John P Creed

8009 Cooke Rd

Elkins Park, Pa. 19027

July 11, 2015

US Department of Transportation

Docket Management Facility

West Building Ground Floor

1200 New Jersey Avenue, S.E.

Washington, D.C. 20590

To whom it may concern,

In response to your letter for the request for additional information, dated July 1, 2015, I have prepared this 

document in the hope that I have supplied the items you have asked for in order to grant me an exemption to 

operate UAS’s for aerial data collection.

I seek relief and/or Exemption of Section 333 of the FAA Reform Act and part 11 of the Federal Aviation 

Regulations from 14 C.F.R. Part 21 Subpart H ,§§ 45.23, 45.27 (a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.23 (a)(c), 

61.113 (a)(b), 91.7, 91.9, 91.103, 91.105, 91.107, 91.109, 91.119 (c), 91.121, 91.151 (a) (1), 91.405 (a), 

91.407 (a) (1), 91.409 (a) (1) & (2), 91.417 (a) & (b) 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, I am

personally preparing this document to request exemption from the above mentioned items to allow for the 

operation of a small lightweight Unmanned Aircraft Systems s (UAS) for use as a video and still imaging, data 

collection and inspection tool for my business in Home Improvements and Media services. I seek relief 

because existing regulations would be an unnecessary burden to my business and the exemption would be in 

the public interest.

The FAA has the authority to grant exemptions from operating rules and regulations and the Secretary of 

Transportation has this authority based on section 333 of Public Law 112-95 in reference to the operation of 

UAS.

Exemptions sought from 14 CFR:

Part 21 Subpart H

This regulation requires the issuance of an Airworthiness Certificate for an aircraft operating in the National 

Air Space (NAS). The fact that my s(UAS) craft will operate in limited capacity and area and at a height no 

greater than 400 feet AGL, this situation meets the requirement of an equivalent level of safety under Part 11 

and section 333 of the Reform Act. Since the FAA has the authorization to grant exemptions based on the 

size, weight, speed, capabilities and proximity to airports and populated areas and given these criteria in 

relations to larger, manned aircraft, it is clear that the UAS will operate with a safety level greater than 

conventional aircraft.

Part 45 Identification and Registration Markings

§§ 45.23, 45.27 (a), 45.29 (3) (c)(d)(e)(f)(g)(h)
July 11, 2015

Page 2

With an exemption granted and given the size and operational restrictions for the UAS, an Airworthiness 

Certificate would not be required as (1) No ample space for registration markings and (2) no cabin or fuselage 

exists and the craft would not carry passengers or fuel and (3) the UAS is not a fix winged craft or rotorcraft 

§that meets size requirements.

Part 61 Medical Certificates

§§ 61.113 (a)(b), 61.23 (a)(c)

These regulations require pilots of manned aircraft to hold a medical certificate. Also private pilot privileges 

or Pilot in Command (PIC), limit private pilots to non-commercial operations. Since the UAS, given the size , 

weight and limitations, would not be carrying fuel or passengers and therefor would pose a decreased threat 

level as compared to manned aircraft. Based on these facts that the UAS will operate in a limited airspace, at 

minimal speeds less than 87 knots and 400 feet AGL (above ground level) or less and in non-congested 

airspace or near any airports the craft can safely be operated without a commercial pilots license.

Part 91 General Operating and Flight Rules

§§ 91.105, 91.107

Since the UAS is a small craft that does not carry or need a crew, passengers or have a cabin these rules 

would not be applicable.

§ 91.109 Flight Instruction

This rule states that no person can operate a civil aircraft that is utilized for flight instruction without the 

presence of dual controls. Since the UAS is not piloted and does not carry passengers flight instruction would 

not take place and is not possible. The craft is operated remotely by a hand held radio frequency control unit 

by a single person with a spotter and visual guide on ground level. This situation makes the operation of the

UAS at a far greater level of safety than conventional manned aircraft.

§§ 91.119 (c), 91.121, 91.151 (a) Minimal Safe Altitudes; Altimeter Settings; Fuel Requirements for Flight in 

VFR Conditions

Since the UAS will operate at a height no greater than 400 feet AGL, does not have an altimeter ( height and 

range of craft are regulated by GPS from ground control unit) and does not carry fuel and can only operate 

during daylight hours with VLOS (Visual Line of Sight) these regulations would not be applicable. Given the 

fact that the UAS does not carry fuel and is battery operated with a maximum flight time of 25 minutes a 30 

minute additional fuel capacity past destination point would not apply and since it would not fly in 

commercial air space it would not follow conventional aircraft VFR conditions.

§§ 91.405 (a), 91.407 (a) (1), 91.409 (a) (1)(2), 91.417 (a)(b) Maintenance Required; Operation After 

Maintenance; Inspections; Maintenance Records

This regulation would require maintenance of conventional aircraft to meet stipulations pertaining to Part 43. 

Since these apply to aircraft with an Air Worthiness Certificate it would not apply to the UAS. Maintenance 

would be performed as needed after inspections prior to and directly after each flight and as suggested by 

the manufacturer. Given the fact that the UAS would not be carrying a payload (other than camera) is 

lightweight and carries no fuel (battery powered) and has far fewer working parts than commercial aircraft, 

maintenance is minimal and can be done much safer. 
July 11, 2015

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National Security, Serving the Public Interest and Public Safety

It is for the greater good to the public, as a whole, to allow for the operation of small UAS for data collection, 

video and still imagery and inspections. Current standards and practices used for these actions involve the 

use of larger and more conventional manned aircraft which carry fuel and a larger payload and if mechanical 

failure were to occur would pose a greater threat to the public than UAS’s. It is also common knowledge that 

the use of ladders and other items for inspections have led to countless injuries and accidents that could 

have been avoided with the assistance of UAS’s. By utilizing UAS for these actions and data gathering it best 

serves The Public Interest by reducing injuries and accident and would also assist in lowering of liability and 

insurance claims and Hospital visits. A greater item that both serves the public interest and public safety is 

the fact that the UAS’s leave a small carbon footprint and has no harmful emissions and thus helps protect 

the environment and the public well-being. UAS’s will be operated in a controlled environment. In limited 

space, away from the general public, on private property with the client signing an agreement to proceed 

with the use of the UAS on his or her property. It will be safely operated at an altitude not to exceed 400 feet 

AGL (Above Ground Level) with a PIC and visual spotter at all times. It will be operated in fair weather 

conditions and only during daylight hours. The UAS has a maximum flight time of 25 minutes and no flight 

would exceed 20 minutes or with 25% remaining battery life (battery life is monitored remotely for every 

flight). The UAS will not be operated in the NAS of commercial flight paths nor will it operate near or around 

any airport, thus poses no threat to National Security. Because the UAS will be flown at low altitudes and low 

speeds and is lightweight and carries no fuel or payload or passengers the situation commands a far greater 

level of safety than commercial craft and thus serves Public Safety.

Safe Operation of UAS’s

Proper preparation and thought went into a procedural plan to operate UAS’s safely and efficiently to be 

utilized for data collection. Steps and protocols will be adhered to at all times. No operation will involve a 

threat to public safety or National Security. No operation will take place if proximity to the public is too close 

and will be cancelled or rescheduled to a time where there will be no safety issues. Everyone will be trained 

to be operators and visual spotters so that everyone has the knowledge to operate and safely bring down the 

UAS if any problems should occur. All operators will train with flight simulators and General Aviation 

knowledge to understand pitch, yaw and attitude of craft so as to better understand technical data and the 

standards of flight. No operation will commence unless a 2 person team is on site. All operations will be done 

at a height of no greater than 400 feet AGL, at low speeds less than 30 knots, with a PIC and visual spotter 

and the craft will have VLOS (Visual Line of Sight) at all times. Because the UAS is the DJI Phantom 2+ it has a 

“return home” feature that will safely return the craft to its lift off point should any problem occur. Another 

safety feature of the UAS is that when the remote control device is not engaged the craft will hover until it is 

directed to move in any particular fashion so if by chance the remote was dropped the craft would hover 

until re-engaged. UAS’s are small, lightweight and slow moving tools that leave a tiny carbon footprint, 

carries no dangerous fuels, leaves no emissions or toxic fumes is far safer than conventional aircraft, poses no 

threat to National Security, and Serves the Public Interest and Public Safety. 

In Summary
July 11, 2015

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I have asked for exemptions under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 CFR Part 21, Subpart H

§§ 45.23, 45.27 (a), 45.29 (3) (c)(d)(e)(f)(g)(h)

Continuation of Requested Exemptions

§§ 91.105, 91. 107, 91.109, 91.119 (c), 91.121, 91.151 (a), 91.405 (a), 91.407 (a) (1), 91.409 (a) (1)(2), 

§ 91.417 (a) (b)

Similar situations with other people seeking exemptions have been granted with similar craft. I feel I have 

satisfied and met the conditions and criteria provided in Section 333 of the Reform Act and ask that the FAA 

grant the above listed exemptions I have requested as soon as possible. 

Sincerely,

John P Creed

Owner/operator John P Creed Painting & Home Repairs

Rotogistics

215-627-4610

jpcpainting@gmail.com