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PETITION FOR SECTION 333 EXEMPTION –

GREGORY B. MAYS

July 12, 2015

U.S. Department of Transportation

Docket Operations

800 Independence Ave., S.W.

Washington, DC 20591

Re: Petition of Gregory B. Mays for Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11

Dear Sir or Madam:

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

Act") and 14 C.F.R. Part 11, Gregory B. Mays (individual) hereby applies for an exemption from 

the Federal Aviation Regulations (“FARs”) identified below, to allow civil operation of small 

unmanned aerial systems (“sUAS” or “UAS”) as part of daily business operations.

TABLE OF CONTENTS

I. Description of Petitioner

II. Description of Proposed Operation

III. Gregory B. Mays Proposed UAS Operations Meet the Requirements of Section 333

a. Approval is Warranted Based on the UAS's Size, Weight, Speed, and Operational 

Capability

b. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

included UAS Standard Operating Guide

IV. Regulations From Which Exemption is Sought

a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

b. 14 C.F.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft 

c. 14 C.F.R. §§ 45.23(b) and 45.27(a): Marking of the Aircraft

d. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civil Aircraft Flight Manual in the 

Aircraft
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f. 14 C.F.R. § 91.103: Preflight Actions

g. 14 C.F.R. § 91.109(a): Flight Instruction

h. 14 C.F.R. § 91.119: Minimum Safe Altitudes

i. 14 C.F.R. § 91.121: Altimeter Settings

j. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

k. 14 C.F.R. § 91.405, 91.407, 91.409, 91.417: Maintenance and Inspections

l. 14 C.F.R. Part 61, 14 C.F.R. § 61.3, 14 C.F.R. § 61.113: Private Pilot Privileges

and Limitations

V. Public Interest

VI. Privacy

VII. Federal Register Summary

VIII. APPENDIX A: Gregory B. Mays UAS Standard Operating Guide

IX. APPENDIX B: Don’t Fly Drones Here Map: Restricted Area

X. APPENDIX C: FAA Advisory Circular

XI. APPENDIX D: AMA Safety Code

I. Description of Petitioner

Gregory B. Mays provides real estate services to clients that often require photographs. In 

recent months clients have requested aerial photographs that would require hiring an outsider to 

provide services related to taking said photographs.

These photos are often utilized for marketing purposes, however, the request for aerial photos 

has been extended to clients who require same in an effort to lend money for mortgage purposes 

in conformance with FNMA/FHLMC, FHA, and others, guidelines.

 Greg B. Mays & Associates, LC is a small real estate appraisal company that has been in 

business since 1991.

 Services include real estate consultation, appraisal, sales, and property management.

 Greg B. Mays & Associates, LC is properly licensed in the Commonwealth of Virginia to 

provide said services.

 Greg B. Mays holds the following licenses/certifications; Realtor and Real Estate Agent, 

Certified Residential Real Estate Appraiser, Private Pilot.
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In accordance with 14 C.F.R. § 11.81(a), Gregory B. Mays provides the following 

information in support of its Petition for Exemption.

Name and Address for Petitioner:

Gregory B. Mays

2220 Swamp Fox Rd.

Midlothian, VA 231112

804-378-9655

gregbm@verizon.net

Point of contact for this Petition and specific contact information is as follows:

Greg B. Mays, RAA

Owner

2220 Swamp Fox Rd.

Midlothian, VA 23112

II. Description of Proposed Operation

Gregory B. Mays proposes to conduct the operation of a UAS, specifically the DJI Phantom 

2 or DJI Inspire, within the parameters of providing aerial photographs of single family

residences and or large acreage parcels of land...

The Pilot in Command (“PIC”) for each operation will, at a minimum, be Gregory B. Mays. 

Gregory B. Mays has adopted and incorporated many of the AMA’s UAS Safety Code (the 

“Code”) and Operating Guide’s (the “Guide”) procedures into its own safety code and guide, 

which sets forth the mandatory standard operating procedures for its proposed UAS operations as 

detailed herein. The exception would be the location of operations that will take place at private 

residences with the authorization of the owner and not on property leased or owned by the AMA. 

These procedures provide a baseline to ensure that the Phantom 2 Vision or Inspire 1 pilot

possess sufficient knowledge of both airspace and the technology to operate safely in the 

National Airspace System (“NAS”). Any other assistant or photographer will operate with 

Gregory B. Mays as the PIC in each operation and will meet the standards specified in the Guide, 

as well as any other additional requirement the FAA requires under this application.

III. Proposed UAS Operations Meet the Requirements of Section 333

Proposed operations in this Petition for Exemption qualify for expedited approval pursuant to 

Section 333 of the Reform Act as each of the statutory criteria and relevant factors are satisfied.

a. Approval is Warranted Based on the UAS’s Size, Weight, Speed, and 

Operational Capability
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Gregory B. Mays will employ the DJI Phantom 2 Vision (“Phantom 2V”) or DJI Inspire

1 quadcopter for the operations described in this Petition for Exemption. Both of these UAS are

classified as a small drone or hobby craft and are lawfully used for recreational operations. The 

Phantom 2V has a maximum take-off weight of 5.53 pounds. The flight speed is limited to a 

maximum of 33.5 miles per hour and it will not be flown at an altitude that exceeds 200 feet 

AGL. All flights will be managed in such a way that they can be safely terminated with a reserve 

battery power of 25% of the battery's maximum charge. Neither the Phantom 2Vor the Inspire 1 

carry any flammable propellant or fuel. Both UAS also has an integrated GPS system that 

calculates the UAS's position and height and relays that information via a secure connection to 

the operator. Through use of this GPS system and the installed firmware, the user is able to set 

maximum height and radius in relation to a pre-determined home point, restricting flight to a 

zone that is both approved by the FAA and the owner of the property being photographed. This 

system also automatically restricts flight within a range of airports that is greater than the 5 miles 

that the FAA requires. Additionally, the UAS contains a failsafe mode if its connection to the

remote control is lost, and this system permits the UAS to return to a predetermined location and

land without injury or damage.

b. Approval is Warranted Based on the Operational Restrictions Set Forth in

the UAS Standard Operating Guide

Together, the Guide and the Phantom 2V’s and or Inspire 1’s User Manual contain all of 

the procedures and limitations necessary to successfully perform the operations specified in this 

Petition for Exemption. To assist the FAA in making a safety assessment of Gregory B. Mays

proposed operations, below is a summary of operational limitations and conditions which will 

ensure an equivalent or higher level of safety to operations conducted under current regulatory 

guidelines:

1. The Phantom 2 weighs 5.53 +/- pounds and the Inspire 1 weighs 6.50 +/- pounds.

2. Flights will be operated within the VLOS of the PIC and or an observer, at a 

minimum.

3. Maximum total flight time for each operational flight will be limited to 25% reserve 

battery power remaining.

4. Flights will be operated at an altitude of no more than 200 feet AGL.

5. All operations will be conducted in class G airspace.

6. Flights will be restricted to pre-determined areas of the owner/clients property, which 

will always be located outside of 5 miles radius from an airport of any size or the 

necessary NOTAM will be filed for safe operation in advance of operations.

7. Flight zones will be located at the maximum distance away from persons, inhabited 

structures, and vehicles that is possible given the layout of the property. The flight 

zone in which operations occurs will be assigned based on the real time traffic, 

activities, and weather conditions. 
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8. Flights will be limited to a speed of 30 mph and vertical ascent will be limited to 15 

mph.

9. The UAS will be operated and maintained in accordance with the requirements of the 

Phantom 2V or Inspire 1 User Manual and any manufacturer Safety Bulletins.

10. Prior to the operation, the flights will be fully preplanned and briefed, including

possible contingencies and emergency procedures. 

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

or emergencies.

12. All required permissions and permits will be obtained from territorial, state, county or

city jurisdictions, including local law enforcement, fire or other appropriate

governmental agencies.

13. All UAS operations will occur in daylight, Visual Flight Rules ("VFR") conditions. 

Instrument flight rules flights are prohibited and no flights will occur at night, or in 

adverse weather conditions.

14. The UAS will be controlled by the Phantom 2 or Inspire 1 Remote Control System 

and the radio frequency spectrum used for operation and control of the UA shall 

comply with the Federal Communications Commission ("FCC") or other appropriate 

government oversight agency requirements.

IV. Regulations From Which Exemption is Sought

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

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined

under § 40101 of the Act, including UASs, from its safety regulations and minimum standards 

when the Administrator decides a requested exemption is in the public interest. Gregory B. Mays

seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 21, 45, 61 and 91 for 

purposes of conducting the requested operations using UAS. Listed below are: (1) the specific 

sections of 14 C.F.R. for which exemption is sought, and; (2) reasons why the exemption would 

not adversely affect safety or provide a level of safety equivalent to the rule, including any 

operating procedures and safeguards that Gregory B. Mays has adopted which will ensure a level 

of safety better than or equal to the rules from which exemption is sought.

a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates

Part 21 Subpart H prescribes procedural requirements for the issue of airworthiness 

certificates. Gregory B. Mays requests exemption from this subpart to operate the Phantom 2V or 

Inspire 1 without the requirement for an airworthiness certificate. Based on the proposed UAS 

being limited in size, weight, speed, operating capabilities, and operating within VLOS, Gregory

B. Mays believes that an airworthiness certificate is not necessary to ensure an equivalent level 

of safety to manned aircraft operations.

Equivalent Level of Safety
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The UAS indicated is safe when taking into account its size, weight, speed, and 

operational capability. As set forth above, the Phantom 2V and or Inspire 1 weigh less than 7

pounds and will be flown at less than 30 mph and completely outside controlled airspace. 

Additionally, neither craft carries pilots nor passengers, carries no explosive materials and or 

flammable liquid fuels, and operates exclusively within the parameters stated in the Guide. 

Operations conducted under this exemption will be closely controlled and monitored by

the PIC and will be conducted in compliance with local public safety requirements, to provide 

security for the area of operation. In all cases, the UAS operated under the proposed conditions, 

will be at least as safe as, or safer than conventional rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions of the proposed UAS operations.

Further, the Phantom 2V does not need a means to communicate with other aircraft or 

ATC, because those capabilities will be possessed by the PIC and Observer, who are not onboard 

the UAS. See Grant of Exemption, Docket FAA-2014-0352 at 13. In addition, the UAS will be 

operated at all times in visual line-of-sight and in VFR conditions. Id.

b. 14 C.F.R. Part 27: Airworthiness Standards for Normal Category Rotorcraft

Title 14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness

certification of normal category rotorcraft. To the extent Gregory B. Mays UAS would otherwise

require certification under Part 27, it seeks an exemption from Part 27's airworthiness standards 

for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

c. 14 C.F.R. §§ 45.23(b) and 45.27(a): Marking of the Aircraft

Gregory B. Mays seeks an exemption from the aircraft marking and identification 

requirements contained in 14 C.F.R. §§ 45.23(b) and 45.27(a).

14 C.F.R. § 45.23(b), Markings of the Aircraft, states:

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. § 45.27(a), Rotorcraft, states:

Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces 

of the cabin, fuselage, boom, or tail the marks required by § 45.23.

Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the Phantom 2V and or Inspire 1 is by definition “unmanned” and so has no entrance 

to a cabin, cockpit, or pilot station on which the above stated words can be placed. Given the size 
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of the UAV, two-inch lettering may be impossible. The word “Exempt” can be placed on the 

fuselage in compliance with 14 C.F.R. § 45.29(f).

Equivalent Level of Safety

The equivalent level of safety will be provided by having the Phantom 2V or Inspire 1 

marked on its fuselage as required by 14 C.F.R. § 45.29(f) where the pilot, observer and others 

working with the UAS will see the identification of the Phantom 2V or Inspire 1 as “Exempt” if 

so desired. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167A.

d. 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 Phantom 2V and the Inspire 1 the description of proposed operations above, 

an equivalent level of safety will be provided.

e. 14 C.F.R. §§ 91.9(b)(2), 91.203(a) and (b): Civil Aircraft Flight Manual in the 

Aircraft

14 C.F.R. § 91.9(b)(2) states:

(b) No person may operate a U.S.-registered civil aircraft 

...

(2) For which an Airplane or Rotorcraft Flight Manual is 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.

14 C.F.R. § 91.203(a) and (b) state:

(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.
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Given the small size and configuration of the Phantom 2V, it would be impossible to 

keep airworthiness documents and other aircraft manuals on board the UAS because there is 

simply no room. Also the UAS has no cabin or cockpit.

Equivalent Level of Safety

In an FAA Office of Chief Counsel's Opinion dated August 8, 2014, and prepared by

Dean E. Griffith, Attorney, AGC-220, it was acknowledged that the intent of 14 C.F.R. 91.9(b) 

and 91.203(a) and (b) is met if the pilot of the unmanned aircraft has access to the UAS flight 

manual, registration certificate, and other required documents from the ground control station 

from which he or she is operating the aircraft. As this FAA Office of Chief Counsel Opinion 

clarifies, the intent of the rule is to ensure the pilot has access to these key documents during 

flight. Therefore, an equivalent level of safety will be achieved be ensuring that the pilot has 

access to the documents at the ground control station or point of control from which he or she is 

piloting the Phantom 2V or Inspire 1.

f. 14 C.F.R. § 91.103: Preflight Actions

This regulation requires each pilot in command to take certain actions before flight to

ensure the safety of flight. As FAA approved flight manuals will not be provided for the aircraft 

an exemption will be needed. 

Equivalent Level of Safety

An equivalent level of safety will be provided through the PIC following the procedures 

set forth in the Guide and Manufacturer’s User Manual. The PIC will take all actions including 

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. The PIC will account for all relevant site-specific 

conditions in the preflight procedures. The FAA has granted exemption from this regulation to 

other small UAS operators. See Exemption No. 11109.

Additionally, the PIC, Gregory B. Mays, also being a licensed pilot, understands the 

importance of being prepared to fly as an airman and will always adhere to the same IAMSAFE 

checklist followed when flying manned aircraft.

g. 14 C.F.R. § 91.109(a): Flight Instruction

Gregory B. Mays seeks an exemption from flight instruction requirements contained 

within 14 C.F.R. § 91.109(a). This section 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.
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Equivalent Safety Protocol

For student training purposes the PIC and student may use a "buddy box" system that 

utilizes two transmitters when applicable. The transmitter of the student is connected by a trainer 

cable to another transmitter (master transmitter) controlled by the PIC instructor. The PIC 

Instructor is able to control the UAS with his or her transmitter then flip a switch to turn control 

over to the student and flip the switch again to reclaim control. In this way, the PIC Instructor 

can easily demonstrate how to fly the UAS or rescue the UAS if the student makes a poor 

aeronautical decision without passing the same transmitter back and forth to preserve safety to 

the NAS and manned aircraft operations.

Given the size and speed of the UAS that the Gregory B. Mays intends to use, an 

equivalent level of safe training can still be performed without dual controls because no pilot or 

passengers are aboard the UAS, and as required by the Guide, all persons will be a safe distance 

away in the event that any difficulties during flight instruction occurs.

Moreover, Petitioner will conduct training in a controlled and sterile environment. As 

required by the Guide, training and instruction will be conducted in a sterile area on property that 

is owned and controlled by the Gregory B. Mays. These facilities will not be open to the public 

during UAS operations, and access will be restricted to authorized business personnel involved 

with the company.

h. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Gregory B. Mays requests an exemption from the minimum safe altitude requirements of 

14 C.F.R. § 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft 

may not operate, including 500 feet above the surface and away from any person, vessel, vehicle, 

or structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated "without 

hazard to persons or property on the surface," provided that "each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

An exemption is required because the proposed UAS operations will occur at under 200 

feet AGL. Further, while the Phantom 2V and or Inspire 1 will never be flown in or over 

congested areas, due to the nature and location of the proposed operations, the PIC, Observer(s),

Instructors and/or Students may at times be less than 200 feet away from the UAS.

Equivalent Safety Protocol

Compared to flight operations with rotorcraft weighing far more than the maximum

weights proposed herein, and given the lack of flammable fuel onboard the Phantom 2V and 

Inspire 1, any risk associated with these operations is far less than those that presently exist with 

conventional aircraft. An equivalent level of safety will be achieved given the size, weight, and 
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speed of the Phantom 2V and or Inspire 1, as well as the controlled and sterile location where the 

operations will occur. In order to avoid any risk to manned aircraft, flight operations will be 

restricted to 200 feet AGL or below. As set forth in the Guide, the Phantom 2V’s or Inspire 1

flight height and radius restrictions will be set according to each operator’s level of experience 

which will be judged by the PIC. The Phantom 2V and or Inspire 1 will be operated in an area 

that is owned by the client and closed to the public when in use. These restrictions will ensure 

that the proposed UAS operations are performed in a manner that protects the safety of

participants, nonparticipants, the UAS, and other property.

i. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C.F.R. § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that 

is set to the elevation of the departure airport or barometric pressure. An exemption is required to 

the extent that the Phantom 2V does not have a barometric altimeter, but rather a GPS altitude 

read out.

Equivalent Safety Protocol

The Guide requires compass calibration prior to each operation of the Phantom 2V to 

ensure the GPS functions correctly. The Phantom 2V User Manuel contains instructions for 

achieving this and the manufacturer, DJI, will provide additional support if necessary. 

j. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Gregory B. Mays requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for 

flight in VFR conditions. Section 91.151 states:

(a) No person may begin 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 –

i. During the day, to fly after that for at least 25 minutes; or

ii. At night, to fly after that for at least 45 minutes.

Here, the technological limitations on the energy capabilities of the 5200mAh LiPo

battery used in the Phantom 2V and the 5700mAh LiPo battery used in the Inspire 1 means that 

no meaningful flight operations can be conducted with the Phantom 2V or Inspire 1 while still 

maintaining a 30 minute battery reserve. An exemption from the fuel requirements of 14 C.F.R. 

§ 91.151(a) is therefore required.

Equivalent Safety Protocol
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The batteries powering the Phantom 2V and or Inspire 1 provide approximately 25

minutes of flight time. Training operations will be limited to a minimum voltage to ensure 

appropriate reserve battery to maintain an equivalent level of safety at all times. The UAS will 

notify the operator when they are approaching and they are required to land at their home point 

and either switch out the battery or pause operations for recharging. If both the operator and PIC 

fail to land the UAS prior to the allotted minimum voltage, the UAS will autonomously return to 

its original launch position.

k. 14 C.F.R. §§ 91.405, 91.407, 91.409, 91.417: Maintenance and Inspections

Gregory B. Mays seeks an exemption from the maintenance inspection requirements 

contained in 14 C.F.R., sections 91.405, 91.407, 91.409, and 91.417. These rules specify

maintenance and inspection standards in reference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 

91.405(a) (stating that each owner or operator of an aircraft "[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ...have discrepancies 

repaired as described in part 43 of this chapter.”) Exemption from these rules is requested

because these sections of Title 14 require the aircraft to be maintained and inspected in 

accordance with Part 43, which only applies to aircraft with an airworthiness certificate. 

Therefore, based on the exemptions sought, these sections do not apply to Gregory B. Mays

proposed UAS operations.

Equivalent Safety Protocol

Maintenance will be accomplished by authorized operators, staff, and/or contracted labor 

pursuant to the Guide and the Manufacturer’s User Manual. An equivalent level of safety will be 

achieved because a UAS like the Phantom 2V or like craft and its platform are very limited in 

size, will carry a small payload, and will operate only in defined areas for limited periods of 

time. If mechanical issues arise the Phantom 2V and or Inspire 1 will be able to land immediately

on property owned by the client and or owner of the craft to receive immediate maintenance. As 

provided in the Guide and Manufacturer’s User Manual, the operator will ensure that the UAS is 

in working order prior to initiating flight, perform required maintenance, and will keep a log of 

any maintenance performed.

l. 14 C.F.R. Part 61, 14 C.F.R. §§ 61.3, 61.113: Private Pilot Privileges and 

Limitations

Gregory B. Mays will serve as the PIC for all flight operations and the instructor/coinstructor of any course including an element of drone flight. This should qualify persons with a 

private pilot’s certificate, among other qualifications, to instruct drone operation education when 

necessary. However, as is the nature of the proposed operations, introductory flight instruction

using the Phantom 2V UAS will be provided to staff who will likely not have a private, or any 

type of, pilot’s license. Accordingly, Gregory B. Mays seeks exemption from 14 CFR Part 61, 

including 14 CFR § 61.3 to the extent that these regulations are interpreted as requiring a student 
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receiving UAS operation instruction to have a private pilot's certificate. All student instruction 

flights will be conducted under closely controlled circumstances, outside of navigable airspace 

and away from persons or property not involved in the instruction. In addition, the student 

instruction flights will be conducted under the close supervision of an instructor acting as PIC. 

In addition, to the extent that Gregory B. Mays may be employing persons with a private

pilot’s license to operate its UAS, an exemption is also sought from 14 C.F.R § 61.113, which

restricts private pilot certificate holders from flying aircraft for compensation or hire, and which 

would also require a second class medical certificate. The purpose of this section is to ensure the

skill and competency of any PIC where the aircraft is carrying passengers or cargo for hire. In 

this case, while instructors acting as PIC during UAS operations will be doing so for educational

purposes as part of Gregory B. Mays staff, the Phantom 2V or like craft carries neither 

passengers nor cargo. Moreover, in the Astraeus Aerial Grant of Exemption (FAA Docket No. 

FAA-2014-0352), the FAA determined that the unique characteristics of UAS operation outside 

of controlled airspace did not warrant the additional cost and restrictions attendant with requiring 

the PIC to have a Commercial Pilot Certificate and Class I or II Medical Certificate.

Equivalent Level of Safety

Gregory B. Mays will ensure an equivalent level of safety to the regulatory requirements 

of 14 C.F.R. Part 61, including 14 C.F.R. §§ 61.3 and 61.113 by following the safety procedures 

provided in the Guide. In addition to training and experience requirements and limitations, 

Gregory B. Mays has placed additional restrictions on its proposed UAS operations to ensure an 

extra margin of safety. The UAS will only operate in a controlled and sterile area away from 

persons and property not involved in the operation. It will be flown based on VLOS at no more 

than 200 feet AGL. Collectively, these procedures ensure that the proposed UAS operations can 

be conducted safely.

V. Public Interest

Because the technology to provide photographs that can better facilitate clients desires to 

either market real estate or lend money for the purchase and or refinance of real estate has 

advanced to a degree that is not possible from traditional photography the public will be well 

served by offering aerial photographs that can better produce the desired results. Some of which 

include the depiction of the beauty and aesthetics of a property for marketing purposes or the 

location of a property to surrounding adverse conditions that may affect the decision process of 

an institutional lender when making a loan for a particular property.

VI. Privacy

All of Gregory B. Mays UAS operations shall be conducted in accordance with applicable

federal, state, or local laws regarding privacy. Gregory B. Mays will not conduct flight 

operations over property that it does not own or control without the prior consent and knowledge 

of the property owner. Moreover, Gregory B. Mays will not capture or use images from 

restricted areas requiring privacy and or confidentiality under any circumstance. This does not 
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mean, however, that images may not be taken that are permitted by law and do not require a level 

of privacy that is an exception to the norm.

VII. Federal Register Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

FEDERAL REGISTER, should it be determined that publication is needed:

Petitioner seeks an exemption from the following sections in Title 14 of the Code of Federal 

Regulations:

Part 21, Subpart H; Part 27; 45.23(b); 45.27(a); 61.3; 61.113; 91.7(a); 91.9(b)(2); 91.103; 

91.109(a); 91.119; 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & 

(2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property

owners by (a) ensuring that the operations of the UAS described above are recognized by the 

FAA in the form of an exemption (b) how to safely operate small UAS in furtherance of career 

objectives and to the benefit of public safety while providing a valuable service as it relates to 

the real estate business provided by Gregory B. Mays. 
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APPENDIX A

Gregory B. Mays UAS Standard Operating Guide

▫ Any UAS in operation must weigh less than 55 pounds at its maximum take-off 

weight. 

▫ Flights will be operated within the VLOS of the PIC and an observer, at a minimum.

▫ Maximum total flight time for each operational flight will be limited to 25% reserve 

battery power remaining.

▫ Flights will be operated at an altitude of no more than 200 feet AGL.

▫ Radius and altitude limitations will be set according to an assessment of the 

experience level of the operator for each flight. 

▫ All operations will be conducted in class G airspace.

▫ Flights will be restricted to pre-determined areas of the client/owners property.

▫ Flight zones will be located at the maximum distance away from persons, inhabited 

structures, and vehicles that is possible given the layout of the property. The flight 

zone in which operations occurs will be assigned based on surface and air traffic, 

activities, and weather conditions.

▫ Flights will be limited to a speed of 30 mph and vertical ascent will be limited to 15 

mph.

▫ The UAS will be operated and maintained in accordance with the requirements of the 

Phantom 2V or Inspire 1 User Manual and any manufacturer Safety Bulletins.

▫ Prior to the operation, the flights will be fully preplanned and briefed, including

possible contingencies and emergency procedures. 

▫ The UAS will have the capability to abort flight in the case of unpredicted obstacles

or emergencies.

▫ All required permissions, NOTAM’s and permits will be obtained from territorial, 

state, county or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies.

▫ All UAS operations will occur in daylight, Visual Flight Rules ("VFR") conditions. 

Instrument flight rules flights are prohibited and no flights will occur at night, or in 

adverse weather conditions.

▫ The UAS will be controlled by the Phantom 2 Remote Control System or like system 

and the radio frequency spectrum used for operation and control of the UA shall 

comply with the Federal Communications Commission ("FCC") or other appropriate

government oversight agency requirements.
15

APPENDIX B

Don’t Fly Drones Here Map: Restricted Areas near the City of Richmond and the area of 

operation most often occurring

Maps are pulled from the “Drones Don’t Fly Here” project website at 

https://www.mapbox.com/drone/no-fly/.
16

APPENDIX C

AMA Advisory Circular

ADVISORY CIRCULAR

DEPARTMENT OF TRANSPORTATION

Federal Aviation Administration

Washington, D.C.

Subject: MODEL AIRCRAFT OPERATING STANDARDS

1. PURPOSE. This advisory circular outlines, and encourages voluntary compliance with, safety

standards for model aircraft operators.

2. BACKGROUND. Modelers, generally, are concerned about safety and do exercise good

judgement when flying model aircraft. However, model aircraft can at times pose a hazard to

full-scale aircraft in flight and to persons and property on the surface. Compliance with the

following standards will help reduce the potential for that hazard and create a good neighbor

environment with affected communities and airspace users.

3. OPERATING STANDARDS.

a. Select an operating site that is of sufficient distance from populated areas. The selected

site should be away from noise sensitive areas such as parks, schools, hospitals, churches, etc.

b. Do not operate model aircraft in the presence of spectators until the aircraft is

successfully flight tested and proven airworthy.

c. Do not fly model aircraft higher than 400 feet above the surface. When flying aircraft

within 3 miles of an airport, notify the airport operator, or when an air traffic facility is located at

the airport, notify the control tower, or flight service station.

d. Give right of way to, and avoid flying in the proximity of, full-scale aircraft. Use

observers to help if possible.

e. Do not hesitate to ask for assistance from any airport traffic control tower or flight

service station concerning compliance with these standards.

R.J. VAN VUREN

Director, Air Traffic Service

Initiated by: AAT-220
17

APPENDIX D

AMA Safety Code

Academy of Model Aeronautics National Model Aircraft Safety Code

Effective January 1, 2014

A. GENERAL: A model aircraft is a non-human-carrying aircraft capable of sustained flight in the atmosphere. 

It may not exceed limitations of this code and is

intended exclusively for sport, recreation, education and/or competition. All model flights must be conducted in 

accordance with this safety code and any

additional rules specific to the flying site.

1. Model aircraft will not be flown:

(a) In a careless or reckless manner.

(b) At a location where model aircraft activities are prohibited.

2. Model aircraft pilots will:

(a) Yield the right of way to all human-carrying aircraft.

(b) See and avoid all aircraft and a spotter must be used when appropriate. (AMA Document 

#540-D.)

(c) Not fly higher than approximately 400 feet above ground level within three (3) miles of an 

airport without notifying the airport operator.

(d) Not interfere with operations and traffic patterns at any airport, heliport or seaplane base 

except where there is a mixed use agreement.

(e) Not exceed a takeoff weight, including fuel, of 55 pounds unless in compliance with the 

AMA Large Model Airplane program. (AMA Document 520-A.)

(f) Ensure the aircraft is identified with the name and address or AMA number of the owner on 

the inside or affixed to the outside of the model aircraft. (This

does not apply to model aircraft flown indoors.)

(g) Not operate aircraft with metal-blade propellers or with gaseous boosts except for 

helicopters operated under the provisions of AMA Document #555.

(h) Not operate model aircraft while under the influence of alcohol or while using any drug that 

could adversely affect the pilot’s ability to safely control the

model.

(i) Not operate model aircraft carrying pyrotechnic devices that explode or burn, or any device 

which propels a projectile or drops any object that creates a

hazard to persons or property.

Exceptions:

・ Free Flight fuses or devices that burn producing smoke and are securely attached 

to the model aircraft during flight.

・ Rocket motors (using solid propellant) up to a G-series size may be used provided 

they remain attached to the model during flight. Model rockets may

be flown in accordance with the National Model Rocketry Safety Code but may not be 

launched from model aircraft.

・ Officially designated AMA Air Show Teams (AST) are authorized to use devices 

and practices as defined within the Team AMA Program Document.

(AMA Document #718.)

(j) Not operate a turbine-powered aircraft, unless in compliance with the AMA turbine 

regulations. (AMA Document #510-A.)

3. Model aircraft will not be flown in AMA sanctioned events, air shows or model demonstrations 

unless:

(a) The aircraft, control system and pilot skills have successfully demonstrated all maneuvers 

intended or anticipated prior to the specific event.

(b) An inexperienced pilot is assisted by an experienced pilot.

4. When and where required by rule, helmets must be properly worn and fastened. They must be 

OSHA, DOT, ANSI, SNELL or NOCSAE approved or comply

with comparable standards.
18

B. RADIO CONTROL (RC)

1. All pilots shall avoid flying directly over unprotected people, vessels, vehicles or structures and shall 

avoid endangerment of life and property of others.

2. A successful radio equipment ground-range check in accordance with manufacturer’s 

recommendations will be completed before the first flight of a new or repaired model aircraft.

3. At all flying sites a safety line(s) must be established in front of which all flying takes place. (AMA 

Document #706.)

(a) Only personnel associated with flying the model aircraft are allowed at or in front of the 

safety line.

(b) At air shows or demonstrations, a straight safety line must be established.

(c) An area away from the safety line must be maintained for spectators.

(d) Intentional flying behind the safety line is prohibited.

4. RC model aircraft must use the radio-control frequencies currently allowed by the Federal 

Communications Commission (FCC). Only individuals properly

licensed by the FCC are authorized to operate equipment on Amateur Band frequencies.

5. RC model aircraft will not knowingly operate within three (3) miles of any pre-existing flying site 

without a frequency-management agreement. (AMA

Documents #922 and #923.)

6. With the exception of events flown under official AMA Competition Regulations, excluding takeoff 

and landing, no powered model may be flown outdoors

closer than 25 feet to any individual, except for the pilot and the pilot's helper(s) located at the 

flightline.

7. Under no circumstances may a pilot or other person touch an outdoor model aircraft in flight while it 

is still under power, except to divert it from striking an

individual.

8. RC night flying requires a lighting system providing the pilot with a clear view of the model’s attitude 

and orientation at all times. Hand-held illumination

systems are inadequate for night flying operations.

9. The pilot of an RC model aircraft shall:

(a) Maintain control during the entire flight, maintaining visual contact without enhancement 

other than by corrective lenses prescribed for the pilot.

(b) Fly using the assistance of a camera or First-Person View (FPV) only in accordance with 

the procedures outlined in AMA Document #550.

(c) Fly using the assistance of autopilot or stabilization system only in accordance with the 

procedures outlined in AMA Document #560.

C. FREE FLIGHT

1. Must be at least 100 feet downwind of spectators and automobile parking when the model aircraft is 

launched.

2. Launch area must be clear of all individuals except mechanics, officials, and other fliers.

3. An effective device will be used to extinguish any fuse on the model aircraft after the fuse has 

completed its function.

D. CONTROL LINE

1. The complete control system (including the safety thong where applicable) must have an inspection 

and pull test prior to flying.

2. The pull test will be in accordance with the current Competition Regulations for the applicable model 

aircraft category.

3. Model aircraft not fitting a specific category shall use those pull-test requirements as indicated for 

Control Line Precision Aerobatics.

4. The flying area must be clear of all utility wires or poles and a model aircraft will not be flown closer 

than 50 feet to any above-ground electric utility lines.

5. The flying area must be clear of all nonessential participants and spectators before the engine is 

started.