Sept 22, 2015

Petitioner: 

Vernon Shurtz

512 3rd St

Spencer, NC 28159

843-619-1347

Email: vern.shurtz@gmail.com

Dear Sir or Madam, 

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

Act) and 14 C.F.R. Part 11.81, Vernon Shurtz, hereby applies for an exemption from the 

listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small, 

unmanned aircraft for photogrammetry, photography/cinematography, industrial 

inspections, search & rescue, and analyses. All operations shall be conducted within and 

under the conditions and limitations outlined previously by the FAA as required by 

Section 333 and conducted in compliance with the attached operator’s manuals.

1. Sections from which exemptions are sought: Application is hereby made for 

exemption from: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFT Part 91:

i.91.103(b)(2)

ii.91.105

iii.91.109

iv.91.119

v.91.121

vi.91.151

vii.91.405

viii.91.407

ix.91.409

x.91.417

2. Relief sought:

a. Vernon Shurtz wishes to operate small Unmanned Aircraft Systems (sUAS) 

for commercial purposes to include (but not be limited to) photogrammetry, 

photography/cinematography, industrial inspections, search & rescue, and 

analyses. This relief is sought because commercial use of sUAS is currently 

prohibited by law unless performed under an exemption.
b. This exemption will cover use of the following commercially available 

airframes, all of which will weigh less than 55 pounds including payload and 

energy sources:

i. DJI Phantom 2 Vision+

ii. DJI Phantom 3 (Standard/Advanced/Professional)

iii. DJI Inspire 1

iv. 3D Robotics Solo

3. Public benefit:

a. Use of sUAS technology to obtain imagery, information and data currently 

obtained by use of manned flight or manual methods:

i. Reduces statistical risk to human life due to manned aircraft 

accidents (e.g., infrastructure inspections) and due to other 

dangerous activities that can be avoided (e.g., scaffolding/rigging 

failures during stack or bridge inspections).

ii. Reduces the cost of obtaining such information, which benefits 

consumers and the economy.

iii. Reduces environmental impact by eliminating sources of 

hydrocarbon emissions from manned aircraft.

4. Safety not adversely affected:

a. Aircraft will be registered and marked in accordance with Section 44711 and 

Part 47 and Part 45, Subpart C.

b. Aircraft will comply with maintenance and inspection requirements of the 

manufacturer. All repair and maintenance work will be conducted or approved 

by qualified personnel such as those authorized by DJI/3D Robotics (or 

equivalent), and will require a test flight after such work. Records of all 

maintenance and repair work will be kept in a maintenance log for each 

aircraft.

c. All operations will be conducted in accordance with valid Certificates of 

Authorization.

d. All flight operations will comply with the following:

i. The manufacturers’ user manuals.

ii. Flight Operations and Procedures Manual (FOPM) and Aircraft 

Flight Manuals (AFM), which include lost communication and 

other emergency and safety procedures. 

iii. Conducted in VMC conditions during daylight hours.

iv. PIC will maintain VLOS at all times.

v. Pre-flight inspections (including ground control station, if any) and 

safety risk assessments will be conducted prior to each flight.

vi. Flight altitudes will remain below 400 feet above ground level. 

vii. Flight ground speeds will not exceed 50 knots
viii. Not intrude into Class B, C or D airspace, or published approach, 

SID or STAR, or take place within 5 nautical miles of an airport.

ix. Not be made near persons as required in 14 CFR 91.119 and not 

over persons on the ground without their prior permission.

x. Each flight will be logged in both the PIC’s logbook and the 

aircraft logbook.

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 30 

minutes, whichever occurs first.

xii. Any incidents will be reported within 24 hours of occurrence. 

xiii. Any applicable local FSDO requirements.

xiv. All other applicable regulations concerned with the operation of 

aircraft.

e. Aircraft will use FCC compliant 2.4 GHz for command & control of the 

aircraft with well-defined and tested lost link procedures. 

Please advise of any additional information or changes that may be required.

Sincerely, 

Vernon Shurtz