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U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

February 10, 2016 

Craig Huey Photography, LLC 

C/o Craig Huey 

12079 Olmstead Drive 

Fayetteville, Georgia 30215 

Email: Craig@CraigHueyPhotography.com 

Subject: Exemption Request under Section 333, FAA Modernization and Reform Act, Part 11 of FARs 14 C.F.R. 

45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.103, 91.119(c), 91.121, 

91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), 91.7(a), 91.9(b)(2) 

Dear FAA Representative: 

Please accept this letter as official application for exemption of the Federal Aviation Association Modernization 

and Reform Act of 2012, Section 333, Federal Aviation Regulations ("FARs"), in accordance with 14 C.F.R. Part 11 

for allowance of commercial operation of Unmanned Aircraft Systems (UAS) platforms. This exemption comes at 

the request of Craig Huey Photography, LLC, petitioner and owner of UAS. 

Proposed Operations 

Petitioner seeks relief from the listed regulations in order to operate a small UAS, commercially, in airspace 

regulated by the Federal Aviation Administration (FAA) for the purpose of aerial photography, videograph/, and 

other aerial operations at a lower altitude within the national and international airspace. Only authorized 

representatives of Craig Huey Photography, LLC, being 17 years of age or older with a valid United States driver's 

license, will operate UAS flights under the conditions outlined herein and as established by the FAA as requ ired by 

Section 333. Petitioner wishes exemption to operate UA Multifunctional Quad-rotor Systems by DJI for 

compensation or hire within the National and International Airspace System as needed by clients. Current 

specification s for the OJ I UAS are as follows: 

UAS Specifications 

Aircraft II 

Phantom 3 

II 

Phantom 3 I Phantom 3 (4K) 

II 

Inspire 1 

(Professional) (Standard) 

Diagonal Size (Including 689mm II 689mm II 689mm II 438x451x301 mm 

Propellers) 

Weight: (Including Battery 1280 g II 1216 g II 1280g 

II 

2935 g and Propellers) 

Flight Time About 23 mins II About 25 mins II About 25 mins II About 18 mins 

1 Please note that videography services by petitioner consist of testimonials, interviews, and b-roil (extra footage 

of images) obtained at corporate membership events. 

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Aircraft I 

Phantom 3 Phantom 3 

I Phantom 3 (4K) II Inspire 1 

(Professional) (Standard) 

Max. Flight Speed II 16m/s II 16m/s II 16m/s II 22 m/s 

CE: 3500 m CE: 500m CE: 500m CE: 3500 m 

Max Transmission Distance FCC: 5000 m FCC : 1000m FCC: 1200m FCC: 5000 m 

(unobstructed) (unobstructed) (unobstructed) (unobstructed) 

Operating Temps II ooc to 40°C II ooc to 40°C II ooc to 40°C II Minus lOoC to 40°C 

C.F.R.s 

45.23(b): The UAS has no entrance to a cabin, cockpit or pilot station upon where the word "Experimental" can be 

placed. The size of the drone prevents two-inch lettering given the size of the UAS. For these reasons the 

petitioner requests relief. In compliance with 14 C.F.R. 45.29, the word "Experimental" will be placed on the 

fuselage based on issued Exemption Nos. 10700, 14226, and 10167. 

61.23(a) and (c): Relief is requested because the Pilot-in-Command (PIC) needs to have EITHER a current medical 

certificate OR a valid United States issued driver's license and demonstrate the ability to safely operate the UAS. 

PIC will be able to do evasive and em ergency maneuvers such as, but not lim ited to, maintaining appropriate 

distances from people and property. FAA has previously allowed relief in Exemption Nos . 11772 and 12688. 

61.101(e)(4) and (5): The UAS does not carry pilot and passengers given its size and speed. The UAS is remotely 

controlled and the area of operation will be coordinated with the permission of the property owner and hiring 

company's representative in advance. The FAA has issued the following exemptions to this regulation: Exemption 

Nos.11275, 11269, 12033. 

61.113(a): Petitioner requests relief to utilize an experienced UAS operator with an optional UAS trained observer. 

Stated usage of the UAS will not pose a threat to National Airspace System, national security or the public, as it will 

not be flown above the maximum altitude of 500 feet from ground level, which is programmed into the UAS. The 

UAS will be operated within the visual line of sight of the operator and/or visual observer unaided by any device 

other than corrective lenses. 

61.31S(a): Petitioner requests relief for any UAS PIC, acting on behalf of petitioner, who holds a sport pilot, 

recreational pilot or private pilot certificate, as well as, an airman medical certificate, to have permission to 

operate UAS flight operations for compensation or hire. (Exemption Nos. 11772 and 12594) 

91.103: Petitioner request relief for separate preflight actions, which are required in using an UAS. The PIC will 

perform preflight actions as recommended by each correspond ing UAS manual, such as, but not limited to 

verifying weather conditions, battery status, and propellers. These actions will provide safety. (Exemption Nos. 

11294, 11062 and 11191) 

91.119(c): The petit ioner requests relief concerning UAS flight over "congested" or "populated" areas as stated in 

Exemption No. 11138 to permit responsible operation in areas of outdoor corporate events when required. Based 

on the hover accuracy, the UAS will not be operated lower than four (4) feet of the tallest person or property in a 

populated area for safety based on the average ability of a person jumping from a standing position. The lack of 

flammable fuel on the UAS and the low-altitude compared to aircrafts, such as helicopters, diminish risks 

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associated with operational compliance in this particular section . Consent of operation for commercial usage will 

be obtained from local municipality and their designated agent. 

91.121: The UAS does not have an altimeter. It uses an electronic GPS with a barometric sensor for altitude; 

thereby, making the requirement inapplicable as stated in Exemption No. 11138. Altitude data is generated by the 

computing system on the UAS. 

91.151(a): Petitioner requests relief based on Exemption Nos. 10673, 10808, 11136 to operate a UAS in a 

controlled area with less than thirty {30) minutes of reserve fuel according to daytime Visual Flight Rules. The 

average flight time is 23 minutes. In the case of low battery level, the onboard flight controllers are designed to 

warn the operator to allow safe landing. A failsafe for loss of Global Positioning System or RC signal strength is also 

designed into the UAS to return to an established landing location. 

91.405{a), 91.407{a)(1), 91.409{a)(1) and (2), 91.417(a) and (b): Prior to usage of the UAS, a preflight checklist will 

be used as a guideline for visual inspection to insure safe operation. Records of the preflight checklist for each "for 

hire" job will be made available to the FAA, upon request. As stated in Exemption No. 11138, FAA found that 

inspection performed by the petitioner based on the manual operating document's requirements for maintenance, 

inspection, and logging is sufficient to ensure safety. 

91.7(a): Petitioner requests relief to operate a UAS based on the size, weight, speed, and limited area of flight as 

stated in Exemption Nos. 14225 and 14234. 

91.9(b)(2): Petitioner requests relief since there are no pilots or passengers on the UAS given its size. The flight 

manual will be maintained at the ground control point where the operator of the UAS will have access to it. FAA 

has given prior approval to this in Exemption Nos. 10167, 10602, and 10700. 

Safety 

Compensated tasks will be conducted only at the request and authorization of clients or their authorized agents in 

compliance with Privacy Laws and FAA Regulations. UAS operation will require completion of a pre- and post-flight 

checklist of flight readiness of UAS. Any and all accidents that result in injury or property damage will be reported 

to the FAA within ten (10) days. All operations of the UAS will occur over private or controlled properties with 

consent of the hiring company's representative(s). Videography will be performed with consent of all persons in 

attendance. Choice of usage of an UAS is to enhance safety and reduce environmental impact compared to usage 

of a manned aircraft. Petitioner promises to uphold the following proposed drone rules: 

• May only be operated from official sunrise to official sunset, (local time). 

• Must yield the right-of-way to other aircraft, whether manned or unmanned. 

• May be flown using "first-person view," but either the operator or the visual observer 

must maintain an unenhanced visual line of sight of the craft. 

• May be flown in minimum weather visibility of 3 miles from the operator. 

• May not be flown in Class A (18,000 feet & above) airspace. 

• May be flown in Class B, C, D and E airspace with ATC permission. 

• May be flown in Class G airspace are allowed without ATC permission. 

• May not be flown carelessly or recklessly. 

• Require a preflight inspection before each flight, including specific aircraft and control 

station systems checks, to ensure the drone is safe for operation. 

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• May not be flown by a person if he or she knows or has reason to know of any physical 

or mental condition that would interfere with its safe operation. 

• No person may act as an operator or visual observer for more than one unmanned 

aircraft operation at one time. 

Public Interest 

Safe UAS operations conducted within the FAA guidelines will support local and national businesses. Usage of UAS 

would allow Petitioner to expand services to include compliant and safe UAS services with the expectation of 

economic growth by providing imaging data for the purpose of a "for hire" basis while acting as an independent 

contractor. Operations of these services allow clients to gain enhanced perspectives of photographic and 

videographic images. Petitioner will provide safe and reliable aerial videography and photography services for 

marketing purposes of corporate events such as, conferences, expositions, annual meetings, symposiums, and 

tradeshows; as well as, documenting projects for businesses, such as, but not limited to, corporations, real estate, 

golf courses, marketing and advertising, architecture, and agriculture. Aerial images or video of outside events 

such as, sports, dinners, cocktails, and other corporate events could be provided in a safe manner compared to 

using a manned aircraft. 

International Request 

Petitioner currently has 16 years of experience providing photography and videography services to national and 

international clients. Because current local and national clients conduct similar events internationally, petitioner 

further wishes permission, according to 14 CFR 11.83, to exercise the privileges of the requested exemptions 

outside the United States. Operation of UAS will not be conducted without prior location approval obtained by the 

client with respect to the international country and local regulations. UAS will only be operated internationally 

during "for hire" work and flight data will be logged and available to FAA, upon request. Petitioner understands 

approval by FAA for usage of UAS in the United States, does not take precedence over a possible disapproval 

with in an international country. 

Best Regards, 

Gt2~~ ~ CraigA.Huey ~r Craig Huey Photography, LLC 

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