Sept. 28, 2015 

Subition by: Brian Thomas 

616 Palastine Rd. 

Chester, Illinois 62233 

(618) 615-2211 

brithom2002@yahoo.com 

U.S. Department of Transportation Docket 

Management System 

1200 New Jersey Ave. SE 

Washington, DC 10590 

Re: Exemption request under section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations. 

Dear Sir or Madam, 

I request an exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.401, 91.405, 91.407(a)(1), 

91.409(a)(2) and 91.417(a) and (b)ofTitle 14, Code of Federal Regulations (14CFR) was granted in 

Exemption Numbers 11138, 11395, 11428 and 11434. 

I will operate a DJIInspire 3, a UAS weighing Jess than 8 lbs. at takeoff, and can take photos and videos 

using the on board camera. The operation performed by myself with this UAS are to include but not 

limited to real estate photography, both residential and commercial, surveying timber stands for 

forestry, crop surveying for agriculture, event coverage and artistic photos. The use of UAS reduces the 

need for conventional aircraft in populated areas and will allow never before possible photos and videos 

to be taken safely and experienced by the public. 
Operations under this exemption will be conducted as outlined in the proposed rule set in motion on 

2/23/2015 in docket FAA-2015-0150. 

• Operational limitations, Visual line of sight (VLOS) only; the unmanned aircraft must remain 

within VLOS of the operator or visual observer. 

• At all times the small unmanned aircraft must remain close enough to the operator for the 

operator to be capable of seeing the aircraft with vision unaided by any device other than 

corrective lenses 

• Small unmanned may not operate over any person not directly involved in the operation. 

• Daylight-only operations (official sunrise to official sunset, local time.) 

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

• May use visual observer (VO) but not required. 

• First person view camera cannot satisfy "see and avoid" requirement but can be used as long as 

requirement is satisfied in other ways. 

• Maximum airspeed 100 mph. (87 knots) 

• Maximum altitude 500 feet above ground level. 

• Minimum weather visibility 3 miles from control station. 

•- · Nooperationareallowed in Class A (18,000 feet and above) airspace. 

• Operations in Class B, C, D and E airspace are allowed with the required ATC permission. 

• Operations in Class G airspace are allowed without ATC permission. 
• No person may act as an operator or VO for more than one unmanned aircraft operation at a 

time. 

• No careless or reckless operations 

• Requires preflight inspection by the operator. 

• A person may not operate the small unmanned aircraft if he or she knows or has reason to know 

of any physical or mental condition that would interfere with the safe operation of a small UAS. 

I request an exemption from 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance 

Inspections since they only apply to the aircraft with an airworthiness certificate. I will however perform 

a preflight inspection of my UAS before each flight as outlined in the operating documents. 

I request exemption from 91.151 the pilot in command will be abiding by the following personal 

protocols and controls: 

• Operator will only operate in a reasonably safe environment that are strictly controlled, are away 

from power lines1 elevated light and airports. Operator will conduct extensive preflight 

inspections and protocols as outlined in the operating documents 

• Operate the UAS below 500 feet and within a radius of 1550 feet from the controller while 

maintaining direct line of sight visual observation (VLOS). 

• Land the UAS before the manufacturer's recommended minimum battery level. 

• Use the UAS GPS flight safety feature whereby the aircraft raises to a predetermined safe altitude 

and then returns to point of takeoff should communications with the remote control operator is 

lost. 
• Contact respective airports and/or Flight Standard District Offices if operations will be within 5 

miles to advise them of my estimated flight time, flight duration, elevation of the flight and other 

pertinent information. 

• Have procedures in place to abort flights in the event of safety breaches or potential danger. 

91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that since 

there is currently no certificate applicable to my operation, this regulation is inapplicable. 

91.119 prescribe safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated 

at lower altitudes in certain conditions. Operator will not operate the UAS above the altitude of 500 feet 

above the ground level (AGL) and will also operate in safe areas away from the public and traffic, thus 

providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. 

91.121 Altimeter settings are inapplicable since my UAS utilizes electronic GPS with a barometer sensor.