I. Name and Information

David E. Anderson

4540 Bowl Street

New Port Richey, FL 34652

(727) 271-5588

Anderson7314@gmail.com 

I, David E. Anderson, received my Associates Degree in Architecture from Purdue 

University, Indianapolis, Indiana, and continued on to receive my Bachelor of Science in 

Construction Management in 1985. I am a Class A State Certified General Contractor with license 

#CGC055976 since August 1, 1996 and a Florida State Certified Home Inspector license #HI1596 

since February 15, 2011, both licenses are active in the State of Florida and are afforded reciprocity

in numerous other states. I also have an active membership in the Academy of Model Aeronautics 

dating back to 1982, license #83430. My interest in UAS’s also includes unmanned water vessels, 

and I, David E. Anderson, also have a Life #16565 S in the International Model Power Boat 

Association which dates back to 1995. 

I, David E. Anderson, received my Student Pilot Certificate with 38.9 hours Dual, and 16.2 

hours Solo for a total of 55.1 hours. This includes 1.0 hours of Instrument, and 13.0 hours of Cross 

Country, along with over 10 hours of ground school training. I am fully familiar with the FAA 

rules and regulations governing airspace “no-fly zones” and I agree to fully comply with all FAA 

regulations in a manner consistent with those followed by a licensed pilot in the operation of my 

UAS. 

I, David E. Anderson, currently own a DJI Phantom Aircraft with a 1080 HP camera and 

intend to add other UAS’s to my inventory for the intent of aerial GPS Global Mapping, 

Commercial and Residential Inspections, Insurance Inspections for damage claims as well as 

documenting existing conditions for Insurance Companies, Construction Management and 

inspections of new and renovation projects including the interior of buildings, and potential 

government assistance as needed. As the owner/principal of the following companies incorporated 

within the State of Florida, this exemption will be used for the above purposes by myself and/or 

one of my following business entities for the exclusive use of myself, business, or clients. 

1. Anderson Inspections, Inc., 5/31/2005; 

2. dba: Anderson Construction Group; 1/17/2007; 

3. dba: Anderson Hurricane Protection: 3/27/2009; 

4. dba: Anderson: 7/23/10. 

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which 

David E. Anderson Requests Exemption are:

14 CFR 21;§14 C.F.R. 45.23(b);§14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.;§14 CFR 

407 (a) (1);§14 CFR 409 (a)(2); and, 14 CFR 417 (a) & (b).

III. The Extent of Relief David E. Anderson Seeks and the Reason He Seeks Such Relief:

I, David E. Anderson, submit this application in accordance with the Reform Act,112 P.L. 

95 §§ 331-334, seeking relief from currently applicable FARs operating to prevent me, David E. 

Anderson, contemplated commercial cinematic, academic and other flight operations within the 
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national airspace system. The Reform Act in Section 332 provides for such integration of civil 

unmanned aircraft systemsinto our national airspace system as it is in the public’s best interest to 

do so.

My, David E. Anderson's, ultralight weight UAS meets the definition of “small unmanned 

aircraft” as defined in Section 331 and therefore the integration of my ultralight weight UAS is 

expressly contemplated by the Reform Act.

The Reform Act guides the Secretary in determining the types of UAS's thatmay operate 

safely in our national airspace system. Considerations include: weight, size, speed and overall 

capabilities of the UAS's; whether the UAS will be operated near airports or heavily populated 

areas; and, whetherthe UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these

items reflect in favor of an exemption for me, David E. Anderson.

My UAS utilizes four (4) counter-rotating propellers for balance, control and stability. My 

UAS is equipped with GPS and auto return safetytechnology, and weighs under three (3) pounds 

(below the maximum 55 pound limit); including camera with gimbal.

I, David E. Anderson, consider safety as foremost with each flight. My small, unmanned 

aircraft is designed to hover in place via GPS and operate in lessthan a 24 knot (15 mph) wind. 

Built in safety systems include a GPS mode that allows my UAS to hover in place when radio 

controls are released. With three modes to choose from, I utilize the GPS Mode for aerial 

videography/photography. This is the safest, most reliable and stable mode to prevent accidents. 

If pilot communication is lost, UAS are designed to slowly descend to the original point of 

takeoff. I do not operate my UAS near airports, hospitals, police heliports, and, with the exception 

of my clients being present, will not operate near areas where the general public is within fifty to 

one hundred (50-100) yards depending on location, conditions and weather. I am constantly on 

alert for any manned aircraft and am prepared to lower/land/abort immediately to the nearest and 

safest ground point should a manned aircraft approach my location or I suspect manned aircraft 

may approach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within my 

line of sight, as the remote control pilot, or with my licensed PIC. The equipment runs on battery 

power and an average flight generally takes between three (3) to twelve (12) minutes, with an 

altitude under twohundred (200) feet. I, David E. Anderson, utilize a fresh fully charged battery 

with each flightas a safety precaution; the average flight time limit for each battery is twenty (20) 

to twenty-five (25) minutes as tested. I do not operate my UAS at or below manufacturer’s

recommend minimum charge levels for operation; preferring to remain well within a safe 

operating range to insure adequate communication between radio control and UAS to eliminate 

potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to 

insure replacement for sufficientsafe level of operation. I have clocked numerous practice flights 

in remote areas to hone my skills with the characteristics of this specific UAS's performance 

under different temperatures and weather conditions. In addition to my concern and respect for 

the use of this machine, I have a financial investment at stake and do not wish to take any 

unnecessary risks to jeopardize the safe return of my investment. 

I, David E. Anderson, am extremely cautious when operating of my UAS/ultralight weight 

unmanned aircraft and will not “create a hazard to users of the national airspace system or the 
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public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS it falls well within 

Congress’s contemplated safety zone when it implemented the Reform Act and the corresponding 

directive to integrateUAS's into the national airspace system. My, David E. Anderson’s UAS has 

a demonstrable safety record and does not pose any threat to the general public or national

security.

IV. How David E. Anderson’s Request Will Benefit the Public As A Whole:

The inherent ability of the UA is to capture imagery from a low altitude including

oblique photos and video from several anglesis far more effective than ground based imagery

for displaying the characteristics of buildings, sites and properties or areas where inspections 

are needed. The applicant in the past has required a ladder for this purpose, which creates a 

hazard and potential for serious injury. The property owner or construction manager would 

benefit from an aerial “real-time” inspection of the area so that he/she may assess the situation 

and proceed in their best interests. The reduced cost and higher quality data from the UA will

be beneficial to the public in applications where access is limited and reduce if not eliminate 

any potential for injury by the property owner to inspect the situation. Construction projects will 

proceed in a timely fashion with the use of this equipment and it will assist property buyers in 

evaluating the condition of their property without risking serious injury or death for an up-close 

view. 

Aerial videography for geographical awareness and for real estate marketing has been 

around for a long time through manned fixed wing aircraft and helicopters. For small budget 

real estate companies and average homeowners the expense of such aerial videography is cost 

prohibitive. The same is also true for construction sites, land surveying, and all aspects of 

property inspections and evaluations in both residential and commercial arenas. 

My, David E. Anderson’s, UAS does not pose any threat since size and lack of

combustible fuel alleviates any potential harm to the public. Congress has already proclaimed 

that it is in the public’s interest to integrate commercially flown UAS's into the national airspace 

system, hence the passing of the Reform Act. My ultralight weight UAS is battery powered and 

creates no emissions that can harm the environment.

The public’s interest is furthered by minimizing ecological and crash threat by permitting 

aerial video/photo capture through my battery operated ultralight weight UAS's. Permitting me, 

David E. Anderson, to immediately fly within national air space furthers economic growth. 

Granting my exemption request substantially furthers the economic impact for companies 

looking to relocate or build in the area as well as individuals looking to relocate which is a 

stimulus to the economy of the community.

V. Reasons Why David E. Anderson’s Exemption Will Not Adversely Affect Safety Or 

How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

My, David E. Anderson’s, exemption will not adversely affect safety. Quite the contrary, 

for the reasons stated permitting me, David E. Anderson, to log more flight time in FAA 

controlled airspace, with communication with the FAA, will allow me to contribute to the 

innovation and implementation of new and novel, as of yet undiscovered safety protocols for 

Realtors, construction sites, land surveying, location historical documentation, and 
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infrastructure inspections that can be embraced by the NAR, AAR, and TAR for development 

in cooperation with the FAA. In addition I, David E. Anderson, submit the following 

representations of enhancements to current aerial videography and photography for real estate,

construction sites, land surveying, location historical documentation, infrastructure inspections, 

athletic field marketing and maintenance:

My UAS, a Phantom 2 manufactured by DJI weighs less than three (3) pounds complete 

with a small ultralight weight high quality 1080 HD camera;

I, David E. Anderson, only operate my UAS below 200 feet (well within the 400 foot

permissible ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only 

operates for 12-25 minutes per flight;

I land my UAS prior to manufacturer recommended minimum level of battery power;

I pilot my UAS through remote control only by line ofsight;

My UAS has a GPS flight safety feature whereby it hovers and then slowly lands if 

communication with the remote control pilot islost;

I actively analyze flight data and other sources of information to constantly update and 

enhance safety protocols;

I only operate in reasonably safe environment that are strictly controlled, are away from 

power lines, elevated lights, airports and actively populated areas;

I conduct extensive pre-flight inspections and protocol, during which safety carries primary

importance;

I obtain all necessary permissions prior to operation; and,

I have procedures in place to abort flights in the event of safety concerns or potential

danger.

My, David E. Anderson’s, safety protocols provide a level of safety equal to or exceeding 

existing rules. Further, my hours of flight instruction will benefit me, my clients, and the 

community as I will be held to a higher standard of care based on my knowledge of FAA rules 

and regulations that exceed most UAS operators

VI. A Summary The FAA May Publish in the Federal Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals andThe Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, 

weight and operational area of my, David E. Anderson's, UAS permits exemption from Part 21 

becausemy UAS meets (and exceeds) an equivalent level of safety pursuant to Section333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both 

pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. My, David E. Anderson, current and projected UAS's 

meetor exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. 

As no such certificate will be applicable in the form contemplated by the FARs, this Regulation 
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isinapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. Asthere are no 

on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas 

of where safety can be defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A,

10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes 

electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent level 

of safety will be achieved bymaintaining any such required certifications and registrations by me, 

David E. Anderson.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. My UAS are, by definition, 

unmanned. They therefore do not have a cabin, cockpit or pilot station on which to mark certain 

words or phrases. Further, two-inch lettering is difficult to place on such small aircraft with 

dimensions smaller that minimal lettering requirement. Regardless, I will mark its UASs in the 

largest possible lettering by placing the word “EXPERIMENTAL” on its fuselage as required by

14 C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the UAV will see 

the markings. The FAA has previously issued exemptions to this regulation through Exemptions 

Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non- commercial 

operations. I, David E. Anderson, can achieve an equivalent level ofsafety as achieved by current 

regulations because my UAS does not carry any pilots or passengers. Further, while helpful, a 

pilot license will not ensure remote control piloting skills. The risks attended to the operation of 

my UAS is far less than the risk levels inherent in the commercial activities outlined in 14 C.F.R. 

§ 61, etseq. Thus, allowing me, David E. Anderson, to operate my UAS meet and exceedcurrent

safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows 

helicopters to be operated at lower altitudes in certain conditions. MyUAS will never operate at 

an altitude greater than 200 AGL; safely below the standard of 400 AGL. I, David E. Anderson, 

will however operate my UAS in safe areas away from public and traffic, providing a level of 

safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size,

weight, maneuverability and speed of my UAS, an equivalent or higher level of safety will be

achieved.

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

The above-cited Regulations require, amongst otherthings, aircraft owners and operators 

to “have [the] 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. . . .” These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to my, David E. Anderson's, UAS. 

However, as a safety precaution I carefully and thoroughly inspect myUAS before and after each

flight.

In summary, David E. Anderson seeks an exemption from the following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 

91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14C.F.R. § 91.119; 

14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 

(a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R.§ 91.409 (a ) (2); and, 14 

C.F.R. §§ 91.417 (a) & (b) to commercially operatemy, David E. Anderson’s, small unmanned 

vehicle/lightweight unmanned aircraft vehicle in community awareness, grounds and building 

maintenance, infrastructure inspections, real estate operations, and to develop economic 

platforms forreal estate to enhance the experience of those seeking to construct and/or purchase 

residential or commercial structures. 

My UAS craft do not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional video and photographic aircraft with much less flight time. 

Further, I operate at lower altitudes and in controlled airspace eliminating potential public risk 

flying to and from established airfields. There are no personnel on board my, David E. 

Anderson’s, UAS and therefore the likelihood of death, serious bodily injury, or any injury is

significantly diminished. My, David E. Anderson's, operation of my UAS, weighing less than 

three (3) pounds and traveling at lower speeds within limited areas will provide an equivalent 

level of safety as that achieved under current FARs. Accordingly I, David E. Anderson, 

respectfully request that the FAA grant my exemption request. This request follows many 

others using similar systems and process that have been granted previously. My request

for the FAA to issue an exemption would not set a precedent and I respectfully request this 

request be granted. 

Respectfully Submitted,

David E. Anderson

/lmf