Submitted On-line www.regulations.govon August 19, 2015 by Travis D Gearhart 

United States Department of Transportation 

Docket Management System 

PIC Pilot In Command SO 

UAs Unmanned Aircraft(s) FAA 

UASs Unmanned Aircraft System(s) GCS 

VLOS Visual Line of Sight GPS 

Safety Observer 

Federal Aviation Administration 

Ground Control Station 

Global Positioning System 

Travis D Gearhart seeks exemption from the requirements of 14 C.F.R 91.7(a), 91.151(b), to operate an 

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Travis D Gearhart to operate an Unmanned Aircraft System 

(UASs) without an airworthiness certification for the commercial purpose of conducting aerial video 

and photography including but not limited to real estate, farmland, and landscape over certain areas of 

the United States. 

Additional Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

The UAS(s) to be operated carries neither pilot nor passenger and carries no explosive materials or 

flammable liquids. Given the size, weight, speed and limited operating area associated with the UAs 

and its operation, Travis D Gearhart's operation of the UAs meets the conditions of FMRA Section 333 

and therefore, will not require an airworthiness certificate. 

14 CFR 61 

Considering the UAs will not require an airworthiness certificate and considering the speed, weight, 

size, and limited operating area associated with the UAs and its operation, Travis D Gearhart requests 

exemption from obtaining a airline transport, commercial, private, recreational, or sport pilot 

certificate. By following the safety guidelines set forth by the manufacture and the additional 

requirements of an approved exemption Travis D Gearhart will maintain a safe environment. 

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) 

These sections set forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. Travis D Gearhart submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Travis D Gearhart will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents. 

14 CFR 45.23 (b) 

Due to the size of this UAS(s)it does not have a cockpit, cabin, or pilot station on which to mark certain 

words or phrases. Lettering would be very difficult to place on such a small aircraft and dimensions 

would need to be smaller than required 2" minimum. 

14 CFR 91.9 (b) (2) & 14 CFR 91.203 (a) and (b) 

Given the size and configuration, the UAS has no ability to carry operating documents on the aircraft. 

There is no room, capacity, or pilot on board to adequately carry the operating documents. A equivalent 

level of safety will be maintained by keeping the operating documents at ground control point where 

the PIC will have immediate access to it. 

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Submitted On-line www.regulations.gov on August 19, 2015 by Travis D Gearhart 

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft an exemption is requested. 

Normal procedures including but not limited to: reviewing weather, inspecting flight area, flight battery 

requirement, landing and takeoff distances. An equivalent level of safety will be provided by preflight 

guidelines. 

14 CFR 91.121 

Altitude information of the UAs will be provided to the PIC via Global Positioning System (GPS) 

equipment and communications telemetry data link, which down-links from the UAs to the GCS for 

active monitoring of the flight path. This altitude information, combined with Travis D Gearhart's 

operation of the UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety. 

14 CFR 91.151 (b) 

The UAs listed below are battery-powered and do not require fuel. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b) 

Given these sections only apply to aircraft with an airworthiness certificate, these section do not apply 

to the applicant. As a safety precaution, PIC will perform preflight inspections and ensure the UAs 

is/are in working condition before initiating each flight. 

Additional Beneficial Information 

The Public Will Benefit From Decreased Congestion Of The NAS. UAs are battery powered and serves 

as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain 

aerial imagery. By reducing the number of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a UAS would reduce the number of manned aircraft in the NAS and 

reduce noise and air pollution, as well as increase the safety of life and property in the air and on the 

ground. Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. UAs do not require an airport 

to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations. With the rising cost of aviation fuel 

and the Environmental Protection Agency (EPA) regulatory actions phasing out leaded aviation fuels, 

U.S. owned and operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered UAS is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such flexibility 

without the high operational cost of a traditional manned aircraft. By operating UAs, companies can 

remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the UAs, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United States and abroad. 

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Submitted On-line www.regulations.gov on August 19, 2015 by Travis D Gearhart 

Additional Safety Information 

PIC and UAs listed below will maintain a level of safety when considering the following: 

UAs will only be operated during daylight hours. 

UAs will not exceed 40 knots. 

UAs will only be operated below 400 feet above ground level (AGL). 

UAs will be operated within visual line of sight (VLOS) of the PIC at all times. 

UAs operating documents will available and accessible during operations. 

Weather conditions will be good to moderate, to avoid collisions of any kind. 

Flight area including ground and NAS will be inspected for hazards before each flight. 

UAs will undergo a manufacture Pre-Flight checklist before each flight. 

PIC will follow the manufacturer's maintenance, overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components. 

PIC Travis D Gearhart born in 1975 holds a current Colorado Drivers license. 

UAs complies with part 15 of FCC Rules. Operation is subject to the following two conditions: 

(1) this device may not cause harmful interference, and 

(2) this device must accept any interference received, including interference that may cause 

undesired operation. 

UAs will not operate within 5 nautical miles of an airport reference point, unless a letter of agreement 

is obtained from the airport management. 

Both UAs listed have "Return to Home" safety features in case of loss of communication. 

Thank you for taking the time to review my request. 

~ 

Travis D Gearh 

PO Box 94 

Ignacio, CO 81 

/ 

Listed UAs for exemption request. 

Parrot Bebop 

DJI Phantom 3 

Documents included with this request. 

Parrot Bebop 

Bebop-drone_User-guide.pdf 

BAT—SAFETY_BEBOP—DRONE-297x218mm—EN-FR-27feb2015-3.pdf 

BD_BeBop—Datasheet-210x297-19nov14.pdf (Technical Specifications) 

DJI Phantom 3 

Phantom-3—Professional—User—Manual_v1.4—en.pdf 

Phantom_3_Safety—Guidelines—Disclaimer—en.pdf 

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