Patrick Gannon 8/28/15

405 6th Ave. Apt. 806

Des Moines, IA 50313

515.290.3427

Petition for exemption

Summary:

I seek exemption to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit me to operate an Unmanned 

Aircraft System (UAS) for aerial video and photography for commercial & agricultural conservation 

surveying. Currently I work as a freelance producer/videographer in Iowa, specifically in the Des 

Moines/central Iowa area. I have flown over 30 hours with the Inspire 1 without incident.

Seeking Exemption from:

14 CFR Part 21 subpart H 

14 CFR 45.23 (b)

14 C.F.R. 61.113(a)(b); 61.133(a)

14 CFR 61.56

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.113 (a) and (b) 

14 CFR 91.119 (c)

14 CFR 91.121 

14 CFR 91.151 (a)

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a)(1) & (2) 

14 CFR 91.417 (a) and (b)

Extent of relief sought:

14 CFR Part 21 subpart H 

The UAs 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 aircraft to be utilized, 

I request exception. In the restricted environment and under the conditions proposed operation will be at 

least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said 

restrictions.

14 CFR 45.23 (b) 

As this UAS does not have a cockpit, cabin, or pilot station on which to market 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 minimum. Understanding the importance of lettering I will mark my UAS with the largest 

possible letters by placing the word "Experimental" or assigned number or name, based on request/ruling of 

FAA, on UAS fuselage. The equivalent level of safety will be provided by having the UAS marked on its 

fuselage as required.

14 C.F.R. 61.113(a)(b); 61.133(a):

My UAS will only carry a camera onboard for hire. No living thing at anytime will be carried, therefor an 

exemption from the above requirement is requested.
14 CFR 61.56:

I request exemption from 14 CFR 61.56 which requires the PIC to conduct a flight review consisting of a 

minimum of 1 hour of flight training and 1 hour of ground training. This requirement is not pertinent to the 

safe operations of the Inspire 1. Safety and procedures will adhere to those outlined in the Inspire 1 User’s 

Manual

14 CFR 91.7 (a) 

As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft for maintenance 

and use of safety check list prior to each flight an equivalent level of safety will be provided.

14 CFR 91.9 (b) (2) 

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no 

room, capacity, or pilot on board to adequately carry flight manual. An equivalent level of safety will be 

maintained by keeping the flight manual at ground control point where the pilot will have immediate access 

to it.

14 CFR 91.103 

As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal 

procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff 

distances, along with all of those found in "Inspire 1 User Manual". An equivalent level of safety will be 

provided by preflight protocol to properly match the machine.

14 CFR 91.113 (a) and (b) 

I can achieve an equivalent level of safety as achieved by current regulations because my UAS does not 

carry pilot nor passenger. While helpful, a pilots' license will not ensure remote control piloting skills. The 

risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 

CFR part 61

14 CFR 91.119 (c)

Due to the small size, weight, limited speed and absence of flammable liquids on board, the Inspire 1 is 

safer than an airplane. Flying will only occur with the proper consent of the property owners and/or local 

officials. This permission will give ample time for all owners and neighbors to be aware of the times of 

operation. Multiple signs will be posted to ensure people are aware when drone operations are being 

conducted. At no time will the UAS be operated at or near any airport and/or be flown over any person, 

vessel, vehicle or structure without prior coordination and permission of the concerned parties.

14 CFR 91.121 

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I believe an 

exemption may be needed. An equivalent level of safety is achieve by the operator receiving live flight data 

monitoring and confirming current altitude along with altitude of launch site shown on GPS altitude 

indicator.

14 CFR 91.151 (a)

The battery powering the UAS provides approx.. 17 minutes of powered flight, therefor making it 

impossible to meet the 30 minute reserve requirement. However, I use a strict return-to-ground procedure 

whenever the battery reaches 20%.

14 CFR 91.203 (a) and (b) 

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry certificate 

and registration documents on the aircraft. There is no room, capacity, or pilot on board to adequately carry 

such documents. An equivalent level of safety will be achieved by keeping these documents, to the extent 

they are applicable to the UAS, at the ground control point where pilot has immediate access to them. 

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (1) & (2), 14 CFR 91.417 (a) and (b) 
Given these sections only apply to aircraft with an airworthiness certificate, theses sections do not apply to 

this applicant. As a safety precaution, operator will perform preflight inspections and ensure UAS is in 

working condition before initiating each flight.

Operation & Safety Compliances:

I plan on operating a UAS, an Inspire 1 (manufactured by DJI) for my aerial photography and surveying.

I have logged close to 30 hours flying this model recreationally, and always abide by all safety regulations. 

I provide, and will continue to provide, these following levels of safety

- I will only operate in reasonably safe environments

- I will conduct extensive preflight inspections and protocols, during which safety carries primary 

importance.

- I will only operate in direct line-of-site with the UAS (VLOS)

- I will operate the UAS below 400 feet

- I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or the 

airport manager has been made. 

- I land my UAS prior to manufacturer recommended minimum level of battery power 

- My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed position and 

then slowly lands if communication with the remote control pilot is lost 

- I actively analyze flight data and other sources of information to constantly update and enhance 

safety protocols

- I always obtain all necessary permissions prior to operation

- I have procedures in place to abort flights in the event of safety breaches or potential danger.

- Follow all other safety procedures and take off/operation/landing procedures as outlined in the 

Inspire 1 User Manual 

Public Interest

One aspect to flying and recording with my UAS would be to provide landowners with data pertaining to 

erosion or damage to their land, fields, buildings etc. Many landowners own and/or operate over hundreds 

or even sometimes thousands of acres of land, and providing information via aerial photography about their 

land would prove invaluable when implementing or maintaining conservation practices such as avoiding 

erosion, maintaining soil levels, recognizing and repairing damaged areas, etc

Thank you,

-Patrick Gannon