Ben	Richardson

14000	Co	Rd	51

Collinsville,	AL	35961

Exemption	Request	Pursuant	to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	

the	Federal	Aviation	Regulations	from:	14	CFR	21	subpart	H

14	CFR	45.23(b),

14	CFR	61.113(a)	and	(b),

14	CFR	91.7(a)

14	CFR	91.9(b)(2)

14	CFR	91.103

14	CFR	91.109

14	CFR	91.119(c)

14	CFR	91.121

14	CFR	91.151(a)

14	CFR	91.203	(a)	and	(b)	14	CFR	91.405	(a)

14	CFR	91.407	(a)	(1)

14	CFR	91.409	(a)(1)	and	(2)	14	CFR	91.417(a)	and	(b)

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

“Reform	Act”)	and	14	CFR	Part	11,	Ben	Richardson,	operator	of	Unmanned	Aircraft	

Systems	(UAS),	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	

Regulations	(“FARs”)	to	allow	commercial	operation	of	designated UAS,	provided	

such	operations	are	conducted	within	and	under	the	conditions	outlined	herein	or	

as	may	be	established	by	the	FAA	as	required	by	Section	333.

Commercial	operation	of	an	UAS,	as	described	herein,	which	are	equipped	with	

camera(s)	and	sensors, would	provide	professional	services	in	the	following	areas:

1.	Aerial	photography	and/or	video	for	public	and/or	private	use	including	real	

estate,	architecture,	land	surveying,	engineering	and	other	related	professional	

activities.

2.	Aerial	video	and/or photography	for	public	and/or	private	use	including	

television,	public	events,	cinematography	and	newsgathering.

3.	Aerial	inspection/photography	of	residential/commercial	structures	under	

contract	with	the	owners	or	local	government	authority.

4.	Aerial	inspection/photography	of	residential/commercial	utility	infrastructure	

including	but	not	limited	to	electrical	power	lines,	wind	turbines	and	cell	towers.

5.	Aerial	video/photography	or	providing	live	video	feed	to	assist	with	search	and	

rescue	operations in	cases	of	an	emergency	or	natural	disaster	only	when	the	local	

authorities	or	government	has	requested	it	by	contract	or	donation.

6.	Training	to	persons	individually	or	belonging	to	both	private	and/or	public	

organizations	to	increase	awareness	and	improve	safety	for	current	and	future	UAS	

operations	within	the

NAS.

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

designated	UAS	as	set	forth	in	this	document	under	controlled	conditions	in	the	NAS	

that	would	be	a)	limited	b)	controlled	c)	predetermined	and	d)	safe.	Approval	of	this	
exemption	would	increase	public	awareness	of	UAS	operations	and	enhance	safety	

to	aid	in	fulfilling	the	Secretary	of

Transportation’s	(the	FAA	Administrator’s)	responsibilities	to	“....establish	

requirements	for	the	safe	operation	of	such	aircraft	systems	in	the	national	airspace	

system.”

I	plan	to	operate	a	UAS,	the	DJI	PHANTOM	3	Professional	which	is	comprised	of	an	

unmanned	aircraft	(UA	or	Phantom	3)	and	a	transportable	ground	station.	The	

Phantom	3	is	referred	to	as	a	quad-copter	with	a	maximum	gross	weight	of	about	3	

pounds.	It	is	equipped	with	four	rotors	that	are	driven	by	electric	motors	powered	

by	batteries.	The	UA	has	a	maximum	airspeed	of	16	m/s.

Also,	given	the	small	size	of	the	UAS’s	involved	and	the	restricted	controlled	

environment	within	which	they	will	operate,	the	applicant	fits	within	that	zone	of	

safety	(an	equivalent	level	of	safety)	in	which	Congress	envisioned	that	the	FAA	

must,	by	exemption,	allow	commercial	operations	of	UASs	to	commence	

immediately.	Also	due	to	the	size	of	the	UASs	and	the	controlled	areas	in	which	the	

relevant	UASs	will	operate,	approval	of	the	application	presents	no	national	security	

issue.	Given	the	following,	the	grant	of	the	requested	exemptions	is	clearly	in	the	

public	interest:	Ben	Richardson	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	an	exceptional	level	of	safety	

to	operations.	These	limitations	and	conditions	to	which	Ben	Richardson	agrees	to	

be	bound	when	conducting	commercial	operations	under	an	FAA	issued	exemption	

including:

1.	The	UAS	will	weigh	less	than	55	lbs.

2.	Flights	will	be	operated	within	line	of	sight.

3.	Maximum	total	flight	time	for	each	operational	flight	will	be	30	minutes.

4.	Flights	will	be	terminated	at	15%	battery	power	reserve.

4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL

5.	UAS	operator	will	be	trained	and	certified	in	the	proper	safety	and	operations	of	

the	UAS.	6.	The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the	

Procedures.

7.	The	operator	will	post	advisor	notice	around	the	controlled	area.

8.	The	operator	will	have	been	trained	in	operation	of	UAS	generally	and	received	

up-to-date	information	on	the	particular	UAS	to	be	operated	as	required.

9.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	

capability	to	return	to	a	pre-determined	location	within	the	Security	Perimeter	and	

land.

10.	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	obstacles	

or	emergencies.

Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the	requested	

exemption	and	are	prepared	to	modify	or	amend	any	part	of	this	request	to	satisfy	

the	need	for	an	equivalent	level	of	safety.	We	look	forward	to	working	with	your	

office.	Please	contact	us	at	any	time	if	additional	information	or	clarifications	are	

needed.