US Department of Transportation Exemption Request Pursuant to 

Section 333 of the FAA

Reform Act and Part 11 of the Federal Aviation 

December 23, 2015 

Fred Scadron

5129 Chatsworth Ave. 

Tampa, Fla. 33625

Turbobuick4@yahoo.com

UAS Certificate Number: FA3NTKYTLK

U.S Department of Transportation Docket Management System 1200 

New Jersey Ave., SE Washington DC 20590

Re: 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) 

Dear Sir or Madam: Pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (the "Reform Act") And 14 CFR Part 11 of 

Unmanned Aircraft Systems (UAS), Fred Scadron 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. 

Thank you in advance for your consideration. 
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. Civil Engineering 

2. Real Estate 

3. Agricultural 

4. Aerial Photography / Videography 

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."

The name and address of the applicant is:

Fred Scadron

5129 Chatsworth Ave.

Tampa, Fl. 33625

Turbobuick4@yahoo.com

From which the exemption is requested: 14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (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) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) 

14 CFR 91.409 (a) 

14 CFR 91.417 (a):

Grants of exemption in circumstances similar in all material respects, 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), 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), and 12645 to Allied Drones (see Docket No. FAA2014-0804) Exemption Nos. 11062, 11109, 11112, 11213, and 12645; 

Nos. 11062, 11109, 11112, 11213, and 12645. 

Fred Scadron Will operate one or more of the Following model UAS:

DJI Phantom 2, 3, and DJI Inspire 1 

Safety requirements. The approval of this application presents no 

national security issues. Regarding the level of safety surrounding the 

proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the 

grant of the requested exemption is in the public interest. Accordingly, 

the applicant graciously requests that the FAA grant the requested 

exemption. 
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of 

safety because operations will further enhance the safety of the 

persons and/or property using conventional aircraft. These limitations 

and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as 

set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 

pounds with battery and camera. 

2. The UAS, depending on the model in operation, will have a maximum 

operating speed of no more than 50mph. 

3. Flights will be operated within line of sight of the Pilot in Command 

(PIC) and/or Visual Observer (VO). 

4. Maximum flight time for each operational flight will be depending on 

the UAS model in operation, but will not exceed 30 minutes. Flights will 

be terminated at 25% battery power reserve or 30 minutes of flight 

time whichever occurs first. 

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

Above Ground Level (AGL) and not more than 200 feet above an 

elevated platform from which filming is planned. 

6. Minimum crew for each operation will consist of the UAS Pilot and at 

least one Visual Observer (VO), and may include a third, but separate, 

Camera Operator (CO). 

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC 

will have logged a minimum of 20 hours on the designated UAS. 
8. A safety briefing will be performed prior to each day's flights 

consisting of all the days' Production activities. 

9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological 

Conditions (VMC) only. 

11. The flights will occur in Class G airspace no closer than a mile radius 

of the geographic center/Airport Reference Point (ARP) of a tower 

controlled or uncontrolled airport. 

12. Flights will not be closer than a 5-mile radius of the geographic 

center/Airport. 

13. The operator will do a pre check of aircraft prior to each flight. And 

log each flight. 

14. The operator will obtain verbal/written consent of all persons 

involved with the planned operation and ensure that only consenting 

persons will be allowed within 100 feet of the flight operation, and the 

radius may be reduced to 30 feet based upon an equivalent level of 

safety determination, as U.S. Department of Transportation required 

under the FOM. With the advanced permission of the FSDO, operations 

at closer range may be approved. 

15. The PIC and VO will have been trained in operation of UAS and 

receive up to date information for the particular UAS to be operated. 

16. The PIC and VO will be able to communicate by voice and/or radio 

at all times. 

17. The PIC will abide by all rules 
18. If the UAS loses communications with the remote controller or loses 

GPS signal, the UAS will have the capability to return to a 

predetermined location within a designated location and land 

autonomously. 

19. The UAS will have the capability to abort a flight in case of 

emergencies with an automated "Return Home and Land" function. 

20. The UAS will have the capability to abort a flight in case of 

unpredicted obstacles, weather, or emergencies such as low battery. 

14 C.F.R. 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 the Applicant, 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 

U.S.C.§44701 (f)) 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 UAS. In all cases, an analysis of these criteria demonstrates 

that the UAS 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 

rotorcraft) operating with an airworthiness certificate without the 

restrictions and conditions proposed. The UAS to be operated 

hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. 
Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by both the operator and under the 

requirements and in compliance with local public safety requirements. 

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 UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or 

flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: 

When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light sport 

category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited/' "restricted/' "light sport/' 

"experimental/' or "provisional/' as applicable 

14 C.F.R. § 45.23 (b). Marking of the Aircraft The regulation requires: 

When marks include only the Roman capital letter "N" and the 

registration number is displayed on limited, restricted or light sport 

category aircraft or experimental or provisionally certificated aircraft. 

The operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited/' "restricted/' "light sport/' 

"experimental/' or "provisional/' as applicable. Even though the UAS 

will have no airworthiness certificate, an exemption may be needed, as 

the UAS will have no entrance to the cabin, cockpit or pilot station on 

which the word lettering will be impossible. The word "Experimental" 

will be placed on the fuselage in compliance with §45.29 (f). US 

Department of Transportation February 20, 2015. 
The equivalent level of safety will be provided by having the UAS 

marked "Experimental" can be placed. Given the size of the UAS, two 

inch on its fuselage as required by §45.29 (f) where the pilot, observer 

and others working with the UAS will see the identification of the UAS 

as "Experimental." 14 C.F.R. § 61.113 (a) and (b The proposed UAS 

operations may achieve an equivalent level of safety as achieved by 

current Regulations because the applicant's UAS do not carry any pilots 

or passengers nor property. The risks attendant to the It is believed that 

the operation and limitations set forth in the FOM will equate to the 

safe operation of the UAS. 

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 

for maintenance and use of safety checklists prior to each flight, an 

equivalent level of safety will be provided. 14 C.F.R. § 91.9 (b) (2): Civil 

Aircraft Flight Manual in the Aircraft. Section 91.9 (b) {2) provides: No 

person may operate a U.S. registered civil aircraft ... (2) For which an 

Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved 

airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. The UAS, 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 

UAS will have immediate access to it. 
14 C.F.R. § 91.103: Preflight Action. This regulation requires each pilot 

in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided 

for the aircraft an exemption will be needed. The PIC will take all 

actions as stated in the FOM in Section 4 under Normal Procedures 

including but not limited to reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance 

data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. Section 91.103 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. UAS and remotely piloted aircraft, by their 

design 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 approved 

exemptions for flight training without fully functional dual controls for a 

number of aircraft and for flight instruction in experimental aircraft. 

The equivalent level of safety is provided by the fact that neither a pilot 

nor passengers will be carried in the aircraft 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. As this exemption is 

for a UAS that is a helicopter and the exemption requests authority to 

operate at altitudes up to 400 AGL, or not more than 200 above an 

elevated platform from which filming is planned, an exemption may be 

needed to allow such operations. As set forth herein, the UAS will never 

operate at higher than 400 AGL with the exception that in 

circumstances where the UAS is used to survey or photograph a 
structure whose height exceeds 400 feet AGL, the UAS will not be 

operated more than 200 feet above the highest point on the structure. 

It will however be operated 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, 

and speed of the UAS 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 

participants in the filming activity, all affected individuals will be aware 

of the planned flight operations. Compared to flight operations with 

aircraft or rotorcraft weighting far more than the maximum SSibs. 

Proposed herein and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented with 

conventional aircraft operating at or below 500 AGL. In addition, the 

low altitude operations of the UAS will ensure separation between 

these UAS operations and the operations of conventional aircraft that 

must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set "...to the 

elevation of the departure airport or an appropriate altimeter setting 

available before departure." As the UAS may not have a barometric 

altimeter, but instead a GPS altitude read out, an U.S. exemption may 

be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the safety check list and live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements 

for Flight in VFR Conditions Section 91.151 (a) prohibits an individual 

from beginning "a flight in an airplane 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- (1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to fly after that for at least 45 minutes." The 

applicant believes that an exemption from 14 CFR §91.151(a) falls 

within the scope of prior exemptions. Operating the UAS in a tightly 

controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed does not 

engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. The applicant 

believes that an equivalent level of safety can be achieved by limiting 

flights to 30 minutes or 25% of battery power- whichever happens first. 

This restriction would be more than adequate to return the UAS to its 

planned landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration The regulation provides in pertinent 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. The 

UAS fully loaded weighs well under the proposed 55 lb limit and is 

operated without an onboard pilot. As such, there is no ability or place 

to carry certification and registration documents or to display them on 

the UAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the UAS 

will have immediate access to them, to the extent they are applicable 

to the UAS. 

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 the applicant. Maintenance will be 

accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved 

because the UAS is very limited in size and will carry a small payload 

and operate only in restricted areas for a limited period of time. If 

mechanical issues arise the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. The operator will ensure 

that the UAS 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. An equivalent level of safety will 

be achieved because maintenance and inspections will be performed in 

accordance with the UAS Manufacturer's User Manual. As provided in 

the FOM, and a link on last page, the operator will ensure that the UAS 

is in working order prior to initiating flight and perform required 

maintenance needed. Authority contained in 49 U.S.C. 106(f), 40113, 

and 44701. 
Additional Information:

The applicant Fred Scadron believes this exemption request and 

associated safety considerations adequately satisfy criteria provided in 

Section 333 of the Reform Act of 2012, providing sufficient justification 

for the granting of commercial operations of the applicant's UAS. 

The applicant, Lino Fred Scadron requests your respective approval of 

this Section 333 exemption petition request.

Thank you for your attention in this matter. Please notify Fred Scadron

Of your actions, and or approvals. Thank you, for your interest in this

request.

Sincerely,

Fred Scadron

Manual Link: 

http://download.djiinnovations.com/downloads/phantom_2/en/PHAN

TOM2_User_Manual_v1.4_en.pdf

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professi

onal_User_Manual__V1.6.pdf

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_

1_User_Manual_v1.4_en.pdf