September 20, 2015

Exemption request under section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations.

To Whom Is May Concern: 

I request an exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405, 91.407(a)!1), 

91.409(a)(2), and 91.417(a( and (b) of Title 14, Code of Federal Regulations (14CFR) as was 

granted in Exemption Numbers 11138, 11395, 11428 and 11434. 

I will operate a DJI Inspire 1, a UAS weighing less than 7 pounds at take off, and will take photos 

and videos using the onboard camera. The operations performed by myself with the UAS will 

include but not be limited to real estate photography, both commercial and residential, 

surveying land, insurance inspections, event coverage, and artistic photos. The use of the UAS 

reduces the need for conventional aircraft in populated areas and will allow photos and videos 

to be much more safely. 

Operations under this exemption will be conducted as outlined in the proposed rule set in 

motion on February 23rd 2015 in docket FAA-2015-0150. 

Operational Limitations: 

 Visual line-of-sight (VLOS) only: the aircraft must remain within VLSO of the operator of 

visual observer. 

 At all times the small unmanned aircraft must remain close enough to the operator for 

the operators to be capable of seeing the aircraft with vision unaided by any device 

other than corrective lenses. 

 Aircraft may not operate over any persons not directly involved in the operation. 

 Daylight only operations. 

 Must yield right-of-way to other aircraft, manned or unmanned. 

 May use visual observer (VO) but not required. 

 First-person view camera cannot satisfy “see-and-avoid” requirement but can be used 

as long as requirement is satisfied other ways. 

 Maximum airspeed 100 mph (87 kts). 

 Maximum altitude of 500 feet above ground level. 

 Minimum weather visibility of 3 statute miles from control station. 

 No operations are allowed in Class A airspace (18,000 feet and above).

 Operations in class B, C, D and E airspace are allowed with the required ATC permission. 

 Operations in Class G airspace are allowed without ATC permission. 

 No person my act as operator or visual observer for more than one aircraft at one time. 

 No Careless of reckless operations are allowed. 

 Requires preflight inspection by the operator. 

 No person may operate the UAS if he or she knows or has reason to know of any 

physical or mental condition that would interfere with the safe operation of the aircraft. 

I request an exemption from 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) 

Maintenance Inspections since they only apply to aircraft with an airworthiness certificate. 
However, I will perform a pre-flight inspection of the UAS before each flight as outlined in the 

operating documents. 

I request exemption from 91.151. The Pilot in Command will abide by the following personal 

protocols and controls: 

 Operator will only operate in reasonably safe environments that are strictly controlled, 

are away from power lines, elevated lights and airports. Operator will conduct extensive 

preflight inspections and protocols as outlines in the operating documents. 

 Operate the UAS below 500 feet and within a radius distance of 1500 feet from the 

controller and within visual line of sight. 

 Land the UAS before the manufacturer’s recommended minimum battery level. 

 Use the UAS’ GPS flight safety feature whereby the aircraft raises to a predetermined 

safe altitude and then returns to the point of take off in the event of loss of 

communication with the operator. 

 Contact respective airports and/or Fight Standard District Offices if operations will be 

within 5 miles to advise them of my estimated flight time, flight operation, elevation of 

flight and other pertinent information. 

 Have procedures in place to abort flights in the event of safety breaches of potential 

danger. 

91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that 

since there is currently no certificate applicable to my operation, this regulation is inapplicable. 

91.119 prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be 

operated at lower altitudes in certain conditions. Operator will not operate the UAS above the 

altitude of 500 feet above ground level and will also only operate in safe areas away from the 

public and traffic, thus providing a level of safety at least equivalent to those in relation to 

minimum safe altitudes. 

91.121 Altimeter Settings is inapplicable since my UAS utilizes electronic GPS with a barometer 

sensor. 

This exemption is in the public interest:

The uses in which I plan on using this aircraft would normally require some other type of 

human and or other manned aircraft to complete, thus either unnecessarily 

endangering the safety of a person or causing undue cost. 

Specifically:

 Land surveying: Flying over a track of land at a low elevation is less safe in 

conventional aircraft. This will allow the surveying industry to see up to date 

images at a lower cost and better resolution than hiring a conventional aircraft, 

or looking at out of date satellite imagery. Thus lowering operation costs that 

need to be passed on to the consumer.
 Insurance claim investigation: In 2006 a State Farm independent contractor was 

killed while inspecting a damaged roof. Since then more and more insurance 

companies have been relying on independent contractors to inspect damages. 

With this technology we can eliminate the need to put people in these 

dangerous situations. I have the ability to fly above a damaged structure, take 

high resolution images to be reviewed by a qualified claims adjuster back in the 

safety of their office with real time feeds via the internet, or on site looking a 

separate display and taking the pictures they need. Not only does this impact 

the safety of the job but will have a huge impact on unneeded insurance claims 

resulting in fewer fraudulent claims by independent contractors that are not 

looking out for the greater good of the public and just out to take advantage of 

a natural incident to take advantage of the insurance company. With all of these

factors this will help lower the insurance premiums to millions.

 Real estate photography: The ability to see properties from vantage points 

unobtainable by the normal home buyer, such as roof inspections, viewing large 

properties from above without relying on out of date satellite images. With this 

powerful tool we can get real time images and get them into the purchasers’ 

hands so they can make a complete informed decision, resulting in fewer 

complications from incomplete disclosure.

As you can see the benefits of my intended uses are looking out for the greater good of the 

public. All flights would be made with home/property owner approval.

Robert Boyle