the DJI PHANTOM 3 

PROFESSIONAL, Model W323, unmanned aircraft (UA or Phantom), an attached 4K camera 

and a transportable ground station. 

The PHANTOM 3 is a quad-copter with a gross weight of 2.82 pounds. It is equipped with four 

rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed 

of 30 knots (15 m/s) and a maximum climb rate of less than 1200 feet per minute (6 m/s). It’s 

diagonal size (including propellers) is 590mm. The UA utilizes an internal inertial measuring unit 

(IMU) with integrated barometric sensor augmented with global position system (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information is transmitted back 

to a ground control station allowing the pilot-in-command (PIC) to monitor battery level, GPS 

signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. 

The UA has fail safe modes of operation for either loss of RC or GPS signal. Altitude is 

automatically limited to 500 feet and lower maximum altitudes can be preprogrammed by the 

PIC. Battery life limits flight times to approximately 23 minutes or less. The onboard flight 

controller will warn the pilot via telemetry, sound, and external lighting cues before reaching a 

low battery state. An automatic termination of flight and landing will be initiated when the battery 

reaches a predetermined low state.
Proposed Operations and Operating Conditions:

I, Robert Mahaffie, am requesting this exemption for the purposes of aerial photography and 

videography. My business model is to provide small UAS services to clients who wish to 

employ these services as a safe, effective and legal option to enhance their operations. I will 

abide by the following operating conditions under this exemption, which ensures a level of 

safety at least equal to existing rules. These procedures will be utilized in order to manage and 

mitigate risk and ensure public safety.

1) Operations will be limited to the following aircraft, the Unmanned Aircraft System: DJI 

Phantom 3 Professional, which is a quad-rotor aircraft weighting 2.8 pounds.

2) The UA will not be flown at an indicated airspeed exceeding 50 knots.

3) The UA will be operated an an altitude of no more than 400 feet above ground level (AGL),

4) The UA will be operated within visual line-of-sight (VLOS) of the Pilot In Command (PIC) at 

all times.

5) All operations will utilize a visual observer (VO). The UA will be operated within the visual 

line of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate 

verbally at all times. The PIC will be designated before each flight and will not transfer his or 

her designation for the duration of the flight. The PIC will ensure that the VO can perform 

the functions prescribed in the operating documents.

6) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe flight. If 

the inspect reveals a condition that affects the safe operation of the UAS, the UAS will not 

be operated until the necessary maintenance has been performed and the UAS is found to 

be in a condition for safe flight. The Ground Control Station will be included in the preflight 

inspect. All maintenance and alterations will be properly documented in the aircraft records.

7) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, 

e.g. replacement of a flight critical component, will undergo a function test flight. The PIC 

who conducts the functional test flight will make an entry in the aircraft records.

8) We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection and life limit requirements.

9) The UAS operated will comply with all manufacturer Safety Bulletins.

10) Prior to operations conducted for the purpose of aerial videography/photography and for real 

estate listing videos and public and private events and similar operations, the PIC will have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 

hours of total time as a UAS rotorcraft pilot. 

11) UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All operations 

will be conducted under visual meteorological conditions (VMC).

12) The UA will not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart.

13) The UA will not be operated less than 500 feet below or less than 2000 feet horizontally from 

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

14) If a UA loses communications or loses its GPS signal, it will return to a predetermined 

location within the planned operating area and land or be recovered.

15) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

16) The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and land 

the UA with 30% battery power or more remaining.
17) Before conducting operations, the radio frequency spectrum used for operation and control 

of the UA will comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements.

18) The UA will remain clear and yield the right of way to all manned aviation operations and 

activities at all times.

19) Operations will be conducted under the flight safety protocols (including posting a warning 

sign reading: “Attention Aerial Photography in Progress — Remain Back 150 feet”) 

contained in the operating documents and will actively analyze flight data and other sources 

of information to constantly update and enhance safety protocols;

20) The UAS will not be operated by the PIC from any moving device or vehicle.

21) The UA will not be operated over congested or densely populated areas.

22) Flight operations will be conducted at least 500 free from all nonparticipating persons, 

vehicles, vessels and structures unless:

• Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. We will 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 and/or;

• The aircraft is operated near vehicles, vessels or structures where the owner/

controller of such vehicles, vessels, or structures has granted permission 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, and;

• Operations nearer to the PIC, VO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a)

23) All operations will be conducted over private or controlled-access property with permission 

from the land owner/controller or authorized representative. Permission from land owner/

controller or authorized representative will be obtained for each flight to be conducted.

24) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operation areas as defined by the applicable COA will be reported to the FAA’s UAS 

Integration Office (AFS-80) within 24 hours. Accidents will be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov

Regarding UAS operational training, I have flown numerous practice flights in remote areas as a 

hobbyist simulating flights for future commercial use and to gain extensive familiarization with 

the characteristics of the UAS’ performance under different temperature and weather conditions. 

I also have extensive flight background with hobby-grade remote control helicopters and fixedwing craft.

The Specific Sections of Title 14 of the Code of Federal Regulations from Which, I Robert 

Mahaffie Seek Exemption:

1. I, Robert Mahaffie seek exemption from the requirements of Part 21 Subpart H.

Part 21, entitled Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates.

2. I, Robert Mahaffie seek exemption from the requirements of section 61.113(a) & (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections 

(a) and (b):
(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person for 

compensation or hire, acts as PIC of an aircraft

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

3. I, Robert Mahaffie seek exemption from the requirements of section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection 

(a) No person may operate a civil aircraft unless it is an airworthy condition

4. I, Robert Mahaffie seek exemption from the requirements of section 91.9(b)(2).

Section 91.9, entitled Civil aircraft flight manual, marking, and placard requirements, subsection

(b) (2) requires an aircraft flight manual in the aircraft

5. I, Robert Mahaffie seek exemption from the requirements of section 91.119.

Section 91.119, entitled Minimum safe altitutdes: General: Except when necessary for takeoff or 

landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue 

hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any 

open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a 

horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of 

this section, provided each person operating the helicopter complies with any routes or altitudes 

specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section.

6. I, Robert Mahaffie seek exemption from the requirements of section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a):

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(I) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft;

(II) If there is no station within the area prescribed in paragraph (a)(1)(I) of this section, the 

current reported altimeter setting of an appropriate available station; or

(III)In the case of an aircraft not equipped with a radio, the elevation of the departure airport 

or an appropriate altimeter setting available before departure. 

7. I, Robert Mahaffie seek exemption from the requirements of section 91.151 (b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b):
(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 20 minutes.

8. I, Robert Mahaffie seek exemption from the requirements of section 91.203(a) & (b).

Section 91.203, entitled Civil aircraft: Certifications required, subsection (a) & (b):

(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. Each U.S. airworthiness certificate 

used to comply with this subparagraph (except a special flight permit, a copy of the 

applicable operations specifications issued §21.197(c) of this chapter, appropriate sections 

of the air carrier manual required by parts 121 and 135 of this chapter containing that portion 

of the operations specifications issued under §21.197(c), or an authorization under §91.611) 

must have on it the registration number assigned to the aircraft under part 47 of this chapter. 

However, the airworthiness certificate need not have on it an assigned special identification 

number before 10 days after that number is first affixed. A revised airworthiness certificate 

having on it an assigned special identification number, that has been affixed to an aircraft, 

may only be obtained upon application to an FAA flight Standards district office. 

(2) An effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft registration Application as provided for in §47.31 (c), 

or a registration certification issued under the laws of a foreign country. 

(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.

9. I, Robert Mahaffie seek exemption from the requirements of section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a):

Each owner or operator of an aircraft—

(a) 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.

10. I, Robert Mahaffie seek exemption from the requirements of section 91.407 (a) (1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)(1):

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this 

chapter.

11. I, Robert Mahaffie seek exemption from the requirements of section 91.409(a) (1) & (a) (2)

Section 91.409, entitled Inspections, subsection (a):

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had —

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by §43.7 of this chapter; or

(2) An inspection for the issuance of an earthiness certificate in accordance with part 21 of this 

chapter.

12. I, Robert Mahaffie seek exemption from the requirements of section 91.417 (a) & (b)
Section 91.417, entitled Maintenance records, subsections (a) and (b):

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of 

an aircraft. The records must include — (i) A description (or reference to data acceptable to 

the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature and certificate number of the person approving the aircraft for return to 

service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection 

required by the inspection program under which the aircraft and its appliances are 

maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, 

for each, the method of compliance, the AD or safety directive number and revision date. If 

the AD or safety directive involves recurring action, the time and date when the next action 

is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed.

The Extent of Relief Robert Mahaffie seeks and the Reason he seeks such relief:

1. I, Robert Mahaffie, am submitting this request in accordance with the Federal Aviation 

Regulations (14 C.F.R. 11) and the FAA Modernization and Reform Act of 2012 (FMRA), 

Section 333, to the Administrator to commercially operate my DJI Phantom 3 Professional in 

the National Airspace System and for exemption from certain requirements of Title 14 C.F.R.

2. The Reform Act details the guidelines for determining the types of UAS that may operate 

safely in our National Airspace System. Due to the speed, weight, size, and limited operating 

range of the DJI Phantom 3 Professional, my UAS meets the conditions of FMRA Section 333 

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21. 

Subpart H.

3. I, Robert Mahaffie, request relief from the requirements of Section 61.113(a) and (b): 

Private pilot privileges and limitations: Pilot in command. Private pilots are limited to noncommercial operations, whereby carrying passengers or property is not allowed. Being that my 

UAS does not accommodate for carrying passengers or property, thus operating it carries far 

less risk than private and commercial flights.
4. I, Robert Mahaffie, seek relief from Section 91.7(a), Civil aircraft airworthiness. The 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H is not applicable for 

the DJI Phantom 3 Professional. However, I will ensure that it is in airworthy condition, prior to 

every flight, by being in compliance with the operating documents, such as the monthly 

maintenance log, and instruction manual.

5. I, Robert Mahaffie, seek an exemption from Section 91.9 (b) (2) which requires an aircraft 

flight manual in the aircraft. Given the size of the DJI Phantom 3 Professional, which does not 

accommodate for pilots or passengers, this Regulation is inapplicable. However, as the pilot of 

my UAS, I will ensure an equivalent level of safety by maintaining a safety/flight manual 

delineating areas of where safety can be defined.

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700, 32827 and many others.

6. Furthermore, I, Robert Mahaffie, seek an exemption from Section 91.119, Minimum Safet 

Altitudes. Operation of my UAS will always be well within the 400 feet AGL allowed by the FAA 

Modernization and Reform Act of 2012).

Additionally, the DJI Phantom 3 Professional also has a unique Beginner Mode that helps you 

learn how to fly in a safe, limited area. In practice, I have set my UAS to fly only within a given 

distance and altitudes from me, making it automatically stay inside limits. These exercises also 

provide me with the training needed to operate my UAS, making it safer to fly with these learned 

controls.

7. I, Robert Mahaffie, seek an exemption from Section 91.121, Altimeter Settings. The 

altimeter settings are not applicable to the DJI Phantom 3 Professional as it comes equipped 

with a barometric pressure sensor and Global Positing System. However, because it is 

equipped with a barometric pressure sensor and Global Positioning System, an equivalent level 

of safety can be maintained as this technology automatically ensures that a ground level 

pressure setting will be established prior to each flight, and provides altitude information on the 

display of the GCS.

8. I, Robert Mahaffie, seek an exemption from Section 91.151(b), Fuel requirements for flight 

in VFR conditions. Operation of my UAS does not require fuel. It is powered by a Lithium 

Polymer battery. Safety will not be impacted with the operation of my UAS as its built in 

technology provides visual warnings to the GCS when it experiences low battery voltage. At the 

critically low battery level, the DJI Phantom 3 Professional will descend and land automatically. 

As the pilot of my UAS, I ensure there is a fresh fully charged battery with each flight as a safety 

precaution and take every measure to ensure I only operate it at or below manufacture 

recommend minimum charge levels for operation; full flight time limit for each battery is up to 

twenty-three (23) minutes. I will safely operate the battery powered DJI Phantom 3 Professional 

during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR).

9. I, Robert Mahaffie, seek an exemption from Section 91.203 (a) & (b) which provides for 

carrying of civil aircraft certifications and registrations. Because my UAS will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H 91.203 (a) & (b) are 
inapplicable for the same reasoning. However, an equivalent level of safety will be achieved by 

maintaining any such required certifications and registrations.

10. Additionally, I, Robert Mahaffie, request relief from Sections 91.405(a), 91.407(a) (1), 

91.409 (a)(1) & (a) (2) and 91.417 (a) & (b), as these sections set forth the requirements for 

maintenance items that only apply to aircraft with an airworthiness certificate which is not 

required for my UAS, DJI Phantom 3 Professional, due to its speed, weight, size and limited 

operating range.

However, as safety is of the utmost importance to me, I will ensure the DJI Phantom 3 

Professional is carefully inspected and maintained before every flight in accordance with the 

methods, techniques, and practices outlined in the operating documents and instruction manual.

Furthermore, the UAS includes a Ground Control Station with image transmission technology, 

giving me live viewing capability from the UA’s onboard camera. This allows me to see 

surroundings while in flight and provides the ability to send control commands to the UA from 

any direction. It’s relative small size makes it easy to maneuver. Therefore, maintaining 

distances from people, vehicles, buildings and other air craft can be easily accomplished. 

Public Interest:

Aerial photography and videography for events and real estate are proven strategies to enhance 

marketing efforts and increase business success. The industry is not new. However, until 

recently it was conducted through the use of costly manned fixed-wing or rotor aircraft, a 

prohibitive business activity for small companies. By granting this exemption I would be able to 

provide affordable services. Use of the UAS in lieu of a manned aircraft would also enhance

safety and reduce the environmental impact of similar operations conducted by a manned 

aircraft.

Further, the small UAS will pose no threat to the public given its small size and lack of 

combustible fuel when compared to larger manned aircraft. Additionally, the operation of our 

UAS will minimize the harm to the environment and promote economic growth by providing 

information to companies and the public looking to relocate to the metro areas I service. Public 

and private events serviced by my business enhance vibrancy and add culture to the community 

and its citizens. Finally, the safe and professional operation of civil UAS in the public sphere will 

help promote a better understanding of the positive impacts UAS technologies, commonly 

referred to as “drones”, can have on many aspects of communities and businesses. Showing 

the public that UAS use is incredibly beneficial and is a safe and soothing under the right 

guidelines and laws already set in place. 

Summary the FAA May Publish in the Federal Register:

I, Robert Mahaffie, seek exemption from the requirements of Title 14 of the code of Federal 

Aviation Regulations: Part 21, Subpart H; 45.23(b), 61.113(a)&(b); 91.7(a), 91.9(b) (2); 91.119; 

91.121; 91.151(b); 91.203(a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (a)(2); 

91.417(a)&(b).

Brief Summary of the Exemption:
This exemption will permit, I, Robert Mahaffie, to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial video and photography for hire or 

compensation.

Aerial videography and photography has been around for quite some time through use of 

helicopters and other aircrafts alike, however, for small businesses it has been cost-prohibitive. 

Granting this exemption will allow me to provide services at a more cost effective rate, this 

helping to stimulate the local economy.

Operations of my UAS pose no potential risk to the public. It’s battery powered, small in size, 

thus not accommodating passengers or property onboard which makes it more safe to operate 

and easier to maneuver. This helps to avoid hazardous situations more readily.

It has technology that allows for safety controls with warning alerts and a failsafe mode that 

allows for safe return home, if it loses connectivity with the GPS. All stated, it reduces the risk 

exposure in both air and ground.

In summary, I, Robert Mahaffie, seek an exemption pursuant to 14 C.F.R. 11.61 and Section 333 

of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of 

the DJI Phantom 3 Professional commercially for the purpose of conducting aerial video and 

photography and other opportunities which may present itself.

Therefore in accordance with the Federal Aviation Regulations and the FAA Modernization and 

Reform Act of 2012, Section 333, I, Robert Mahaffie, request that the Administrator grant this 

Petition for an exemption from: 14 C.F.R. 21, subpart H; 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. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(b); 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)(1); 

14. C.F.R. 91.409 (a)(2); and, 14 C.F.R. 91.417 (a) & (b) to safely, efficiently and economically 

operate the DJI Phantom 3 Professional within the NAS.

If you have questions or need additional information, please contact me at

rob.mahaffie@gmail.com or (202)-487-5624

Thank you,

Robert Mahaffie, Owner/Operator

d.b.a. Bobcat Creative LLC

304 E. Monument St. #6

Colorado Springs, CO 80903