Eric Olson

All Around The House, Inc

General Contractor CCB# 203051

Certified Home Inspector OCHI # 1508

255 N Arney Rd Suite 230

Woodburn, OR 97071

Phone: 503-851-7234

October 9, 2015

U. S. Department of Transportation Docket Management System 1200 New Jersey 

Ave., SE Washington, DC 20590

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) 

(c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 91.119, 91.121, 91.203, 91.151

Following the format of FAA Exemption No. 11138 -Regulatory Docket No. FAA –

2014 – 0481 I have included:

1) Supplemental Response for Petition 

2) 3D Robotics Solo Manual User Manual

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

C.F.R. Part 11, I, Eric Olson, a professional photographer, videographer, Licensed, 

Bonded and Insured General Contractor and Certified Home Inspector, I am 

preparing this exemption request myself, would like to apply for an exemption from 

the following Code of Federal Regulations (C.F.R) to be allowed commercial 

operation of lightweight Unmanned Aircraft Systems (sUAS) for aerial imaging and 

video of homes and points of interest for Real Estate Clients and for General Home 

Inspection purposes.

I have a BA in Industrial/Scientific Photography from the Brooks Institute of 

Photography. I graduated in 1995. I am licensed in the State of Oregon as a 

General Contractor and Certified Home Inspector. I have experience in flying hobby 

quads for recreational purposes during the past 4 years without incident. I would like 

to purchase a 3DRobotics Solo quad-copter (Equipped with four rotors that are driven 

by electric motors powered by batteries, the UAS has a maximum airspeed of 48

knots) and add to my inventory equipped with a GoPro 4 HERO Black camera with 

intent for Home Inspection and aerial videography/cinematography to enhance 

personal safety while inspecting areas of real estate that can not be easily accessed 

or are a part of a roofing system. By adding a UAS, it will greatly diminish the need 

for me to inspect a roofing system by climbing up on a ladder and walking around for 

a visual inspection; following an exemption and approval by the FAA.

My exemption request would permit operation of light weight, unmanned (piloted by 

remote control with a live video monitor feed) in predetermined areas away from 

general public, airports, heliports and vehicular traffic, under 300 ft. and after carefully 
reviewing, inspecting and examining the area of aerial observation. This would allow 

for community videos and within property boundaries for individual homeowner real 

estate listing videos/photos. I will abide all FAA requirements to ensure this 

exemption will provide a level of safety at least equal to existing rules and will only 

operate in a safe environment that is strictly controlled, are away from power lines, 

elevated lights, airports and actively populated areas; and I will conduct extensive 

preflight inspections and protocols, during which safety carries primary importance.

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

Given the size, weight, speed, and limited operating area associated with the aircraft 

to be utilized, I am asking exemption from 14CFRpart21,Subpart H(Airworthiness 

Certificates)and§91.203 (a) and (b) (Certifications required),subject to certain 

conditions and limitations, is warranted and meets the requirements for an equivalent 

level of safety under14CFRpart 11 and Section 333 of P.L. 112-95 (Section 333).

14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 

(3) (c)(d)(e)(f)(h): Size of Marks

Furthermore I request an exemption from §45.23 Marking of the aircraft because my 

UAS will not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Additionally two -inch lettering is difficult to place on such a small aircraft 

with dimensions smaller than the minimal lettering requirement. I understand the 

need for markings and will mark my UAS in the largest possible lettering by placing 

the word “Experimental” or assigned number or name (based on a request or ruling 

by the FAA ) on its fuselage as required by §45.29(f) so that anyone assisting him as 

a spotter will see the markings.

I also ask for an exemption from §§91.405(a),91.407(a)(1), 91.409(a)(2) and 

91.417(a) and(b) Maintenance inspections may be required and should be granted 

since they only apply to aircraft with an airworthiness certificate. But, as a safety 

precaution I will perform a preflight inspection of my UAS before each flight as 

outlined in his operating documents.

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in 

command.

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, 

however I can achieve an equivalent level of safety as achieved by current 

regulations because my UAS does not carry any pilots or passengers. While helpful, 

a pilots’ license will not ensure remote control piloting skills. The risks of operating a 

UAS are far less than the risk levels inherent in the commercial activities outlined in 

14 CFR part61,et seq., I requests an exemption from §61.113 Private Pilot Privileges 

and Limitations. Regarding UAS operational training, as stated previously I have four 

years’ experience flying hundreds of practice flights as a hobbyist simulating flights 

for future commercial use to gain familiarization with the characteristics of his UAS’ 

performance under different temperature and weather conditions. I also practiced on 

a computer simulated flight software to maintain adequate skills and response reflex 

time. 
14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action

If granted an exemption I agree to additional safety procedures including, but not 

limited

to: 

1) Keeping my UAS within a radius distance of 1000 feet from the controller to both 

aid in direct line of sight visual observation. 

2) Operate the UASfor3-7 minutes per flight; land my UAS according to the

manufacturer’s recommended minimum level of battery power. 

3) Operate my UAS only within visual line of sight (VLOS). 

4) Use the UAS’ global positioning system(GPS) flight safety feature; it hovers and 

then slowly lands if communication with the remote control. 

5) Conduct all operations under my own personal and flight safety protocols

(including posting a warning sign reading: “Attention Aerial Photography in

Progress –Remain Back 150 feet”). 

6) I will operate and will actively analyze flight data and other sources of information 

to constantly update and enhance my safety protocols. 

7) Contact respective airports if operations will be within 5 miles to advise them of 

estimated flight time, flight duration, elevation of flight and other pertinent

information. 

8) Always obtain all necessary permissions prior to operation. 

9) Have procedures in place to abort flights in the event of safety breaches or

potential danger.

Personal safety is a great concern of mine. I am a husband and father to 6 children 

and I feel the addition of a UAV will greatly diminish the possibility of severe injury or 

death. Also I will be able to add Aerial videography for geographical awareness of 

real estate marketing. Aerial inspections have been around for a long time through 

helicopters, but for small business owners, its expense has been cost-prohibitive. 

Granting this exemption would allow me to provide this service at a much lower cost. 

Further, my small UAS, when used properly, will pose no threat to the public given its 

small size and lack of combustible fuel when compared to larger manned aircraft. The 

agents I am working for see this as a necessity to market many of their listings. I 

want to meet the needs of my clients with the confidence that I am under the 

protection of the FAA guidelines.

Sincerely,

Eric Olson

All Around The House, Inc

Licensed, Bonded and Insured

Certified Home Inspector

General Contractor

OCHI# 1508

CCB# 203051