Petition for	333	Exemption

I,	Samuel Clayton	Adams,	Commercial	Pilot (airman	certificate #3689434),	of	8271	

Barnett	Dr.	Anchorage, AK	99518	am	petitioning	the Federal	Aviation	

Administration	(FAA)	for	an	exemption	from	part	21,	subpart	H;	and	Sections	

45.23(b),	91.9(b)(2),	91.119,	91.121,	91.151(a),	91.203(a)	and	(b),	91.405(a),	

91.407(a)(1),	91.409(a)(2),	and	91.417(a)	and	(b)	of	Title	14,	Code	of	Federal	

Regulations	(14	CFR).		This	proposed	exemption	would	allow	me to	operate	a	DJI	

Inspire	1 Quad	Copter	Unmanned	Aerial	System	(UAS)	for	the	purpose	of	aerial	

mapping,	videography	and	photography.		The	use	of	a	UAS	for	these	activities	will	

have	a	substantial	societal	benefit.		It	will	bring	an	over-head	perspective	to	future	

customers that	was	previously only	possible	through	the	prohibitively	expensive	

use	of	rotorcraft	and	fixed	wing	aircraft with	expensive	camera	equipment.		I	would	

bring	this	service	at	an	affordable	price and	due	to	the	simple	nature	of	the	UAS,	

with	substantial	time	savings.

Due to	the	ever-improving	nature	of	this	technology	a	new	UAS	can	become	obsolete	

within	a	few	months	of	release.		Therefore	requiring	a	new	petition	for	exemption	to	

be	filed	each	time	a	model	of	UAS	not	specified	in	the	original	exemption	is	used.		In	

order to	streamline	this	process	and	to	save	time	and	money	on	both	parties	behalf,	

I	am	also	seeking	an	exemption	in	addition	the	to	one	listed	above.		I	am seeking	

approval	to	utilize	other	unmanned	aerial	systems (UAS) that	meet	the	operational	

limitations	outlined	in	the	notice	of	proposed	rulemaking	(NPRM)	pertaining	to	the	

operation	of	small	unmanned	aircraft	systems	in	proposed	part	107	to	Title	14	Code	

of	Federal	Regulations	(14	CFR).

Safety	

I	will	utilize	my	knowledge	as	a	professional	pilot	to	maintain	the	highest	level	of	

safety	during	the	proposed	use	of	the	UAS.	Flight	would	consist	of	three	parts:	

preflight,	flight and	post	flight.		

The	preflight	will	consist	of	extensive	inspections	of	the area,	the	UAS	and	the	

airspace	in	which	it	will	be	operating.	A detailed	inspection	of	the	UAS	will	be	

conducted	and	all	major	systems	will	be	examined,	including	power	plant,	airframe	

and	controls.		Any	discrepancy	will	be	noted	and	if	the	discrepancy	affects	the	safety	

of	the	flight,	the	flight	will	not	commence.

Operations	will	only	commence	in reasonably	safe	environments	that will	be	strictly	

controlled	during	the	flight	of	the	UAS.		The	area	will	be	surveyed	for	power	lines,	

elevated	lights	and other	property	with	the	potential	to	affect	the	safety	of	the	flight.		

There	will	be	no	flights	within	the	proximity	of	active	airports	without	first	

contacting	the	appropriate	agencies	or	authorities	to	ensure	the	highest	level	of	

safety	and	compliance	with	all	regulations.		Operations	will	also	not	commence	
where	there	is	a	reasonable	possibility	of	inadvertent	physical	contact	with	the	

populace.

During	the	flight	portion	of	the	operation,	safety	will	be	the	primary	concern.		Given	

the	size,	weight,	speed	and	limited	operating	area	of	the	UAS;	flight	will	be	

inherently	safe.		The	UAS	will	not	be	operated	above	individuals	not	associated	with	

its	operation	and	care	will	be	given	to	avoid	property	that	was	noted	during	the	

preflight	inspection	of	the	area.

During	the	post-flight	debrief,	all	individuals	associated	with	the	operation	will	

evaluate the	success	of	the	operation	and	address	any	concerns	brought	forward	

about	the	safety	of	the	flight.		Any	pertinent	issues	will	be	noted	and	action	will	be	

taken	to	ensure	the	safety	of	future	flights.

Exemptions	from	regulations

All	proposed	exemptions	from	regulations	are	listed	below	and	are	accompanied	by	

reasoning	as	to	why	it	would	be	unreasonable	to	comply	with	the	regulation.

• 14	CFR § 21	Subpart	H:	Airworthiness	Certificates	and	91.203	(a)	and	(b):

Certifications	required

o Given	the	size,	weight,	speed,	and	limited	operating	area	

associated with	the	aircraft	to	be	utilized,	an	exemption	is	requested	

and	would	meet the	requirements	for	an	equivalent	level	of	safety	

under	14	CFR	part 11	and	Section	333	of	P.L.	112-95	(Section	333)

• 14	CFR	§	45.23: Display	of	marks;	general	

o An	exemption	is	requested because	the	UAS has	no cabin,	cockpit	or	

pilot	station	on	which	to	display	certain	words	or	phrases.		

Furthermore,	is	would	be	unreasonable	to	mark	the	aircraft	with	2	

inch	lettering	since	the	airframe	has	dimensions	smaller	than	the	

minimal	lettering	requirement.		I	will	place the	word	“Experimental”	

on	the	airframe	of	the	UAS	as	required	by	§	45.29(f) so	that	anyone	

assisting	as	a	spotter	and	I	will	see	the	markings.

• 14	CFR	§	91.9 (b)	(2): Civil	aircraft	flight	manual,	marking	and	placard	

requirements

o An	exemption	is	requested from	the	cited	regulations	because	the	UAS	

manufacturer	does	not	supply	a	flight	manual that	contains	

information	found	in	manuals	supplied	by	manufacturers	of

traditional	aircraft.		Also,	due	to	the	size,	weight,	speed	and	operating	

area	of	the	aircraft	to	be	utilized	it	would	be	unrealistic	to	expect	it	to.

• 14	CFR	§	91.119:	Minimum	safe	altitudes

o An	exemption	is	requested from	the	cited	regulations due	to	the	

purpose	that	the	UAS	being	used	was	created	for.		This UAS	is

designed	for	use in	an environment	that	is	contrary	to	this	regulation.		
Also,	the	UAS	would	not	be	operated	at	an	altitude	of	more	than	500	

feet	above	the	surface,	as	to	not	interfere	with	any	potential	air	traffic.

• 14	CFR	§	91.121: Altimeter	settings

o An	exemption	is	requested because	no	pitot	static	system	is	installed	

in	the	aircraft	and	due	to	the	altitudes	is	operates	at,	adherence	to	this	

regulation	would	be	unrealistic	and	unnecessary.		Also,	GPS	position	

information	is	transmitted	to	the	aircraft	controller,	providing	much	

more	accurate	information	than	what	would	be	shown	by	a	traditional	

altimeter.

• 14	CFR	§	91.151: Fuel	requirements	for	flight	in	VFR	conditions

o Due	to	the	nature	of	the	aircraft	being	used,	adherence	to	the	

regulation	would	be	unrealistic.		The	UAS	has	an	average flight	time	of	

approximately	18 minutes	and	a	“return	to	home”	function	in	the	

event	of	an	impending	power	failure.		Therefore,	an	exemption	from	

the	cited	regulation	is	requested.

• 14	CFR	§ 91.405(a): Maintenance	required,	91.407(a)(1): Operation	after	

maintenance,	preventative	maintenance,	rebuilding	or	alteration,	91.409	

(a)(2): Inspections,	91.417(a)	and	(b): Maintenance	records

o Exemptions	are	requested from	the	cited	maintenance regulations	

because	they	only	apply	to	traditional	aircraft	with an airworthiness	

certificate.	

Qualifications and	closing

By	granting	me	a	section	333	exemption	I	will	be	able	to	bring	a	service	to	my	

community	that	before,	was	associated	with	high	cost	and	high	environmental	

impact.		As	a	professional	pilot,	the	skills	and	knowledge	that	I	have	gained	through	

training	and	experience	will	add	an	additional	level	of	safety	to	the	operation	of	the	

UAS.		Coupled	with	an	in-depth	knowledge	of	airspace,	Federal	Aviation	Regulations	

(FARs),	safety	of	flight	and	science	of	flight	information	I	believe	there	should	be	no	

question	as	to	the	soundness	of	my	petition	for	exemption.		

*Note

All	information	regarding	the	Inspire	1	quad	copter	can	be	found	on	the	

manufacturers	webpage	below. Model	specifications	will	be	submitted	with	this	

document	for	ease	of	reference.

http://www.dji.com/product/inspire-1/download