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Ashton	M.	Onesko

Prestige	Pro	Photo

2082	Aurora	Avenue

Lewis	Center,	OH		43035

(Office)	614-330-8295

June	8,	2015

U.S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Avenue

SE	Washington,	DC		20590

Subject:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations	from	14	C.F.R.	Part	21,	45.27(a),	45.29	

(3)(c)(d)(e)(f)(g)(h),	61.113	(a)	&	(b),	91.103,	91.119,	91.121,	91.203,	91.151

Following	the	format	of	FAA	Exemption	No.	11138-Regulatory	Docket	No.	FAA2014-0481	I	have	included:

1) Supplemental	Response	with	Petition

-Inspire	1	Quick	Start	Manual	v.1.7

2) DJI	Inspire	1 User	Manual

3) Personal	protocols	and	controls-Safety/Flight	concerns

Pursuant	to	Section	333	of	the	FAA	Modernization and	Reform	Act	of	2012	and	14	

C.F.R.	Part	11,	I,	Ashton	Onesko,	a	drone	hobbyist,	preparing	this	exemption	request	

for	myself,	would	like	to	apply	for	an	exemption	from	the	following	Code	of	Federal	

Regulations	(C.F.R.)	to	be	allowed	commercial	operation	of	lightweight	Unmanned	

Aircraft	Systems	(UAS)	for	aerial	imaging	and	videos	for	sale	of	real	estate	in	Ohio	

and	surrounding	areas.

I	have	experience	in	flying	hobby	quads	for	recreational	purposes	during	the	past	2	

years	without	incident.				I	have	added a	hobby	grade	Dji	Inspire	1 quad-copter	

(maximum	gross	weight	6.4	pounds,	equipped	with	four	rotors	that	are	driven	by	

electric	motors	powered	by	batteries,	the	UAS	has	a	maximum	airspeed	of	42 knots)	

to	my	inventory equipped	with	a	Inspire	1	gimbal with	intent	for	aerial	

videography/cinematography	to	enhance	academic	community	awareness	and	

augment	real	estate	listing	videos;	following	an	exemption	and	approval	by	the	FAA.		

My	exemption	request	would	permit	operation	of	ultra-light	weight,	unmanned	

(piloted	by	remote	control)	in	predetermined	areas	away	from	general	public,	

airports,	heliports	and	vehicular	traffic,	under	200	ft.	and	after	carefully	reviewing,	

inspecting	and	examining	the	area	of	aerial	observation.		This	would	allow	for	

community	videos and	within	property	boundaries	for	individual	homeowner	real	

estate	listing	videos/photos.		I	will	abide	by	all	FAA	requirements	to	ensure	this	

exemption	will	provide	a	level	of	safety	at	least	equal	to	existing	rules	and	will	only	
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operate	in	a	safe	environment	that	is	strictly	controlled,	is	away	from	power	lines,	

elevated	lights,	airports	and	actively	populated	areas;	and	I	will	conduct	extensive	

preflight	inspections	and	protocols,	during	which	safety	carries	primary	importance.		

14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	CF§ 91.203

Given	the	size,	weight,	speed,	and	limited	operating	area	associated	with	the	aircraft	

to	be	utilized,	I	am	asking	exemption	from	14CFRpart21,	Subpart	H	(Airworthiness	

Certificates)	and	§ 91.203	(a)	and	(b)	(Certifications	required),	subject	to	certain	

conditions	and	limitations,	is	warranted	and	meets	the	requirements	for	an	

equivalent	level	of	safety	under	14CFR	part	11	and	Section	333	of	P.L.	112-95	

(Section	333).

14	C.F.R.	45.27(a):	Location	of	marks;	non	fixed-wing	aircraft.			14	C.F.R.	45.29	(3)	

(c)(d)(e)(f)(h):	Size	of	Marks

Furthermore,	I	request	an	exemption	from	§ 45.23	Marking	of	the	aircraft	because	

my	UAS	will	not	have	a	cabin,	cockpit	or	pilot	station	on	which	to	mark	certain	

words	or	phrases.		Additionally,	two-inch	lettering	is	difficult	to	place	on	such	a	

small	aircraft	with	dimensions	smaller	than	the	minimal	lettering	requirement.		I	

understand	the	need	for	marking	and	will	mark	my	UAS	in	the	largest	possible	

lettering	by	placing	the	word	“Experimental”	or	assigned	number	or	name	(based	on	

a	request	or	ruling	by	the	FAA)	on	is	fuselage	as	required	by	§ 45.29(f)	so	that	

anyone	assisting	me	as	a	spotter	will	see	the	markings.

I	also	ask	for	an	exemption	from	§ 91.405(a),	91.407(a)(1),	91.409(a)(2)	and	

91.417(a)	and	(b)	Maintenance	inspections	may	be	required	and	should	be	granted	

since	they	only	apply	to	aircraft	with	an	airworthiness	certificate.		But,	as	a	safety	

precaution	I	will	perform	a	preflight	inspection	of	my	UAS	before	each	flight	as	

outlined	in	my	operating	documents.

14	CFR	61.113	(a)	&	(b):	Private	pilot	privileges	and	limitations:		Pilot	in	command.

Under	§ 61.113	(a)	and	(b)	private	pilots	are	limited	to	non-commercial	operations,	

however,	I	can	achieve	an	equivalent	level of	safety	as	achieved	by	current	

regulations	because	my	UAS	does	not	carry	any	pilots	or	passengers.		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	part61,	et	seq.,	I	requests	an	exemption	from	§ 61.113	Private	Pilot	

Privileges	and	Limitations.

Regarding	UAS	operational	training,	as	stated	previously,	I	have	two	years	

experience	flying	numerous	practice	flights	in	remote	areas	as	a	hobbyist	simulating	

flights	for	future	commercial	use	to	gain	familiarization	with	the	characteristics	of	

my	UAS	performance	under	different	temperature	and	weather	conditions.		I	also	
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own	and	practice	on	a	computerized	simulated	flight	software	to	maintain	adequate	

skills	and	response	reflex	time.	

14	C.F.R. 91.103	(b)(1),	(b)(2):	Preflight	Action

If	granted	an	exemption	I	agree	to	additional	safety	procedures	including,	but	not	

limited	to:

1) Keeping	my	UAS	within	a	radius	distance	of	1000	from	the	controller	to	both	

aid	in	direct	line	of	sight	visual	observation.

2) Operate	the	UAS	for	3-7	minutes	per	flight;	land	my	UAS	according	to	the	

manufacturer’s	recommended	minimum	level	of	battery	power.

3) Operate	my	UAS	only	within	visual line	of	sight	(VLOS).

4) Use	the	UAS’	global	positioning	system	(GPS)	flight	safety	feature;	it	hovers	and	

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

5) Conduct	all	operations	under	my	own	personal	and	flight	safety	protocols	

(including)	posting	a	warning	sign	reading:		“Attention	Aerial	Photography	in	

Progress-Remain	Back	150”).

6) I	will	operate	and	will	actively	analyze	flight	data	and	other	sources	of	

information	to	constantly	update	and	enhance	my	safety	protocols.

7) Contact	respective	airports	if	operations	will	be	within	5	miles	to	advise	them	

of	my	estimated	flight	time,	flight	duration,	elevation	of	flight	and	other	

pertinent	information.

8) Always	obtain	all	necessary	permissions	prior	to	operation.

9) Have	procedures	in	place	to	abort	flights	in	the	event	of	safety	breaches	or	

potential	danger.

Aerial	videography	for	geographical	awareness	of	real	estate	marketing	has	been	

around	for	a	long	time	through	manned	fixed	winged	aircraft	and	helicopters,	but	

for	small	business	owners,	its	expense	has	been	cost-prohibitive.			Granting	this	

exemption	would	allow	me	to	provide	this	service	at	a	much	lower	cost.		Further,	my	

small	UAS,	when	used	properly,	will	pose	no	threat	to	the	public	given	its	small	size	

and	lack	of	combustible	fuel	when	compared	to	larger	manned	aircraft.		The	

operation	of	my	UAS	will	minimize	ecological	damage	and	promote	economic	

growth	by	providing	information	to	companies	looking	to	relocate	or	build	in	the	

Ohio	area.

One	final	comment,	the	use	of	a	UAS	has	already	proven	to	increase	the	

marketability	of	a	home.		For	example	please	review	the	article	published	January	7,	

2015	in	the	San	Diego	source	entitled	“Drone	use	in	real	estate	may	increase:,	(also	

added	as	an	attachment).		The	article	cites	the	FAA’s	exemption	given	to	Douglas	

Trudeau,	but	also	describes	a	record	high	price	for	an	area	home	that	used	a	drone	

for	aerial	photography		.”				I	think	it’s	important	to	point	out	that	the	use	of	any	tool	

that	increases	value	to	a	home	or	community	(by	adding	visibility to	more	potential	

buyers)	is	in	the	best	interest	of	homeowners	nationwide.		Selling	a	home	faster	and	

for	more	money	because	of	the	use	of	new	technology	(being	safely	used	and	

approved	by	the	FAA)	will	go	a	long	way	to	ensure	our	economy	continues	to	grow.
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