Jonathan Troy Ward

FAA 3138087 license

2735 Kantian Drive 

Columbus, Ohio 43219

jonathantroyward@gmail.com

Petition for exemption/rulemaking for operating UAV

I would like to seek a 333 exemption for operating a UAV under 55lbs. My intentions are to use the exemption for 

commercial purposes under 200 feet for aerial videography and photography. Additionally, I would like your consideration 

for approval outside the US for instances of international shots and approval to operate within and under class B and C 

airspaces with tower approvals. By seeking this relief, I will be able to maintain my livelihood after the surrendering of my 

medical certificate due to new regulations in March of 2015. I have experience doing aerial photography and videography 

from aircraft and would eventually like to acquire several UAV’s with different characteristics under this application. I 

recognize that I may be limited to the blanket exemption initially with a need to further request through separate channels 

after this acceptance.

I believe that within this industry, trained pilots could offer vast input to the FAA for recommendations in this 

emerging field and I could position myself and my training background to help educate non pilot UAV operators about 

operations within the airspace system. Additionally, I feel (just like numerous others) that this is an emerging market 

where oversite is necessary and feel that I can offer a margin of safety that will benefit clients. 

I believe that in most cases, operating a UAV (even within a 5 mile radius of a towered airport) can be safe. For the 

majority of the aerial photography and videography shoots can be done around 100 feet and in many cases under 50 feet 

(which would make it like a football being punted or a golf ball or baseball with way more control) and with an awareness 

of instrument approaches, basic pilot operations within these airspaces and working with airspace controllers, the public 

and businesses within these airspaces may be serviced also at an altitude that is lower than most kites. I find this 

especially necessary as my house falls within this limit and it is directly north of east/west runways by a few miles. This 

rule prevents me from even flying at low altitudes around my house below my tree line where kids are throwing objects 

higher than this UAV.

Also, in some cases when I deem necessary for the video footage for a contract required and with proper planning 

on my part, allow to operate after Sunset at my discretion with proper planning and safety procedures which may consist, 

but not limited to the programming of the intended flight path during daylight operations to execute at night. With the 

capabilities of these drones, the autoflight modes with ability for the pilot to take over and remarkable hovering abilities, 

night time operations by skilled operators will not reduce safety.

Utilizing my CFI, I would request that this waiver is for others being trained under my supervision and ability to 

release them with a minimum of 25 hours of UAV operation hours to operate under my waiver for business growth.

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en_0915.pdf

The DJI Phantom 3 user manual with instructions on preflight and operations is in the link above. The automatic functions 

manual is in development although there are wiki explanations out there for straight forward explanations to go along with 

the intuitive app designed for this function. 

SUMMARY OF REQUEST:

Seek a “blanket” 200-foot COA with the ability to operate inside the restricted airport areas with approval from local 

airspace controllers. Seek exemption to exercise this privilege outside the United States only with knowledge that ICAO 

and other foreign governments may restrict operations. Additionally, the ability to fly in open International waters in case 

filming becomes necessary there in the future. Ability to gain approval for operating above 200 feet on a case by case 
basis by communicating directly with local FSDO or local airspace controllers and in the event there is no local airspace 

control over the intended area, the ability to fly to 400 feet. 

These requests are for the ability to start up and operate a business with minimal interference. In the majority of 

flights I will be seeking, the only one that I would like to make permanent would be the flying under the class C at KCMH 

to have a permanent exemption to state allowed to fly under 150 feet outside the airport boundary fences and 1500’ north 

or south outside the extended centerlines of the runways. All other instances requires FSDO approval on a case by case 

basis. There are several building and business projects in these areas that can benefit from aerial videography services 

and it allows me to operate my UAV at my house approximately 3 miles north of the field at altitudes lower than a kite and 

in most cases- tree lines.

Ability to fly during night when required by job and/or deemed safe by myself.

Because I will only be operating one UAV at a time beginning with the DJI Phantom 3, I seek that when requesting 

individual exemptions, it will work for any of the future drones under the 55 pound category for the time of the exemption.

I seek a civil airworthiness certificate and register the DJI Phantom 3 for operation.

Sincerely,

Jonathan Troy Ward