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Private and Confidential

PAUL SHERIDON, St. Petersburg, Florida - Section 333 Exemption Petition

February 1, 2016

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave,

SE Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 

91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) 

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

Dear Sir or Madam, I, PAUL SHERIDON, am writing pursuant to the FAA Modernization and 

Reform Act of 2012 and the procedures contained within 14 C.F.R. 11, to request that I, PAUL 

SHERIDON, an owner and operator of small unmanned aircraft, be exempted from the Federal 

Aviation Regulations (“FARs”) listed below so that I, PAUL SHERIDON, may operate my small 

ultra lightweight unmanned aircraft system (“UAS”) in commercially regulated airspace by the 

Federal Aviation Administration (“FAA”). 

Following exemption and approval by the FAA, I, PAUL SHERIDON, will primarily use my 

professionally built DJI Inspire 1; DJI Inspire 1 Professional; DJI Phantom 3; DJI Phantom 4; 

DJI S 900; DJI S1000+) UAS equipped with cameras for the following applications: Closed-Set 

Film Operations on Film and Television Productions, as well as aerial 

videography/cinematography/photography to safely enhance films and commercials; 

augmentation of real estate listing photography and videos; and the creation of visual and 

topography layout videos for Search and Rescue (SAR) missions for state and local agencies, 

education, agricultural inspections and building and construction zone inspections and mapping; 

aerial surveying of commercial sites and civic landscapes; community volunteer work. 

My, PAUL SHERIDON’s, exemption request would permit the operation of ultra-lightweight, 

unmanned (i.e. piloted by remote control) UAS’s for the of community and government use 

videos, permissible within property boundaries for individual homeowners and within in tightly 

controlled, limited airspaces in areas away from the general public, airports, heliports and 

vehicular traffic. Currently, similar lightweight, remote controlled UAS's are legally operated by 

unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. 

Furthermore, it is my intent to assist future FAA safety protocols and regulations exclusive to 
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lightweight UAS's for specific video and photography usage by sharing information with the FAA 

as I, PAUL SHERIDON, record flight data and other pertinent information gained through 

permitted flight operations. 

In addition, granting my, PAUL SHERIDON’s, exemption will comply with the Secretary of 

Transportation’s (FAA Administrator’s) instructions to not only integrate UAS's into the national 

airspace system, but to “...establish requirements for the safe operation of such aircraft systems 

[UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the 

use of UAS's for real estate/Realtor purposes, videos, Search and Rescue, land/trusts 

inspections, agricultural field monitoring, film/video productions, closed-set motion picture film 

operations and television, and structure inspections, to aid state and local agencies. Further I, 

PAUL SHERIDON, will conduct my operations in compliance with the protocols described 

herein or as otherwise established by the FAA. For the reasons stated below, I, PAUL 

SHERIDON, respectfully request the grant of an exemption allowing me to operate ultralightweight, remote controlled UAS’s to aid academic community awareness, to benefit/stimulate 

attraction not only to the Tampa Bay area but in areas of interest throughout the United States 

and to enhance personal and public video feeds. A grant that will ultimately allow UAS’s to play 

a more positive role in our local community by increasing employment opportunities, 

heightening security measures and decreasing government expenditures by the need for 

heavier manned aircraft, containing costly, combustible fuel- a potential public hazard in and of 

itself. 

I. Contact Information:

Paul Sheridon

3641 Queen Street North

St. Petersburg, Florida 33713

Phone: 727-686-6309

Email: psheridon@yahoo.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations from Which 

PAUL SHERIDON Requests Exemption are: 

14 CFR 21; 14 C.F.R. 45.23(b); 

14 CFR 61.113 (a) & (b); 

14 C.F.R. 91.7(a), 9(b) (2), 103, 109, 119,121, 151(a), 203(a) & (b), 405(a)

14 CFR 407 (a) (1); 

14 CFR 409 (a) (2); and, 

14 CFR 417 (a) & (b). 

III. The Extent of relief PAUL SHERIDON Seeks and the Reason He Seeks Such Relief: 

I, PAUL SHERIDON, submit this application in accordance with the Reform Act, 112 P.L. 95 §§ 

331-334, seeking relief from any currently applicable FARs operating to prevent me, PAUL 

SHERIDON, contemplated commercial cinematic, academic and other flight operations within 

the national airspace system. The Reform Act in Section 332 provides for such integration of 

civil unmanned aircraft systems into our national airspace system as it is in the public’s interest 
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to do so. My, PAUL SHERIDON’s, ultra-lightweight UAS meets the definition of “small aircraft” 

as defined in Section 331 and therefore the integration of my ultra light weight UAS is expressly 

contemplated by the Reform Act. I would like to operate my ultra lightweight UAS prior to the 

time period by which the Reform Act requires the FAA to promulgate rules governing such craft. 

Thereby, providing direct experience and valuable information for formal regulation that can be 

administered uniformly to all related UAS aerial video and photography. The Reform Act guides 

the Secretary in determining the types of UAS's that may operate safely in our national airspace 

system. Considerations include: The weight, size, speed and overall capabilities of the UAS's; 

whether the UAS will be operated near airports or heavily populated areas; and, whether the 

UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). 

Each of these items reflects in favor of an exemption for me, PAUL SHERIDON. My UAS’s 

utilize eight (8) or less rotating propellers for balance, control and stability. My UAS’s are 

equipped with the following via video and data telemetry:

1) Altimeter

2) Attitude indicator 

3) Ground Speed indicator 

4) Magnetic compass 

5) Heading indicator 

6) Vertical speed indicator 

7) Course deviation indicator 

8) Radio magnetic indicator 

9) GPS location 

10) Battery consumption and Battery Left with approximate time. 

11) Loiter and circle mode. 

12) Auto safety or RTL (Return To Launch) 

13) Auto landing technology. 

Each UAS weighing less than thirty five (35) pounds (far below the maximum 55 pound limit); 

Including camera(s) with or without gimbal (a camera stabilizer). I, PAUL SHERIDON, consider 

safety as foremost with each flight. My small unmanned aircraft is designed to hover in place, 

circle in a specific place or loiter via GPS and can be operated in winds up to 30.4 knots 

(35mph) wind. For safety, stability and fear of financial loss I will not fly in winds exceeding 21.7 

knots (25 mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle 

in place or land when radio controls are released. 

With three (3) modes to choose from, I will fly with the modes safest to complete the videos for 

aerial videography/photography and have the ability to choose the safest, most reliable and 

stable mode to prevent accident and hazard. When pilot communication from the radio control is 

lost, UAS is designed slowly descend to point of takeoff and or to land at point of launch after 

ascending to a pre-set altitude to ensure the UAS will clear any obstacles that may be between 

the takeoff point and the current position of the UAS. This failsafe altitude will not be set more 

than 200ft and is determined before each flight. 
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I, PAUL SHERIDON, will not operate my UAS near airports, hospitals nor police heliports, and 

do not operate near areas where general public is within fifty to one hundred (50-100) yards 

depending on location, conditions and weather. I am constantly on alert for any manned aircraft 

(police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and 

safest ground point should a manned aircraft approach my location or I suspect manned aircraft 

may approach near my location. My UAS’s are capable of vertical and horizontal operations, 

and is flown only within my line of sight, as the remote control pilot. My UAS's are also flown 

with a second operator who aids in watching for any obstacles, including manned aircraft, within 

the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights generally 

last between three (10) to fifteen (25) minutes, with an altitude under one hundred fifty (150) 

feet. (3) Smart Mode includes, position hold, self-leveling, altitude command, GPS, return home 

feature, and safety control to return home or land in the event of communication interruption 

between RC transmitter and UAS.

I, PAUL SHERIDON, utilize a fresh fully charged battery with each flight as a safety precaution; 

full flight time limit for each battery is eight (8) to thirty (30) minutes as tested. I do not operate 

my UAS at or below manufacturer recommend minimum charge levels for operation; preferring 

to remain well within a safe operating range to insure adequate communication between radio 

control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are 

at hand with each exercise to insure replacement for sufficient safe level of operation. I do not 

believe in taking risk that may cause a crash that could create hazard to the 

public/property/manned aircraft, and have no desire to lose an investment. I have clocked 

numerous practice flights in remote areas as a hobbyist simulating flights for future commercial 

use to gain familiarization with the characteristics of this specific UAS's performance under 

different temperature and weather conditions. I also practice computerized simulated flights to 

maintain adequate skills and response reflex time, all for the sake of safety. 

I, PAUL SHERIDON, am extremely cautious when operating of my UAS/ultra lightweight 

unmanned aircraft and will not “create a hazard to users of the national airspace system or the 

public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within 

Congress’s contemplated safety zone when it promulgated the Reform Act and the 

corresponding directive to integrate UAS's into the national airspace system. PAUL 

SHERIDON’s UAS, used in hobby flight, has a demonstrable safety record and does not pose 

any threat to the general public or national security. 

IV. How PAUL SHERIDON’s Request Will Benefit the Public as A Whole: Aerial videography for 

geographical awareness, education, search and rescue, land management, structure 

inspections, mapping and for real estate marketing has been around for a long time through 

manned fixed wing aircraft and helicopters. For small budget companies, average homeowners 

and property owners the expense of such aerial videography is cost prohibitive. Only large 

companies and high end Realtors or luxury homeowners can afford to absorb such expense; 

depriving non-luxury owners and lower budget companies from a valuable marketing tool. 

Manned aircraft pose a threat to the public through potential catastrophic crash that local 
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communities have experienced in the past with military aircraft, medical helicopters, and news 

helicopters crashes, with each incident resulting in loss of life and with combustible fuel that 

explodes and burns on impact. 

My, PAUL SHERIDON's, UAS poses no such threat since size and lack of combustible fuel 

alleviates any potential threat to the public. Congress has already proclaimed that it is in the 

public’s interest to integrate commercially flown UAS's into the national airspace system, hence 

the passing of the Reform Act. Granting my, PAUL SHERIDON’s, exemption request furthers 

the public interest through academic/visual awareness of the geographical benefits in and 

around the metro area. My ultra light weight UAS is battery powered and creates no emissions 

that can harm the environment. The consequence of my ultra light weight UAS crashing is far 

less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel 

and can cause catastrophic devastation to the public. The public’s interest is furthered by 

minimizing ecological and crash threat by permitting aerial video/photo capture through my 

battery operated ultra-lightweight UAS's. Permitting me, PAUL SHERIDON, to immediately fly 

within national air space furthers economic growth. Granting my exemption request substantially 

furthers the economic impact for the local and surrounding community for companies looking to 

relocate or build around the area as well as individuals looking to relocate for career 

advancement through academic and geographical awareness, both of which serve as a 

stimulus to the community. 

V. Reasons Why PAUL SHERIDON’s Exemption Will Not Adversely Affect Safety or How the 

Exemption Will Provide a Level of Safety At Least Equal to Existing Rule: 

My, PAUL SHERIDON’s, exemption will not adversely affect safety. Quite the contrary, for the 

reasons stated permitting me, PAUL SHERIDON, to log more flight time in FAA controlled 

airspace, with communication with the FAA, will allow me to contribute to the innovation and 

implementation of new and novel, as of yet undiscovered safety protocols for Realtors, land and 

structured owners for development in cooperation with the FAA. In addition I,PAUL SHERIDON, 

submit the following representations of enhancements to current aerial videography and 

photography: My UAS’s weigh less than thirty-five (35) pounds complete with a an integrated 

ultra-light weight camera.; I only operate my UAS below 300 feet (well within the 400 foot 

permissible ceiling set by the FAA Modernization and Reform Act of 2012); My UAS only 

operate for 3-30 minutes per flight; I land my UAS prior to manufacturer recommended minimum 

level of battery power; I pilot my UAS through remote control only by line of sight; and have live 

video feed for a secondary pilot to monitor video recording; I receive a live telemetry feed from 

my UAS during all flights which include remaining battery voltage, distance, altitude, and any 

anomalies that may occur during flight;

My UAS’s Command and Control utilizes spread spectrum 2.4Ghz-2.485Ghz frequencies in 

accordance with CFR 47, Part 15 for model aircraft use.

My UAS’s camera system utilizes 5.725Ghz-5.875Ghz frequencies in accordance with CFR 47, 

Part 15.
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My UAS’s have a GPS controlled flight controller- a flight safety feature whereby it hovers or 

circles and then lands at the GPS takeoff point if communication with the remote control pilot 

is lost; I actively record and analyze flight data through the DJI Inspire 1, DJI phantom 3 or DJI 

S-1000 flight controller app to constantly update and enhance safety protocols; I only operate in 

reasonably safe environment that are strictly controlled, are away from power lines, elevated

lights, airports and actively populated areas; I conduct extensive preflight inspections and 

protocol, during which safety carries primary importance; I always obtain all necessary 

permissions prior to operation; and, I have procedures in place to abort flights in the event of 

safety breaches or potential danger. My, PAUL SHERIDON’s, safety protocols provide a level of 

safety equal to or exceeding existing rules. It is important to note that absent the integration of 

commercial UAS into our national airspace system, helicopters are the primary means of aerial 

video and photography for community awareness real estate, structured inspections, land 

management and search and rescue. While the safety record of such helicopters is remarkably 

astounding, there has been local incident involving loss of life as well as extensive property 

damage; it is far safer to operate a battery powered ultra lightweight UAS. First, the potential 

loss of life is diminished because UAS's carry no people on board and I only operate my UAS in 

specific areas away from mass populations. Second, there is no fuel on board a UAS and thus 

the potential for fire or explosions is greatly diminished. Third, the small size and extreme 

maneuverability of my UAS allow me to remotely pilot away from and avoid hazards quickly and 

safely. Lastly, given its small size and weight, even when close enough to capture amazing 

images, my UAS need not be so close to the objects they are focused on through the 

technology and use of post editing software allowing pan and zoom. Accordingly, my UAS has 

been experimentally operated for familiarization/competency and will continue to operate at and 

above current safety levels. 

VI. A Summary the FAA May Publish in the Federal Register: 

14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, 

weight and enclosed operational area of my, PAUL SHERIDON’s, UAS permits exemption from 

Part 21 because my UAS meets (and exceeds) an equivalent level of safety pursuant to Section 

333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the 

Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness 

certificate requirement in consideration of the weight, size, speed, maneuverability and proximity 

to areas such as airports and dense populations. My, PAUL SHERIDON’s, current and 

projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no 

such certificate will be applicable in the form contemplated by the FARs, this Regulation is 

inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on 

board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 
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equivalent level of safety will be achieved by maintaining a safety/flight manual delineating 

areas of where safety can be defined. 

The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827. 

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor or controlled GPS “geofencing” 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved by maintaining any such required certifications and registrations by 

me, PAUL SHERIDON. 

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation require 

aircraft to be marked according to certain specifications. My UAS can be marked with the 

appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. I, PAUL SHERIDON, 

The sUAS Pilot in Command must possess at least a sport pilot certificate and a driver's license. 

The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the 

PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for 

the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain 

conditions. My UAS will never operate at an altitude greater than 300 feet AGL; safely below the 

standard of 400 AGL. I, PAUL SHERIDON, will however operate my UAS in safe areas away 

from public and traffic, providing a level of safety at least equivalent to or below those in relation 

to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS, an 

equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections Manual

The above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] 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. . . .”These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to my, PAUL SHERIDON's, UAS. 

However, as a safety precaution I inspect my UAS before and after each flight. 

A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: 

Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled 

Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness 

certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area 
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of my UAS permits exemption from Part 21 because my, PAUL SHERIDON’s, UAS meets an 

equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to 

exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 

44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. My UAS 

meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft 

without an airworthiness certificate. As no such certificate will be applicable in the form 

contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an 

aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of 

the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a manual. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program 

that involves regular software updates and curative measures for any damaged hardware. 

Therefore, an equivalent level of safety will be achieved. 

In summary, PAUL SHERIDON seeks an exemption from the following Regulations:14 C.F.R. 

21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. 

§ 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 

91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. 

§ 91.407 (a)(1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 

91.417 (a) & (b) to commercially operate my, PAUL SHERIDON's, small unmanned 

vehicle/lightweight unmanned aircraft vehicle in community awareness, education, structural 

inspection land management, search and rescue and real estate operations, and to develop 

economic platforms for the aforementioned to enhance the experience of those seeking to 

relocate, rebuild, reevaluate and to find in the area of operations. 

F. Additional FAA Required Operating Conditions and Limitations

When not covered elsewhere in this Operations Manual, the following conditions and limitations 

apply:

1. The UA must weigh less than 55 pounds (25kg), including energy source(s) and equipment

2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.

3. Flights must be operated at an altitude of no more than 500 feet above ground level (AGL), 

as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC 

must be in feet AGL.

4. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC's state driver’s license.

5. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be 

able to communicate verbally at all times.
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6. If a discrepancy exists between these limitations and any procedure outlined elsewhere in 

this operations manual, the conditions and limitations herein take precedence and must be 

followed.

7. Prior to each flight, the PIC must inspect the UAS to ensure it is in a condition for safe flight. 

If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included 

in the preflight inspection. All maintenance and alterations must be properly documented in the 

aircraft records.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional 

test flight in accordance with the operator's manual. The PIC who conducts the functional test 

flight must make an entry in the UAS aircraft records of the flight.

9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements 

must be established and identified in the operator's manual. At a minimum, the following must 

be included in the operator's manual:

a. Actuators / Servos

b. Transmission (single rotor)

c. Powerplant (motors)

d. Propellers

e. Electronic speed controller 

f. Batteries

g. Mechanical dynamic components (single rotor)

h. Remote command and control

i. Ground control station (if used)

j. Any other components as determined by the operator

10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a 

current state driver’s license. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate.

11. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and 

at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). 

Prior documented flight experience that was obtained in compliance with applicable regulations 

may satisfy this requirement. Training, proficiency, and experience-building flights can also be 

conducted under this grant of exemption to accomplish the required flight cycles and flight time. 

During training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered non-participants, and the PIC must operate the UAS with appropriate 

distance from non-participants in accordance with 14 CFR § 91.119.
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12. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51 (b), a minimum of five hours as UAS pilot operating the make and model of UAS to be 

utilized for operations under the exemption and three take-offs and three landings in the 

preceding 90 days. Training, proficiency, experience-building, and take-off and landing currency 

flights can be conducted under this grant of exemption to accomplish the required flight time and 

90 day currency. During training, proficiency, experience-building, and take-off and landing 

currency flights, all persons not essential for flight operations are considered non-participants, 

and the PIC must operate the UAS with appropriate distance from non-participants in 

accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual 

observer (VO) must have successfully completed a qualification process, as outlined in the 

operator’s manual. As this is a requirement stipulated by the operator, the test must be 

developed and implemented by a qualified person designated at the sole discretion of the 

operator. A record of completion of this qualification process must be documented and made 

available to the Administrator upon request.

14. Prior to operations conducted for the purpose of motion picture filming (or similar 

operations), a flight demonstration, administered by an operator-approved and -qualified pilot 

must be successfully completed and documented. This documentation must be available for 

review upon request by the Administrator. Because the knowledge and airmanship test 

qualifications have been developed by the operator, and there are no established practical test 

standards that support a jurisdictional FAA FSDO evaluation and approval of company 

designated examiners, the petitioner will conduct these tests in accordance with the operator’s 

manual.

15. The UAS may not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface 

in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting production personnel. At all times, those persons 

must be essential to the closed-set film operations. Because these procedures are specific to 

participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary 

for reductions to the distances specified in the petitioner’s manuals. This is consistent with the 

manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificate of 

Waiver for Motion Picture and Television Filming.

17. Regarding distance from non-participating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the filming production. This provision may be reduced to no less than 200 feet if it 

would not adversely affect safety and the Administrator has approved it. For example, an 

equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the 

filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such 

barriers may protect non-participating persons (observers, the public, news media, etc.) from 

debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, 
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C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

the operator’s manual.

19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual.

20. Each UAS operation must be completed within 30 minutes flight time or with 25% battery 

power remaining, whichever occurs first.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under this grant of exemption. This COA 

will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation.

22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N-Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures must be added to the 

operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.

25. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operator’s manual.

27. Before conducting operations, the radio frequency spectrum used for operation and control 

of the UAS must comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements.

28. At least three days before scheduled filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local FSDO with jurisdiction over the 

area of proposed filming. The 3-day notification may be waived with the concurrence of the 

FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights

b. Name and phone number of the person responsible for the UAS filming production under 

this grant of exemption

c. Name and phone number of the person responsible for the on-scene operation of the UAS.

d. Make, model and serial or N-number of the UAS to be used

e. Name and certificate number of the UAS PIC's involved in the filming production event 
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f. A statement that the operator has obtained permission from property owners and/or local 

officials to conduct the filming production event; the list of those who gave permission must be 

made available to the inspector upon request.

g. Signature of exemption-holder or representative

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, 

and/or state over which filming will be conducted and the altitudes essential to accomplish the 

operation

29. The documents required under 14 CFR § 91.9 and § 91.203 must be available to the PIC at 

the ground control station of the UAS any time the aircraft is operating. These documents must 

be made available to the Administrator or any law enforcement official upon request.

30. The UAS must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized.

32. The UAS cannot be operated by the PIC from any moving device or vehicle.

33. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

34. The UAS may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered airport 

as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. The letter of agreement with the airport management must 

be made available to the Administrator upon request.

35. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

Federal Aviation Administration’s (FAA) UAS Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov. Further flight operations may not be conducted 

until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume 

operations is provided.

Currently, the aforementioned aerial videography/photography relies primarily on the use of 

larger aircraft running on combustible fuel, posing potential risk to the public. Granting my, 

PAUL SHERIDON’s, request for exemption will reduce current risk levels and thereby enhance 

safety. My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional video and photographic aircraft with much less flight time. 

Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk 

flying to and from established airfields. I, PAUL SHERIDON, have been informally analyzing and 

recording flight information and will compile safety protocols and the implementation of a flight 

operations manual for usage that exceeds currently accepted means and methods for safe 
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flight. Formal collection of information shared with the FAA will enhance the FAA's internal 

efforts to establish protocols for complying with the FAA Modernization and Reform Act of 2012. 

There are no personnel on board my, PAUL SHERIDON’s, UAS and therefore the likelihood of 

death or serious bodily injury is significantly diminished. My, PAUL SHERIDON’s, operation of 

my UAS, weighing less than thirty-five (35) pounds and traveling at lower speeds within limited 

areas low to the ground will provide an equivalent level of safety as that achieved under current 

FARs. Accordingly I, PAUL SHERIDON, respectfully request that the FAA grant my exemption 

request and am willing to cooperate in sharing information to benefit the FAA, safety of manned 

aircraft, and the general public at large. 

Respectfully submitted, 

PAUL SHERIDON

3641 Queen Street North

St. Petersburg, FL 33713
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Appendix A

List of Aircraft:

DJI Inspire 1 and DJI Inspire Professional

The operation of the DJI INSPIRE ONE system is as follows:

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The DJI Inspire 1 and Pro- flight is a 4 motor quadcopter setup. 

3. Payload 

I. The DJI Inspire 1 and Pro flies its own light-weight integrated camera. 

II. Maximum All-up weight- 6lbs

4. Maintaining the DJI 1 and Pro

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

corrosion or wear.

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight:

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

4. Replace if propeller is questionable. 

5. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

6. Check for updates to flight controller firmware. If available, install and perform a minimum of 

15 test flights before conducting commercial work.

DJI Phantom 3 Professional

The operation of the DJI Phantom 3 Pro system is as follows:

1. Build Materials

I. Plastic

II. Aluminum 

2. Motor Configuration

I. The Phantom 3 Pro flight in a 4 motor quadcopter setup.

3. Payload

I. The Phantom 3 Pro its own integrated camera. 

II. Maximum All-up Weight- 4lbs
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4. Maintaining the Phantom 3 Pro

I. Before each flight:

1. Check all hardware to ensure it is securely tightened.

2. Check that the motor is level and locked in place.

3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs of 

5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight:

1. Remove and check all motors and motor mounts for signs of wear and tear. Replace as 

necessary. 

2. Remove motor controllers and visually inspect and check for damage. Replace as necessary. 

3. Remove flight controllers and visually inspect and check for damage. Replace as necessary. 

4. Replace if propeller is questionable. 

5. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

6. Check for updates to flight controller firmware. If available, install and perform a minimum of 

15 test flights before conducting commercial work.
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Appendix B

Personal Protocols/Controls/Flight Manual Protocols and Controls 

PAUL SHERIDON, St. Petersburg, Florida

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. As such, safety protocols and controls must be 

implemented through pre-flight preparation and during flight. Pre-Flight Protocol: 

Check batteries with voltage meter to insure fully charged and ready for use. 

Inspect batteries for damage or leakage that may affect proper operation. 

Inspect propellers for cracks, chips or damage that may cause sudden loss of propulsion or 

unmanageable/uncontrolled flight. 

Check all GPS and Telemetry connections prior to flight. 

Check weather forecasts for wind advisory or other conditions that my impact flight. 

Consult Sky Vector aeronautical Charts (Skyvector.com) for airport vicinity and flight paths of 

possible air traffic.

Contact respective airport to advise of estimated flight time, estimated flight duration, estimated 

elevation of flight, and any other pertinent information. 

Inspect flight area for:

Vicinity of public safety helipads/heliports.

Vicinity of medical helipads/heliports.

Vicinity of light poles vicinity or utility wires.

Vicinity of trees flocks of birds that may cause interference and potential flight impact.

Vicinity of any elevated obstructions that may pose potential flight hazard.

Vicinity of roadways with moderate to heavy traffic that can be distracted public gatherings that 

may attract viewers optional point of control for best visual site of UAS while in flight.

Emergency landing areas.

Takeoff and landing:

Inspect area for best and safest point of takeoff and landing.

If in a subdivision or area that is within 150 feet of a residential street, post warning 

sign(s)/stand(s) "Attention Aerial Photography In Progress - Remain Back 150 Feet” 

Flight Protocol: 

Takeoff and land from same location (have alternate landing areas in case of emergencies) 

remain alert to birds, sound or aircraft, curious public, and approaching vehicles do not allow 

anyone to engage in conversation or distract the remote control pilot restrict flight to minimal 

elevation sufficient to acquire desired results remained prepared for emergency landing at all 

times pay attention to flight time – warning meter for low voltage. 
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Set voltage meter alarm for low voltage and flight timer as a safety alert land UAS and shut 

down propulsion immediately following landing – priority of disconnecting batteries.

Post flight:

Disconnect battery to prevent accidental activation of propulsion system.

Secure UAS in a safe location.

Remove all warning signs from public access areas Emergency or Suspected Hazard: 

Immediate land UAS at safest and closet ground location in the event:

Manned aircraft is heard or seen in vicinity of flight.

There is a public gathering within established safety boundary wanting to observe flight.

Pilot is being distracted from focusing on flight and safety.

Sudden change in weather (wind bursts).

Sudden increase in vehicular traffic in vicinity of flight.

Birds enter into proximity of flight.

Any sudden unsafe event that can cause collision, distraction or interruption of control.

Safety for public on the ground as well as manned aircraft above is an essential and utmost 

consideration for aerial videos and photography. 

Maintaining a record of safe flight for FAA request and for determining future UAS safety 

protocols is imperative. 

Date:____________________ 

Location:___________________________________________________ 

Pre-flight Inspection: Yes or No 

Comments: _________________________________________________ 

Elements:

Proximity to airport: _________________ (see attached map pinpointing approximate location 

of flight) 

Airport notified: Yes or No 

Date:_______________ Time: ______________ 

Phone Number: _______________________ 

Contact Name:___________________________________ 

Nearest major intersection: 

______________________________________________________________ 
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Proximity to medium traffic road: 

_________________________________________________________ 

Proximity to heavily traveled roadway road: 

_________________________________________________ 

Proximity to congested population: 

________________________________________________________ 

Approx. Takeoff Time: GMT: 

Weather Good Fair Poor Comment:

________________________________________________________

Visibility Good Fair Poor Comment:

________________________________________________________

Wind Speed ____mph ____Gusts/MPH ____avg/MPH Comment:

________________________________________________________

Approx. Landing Time:_____ Estimated Elevation Ground level: _____

Safety Concerns:

________________________________________________________

________________________________________________________

Additional Comments: 

________________________________________________________

________________________________________________________

Sea level: ________
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Appendix C

Aircraft Manuals:

This Appendix includes UAS manufacturer's user manuals, maintenance instructions, and 

illustrated parts catalogs. These manuals may be attached to the docket when submitted. 

Information regarding design, aircraft performance, fail-safe features, operating limitations, 

normal and emergency procedures, and maintenance and inspection procedures is contained 

within the manuals and supplemental information documents listed below:

1. DJI Inspire 1 and Pro Manual V1.0

2. Inspire 1 and Pro Maintenance Manual v1.0

3. Intelligent Flight Battery Safety Guidelines v1.4

4. DJI Inspire 1 and Pro Safety Guidelines

5. Phantom 3 Professional Manual V1.0

6. Phantom 3 Intelligent Flight Battery Safety Guidelines v1.0 (EN)

For more information or questions about this manual please contact:

Paul Sheridon

3641 Queen Street North

St. Petersburg, FL 33713

727-686-6309`