UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

March 20, 2015

Dear Sir or Madam,

I, Jonathan Held, am writing pursuant to the FAA Modernization and Reform Act of 

2012 Section 333 and the procedures contained within 14 C.F.R. 11, to request 

exemption from the Federal Aviation Regulations listed below so that I may operate a 

small Unmanned Aircraft System (sUAS) within the National Airspace System for the 

purpose of high resolution commercial aerial photography and videography.

I am a licensed pilot (ASEL, ASES, Glider) and instructor (CFIG). Because of this I have 

a full understanding of the value of aircraft inspection, maintenance, flight safety 

awareness and procedures, and use of the National Airspace System. Furthermore I have 

over 100 hours of experience flying an Unmanned Aircraft (UA). 

The UA (henceforth called the P2 Mulitrotor) for which I seek exemption is a custom 

built vertical take-off 8 motor multirotor system with a maximum gross weight of 32

pounds and dimensions of 56 inches in diameter and 20 inches in height. The system is 

electrically powered by Lithium Polymer batteries and has a maximum speed of 40 knots. 

The P2 Multirotor incorporates multiple safety measures including an auto land feature in 

the event of a lost communication or GPS link, motor redundancy to assure controlled 

flight in the case of a motor failure, frequency hopping radio technology to prevent 

control loss due to radio interference, telemetry to monitor battery power during flight, 

and the use of a robust and reliable flight controller. The P2 Multirotor operation follows 

safety procedures and operating limitations (including preflight checklist) set out in the 

P2 Multirotor Pilot Operators Handbook. 

Respectfully submitted,

Jonathan William Held

P2 Photography
I. Contact Information:

Jonathan William Held

119 Loma Alta Drive

Oceanside, CA 92054

jon@p2photography.net

(858)-602-2839

CFIG 3150235

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

I Seek Relief:

61.113 (a) Private Pilot Privileges and Limitations

91.7 (a) Civil Aircraft Airworthiness

91.119 (b) and (c) Minimum Safe Altitudes

91.121 Altimeter Settings

91.151 (a)(1) Fuel Requirements for Flights in VFR Conditions

91.405 (a) Maintenance Required

91.407 (a)(1) Operation After Maintenance

91.409 (a)(1) and (2) Inspections

91.417 (a) (iii) and (b)Maintenance records

III. Extent of Relief and the Reason for Requesting Such Relief:

I request an exemption from 14 C.F.R. 61.113 (a) so I may fly the P2 Multirotor (a 

powered aircraft) commercially on the basis of my Private (ASEL) rating. 

I seek relief from C.F.R. 91.7 (a), as the P2 Multirotor does not have an airworthiness 

certificate and no standard exists for determining airworthiness.

Considering that the most desirable range of altitudes for photography and videography

from a UA is between 20 and 500 feet, I request an exemption from 14 C.F.R. 91.119 (b)

with the exception of flight over an open air assembly of persons or any person not 

involved with the UA flight directly. To keep 1000 feet above the highest obstacle within 

a 2000 foot horizontal radius would require the UA to fly higher than is safe. Furthermore, 

to keep 1000 feet above the highest obstacle within 2000 feet would defeat a commonly 

requested use of a UA, which is low altitude photography of buildings and structures. 

Similarly I request an exemption from 14 C.F.R. 91.119 (c) as it would prove difficult in

many practical situations to takeoff and execute flight while keeping 500 feet away from 

any person, vessel, vehicle, or structure. I propose that the P2 Multirotor maximum 

altitude be established at 500 feet Above Ground Level.

Furthermore I propose that P2 Multirotor flight operations would be prohibited while 

non-participating persons are within 100 feet of the UA unless those persons remain in or 
under structural protection during the flight, or if those persons are necessary to the 

purpose of flight, there is no undue hazard to them and they have been given a detailed 

safety briefing. Nevertheless, all persons shall stand back at least 25 feet during takeoff 

and landing.

Due to the local and low altitude flight profile of the P2 Multirotor I seek exemption from 

14 C.F.R. 91.121. Furthermore the P2 Multirotor has a GPS altimeter which is set to read 

0 (zero) feet at the takeoff point prior to each flight. All P2 Multirotor flights are “local”, 

and unaided visual contact is maintained with the aircraft during all flight operation. 

The P2 Multirotor is electrically powered and carries no fuel onboard therefore I request 

an exemption from 91.151 (a) (1). 

The P2 Multirotor has no airworthiness certificate and there is no person authorized to 

perform the required inspections and maintenance therefore I request an exemption from 

14 C.F.R. 91.405 (a). 

The P2 Multirotor has no airworthiness certificate and there is no person authorized to 

return of the aircraft to service therefore I request an exemption from 14 C.F.R. 91.407 

(a)(1). 

The P2 Multirotor has no airworthiness certificate and there is no person authorized to 

perform an annual inspection therefore I request an exemption from 14 C.F.R. 91.409 

(a)(1) and (2).

The P2 Multirotor has no airworthiness certificate and there is no person authorized to 

log maintenance records nor to approve the aircraft for return to service therefore I 

request an exemption from 14 C.F.R. 91.417 (a)(iii) and (b).

IV. The Reasons Why Granting My Request Would be in the Public Interest or How 

It Would Benefit the Public as a Whole:

Because of the passage of the FAA Modernization and Reform Act of 2012 specifically 

TITLE III subtitle B-Unmanned Aircraft Systems it is a priori knowledge that the 

integration of sUAS into the National Airspace System is in the public interest. Specific 

to my request however is the rapidly growing need and desire for quality aerial 

photographs and videography. It is my intent to make use of the P2 Multirotor to address 

those needs. While it is commonly known that a UA is a great tool for low altitude aerial 

photography and videography, it is not so well understood that the use of a UA often 

allows for better aerial photography and videography in general. Since the UA and Pilot 

In Command are present at the site of interest, the photographer or videographer has the 

ability to wait until the conditions (of light etc.) are at an optimum. When operating from 

a manned aircraft this is rarely the case. Manned aircraft typically launch many miles 

from the site of interest and thus a photographer or videographer must accept the 

conditions of lighting that are found upon arrival. The public benefit of better images is
very real both economically and aesthetically. Furthermore a manned aircraft is loud 

when it dwells over a given site whereas a UA is far quieter and will result in quieter 

skies and less complaints. In addition the FAA Office of Aviation Policy and Plans has 

stated (in the Notice of Proposed Rulemaking Regulatory Evaluation, Small Unmanned 

Aircraft Systems 14 CFR Part 107, page 17) , “Consequently, once a small UAS aerial 

photography market becomes established, it would increase safety by substituting an 

unmanned aviation operation using a very light aircraft for a more complex manned 

aviation operation that uses a much heavier aircraft. A heavier manned aircraft would 

pose more risk to the public in the event of an accident. This market would also 

generate significant cost savings to the economy.”

V. The Reasons Why Granting the Exemption Would Not Adversely Affect Safety 

or How the Exemption Would Provide a Level of Safety That is at Least Equal to 

the Level Provided by the Rule From Which Relief is Sought:

General:

I have been a commercial pilot and flight instructor since 2006 and a rated pilot since 

1998. I have 29 years of experience using the National Airspace System. I also have more 

than 100 hours of UA experience without incident. As is done with manned flight, any 

UA flight should and will be conducted with appropriate consideration to the safety of 

persons, property and other aircraft. This includes the use of a written takeoff checklist, 

regular aircraft maintenance and inspection, reference to weather information, airspace 

maps, aircraft manuals, use of a visual observer, etc. The P2 Multirotor is an octocopter 

with 8 motors. The loss of any one motor will not affect the ability of the aircraft to 

maneuver and land safely. The P2 Multirotor has battery power monitoring telemetry and 

uses an XAircraft SuperX flight controller that has an automated return home feature 

which will land the aircraft safely in the event of loss of the radio control communication 

or GPS link. Furthermore the SuperX is proven as a reliable flight controller and has no 

reported "flyaways" as is the case with some other flight controllers. The P2 Multirotor 

radio transmitter and receiver operate on a 2.4 GHz frequency and utilize frequencyhopping technology, which provides superb protection from potential radio interference. 

In addition the FAA Office of Aviation Policy and Plans has stated (in the Notice of 

Proposed Rulemaking Regulatory Evaluation, Small Unmanned Aircraft Systems 14 CFR 

Part 107, page 17) , “Consequently, once a small UAS aerial photography market 

becomes established, it would increase safety by substituting an unmanned aviation 

operation using a very light aircraft for a more complex manned aviation operation that 

uses a much heavier aircraft. A heavier manned aircraft would pose more risk to the 

public in the event of an accident.”

61.113 (a) Private Pilot Privileges and Limitations:

Although I do not have a commercial power rating I believe the knowledge and skill set 

of my commercial glider and instructor rating (CFIG) to be sufficient for safe commercial 

operation of the P2 Multirotor. I have logged over 500 hours instructor time in gliders 
with over 1300 hours pilot in command. I also hold ASEL and ASES ratings and a third 

class medical certificate.

91.7 (a) Civil Aircraft Airworthiness:

The P2 Multirotor has no airworthiness certificate so no standard exists for airworthiness. 

However, regular airworthiness inspections and maintenance will be carried out, 

including preflight preparation and preflight procedures including a preflight checklist. 

Furthermore, compliance with all operating documents, manufacturers recommendations, 

safety bulletins, and airworthiness inspections will be faithfully carried out by the 

owner/operator in the spirit of the safety considerations of any relevant C.F.R.'s. I have 

maintained, inspected and flown a UA for several years without incident.

91.119 (b) and (c) Minimum Safe Altitudes:

To be useful the P2 Multirotor must be able to fly below 1000 feet above the highest 

obstacle and within a 2000 foot radius. The small size, low weight, tight maneuvering 

capability, vertical takeoff profile, flight controller reliability, motor redundancy and the 

lack of combustible fuel onboard the P2 Multirotor allow for its safe use at lower 

altitudes and in closer proximity to persons and structures than the altitude and distance 

limitations required by 91.119 (b) and (c). 14 C.F.R 91.119 (d) exempts helicopters 

from the limitations of 91.119 (b) and (c). While the P2 Multirotor is not a helicopter

(owing to the fact that it does not have engine-driven rotors), it is a rotorcraft and it is 

intended primarily for hovering. I propose that the P2 Multirotor can operate safely 

within the limitations of 91.119 (d). More specifically I propose (as stated in the P2 

Multirotor Pilot Operating Handbook section 2) that P2 Multirotor “flight operations are 

not allowed while non-participating persons are within 100 feet of the UA unless those 

persons remain in or under structural protection during the flight, or if those persons are 

necessary to the purpose of flight, there is no undue hazard to them and they have been 

given a detailed safety briefing. Nevertheless, all persons shall stand back at least 25 feet 

during takeoff and landing.”

The current standard limitation of a 400 foot AGL maximum altitude for a UA in itself 

does not provide adequate safety. Helicopters regularly fly below 400 feet, and while 

airplanes are theoretically required to fly above 500 feet AGL (except in proximity of an 

airport), it certainly is possible that one will be flying below 400 feet for a variety of 

reasons. The point is that visibility, traffic identification and collision avoidance are 

necessary for safe operation. Safe UA flight requires that the Pilot In Command and/or 

the Visual Observer identify traffic in a timely fashion that will allow the UA to 

effectively maneuver out of the way. See and avoid is the key to safe operation. The 

altitude and flight path of the P2 Multirotor is always constrained by the consideration of 

timely air traffic collision avoidance. The P2 Multirotor will always remain clear of and 

give way to any manned aircraft operations as well as giving way to any other UA or 

hazard deemed to pose a collision threat. Therefore I propose that the P2 Multirotor can 

operate safely to a maximum altitude of 500 feet Above Ground Level or (as stated in the 

P2 Mulitrotor Pilot Operating Handbook section 2), “ Flight altitude shall not exceed 500 

feet AGL”.
91.121 Altimeter Settings:

The most useful and relevant altitude information for any P2 Multirotor flight is the 

height above ground level. The P2 Multirotor has a GPS altimeter which is set to 0 (zero) 

elevation at the takeoff site. The GPS altimeter has a proven accuracy. Concerns 

regarding the altimeter reading should be alleviated by the fact that all P2 Multirotor 

flights are local line-of-sight in a confined area in Visual Meterological Conditions. 

Visibility is paramount and see and avoid is always in play. A Visual Observer is always 

onsite during P2 Multirotor flights to act as a traffic spotter. The AIM 7-2-3 describes 75 

feet as the maximum acceptable error in barometric altimeters. If an airplane were flying 

at 500 feet AGL by reference to a barometric altimeter with a 75 foot error then it may be 

flying as low as 425 feet. Again I state that see and avoid is what provides the element of 

safety.

91.151 (a)(1) Fuel requirements for Flights in VFR Conditions:

The P2 Multirotor carries no fuel as it is an electrically powered aircraft. However, 

adequate power reserves for extended flight in the case of unexpected situations can be 

readily achieved by flight planning and power consumption telemetry such that the return 

to the landing point and the landing will be accomplished with at least 25% battery power 

remaining. 

91.405 (a) Maintenance Required:

Since the P2 Multirotor has no airworthiness certificate the owner/operator will be 

responsible for the maintenance, repairs and alterations of the P2 Multirotor. Such 

maintenance will be carried out in accordance to the manufacturers recommendations and 

in the spirit of the safety considerations of the relevant C.F.R.s. As owner, operator and 

Pilot In Command of the P2 Multirotor it is in my best interest to assess its condition at 

all times and to provide quality service and repairs. I have maintained, inspected and 

flown a UA for four years without incident.

91.407 (a)(1) Operation After Maintenance:

The owner/operator will be responsible for the approval of the aircraft for return to 

service as well as making logbook entries of such approval. As the owner, operator and 

Pilot In Command of the P2 Mulitrotor I am the person most intimately aware of the 

condition of my aircraft. It is in my best interest to track its service and repair history and 

to assess its condition at all times. I have maintained, inspected and flown a UA for four 

years without incident.

91.409 (a)(1) and (2) Inspections:

The owner/operator will be responsible for the inspections and maintenance of the P2 

Multirotor. As the owner, operator and Pilot In Command of the P2 Mulitrotor it is in my 

best interest to assess its condition at regular and frequent intervals. Inspections will be 

made in the spirit of the safety considerations of the relevant C.F.R.'s. I have maintained,

inspected and flown a UA for four years without incident.

91.417 (a)(iii) and (b) Maintenance records:
The owner/operator will be responsible for logging of maintenance, repairs, alterations 

and inspections. The owner/operator will be responsible for the approval of the aircraft 

for return to service. It is in my best interest to track the service and repair history of the 

P2 Multirotor and to assess its condition at all times. I have maintained, inspected and 

flown a UA for four years without incident.

VI. Summary for Public Distribution:

1) I, Jonathan Held, seek relief from the FAR Part 14 Sections listed below so that I may 

legally operate a small Unmanned Aircraft System (sUAS) within the National Airspace 

System for the purpose of high resolution commercial aerial photography and 

videography:

61.113 (a) Private Pilot Privileges and Limitations

91.7 (a) Civil Aircraft Airworthiness

91.119 (b) and (c) Minimum safe altitudes

91.121 Altimeter settings

91.151 (a)(1) Fuel requirements for flights in VFR conditions

91.405 (a) Maintenance required

91.407 (a)(1) Operation after maintenance

91.409 (a)(1) and (2) Inspections

91.417 (a)(iii) and (b) Maintenance records

I am a licensed pilot (ASEL, ASES, Glider) and instructor (CFIG). I have a full 

understanding of the value of aircraft inspection, maintenance and flight safety 

procedures and use of the National Airspace System. Furthermore I have 4 years of 

experience flying an unmanned aircraft (UA). 

The multirotor (hereafter called the P2 Multirotor) for which I seek exemption is a 

custom built vertical take-off system with a maximum gross weight of 32 pounds and 

dimensions of 56 inches in diameter and 20 inches in height. The system is electrically 

powered by Lithium Polymer batteries and has a maximum speed of 40 knots. The P2 

Multirotor incorporates multiple safety measures including an auto land feature in the 

event of a lost communication or GPS link, motor redundancy to assure controlled flight 

in the case of a motor failure, frequency hopping radio technology to prevent control loss 

due to radio interference, telemetry to monitor battery power during flight and the use of 

a robust and reliable flight controller. The P2 Multirotor operation follows safety 

procedures and operating limitations set out in the P2 Multirotor Pilot Operators 

Handbook. An equivalent level of safety has been described for each requested C.F.R. 

exemption and my years of experience using the National Airspace System will provide 

an additional level of safety during flight operations.

2) Description of the Nature of the Exemptions Sought:

The exemptions sought are to allow the use of a UA for commercial purposes (aerial 

photography and videography) without an airworthiness certificate but under the safety 

guidelines set forth by the FAA for UA operation. 
61.113 (a) Private Pilot Privileges and Limitations:

Exemption will allow the private pilot certificate holder to fly the UA commercially. 

91.7 (a) Civil Aircraft Airworthiness:

Exemption will allows the owner/operator to determine the airworthiness of the UA.

91.119 (b) and (c) Minimum safe altitudes:

Exemption will allow the UA to fly closer to structures and persons in certain situations.

91.121 Altimeter settings:

Exemption will allow the UA to use non-standard altimeter settings for the purpose of 

altitude reporting.

91.151 (a)(1) Fuel requirements for flights in VFR conditions:

Exemption allows for the use of reserve battery power rather than reserve gas.

91.405 (a) Maintenance required:

Exemption allows for the UA to be maintained by the owner/operator.

91.407 (a)(1) Operation after maintenance:

Exemption allows for the owner/operator to return the UA to flight service after 

maintenance.

91.409 (a)(1) and (2) Inspections:

Exemption allows for the owner/operator to perform all inspections.

91.417 (a)(iii) and (b) Maintenance records:

Exemption allows for the owner/operator to maintain and authorize all maintenance 

records.

VII. Additional Information

A. P2 Multirotor Pilot Operating Handbook:

The POH includes: XAircraft SuperX Flight Control System User Manual V1.9

XAirfract SuperX OSD Module User Manual

Futaba 8FG Instruction Manual

KDE Direct XF UAS ESC Series Instruction Manual

Gaui 950Q Multirotor Frame Assembly Instruction Manual

Aligh G3-5D 3 Axis Gimbal Instruction Manual

VIII. No flight privileges outside the USA are sought.

Jonathan William Held 119 Loma Alta Drive Oceanside, CA 92054

jon@p2photography.net 858-602-2839 CFIG 3150235