US Department of Transportation Exemption Request Pursuant to Section 333 of 

the FAA 

Reform Act and Part 11 of the Federal Aviation 

December 30, 2015

Ricky Williams

169 Clancy Cir.

Cary, NC 27511

Ric.engineer@gmail.com

U.S Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 

45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR91.9(b)(2); 14 CFR 

91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 

14 CFR 91.203(a) and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 

91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b)

The exemption is in the public interest. Pursuant to the authority contained in 49 

U.S.C. 106(f), 40113, and 44701.

Dear Sir or Madam: 

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

"Reform Act") and 14 CFR Part 11 of Unmanned Aircraft Systems (UAS), Ricky 

Williams hereby applies for an exemption from the listed Federal Aviation 

Regulations ("FARs") to allow commercial operation of Designated UAS, 

provided such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 
Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would provide professional services in the following 

areas:

1. Real Estate

2. Aerial Videography / Photography

3. Weddings

4. Bridge Inspections / Flare Stack Inspections

5. Law Enforcement / Fire Rescue

6. Utility Inspections not to limit, Pipelines / Cell Tower’s

7. Cinematography / Photography 

8. Public / Private Events

9. Construction Sites

10. Search and Rescue

11. News Gathering 

12. Public and Private Awareness to improve safety for currant & future 

UAS operations within the NAS.

13. Special Events

14. Disaster and Catastrophe Events.

On or about Sept 25, 2014 the FAA granted exemptions to six UAS operators, 

including Astraeus Aerial. As set forth in Top Shot’s Flight Operations and 

Procedures Manual (the “FOMP”) and Motion Picture Television Operations 

Manual (both submitted separately under 14 CFR 11. 35 (b), Ricky Williams will 

Adhere to the terms of the Astraeus Exemption. 

Ricky Williams requested exemption would permit the operation of small, 

unmanned UAS under controlled And “sterile” conditions in the “outdoor 

television filming” airspace that is: (1) limited, (2) predetermined, (3) subject to 

controlled access, and (4) provide greater safety in connection with aircraft 

operations in the Outdoor film and television industry. As established by the 

exemptions already granted by the FAA, approval of Ricky Williams

exemption would enhance safety and fulfill the Secretary of Transportation’s (the 

FAA Administrator’s) responsibilities to establish requirements for the safe 

operation of such aircraft systems in the national airspace.

Below is an example how leading film organizations feel about using UAS’s by 

aerial production companies; 

The following is a statement from Neil Fried, Senior Vice President, Government 

and Regulatory Affairs for the Motion Picture Association of America, Inc., 

“Unmanned aerial systems (UAS) offer the motion picture and television industry 

an innovative and safer option for filming. This new tool for storytellers will allow 

for creative and exciting aerial shots, and is the latest in a myriad of new 
technologies being used by our industry to further enhance the viewer 

experience. We welcome the FAA’s leadership and support their guidance to 

safely authorize the use of UASs for the motion picture and television industry.” 

This application is submitted by: 

Ricky Williams

169 Clancy Cir.

Cary, NC 27511

Ric.engineer@gmail.com

Regulations from which the exemption is requested : 

From which the exemption is requested: 14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a)

14 CFR 91.405 (a)

14 CFR 91.407 (a)

14 CFR 91.409 (a)

14 CFR 91.417 (a)

As in Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. 

FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 

11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), 11213 to Aeryon 

Labs, Inc. (see Docket No. FAA−2014−0642), and 12645 to Allied Drones (see 

Docket No. FAA-2014-0804), There is enhanced safety achieved using an 

unmanned aircraft (UA) with the specifications described by the petitioner and 

carrying no passengers or crew, rather than a manned aircraft of significantly 

greater proportions, carrying crew in addition to flammable fuel, gives the FAA 

good cause to find that the UAS operation enabled by this exemption is in the 

public interest. 

Ricky Williams Will operate one or more of the Following model UAS
DJI Inspire 1, 3DR Solo 8X, DYS D800 with the A2 Controller

Safety requirements. The approval of this application presents no national 

security issues. Regarding the level of safety surrounding the proposed 

operations and the public benefit, reduction in environmental impacts, including 

but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly, the applicant graciously requests 

that the FAA grant the requested exemption.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETEY

The operation limitations proposed for an equivalent or higher level of safety 

because operations will further enhance the safety of the persons and/or property 

using conventional aircraft. These limitations and conditions to which the 

applicant agrees to adhere to when conducting commercial operations under the 

FAA issued exemption as set forth in the Flight Operations Manual (FOM) 

include:

1. The UAS will weigh significantly less than 55 lbs. 

2. The UAS, depending on the model in operation, will have a maximum 

operating speed of no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) 

and/or Visual Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS 

model in operation, but will not exceed 30 minutes. Flights will be terminated at 

25% battery power reserve or 30 minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground 

Level (AGL) and not more than 200 feet above an elevated platform from which 

filming is planned. 

6. Minimum crew for each operation will consist of the UAS Pilot and at least one 

Visual Observer (VO).
7. The UAS pilot will be a designated Pilot in Command (PIC) . The PIC will have 

logged a minimum of 20 hours on the designated UAS. 

8. A safety briefing will be performed prior to each day's flights consisting of all 

the days' Production activities. 

9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions 

(VMC) only. 

11. The flights will occur in Class G airspace no closer than a mile radius of the 

geographic center/Airport Reference Point (ARP) of a tower controlled or 

uncontrolled airport. 

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport.

13. The operator will do a pre check of aircraft prior to each flight. And log each 

flight.

14. The operator will obtain verbal/written consent of all persons involved with the 

planned operation and ensure that only consenting persons will be allowed within 

100 feet of the flight operation, and the radius may be reduced to 30 feet based 

upon an equivalent level of safety determination, as U.S. Department of 

Transportation required under the FOM. With the advanced permission of the 

FSDO, operations at closer range may be approved.

15. The PIC and VO will have been trained in operation of UAS and receive up to 

date information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all 

times.

17. The PIC will abide by all rules

18. If the UAS loses communications with the remote controller or loses GPS 

signal, the UAS will have the capability to return to a predetermined

location within a designated location and land autonomously.
19. The UAS will have the capability to abort a flight in case of emergencies with 

an automated "Return Home and Land" function.

20. The UAS will have the capability to abort a flight in case of unpredicted 

obstacles, weather, or emergencies such as low battery.

21. Any incident, accident, or 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's UAS Integration Office (AFS−80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

The operating limitations proposed Ricky Williams provide for a higher level of 

safety because operations further enhance safety of movie and television filming 

operations using conventional aircraft. 

As set forth in the FOPM, the limitations and conditions include: 

The UASs will weigh less than 55 pounds 

Flights will be operated within line of sight of a pilot and observer 

Maximum flight time for each flight will be 30 minutes or at 25% of battery power 

reserve whichever comes first. 

Flights will be operated at an altitude of no more than 400 feet AGL as indicated 

by onboard GPS system. 

Minimum crew for each operation will consist of the UAS pilot, the observer.

A UAS pilot will be Pilot in Command (PIC). 

A UAS pilot will be an FAA licensed airman with at least a private pilot’s 

certificate and third class Medical 

The UAS will only operate within a confined “sterile area” as defined in the 

FOPM. 

The FOPM requires the establishment of a “Security Perimeter” for the flight 

operations area. 

A briefing will be conducted for Planned UAS operations prior to each day’s flight. 

All personnel 
Performing duties within the boundaries of the safety perimeter are required to 

attend. 

The operator will file a FAA Form 7711-1 or its equivalent, as modified in light of 

the requested exemption, with the appropriate Flight Standards District Office. 

The operator will obtain consent of all persons involved in the filming and ensure 

that only Consenting persons will be allowed within 100 feet of the flight 

operation.

The operator will submit a written Plan of Activities to the FSDO three days 

before the proposed shoot as required in the FOPM. 

The Pilot and observer must be trained in UAS operations and received current 

information on the particular UAS to be operated as required by 3 the FOPM. 

The Observer and Pilot will at all times be able to communicate by voice. 

Written and/or oral permission from the relevant property holders will be 

obtained. 

All required permissions and permits will be obtained from territorial, state, 

county, or city Jurisdictions, including local law enforcement, fire or other 

managing governmental agencies. 

If the UAS loses communications or loses its GPS signal, the UAS will and does 

have the capability to return to a pre-determined location within the Security 

Perimeter and land safely. 

The UAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies. 

14 C.F.R. 61.113 (a) and (b): Private Pilot Privileges and Limitations: Pilot in 

Command Sections 61. 113 (a) and (b) limit private pilots to non-commercial 

operations. Because the UAS Will not carry a pilot or passengers, the proposed 

operations can achieve the equivalent level of Safety of current operations by 

requiring the PIC operating the aircraft to have a private pilot’s license

Rather than a commercial pilot’s license to operate a small UAS. Unlike a 

conventional manned aircraft, 

A UAS is remotely controlled by a ground-based operator. The operational area 

is controlled and restricted, and all flights are planned and coordinated in 

advance. The level of safety exceeds that provided by a single individual holding 

a commercial pilot’s certificate operating a conventional aircraft for hire. The risks 

associated with the use of a UAS are so diminished from the level of risk 
associated with commercial operations contemplated by part 61 allowing UAS 

use by a private pilot as PIC exceeds the present level of safety sought by 14 

C.F.R. 61.113 (a) ab (b). 

14 C.F.R. 91.103: Prefight Action 

Section 91.103 requires each Pilot to preflight an aircraft before flight to insure 

the safety of flight. As FAA approved rotorcraft flight manuals will not be used, an 

exemption is requested. However, an equivalent level of safety will be provided. 

The PIC will take actions, including reviewing weather, flight battery 

requirements, landing and takeoff distances, and aircraft performance data 

before each flight. 

14 C.F.R. 91.119 (c) : Minimum Safe Altitudes 

Section 91. 119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 provides, in Pertinent part, that: 

“Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes: ....... 

( c ) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, or structure. “ 

Because Ricky Williams requests authority to operate at altitudes only up to 400 

feet AGL, an exemption is needed to allow such operations. Except for the limited 

conditions stated in the FOPM, the UAS will never operate higher than 400 feet 

AGL. It will, however, be operated in a restricted area within a security perimeter, 

where buildings and people will not be exposed to operations without their preobtained consent. 

The equivalent level of safety will be achieved given the size, weight, and speed 

of the UAS as well as the location where it is operated. No flight will be taken 

without the permission of property owners or local officials. Because of the 

advance notice to the property owners and participants in the filming activity, all 

affected individuals will be informed of the planned flight operations. Compared to 

the flight operations for manned aircraft and the lack of flammable fuel, any risk 

associated with the proposed UAS operations is far less than conventional 

aircraft operating at or below 500 feet AGL.

In addition, the low-altitude operations of the UAS will ensure separation between 

a UAS and conventional aircraft. 
14 C.F.R 91.121 Altimeter Settings 

Section 91.121 requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “... to an elevation of the departure 

airport or an appropriate altimeter setting available before departure.” As a UAS 

may not have a barometric altimeter, but instead a GPS altitude data, an 

exemption is needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the FOPM and Safety Check list, confirming the altitude of 

the launch site shown on the GPS altitude indicator before flight. 

14 C.F.R. 91.151 (a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 

under VFR conditions unless (considering wind and forecast weather conditions) 

there is enough fuel to fly to the first point of intended landing, and, assuming 

normal cruising speed- (1) During the day, to fly after that for at least 30 minutes 

......” 

The battery powering the Ricky Williams UASs provides approximately 20 

minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR 

91.151, UAS flights will be limited to approximately 10 minutes in length. Given 

the limitations on the UAS’s proposed flight area and its proposed flight area and 

proposed operations within a predetermined location, a longer time frame for 

flight in daylight VFR conditions is reasonable. Furthermore, operating the UASs 

in a tightly controlled area where only people, property owners, or official 

representatives who have signed waivers will be allowed, less than 30 minutes of 

reserve fuel does not engender the type of risk that 91.151 was intended to 

address. The owner/operator of Ricky Williams believes that safety can be 

achieved by limiting flights to end with a 25% battery reserve as indicated on the 

PIC’s controller mounted monitor. This restriction would be more than adequate 

to return the UAS to its predetermined landing area. 

14 C.F.R. 91.405 (a) (1); 407 (a) (1); 409 (a) (2); 417 (a) and (b): 

Maintenance Inspections 

These regulations require that an aircraft operator or owner shall “have that 

aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter.....,” and others 

shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections. Maintenance will be accomplished by the operator. An 
equivalent level of safety will be achieved because the UASs are limited in size, 

will carry a small payload and operate only in restricted areas for limited periods 

of time. If mechanical issues arise, the UAS can land immediately and will be 

operating from no higher than 400 feet AGL. 

As provided in the FOPM, the operator will ensure that the UAS is in working 

order prior to flight, perform any required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with 

the UAS and best suited to maintain it in an airworthy condition. 

14 C.F.R. 91.203 (A) and (B); 91.715 Airworthiness certificates 

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil 

aircraft unless it has within it (1) an appropriate and current airworthiness 

certificate; and (2) an effective U.S. registration certificate issued to its owner or, 

for operation within the United States, the second copy of the Aircraft 

Registration Application as provided for in § 47.31(c). Section 91.203(b) 

prescribes, in pertinent part, that no person may operate a civil aircraft unless the 

airworthiness certificate or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

A UAS has no certificate nor does it have a cockpit door, Jonathan Russell Sorli 

is requesting an exemption from 91.203 (a) and (b) also 91.715.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the Federal Register, should it be determined that publication is needed: Ricky 

Williams seeks an exemption from the following rules: 

14 C.F.R. §§ 61.113(a) and (b); 91.103; 91.119(c); 91.121; 91.151(a); 91.405(a); 

91.407(a)(1); 91.409(a)(2); and 91.417(a) and (b); 91.203 (a) and (b); 91.715 to 

operate commercially a small unmanned vehicle (55 pounds or less) in motion 

picture and television operations. 

As established by the UAS exemptions already granted by the FAA, allowing 

commercial operations of UASs in the film industry will enhance safety by 

reducing risk. Conventional film operations, using turbine aircraft, operate at low 

altitudes and present the risks associated with aircraft that weigh around 4,000 

pounds, and which carry large amounts of Jet A fuel. Such aircraft must also fly 

to and from the film location. In contrast, a UAS weighing fewer than 55 pounds 

and powered by batteries eliminates virtually all of that risk given the small size 

and lack of combustible fuel. The UAS is carried, and not flown, to a film set. In 
this regard, the UAS carries no passengers or crew and, therefore, will not 

expose them to the risks associated with manned flights. 

The operation of UASs conducted in the strict conditions outlined in the FOPM 

will provide an equivalent level of safety supporting the grant of the exemption 

requested herein. The UASs operate at slow speeds, close to the ground, and in 

a sterile environment. UAS’s also have far less impact on the environment 

compared to normal filming practices it replaces. As a result, they are far safer 

than

conventional operations conducted with turbine helicopters flying near the ground 

and people. 

Privacy 

All flights will occur over private or controlled access areas with the property 

owner’s prior consent and knowledge. Filming will be only of people who have 

given their consent or otherwise have agreed to be in the area where filming will 

take place. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 

(size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of sight and national security) provide more 

than adequate justification to grant Ricky Williams requested exemption.

If you have any questions or need any additional information,

Ricky Williams

169 Clancy Cir.

Cary, NC 27511

Ric.engineer@gmail.com

Sincerely yours, 

Ricky Williams