UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION

_______________________________________________ 

 ) 

Petition for Exemption ) 

Pursuant to Pub. Law 112-95 § 333 )

and 14 CFR Part 11 )

concerning Unmanned Aircraft Systems )

used for aerial photography, videography )

and aerial data collection ) 

 ) 

_______________________________________________) 

PETITION OF SHANNON ALLISON PHOTOGRAPHY 

FOR REGULATORY EXEMPTION

SUMMARY GRANT REQUESTED

Dated: December 21, 2015 

Filed Electronically 

Please address all communications with respect to this Petition to: 

Shannon Allison

Shannon Allison Photography

Bellefonte, PA 16823 

Phone: (814) 574-7185

Email: shannonballison@gmail.com
I. Introduction and Summary Grant Request

 Petitioner Shannon Allison Photography (“SAP”) respectfully submits this Petition for 

Exemption from regulations the FAA considers applicable to the civil operation of unmanned aircraft 

systems, and that the FAA considers necessary for an operator to be exempted from, in order to conduct 

operations concerning aerial photography, videography, and aerial data collection.1 The benefits of these 

operations to the public are unquestionable, and safety is assured when they are conducted under the 

proposed procedures herein, and as granted by the FAA to other similarly situated exemption grantees.

 Petitioner is eligible for, and hereby requests, a summary grant of exemption, because this 

Petition asks for relief that is similar in all material respects to relief that has been granted to other 

Section 333 petitioners.2 

II. The Identity and Interests of the Petitioner

 Petitioner SAP has been in the photography business since 2008. Its primary business is 

property photography for real estate marketing, with a heavy concentration on the luxury segment of the 

market. Its secondary work includes general commercial photography and videography for various uses 

such as golf course marketing. SAP’s owner, Shannon Allison, has been operating an assortment of radiocontrol helicopters and multirotors for four years, for recreational purposes. SAP sometimes contracts 

with a licensed pilot of a Robinson R44 for commercial aerial photography and videography.

_______________________

1 Petitioner takes no position with respect to which federal aviation regulations legally apply to the proposed 

operations.

2 See FAA Summary Grants Speed UAS Exemptions, available at https://www.faa.gov/news/updates/?

newsId=82485 

 
The name and address of the Petitioner is:

 Shannon Allison Photography

 106 Fieldstone Lane 

 Bellefonte, PA 16823 

 Phone: (814) 574-7185 

Email: shannonballison@gmail.com

III. SAP’s Request Would be in the Public Interest and Benefit the Public as a Whole 

 The benefit to the public interest of SAP’s request has been established. The use of manned 

aircraft for aerial photography, videography and data collection is in many instances more expensive, and 

more dangerous, than the operations proposed herein. Thus, the operations are of significant public 

benefit and, as set out herein, present at least an equivalent level of safety under 14 CFR part 11. 

IV. The Unmanned Aircraft Systems 

 Petitioner intends to operate four UAS models in connection with the operations 

proposed herein, at or below 400 feet above ground level: 

• DJI Inspire 1

 Each of these UAS is built and maintained for SAP by Aerial Visions, Inc. of Brewster, NY. 

The technician at Aerial Visions has been building and operating all types of radio controlled model 

aircraft for over 20 years.
A. DJI Inspire 1

 The DJI Inspire 1 has been approved by the FAA many times in connection with 

Section 333 exemptions for aerial photography and videography. See, e.g., Exemption Grant Nos. 11279 

(April 1, 2015), 11974 (July 1, 2015). 

Aircraft Type: Multi-rotor, Inspire 1 Manufacturer: DJI 

Construction: Carbon fiber, plastic, aluminum Aircraft Empty Weight: 3.3 lbs. 

Aircraft RTF AUW: 4.5 – 5.5 lbs. 

Propulsion: Electric – four two blade propellers 

Power : 5.4AH lithium polymer flight batteries 

Onboard electronics: Manual control system RX, flight control system 

Optics : (1) still imager, up to (1) video, 2.4/5.8Ghz Lightbridge. 

Launch Type : VTOL 

Landing Type : VTOL 

Launch Speed : 15 mph vertical 

Speed Evelope : 15-35 mph 

Cruise Speed : 0-25 mph 

Landing Speed : 0 mph 

Stall : N/A 

VNE : N/A 

Duration : 15 minutes (typical) 

Radio Frequency Spectrum: The Inspire 1 utilizes FCC-approved command-and- control 

and video systems operating on the 5.8 GHz and 2.4 GHz bands. 

 
V. Flight Safety Operations and Procedures

 Petitioner proposes to operate each UAS for the purposes indicated herein pursuant 

to its accompanying Flight Operations Manual which sets out a procedure for the safe and responsible 

operation of UAS.

VI. Summary of Exemptions Sought

 SAP seeks exemption from the following regulations, to the extent the FAA deems 

them applicable to the operation of civil UAS for the indicated purposes:

14 CFR Part 21

14 CFR Part 36

14 CFR 45.23(b) 

14 CFR 61.3 

14 CFR 61.23(a) and (c) 

14 CFR 61.101 

14 CFR 61.113 (a) & (b) 

14 CFR 61.315 

14 CFR. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.105 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2); and 

14 CPR 91.417 (a) & (b) 
VII. The Specific Exemptions Sought and Reasons 

 A. 14 CFR Part 21 and 

 14 CFR Part 36

 Petitioner seeks relief from 14 CFR part 21 concerning airworthiness certificates, as well as 

any associated noise testing requirements of part 36, with respect to the UAS identified in Section IV. As 

set out herein, the size, weight, speed, operational capability, visual line-of-sight operation, and intended 

operating area of these UAS meet the conditions of FMRA Section 333. Moreover, the proposed 

operations, conducted pursuant to the Flight Operations Manual, present an equivalent level of safety or 

better. An exemption ought to be granted or, in the alternative, a finding made that relief from parts 21 

and 36 are not necessary for Petitioner’s intended operation. (See, e.g., Grant of Exemption No. 11282, 

Docket. No. FAA-2014-0977 (April 6, 2015), finding that such an exemption is “not necessary.”)

B. 14 CFR 45.23(b)

 Petitioner seeks relief from 14 CFR 45.23(b) concerning aircraft markings, to the 

extent such relief is necessary. Given the size of the UAS, its operation within visual line of sight of the 

operator, and other factors, such an exemption is warranted. Petitioner will, if required, mark each UAS 

with the word “RESTRICTED” in lettering as large as practicable. However, Petitioner notes that because 

its UAS’s will not be certificated under § 21.185, such marking is not actually required, and therefore 

Petitioner alternatively requests a finding confirming same.

C. 14 CFR 61.23(a) & (c),

 14 CFR 61.101, 

 14 CFR 61.113 (a) & (b), and 

 14 CFR 61.315

 Petitioner seeks relief from 14 CFR 61.101 concerning limitations on recreational pilot 

privileges, 14 CFR 61.113(a) and (b) concerning limitations on private pilot privileges, and 14 CFR 

61.315 concerning limitations on sport pilot privileges, together with an exemption from 14 CFR 61.23(a) 

concerning medical certificates. The Flight Operations Manual establishes a level of safety exceeding that 
provided by a commercial pilot’s certificate in the operation of a passenger aircraft. The UAS’s intended 

to be operated do not carry any person and therefore present an equivalent or better level of safety 

compared to manned aircraft operations. Petitioner understands that the FAA imposes as a condition of an 

exemption that the UAS pilot in command hold either a recreational, sport pilot or private pilot certificate. 

With respect to medical certification, 14 CFR 61.23(a), Petitioner understands that the FAA requires the 

UAS PIC to hold either a current FAA airman medical certificate or a valid U.S. driver’s license issued by 

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government.

D. 14 CFR 91.7(a) 

 Petitioner seeks relief from 14 CFR 91.7(a) concerning civil aircraft airworthiness. 

Given the size of the UAS, its operation within visual line of sight of the operator, and other factors 

providing an equivalent level of safety, such an exemption is warranted. Moreover, because petitioner 

proposes that no airworthiness certificate be issued for the UASs to be operated under this exemption, § 

91.7(a) is inapplicable. Therefore, in the alternative, Petitioner requests a determination that an exemption 

from § 91.7(a) is not necessary.

E. 14 CFR 91.9(b)(2) 

 Petitioner seeks relief from 14 CFR 91.91(b)(2) concerning flight manuals and 

placard requirements. Because all persons involved in the operation will be on the ground, not on board 

the UAS, such an exemption is clearly warranted. Moreover, the FAA determined in an August 8, 2014 

legal interpretation that keeping such documentation at the control station, as Petitioner intends to, meets 

the requirements under these regulations and therefore an exemption is not necessary. See Memorandum 

from Mark. W. Bury to John Duncan, “Interpretation regarding whether certain required documents may 

be kept at an unmanned aircraft's control station” (August 8, 2014).3 
F. 14 CFR 91.103 

 Petitioner seeks relief from 14 CFR 91.103 concerning preflight action, and 

particularly that portion of the regulation concerning FAA-approved flight manuals (which do not exist). 

Petitioners’ pre-flight actions concerning UAS operations reflect that the pilot in command

___________________________ 

3 Available at 

https://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/ 

interpretations /data/interps/2014/Duncan-AFS-1-2%20-%20%282014%29%20Legal

%20Interpretation.pdf 

G. 14 CFR 91.105 

 Petitioner seeks relief from 14 CFR 91.105 concerning “Flight crewmembers at 

stations” and seat belt/harness fastening. Because there is no crew on board the UAS, and persons 

involved in the operations will be present at the UAS ground station, Petitioner believes that such an 

exemption is warranted due to Petitioner’s Flight Operations Manual providing an equivalent level of 

safety, or alternatively that an exemption is not necessary for the operation. Although it does not appear 

that the FAA has addressed § 91.105 in various Section 333 UAS exemptions granted to date, we note that 

§ 91.105 is listed in the FAA’s Public Guidance document as a regulation from which an exemption may 

be required (Rev. 9/25/2014 at page 7).4 Petitioner therefore requests either an exemption or an 

acknowledgement that an exemption is not necessary. 

H. 14 CFR 91.109 

 Petitioner seeks relief from 14 CFR 91.109 concerning flight instruction and dual 
controls. Petitioner will evaluate the qualifications of its PICs based on their experience and capabilities 

with the UAS to be operated. Moreover, as each PIC will have previously been qualified by the FAA as a 

certificated recreational, sport, or private pilot, the operations proposed herein may be conducted without 

an exemption from § 91.109 being required. Thus, Petitioner requests either an exemption or confirmation 

that none is required. 

____________________________ 

4 Available at

https://www.faa.gov/uas/legislative_programs/section_333/how_to_file_a_petition/media/section333_p 

ublic_guidance.pdf).

I. 14 CFR 91.119 

 Petitioner seeks relief from 14 CFR 91.119 concerning minimum safe altitudes. 

Each UAS will be operated no higher than 400 feet above ground level, and, under the Flight Operations 

Manual, safe alternative landing locations will be selected in advance of each flight, in compliance with 

14 CFR 91.119(a) which permits operations “[a]nywhere.”

J. 14 CFR 91.121 

 Petitioner seeks relief from 14 CFR 91.121 concerning altimeter settings. 

Petitioner's UAS will utilize a GPS altitude read-out, set to zero at the ground elevation of the departure 

location, thus indicating to the operator the operational altitude in feet above ground level. This approach 

will provide an equivalent level of safety.

K. 14 CFR 91.151 

 Petitioner seeks relief from 14 CFR 91.151 concerning fuel requirements. 
Petitioner will land the UAS when the battery is at or above 30% capacity. An equivalent level of safety is 

achieved, in particular because each UAS is operated within visual line of sight, can be landed within 

moments of a low-battery condition, and the UAS never has the need to travel any significant distance to 

an alternate airport or landing area.

L. 14 CFR 91.203(a) and (b) 

 Petitioner seeks relief from 14 CFR 91.203(a) and (b) concerning airworthiness 

certificates. Each of the UAS to be operated weighs 11 kilograms or less, and will be operated within 

visual line of sight, pursuant to the Flight Operations Manual, by a knowledgeable certificated operator. 

An exemption from airworthiness certification is warranted pursuant to Section 333 of FMRA in 

consideration of the weight, size, speed, and operational capabilities of the Petitioner's UAS. 

M. 14 CFR 91.405(a) 

 14 CFR 91.407 (a) (1)

 14 CFR 91.409 (a) (2); and 

 14 CPR 91.417 (a) & (b)

 Petitioner seeks relief from 14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417 (a) and 

(b), concerning maintenance inspections. Petitioner proposes to maintain each UAS in accordance with 

the manufacturer's suggested maintenance procedures, and to conduct preflight and post-flight inspections 

in accordance with the Flight Operations Manual for each operation. This approach provides an 

equivalent level of safety with respect to the operational condition of the UAS. Moreover, the UAS are 

not contemplated to have an airworthiness certificate, and therefore no exemption is needed with respect 

to maintenance requirements arising from airworthiness certificates.
N. Other Exemptions 

 Petitioner requests relief from any other federal aviation regulation that the FAA 

deems applicable to and preclusive of the proposed UAS aerial photography and videography operations 

in the absence of such an exemption.

VIII. Request for Blanket COA 

 Petitioner hereby requests a blanket, nationwide Certificate of Waiver or 

Authorization. The FAA has recently indicated that holders of UAS exemptions under Section 333 are 

now granted a “blanket” COA for any operation up to 200 feet AGL. See March 20, 2015 Memorandum 

from Elizabeth L. Ray to Terry Biggio, “Small Unmanned Aircraft Systems Operations in the National 

Airspace System.” 

IX. A Summary That Can Be Published In The Federal Register: 

 The following is a summary that may be included in the Federal Register, should 

the FAA determine that publication of such a summary is required. However, because this Petition is 

eligible for a summary grant, such publication is not needed:

Petitioner Shannon Allison Photography seeks an exemption pursuant to Pub. L. 95-112 Section 333 

and part 11 for the operation of unmanned aircraft systems for purposes of aerial photography, 

videography and aerial data collection. The benefit to the public interest of such an exemption is 

established. The use of manned aircraft is in many instances more expensive, and more dangerous, 

than the operations proposed herein. Thus, the operations are of significant public benefit.

Petitioner’s operations will be conducted at or below 400 feet above ground level, within the visual 

line of sight of the operator, who will be a certificated airman with a sport, recreational or private 

pilot’s certificate, and pursuant to a detailed Flight Operations Manual.

Petitioner seeks exemption from 14 CFR Part 21, 14 CFR Part 36, 14 CFR 45.23(b), 14 CFR 61.3, 14 

CFR 61.23(a) & (c), 14 CFR 61.101, 14 CFR 61.113 (a) & (b), 14 CFR 61.315, 14 CFR. 91.7 (a), 14 

CFR 91.9 (b) (2), 14 CFR 91.103, 14 CFR 91.105, 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 

14 CFR 91.151 (a), 14 CFR 91.203 (a) & (b), 14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 

91.409 (a) (2).; and 14 CPR 91.417 (a) & (b).
Dated: December 21, 2015

 Respectfully submitted,

Shannon B Allison

Shannon Allison Photography 

106 Fieldstone Lane

Bellefonte, PA 16823

Tel. (814) 574-7185 

shannonballison@gmail.com 

Enclosures (filed electronically): 

1. Shannon Allison Photography Flight Operations Manual 

2. DJI Inspire 1 

1. User Manual 

2. Maintenance Manual

3. Battery Safety Information