Bryan Pearson

223 Kirkwood Rd. NE

Atlanta, GA 30317

(404) 729-5062

brypearson@gmail.com

Petition for Exemption

Federal Aviation Administration

Re: Unmanned Aircraft System use in NAS for compensation

Petitioner, Bryan Pearson. (“Mr. Pearson”), hereby petitions the Federal Aviation 

Administration (“FAA”) for an exemption from Part 21; §§ 45.23(b); 61.113(a) and (b); 91.7(a); 

91.9(b)(2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a) and (b); 91.405(a); 

91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 

CFR). The proposed exemption, if granted, would allow operation of unmanned aircraft systems 

(UAS) for the purpose residential and commercial real estate, as well as artistic still photography.

Petitioner hereby proposes the following terms and conditions for the grant of the 

exemption requested herein:

The UAS proposed by the petitioner, the DJI Inspire 1 is an unmanned four-rotor, fourmotor “quadcopter” manufactured by DJI. The UAS is under 45 pounds, will be flown at all 

times under 300 feet AGL as measured by the UAS’ on-board GPS system, will be kept within 

line of sight of the Pilot in Command (“PIC”), will have a separate safety Visual Observer

(“VO”) at all times in communication with and within 5 feet of the PIC, will be flown at all times 

at speeds of 20 miles per hour or less, will be flown at all times during daylight hours, always 

using Visual Flight Rules (“VFR”) and within visual line of sight (“VLOS”), and never using 

first person view by the PIC. The PIC will be able to use human vision unaided by any device 

other than corrective lenses as specified by a current state-issued driver’s license. Each PIC will 

have over 100 hours of logged flight experience in the same UAS type or model, including 10 

take offs and landings within the prior 30 days. The PIC will conduct a full and complete 

inspection of aircraft prior to the initial takeoff of each flight.

A precedent has been set for this type of commercial use with this exact type of

UAS. See: Exemption No. 11428, Regulatory Docket No. FAA–2015–0172.

Public Benefit

Regular helicopters are, except as provided in Section 91.119, not allowed to fly less than 

500 feet AGL. UAS on the other hand are best when flown between 50 and 300 feet AGL and in 

fact the best video quality is 50 to 100 feet. A large manned helicopter could also cause very 
serious damage to persons or property on the ground and even to pilots and passengers inside a 

manned helicopter. A UAS weighing in at approximately six pounds would not be nearly as 

hazardous. Additionally, a regular helicopter is normally larger than a standard automobile 

whereas the UAS is smaller than a basketball. It is substantially safer for the public to have a 

UAS accomplish the job of aerial photography than a manned helicopter just based on size alone.

In addition, the UAS can be operated for substantially less costs than a regular manned 

helicopter. The public is significantly served by reducing the cost of videography via UAS 

aircraft.

Proposed Operational Parameters

The PIC will follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements will

be established and identified in the operator’s manual. At a minimum, the following will be 

included in the operator’s manual: 

1. Actuators / Servos 

2. Transmission (single rotor) 

3. Powerplant (motors) 

4. Propellers 

5. Electronic speed controller 

6. Batteries 

7. Mechanical dynamic components (single rotor) 

8. Remote command and control 

9. Ground control station (if used) 

10. Any other components as determined by the operator 

Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft 

will be prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, will be 

included in the preflight inspection. All maintenance and alterations will be properly documented 

in the aircraft records. 

Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics (e.g. replacement of a flight critical component) will undergo a functional 

test flight in accordance with the operator’s manual. The PIC who conducts the functional test 

flight will make an entry in the UAS aircraft records of the flight. The requirements and 

procedures for a functional test flight and aircraft record entry must be added to the operator’s 

manual. 

Prior to operations conducted for the purpose of capturing video, the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of five 

hours as a UAS pilot operating the make and model of UAS to be utilized for operations under 
the exemption and three take-offs and three landings in the preceding 90 days. Training, 

proficiency, experience-building, and take-off and landing currency flights can be conducted 

under this grant of exemption to accomplish the required flight time and 90 day currency. During 

training, proficiency, experience-building, and take-off and landing currency flights all persons 

not essential for flight operations are considered non-participants, and the PIC must operate the 

UA with appropriate distance from non-participants in accordance with 14 CFR § 91.119. 

Prior to operations conducted for the purpose of capturing video (or similar operations), a 

flight demonstration, administered by an operator-approved and qualified pilot must be 

successfully completed and documented. This documentation must be available for review upon 

request by the Administrator. Because the knowledge and airmanship test qualifications have 

been developed by the operator, and there are no established practical test standards that support 

a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the 

petitioner will conduct these tests in accordance with the operator’s manual. 

The UAS will not be operated directly over any person, except authorized and consenting 

production personnel, below an altitude that is hazardous to persons or property on the surface in 

the event of a UAS failure or emergency. 

Regarding distance from non-participating persons, the operator will ensure that no 

persons are allowed within 200 feet of the area except those consenting to be involved and 

necessary for capturing video. This provision may be reduced to no less than 100 feet if it would 

not adversely affect safety and the Administrator has approved it. For example, an equivalent 

level of safety may be determined by an aviation safety inspector’s evaluation of the video

production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers 

may protect non-participating persons (e.g. observers, the public, news media) from debris in the 

event of an accident. This is also consistent with the Order. 

If the UAS loses communications or loses its GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

the operator’s manual. The proposed UAS, the DJI Inspire 1, is designed to increase altitude 20 

meters or 60 feet upon loss of signal between the ground controller held by the pilot and the 

aircraft itself. Upon reaching the higher altitude (a safety feature to avoid people, trees and 

buildings), the UAS will return to its original take-off point of origin and slowly land. It is 

critically important for the pilot to calibrate the aircraft prior to its flight. The calibration 

procedure sets the compass and lets the aircrafts onboard computer know where it is located on 

Earth. The UAS also has a Flytrex black box system installed which tracks every flight so if a 

loss of link to the aircraft from the controller ever occurs, then the pilot can follow and retrieve 

the UAS when it lands. Additional details concerning lost-link failsafes can be found in the 

Operator’s Manual.

The PIC will abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operator’s manual. 

Each UAS operation must be completed within 30 minutes flight time or with 25% 

battery power remaining, whichever occurs first. 
The PIC will request a Notice to Airmen (“NOTAM”) not more than 72 and not less than 

48 hours prior to the operation.

The operator will develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul component 

parts, and the total time in service of the UAS. These procedures will be added to the operator’s 

manual. 

Each UAS operated under this exemption will comply with all manufacturer Safety 

Bulletins. 

The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

The preflight inspection section in the operator’s manual must be amended to include the 

following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight inspection 

sections of the operator’s manual. 

Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (“FCC”) or 

other appropriate government oversight agency requirements. 

The documents required under 14 CFR § 91.9 and § 91.203 will be available to the PIC at 

the ground control station of the UAS any time the aircraft is operating. These documents must 

be made available to the Administrator or any law enforcement official upon request. 

The UAS will remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All 

operations will be conducted under visual meteorological conditions (“VMC”). Flights under 

special visual flight rules (“SVFR”) are not authorized. 

The UAS will be operated by the PIC from any moving device or vehicle. 

The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

The UA will not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA will not operate within 5 nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in accordance with a 
NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to the 

FAA UAS Integration Office (AFS-80) within 24 hours. Such accidents must be reported to the 

National Transportation Safety Board (“NTSB”) per instructions contained on the NTSB Web 

site: www.ntsb.gov. Further flight operations may not be conducted until the incident, accident, 

or transgression is reviewed by AFS-80 and authorization to resume operations is provided. 

Unless otherwise specified in this grant of exemption, the UAS, PIC, and operator must 

comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

The Federal Aviation Administration by and through its authorized representative is 

requested to approve this petition based on the above terms and conditions for a certificate of 

authority and certificate of exemption to operate within the above parameters for compensation 

or hire within the United States National Air Space.

Respectfully submitted:

Bryan Pearson

Atlanta, Georgia