Exemption Request Section 333 of the FAA Reform Act

John E. Walsh, II, SRQ Drone Pro, LLC 1

March 6, 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption request FAA Modernization and Reform Act, Section 333, 14 C.F.R Sections 21, 45.23, 

61.113(a) & (b), 91.103, 91.105, 91.109, 91.113, 91.119, 91.121, 91.131, 91.151(b), 91.203, 91.405(a),

91.407(a)(1), 91.409(a)(1)&(2), 91.417(a)&(b), 91.7(a), 91.9(b)(2)

Dear Sir or Madam,

In pursuant to the FAA Modernization and Reform Act of 2012 and the procedures contained within 14 

C.F.R. 11, John E. Walsh, II, an operator of small unmanned aircraft for aerial photography and 

videography, seeks an exemption from the Federal Aviation Regulations (FAR) to allow commercial 

operations of its sUAS. Regulations (“FAR’s”) to allow commercial operations of its sUASs, 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. 

John E. Walsh, II, is the owner of SRQ Drone Pro, LLC in Sarasota, Florida. I am a Florida Certified Law 

Enforcement Officer with a B.A. degree in Professional Aeronautics from Embry Riddle Aeronautical 

University Daytona, Florida. I am also a certificated single and multi-engine commercial pilot with 

instrument rating since 2006 (certificate # 3195436). SRQ Drone Pro, LLC has recently purchased a DJI

Phantom 3 quad-copter which is equipped with a camera and intended for aerial 

videography/cinematography. I have completed FAA sUAS registration and received Certificate of 

Registration # FA3W7C4PCH. 

As described more fully below, the requested exemption would permit operation of the ultralightweight, unmanned and relatively inexpensive sUAS(s) under controlled conditions in airspace that is 

limited, predetermined, controlled as to access take photos and record video for its clients. Approval of 

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft 

systems [sUAS’s] in the national airspace system.”
Exemption Request Section 333 of the FAA Reform Act

John E. Walsh, II, SRQ Drone Pro, LLC 2

Information Supporting this Petition as Specified in 14 C.F.R. §11.81

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, 

telephone number, or e-mail address;

John E. Walsh, II / sUAS Pilot

SRQ Drone Pro, LLC

P.O. Box 1046

Sarasota, Florida 34230-1046

 Phone: 941-685-6247

 E-Mail: srqdronepro@gmail.com

(b) The specific section or sections of 14 C.F.R. from which John E. Walsh, II seeks an exemption:

 21 – Subpart H Certification procedures for products and parts, Airworthiness Certificates

 45.23 – Display of marks; general

 61.113 – Private pilot privileges and limitations: Pilot in Command

 91.103 – Preflight Actions

 91.105 – Flight crewmembers at stations

 91.109 – Flight instructions; Simulated instrument flight and certain flight tests

 91.113 – Right-of-Way Rules

 91.119 – Minimum safe altitudes: General

 91.121 – Altimeter settings

 91.131 – Operations in Class B Airspace

 91.151 – Fuel requirements for flights in Visual Flight Rules (VFR) conditions

 91.203 – Civil aircraft: certification required

 91.405 – Maintenance required

 91.407 – Operation after maintenance, preventative maintenance, rebuilding, and alteration

 91.409 – Inspections

 91.417 – Maintenance records

 91.7 – Civil Aircraft Worthiness

 91.9 (b)(2) – Civil Aircraft Flight Manual in the Aircraft 

(c) The extent of relief John E. Walsh, II seeks, and the reason John E. Walsh, II seeks the relief:

John E. Walsh, II seeks an exemption for several provisions of 14 C.F.R. Parts 21, 45, 61, and 91 to the 

extent to operate small sUASs to record aerial photography and videography purposes. 

This exemption application is expressly submitted to fulfill Congress’ 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 (NAS) before 

completion of the rulemaking required under Section 333 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UAS(s) do not create a hazard to 
Exemption Request Section 333 of the FAA Reform Act

John E. Walsh, II, SRQ Drone Pro, LLC 3

uses of the NAS or the public or pose a threat to national security in light of the following:

 The sUAS(s) size, weight, speed and operational capability;

 Operation of the sUAS in close proximity to airports and populated areas; and

 Operation of the sUAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “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”

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

authority by its terms includes civil aircraft, as the term is defined under § 40101 of the Act, that 

includes sUAS(s), from the requirement that all civil aircraft must have 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 USC. § 44701(f) See also 49 USC § 44711(a); 49 USC § 44704; 14 

CFR § 91.203 (a) (1).

14 CFR 21 – Subpart H Certification procedures for products and parts, Airworthiness Certificates

John E. Walsh, II seeks exemption from 14 CFR 21, Subpart H which states the certification procedures 

for products and parts as well as airworthiness certificates. The sUAS to be operated hereunder is less 

than 55 pounds fully loaded, carries neither a pilot nor passenger, carries no explosive materials or 

flammable liquid fuels, and operates exclusively within a secured area as set out in the manual. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the 

operator, pursuant to the manual’s requirements, and under the requirements and in compliance with 

local public safety requirements, to provide security for the area of operation as is now done with 

conventional filming. The FAA will have advance notice of all operations. These safety enhancements, 

which already apply to civil aircraft operated in connection with motion picture and television 

production, provide a greater degree of safety to the public and the property owners than conventional 

operations conducted with airworthiness certificates issued under 14 CFR 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 load. 

John E. Walsh, II has developed its own procedures and protocols to promote and provide safe flying 

experiences for PIC(s) which can be viewed in section (e) of this petition. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the operator, 

pursuant to the manual’s requirements, and under the requirements and in compliance with local public 

safety requirements, to provide security for the area of operation.
Exemption Request Section 333 of the FAA Reform Act

John E. Walsh, II, SRQ Drone Pro, LLC 4

14 CFR § 45.23 (b) Display of Marks; general

John E. Walsh, II seeks an exemption from 14 CFR 45.23, which discusses the display of marks. 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,” “lightsport,” “experimental,” or “provisional,” as applicable. 

An exemption to this section is needed due to the lack of a cabin, cockpit or pilot station where any 

reference to the term “Experimental” could be affixed. Accordingly, the wording will be placed on the 

fuselage. This equivalent level of safety will allow the team to clearly see “Experimental.” John E. Walsh, 

II will also register each aircraft in operations with a certified “N” number as required. The FAA has 

issued the following exemptions to this regulation to exemption numbers 10700, 8738, 10167, and 

10167A. 

CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in Command 

CFR 61.113 (a) & (b) states: 

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot 

certificate may act as pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command 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. 

John E. Walsh, II is seeking an exemption from this regulation, because there is no conclusive evidence 

that a person with a private pilot certificate can successfully maneuver a sUAS without first hand flight 

experience with the particular sUAS. In fact, having a private pilot certificate does not automatically 

ensure competence at flying an sUAS in 3rd person view as required to properly operate an sUAS within 

the required line of sight. However, we believe that the PIC and FOVO (Field Operation Visual Observer) 

must be able to understand and correctly interact with the general aviation community. Our PIC and 

FOVO will be both certified in ground school equivalent training to be able to properly interact with 

General Aviation protocols.
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John E. Walsh, II, SRQ Drone Pro, LLC 5

CFR 91.103 (b) Preflight action 

CFR 91.103 (b) states: 

Each pilot in command shall, before beginning a flight, become familiar with all available information 

concerning that flight. This information must include—

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information: 

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and 

landing distance data is required, the takeoff and landing distance data contained therein; and 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of 

airport elevation and runway slope, aircraft gross weight, and wind and temperature. 

This regulation dictates that a pilot conduct preflight activities. Without an FAA approved flight manual, 

relief is required from this regulation. Extensive pre-flight planning will provide an equivalent level of 

safety by using the operations plan, aircraft flight manual, maintenance manual and available weather 

and NOTAM information. 

14 CFR 91.105 – Flight crewmembers at stations

John E. Walsh, II will need an exemption from this regulation due to the fact that the sUAS will not have 

a flight crew or crew stations other than the PIC and a FOVO. The PIC, not being in the aircraft, 

therefore will also not have to be restrained into a seat via shoulder harness or safety belt at the time of 

the flight. 

CFR 91.109 Flight instruction 

CFR 91.109 states:

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. 

sUAS(s) clearly have no onboard flight controls. An equivalent level of safety will be accomplished by 

conducting pilot training via the control system that communicates with the aircraft from the ground. 

John E. Walsh, II to conduct this training in a rural area in the eastern portion of Sarasota County, Florida 

under controlled conditions.

John E. Walsh, II believes that there is no inconclusive evidence that a person with a private pilot 

certificate or license can successfully maneuver or train someone to use an sUAS without first hand 

flight experience with the particular sUAS. Flying in 3rd person orientation requires built-up experience 

in that form of flying for many years. Therefore, we believe our own flight training, pilot protocols and 

firsthand experience with the sUAS as laid out in our Flight Operations Manual meets and exceeds the 
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John E. Walsh, II, SRQ Drone Pro, LLC 6

requirements necessary to safely operate our sUAS for the tasks we purpose. Also, the sUAS will be 

operated by remote control, which will only require single person operator and dual controls for flight 

operation will not be necessary. 

CFR 91.113 Right-of-way rules: Except water operations. 

CFR 91.113 deals with the many scenarios whereby different types of aircraft in different states must 

give way to other aircraft. 

Because the sUAS PIC does not have “see and avoid” capability, the petitioner requests relief from this 

regulation. All operations will be within LOS of the pilot and well below any airspace where other flight 

activity is taking place. 

CFR 91.119 (d) (1) Minimum safe altitudes; general 

CFR 91.119 states: 

(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. 

As this exemption is for a sUAS 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 sUAS will never 

operate at higher than 400 AGL with the exception that in circumstances where the sUAS is used to 

survey or photograph a structure whose height exceeds 400 feet AGL, the sUAS 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, 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 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 55lbs. 

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 400 AGL. In addition, the 

low-altitude operations of the sUAS 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
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John E. Walsh, II, SRQ Drone Pro, LLC 7

CFR 91.121 Altimeter settings 

CFR 91.121 states: 

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—

Below 18,000 feet MSL, to—

The current reported altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft; 

The sUAS aircraft intended for this activity will not be equipped with a barometric altimeter. Instead it 

will incorporate radio altimetry via the onboard GPS. An equivalent level of safety will be achieved 

through use of the operations and maintenance manuals governing altitude control. A preflight 

calibration of launch site altitude will be accomplished.

CFR 91.131 (a) (1) (c) (2) & (d) (1) Operations in Class B airspace 

CFR 91.131 states: 

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in 

compliance with § 91.129 and the following rules: 

(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area 

before operating an aircraft in that area. 

(c) Communications and navigation equipment requirements. Unless otherwise authorized by ATC, no 

person may operate an aircraft within a Class B airspace area unless that aircraft is equipped with—

(2) For all operations. An operable two-way radio capable of communications with ATC on appropriate 

frequencies for that Class B airspace area. 

(d) Other equipment requirements. No person may operate an aircraft in a Class B airspace area unless 

the aircraft is equipped with—

(1) The applicable operating transponder and automatic altitude reporting equipment specified in § 

91.215 (a), except as provided in § 91.215 (e), and 

Because the planned sUAS to be employed lacks an onboard transponder or two way communication 

capability, relief from this regulation is required. An equivalent level of safety will be achieved by 

limiting the operating ceiling of the sUAS to altitudes well below any conflicting manned aircraft traffic 

(no higher than 400 feet). This assures de-confliction with all other traffic and specifically traffic within 

the Class B airspace. Additionally, John E. Walsh, II will periodically report to the FSDO on operations and 

risk management issues. 
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John E. Walsh, II, SRQ Drone Pro, LLC 8

CFR 91.151 (b) Fuel requirements for flight in VFR conditions. 

CFR 91.151(b) states: 

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 battery powering the sUAS 

provides approximately 25 minutes of powered flight. To meet the 30 minute reserve requirement in 14 

CFR §91.151, UAS flights would be limited to approximately 10 minutes in length. Given the limitations 

on the sUAS’s proposed flight area and the location of its proposed operations within a predetermined 

area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. 

John E. Walsh, II believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. Operating the sUAS, 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 small sUAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the 

utility for which the exemption will be granted. Applicant believes that an equivalent level of safety can 

be achieved by limiting flights to 20 minutes or 25% of battery power— whichever happens first. This 

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

in its limited operating area.

No night time operations are currently planned.

CFR 91.203 (a) & (b) Civil Aircraft: Certifications required 

CFR 91.203 (a) & (b) states: 

(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 under § 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 to 

the aircraft. 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, 
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John E. Walsh, II, SRQ Drone Pro, LLC 9

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. 

The sUAS to be employed has no cockpit or pilot and therefore has no ability to carry onboard any 

certification or registration documentation. 

The equivalent level of safety will be achieved by keeping these documents with the PIC and FOVO on 

the ground at the event. Previous precedence is resident in Exemptions 9565, 9665, 9789, 9789A, 9797, 

9797A, 9816A and 10700. 

CFR 91.405 (a); 407 (a) (1) (2); 409 (a) (2); & 417 (a) & (b) Maintenance 

These CFRs state: 

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; 

Operation after maintenance, preventive maintenance, rebuilding, or alteration. 

(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; and 

(2) The maintenance record entry required by § 43.9 or § 43.11, as applicable, of this chapter has been 

made. 

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—

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

chapter. 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—
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John E. Walsh, II, SRQ Drone Pro, LLC 10

(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. 

(2) The records specified in paragraph (a) (2) of this section shall be retained and transferred with the 

aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service. 

These FARs only concern aircraft with an airworthiness certificate and therefore would not apply in this 

situation. The ability for an almost immediate safe recovery and landing if a malfunction occurs and the 

eight engine configuration with the ability to fly with loss of thrust on 2 engines provides a comfortable 

operating envelope and ensures an equivalent level of safety. 
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John E. Walsh, II, SRQ Drone Pro, LLC 11

CFR 91.7 (a) Civil aircraft worthiness 

CFR 91.7 (a) states: 

No person may operate a civil aircraft unless it is in an airworthy condition. 

Assuming no airworthiness certificate will be required due to relief from Subpart H, no regulatory 

standard exists for determining airworthiness. The equivalent level of safety will be achieved through 

the employment of flight manual and maintenance manual procedures, pilot training and analytical risk 

management for each event. 

CFR 91.9 (b) (2) Civil Aircraft Flight Manual in the Aircraft

CFR 91.9 (b) (2) states: 

No person may operate a U.S.-registered civil aircraft—

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. 

Given the size of the sUAS being utilized in this endeavor, there is no room onboard for an aircraft flight 

manual. 

The equivalent level of safety will be achieved by keeping the flight manual with the pilot/team on the 

ground with easy access. Previous precedence is resident in Exemptions 8607, 8737, f8738, 9299, 

9299A, 9565, 9565B, 10167, 10167A, 10602, f32827, and 10700. 
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John E. Walsh, II, SRQ Drone Pro, LLC 12

The reasons why granting John E. Walsh, II request would be in the public interest; that is, how it 

would benefit the public as a whole: 

Granting the present Petition will further the public interest by allowing John E. Walsh, II to safely, 

efficiently, and economically perform aerial video and photography of construction sites, real estate, 

events, and civic landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 3 sUAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of John E. Walsh, II proposed 

operation of the DJI Phantom 3 sUAS will be realized without implicating any privacy issues.

Granting the exemption to John E. Walsh, II would allow the public to safely view events and property 

from a dynamic and unprecedented aerial perspective. John E. Walsh, II has created a unique way to 

view events and property that benefit the general public socially and economically. John E. Walsh, II will 

set an industry standard in using purpose built small Unmanned Aircraft Systems (sUAS) with multiple 

redundant features that enhance safety. 

The reasons why granting the exemption would not adversely affect safety: 

 John E. Walsh, II shall include at a minimum of a FAA-rated private or recreational flight 

certificate as well as ground school certification.

 During operations at minimum, we will have a Pilot in Command (PIC) and a Flight Operations 

Visual Observer (FOVO) certified under safe operations protocols.

 The flight area of the sUAS will be observed for best takeoff and landing locations. Desired 

conditions include: flat and level surfaces clear of debris, at least 15 feet from power lines and 

structures, and a minimum distance of 12 feet from the PIC and observers. 

 The sUAS will also be in the Visual Line of Sight (VLOS) to both the PIC and FOVO during all 

flights. 

 Flights must take place during good weather conditions with no rain, low laying clouds, or heavy 

winds. All flights will take place during the daylight hours with no night flights.

 The PIC(s) of the sUAS will at least have 12 training hours or 24 flights accrued before being 

designated working flights.

 All batteries must be charged completely before each flight and each flight must end when the 

battery has a 30% power level remaining.

 A visual safety inspection will occur before each flight, testing propeller tightness, security 

mount of camera / detection equipment, remote range test, and proper safety equipment is 

adorned to PIC and FOVO.

 The sUAS will be flown under a height of 400 feet AGL.

 No PIC or FOVO will engage in, nor may a PIC or FOVO permit, any activity during a critical phase 

of flight so as to ensure that the sUAS is in a condition for safe flight operation and in a 

configuration appropriate for the purpose of the intended flight. 

 If there is more than just an operator at a site during a flight, the PIC operator and observer or 
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John E. Walsh, II, SRQ Drone Pro, LLC 13

FOVO will maintain two-way communications with each other during all operations; if unable to 

maintain two-way communications, or if any condition occurs that may otherwise cause the 

operation to be unsafe, the operator will immediately conclude the operation.

 If the communication link is lost, the sUAS will go into fail-safe mode and safely descend to its 

designated home-point location. If the communication link is reconnected during the fail-safe 

mode, control of the sUAS can be regained before landing occurs at the home-point location. 

 There is no fuel or payload to the sUAS, therefore there will be no potential explosives or risk of 

explosion if a crash occurs.

 The sUAS will feature a built in compass that will be recalibrated at every sit to maintain 

accurate directional readings and help in keeping the sUAS stable during flights.

 The sUAS will record GPS location data once Ready to Fly status has been obtained. A minimum 

of six satellites will activate Ready to Fly status. As well as full auto-pilot return-to-home 

feature.

 The aircrafts to be operated will include: the DJI Phantom 3 Advanced with a diagonal size of 

590 mm and a flying weight of less than 1280 grams.

 The aircraft vertical and horizontal aspect concerning hovering accuracy is less than 0.5 m and 

1.5 m respectively. With a maximum wind resistance of 18 mph.

 The aircraft runs off a high quality Li-Pro battery.

(f) A summary FAA can publish in the FEDERAL REGISTER, stating (1) The rule from which you seek 

exemption; and (2) A brief description of the nature of the exemption you see Petitioner: John E. Walsh, 

II. 

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

CFR Part 11, John E. Walsh, II, operator of an Unmanned Aircraft System (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

sUAS, 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. Commercial operation of an UAS, as 

described herein, which are DJI Phantom 3 Advanced, equipped with camera(s) and sensors would 

operate in the following manner: 

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

surveying, engineering and other related professional activities. 

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

cinematography and news gathering. 

• Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 

• 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 
Exemption Request Section 333 of the FAA Reform Act

John E. Walsh, II, SRQ Drone Pro, LLC 14

it by contract or donation. 

• The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the 

protection of the persons and property.

Extensive range testing, “dry-run” testing under benign conditions and simulated emergencies will 

demonstrate that this activity can be accomplished without hazard to the general public. 

Predetermined waypoints using Geographic Instrument System coordinates and auto-pilot “fly to” 

commands provide extremely precise navigation. 

These capabilities, in total, provide a level of safety that should be satisfactory to the FAA and general 

public. 

In view of the beneficial advantages to public safety, we respectfully submit our Section 333 exemption 

request. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and

Reform Act, Section 333, John E. Walsh, II respectfully requests that the Administrator grant this

Petition for an exemption from the requirements of 14 C.F.R Sections 21, 45.23, 61.113(a) & (b),

91.103, 91.105, 91.109, 91.113, 91.119, 91.121, 91.131, 91.151(b), 91.203, 91.405(a), 91.407(a)(1),

91.409(a)(1)&(2), 91.417(a)&(b), 91.7(a), 91.9(b)(2) and permit John E. Walsh, II to operate the

DJI Phantom 3 UAS commercially for the purpose of conducting aerial video and photography over

certain areas of the United States.

Sincerely, 

John E. Walsh, II

SRQ Drone Pro, LLC – Owner

P.O. Box 1046

Sarasota, FL 34230-1046

941-685-6247

srqdronepro@gmail.com