Quentin E. Tyler

18324 West Ocotillo Ave

Goodyear, AZ 85338

28 AUG 2015

To whom it may concern at the FAA: 

I currently have owned a DJI Phantom 2 for over 2 years and I have 

approximately 300 hours of accident free flight time as a hobbyist. Additionally, I 

have over 20 years of experience with radio controlled model aircraft. I currently 

work as a technical supervisor for the Phoenix Fire Department, and fully 

understand the seriousness of safety.

I have been an avid photographer for many years and being able to fly a 

UAS with a camera has been a natural extension of my photography and 

videography. All of my work has been in visual line of site. I have no desire nor 

do I need to ever operate the UAS in any manner than within visual line of site. I 

have recently upgraded to a DJI Phantom 3 which allows for a longer flight time 

and is equipped with a better quality camera for still photos and videos. 

My plan is to pursue a commercial business venture to take still photos or 

produce videos at the request of potential clients. In all cases I will receive

permission prior to any performed work and will always keep safety as the 

number one consideration when flying the UAS. 

Quentin Tyler will be the only Pilot in Command using the UAS.
Quentin E. Tyler

18324 West Ocotillo Ave

Goodyear, AZ 85338

To the Federal Aviation Authority (FAA), 

I hereby request exemption from part 21, subpart H; and Sections 45.23(b), 

61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 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). 

I support my request with the following information:

I plan to operate a UAS, the DJI Phantom 3, which is comprised of an 

unmanned aircraft and a transportable ground station. The DJI Phantom 3 is 

referred to as a quad-copter with a maximum gross weight of about 3 pounds. It 

is equipped with four rotors that are driven by electric motors powered by a

battery. The UAS has a maximum airspeed of 22 m/s. The quad has a built in 

high definition camera. I plan to operate the UAS over various areas within the 

United States. I make the following representations of operational enhancements 

which I propose to abide by to ensure this exemption will provide a level of safety 

at least equal to existing rules:

• I will only operate in reasonably safe environments that are strictly 

controlled, and are away from power lines, elevated lights, airports and actively 

populated areas.

• I will conduct extensive preflight inspections and protocols, during which 

safety carries primary importance.

I state that given the size, weight, speed, and limited operating area associated 

with the aircraft to be utilized, an exemption from 14 CFR part 21, Subpart H 

(Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), 
Quentin E. Tyler

18324 West Ocotillo Ave

Goodyear, AZ 85338

subject to certain conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14 CFR part 11 and Section 

333 of P.L. 112-95 (Section 333).

I request an exemption from § 45.23 Marking of the aircraft because this UAS will 

not have a cabin, cockpit or pilot station on which to mark certain words or 

phrases. Further, I state that two-inch lettering is difficult to place on such a small 

aircraft with dimensions smaller than the minimal lettering requirement. 

Regardless of this, I state that I will mark my UAS in the largest possible lettering 

by placing the word “Experimental” on its fuselage as required by § 45.29(f) so 

that I or anyone assisting me as a spotter will see the markings.

I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 

91.417(a) and (b) Maintenance inspections may be required and should be 

granted since they only apply to aircraft with an airworthiness certificate. 

However, I state that as a safety precaution I will perform a preflight inspection of 

my UAS before each flight as outlined in my operating documents. 

UAS Pilot in Command (PIC) I assert that under § 61.113 (a) and (b) private 

pilots are limited to noncommercial operations, however I can achieve an 

equivalent level of safety as achieved by current regulations because my UAS 

does not carry any pilots or passengers. Further, I state that, while helpful, a pilot 

license will not ensure remote control piloting skills. I further indicate that the 

risks of operating a UAS are far less than the risk levels
Quentin E. Tyler

18324 West Ocotillo Ave

Goodyear, AZ 85338

inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus I 

request an exemption from § 61.113 Private Pilot Privileges and Limitations: Pilot 

in command.

Regarding UAS operational training, I state I have flown numerous practice 

flights in remote areas as a hobbyist simulating flights for future commercial use 

to gain familiarization with the characteristics of this UAS’ performance under 

different temperature and weather conditions. 

UAS Operating Parameters

I will abide by the following additional operating conditions under this exemption: 

• Operate my UAS below 200 feet and within a radius distance of 1000 

feet from the controller to both aid in direct line of sight visual observation.

• Operate the UAS for no more than 20 minutes per flight. 

• Land my UAS prior to the manufacturer’s recommended minimum level 

of battery power. 

• Operate my UAS only within visual line of sight (VLOS). 

• Use the UAS’ global positioning system (GPS) flight safety feature 

whereby it hovers and then slowly lands if communication with the remote 

control pilot is lost. 
Quentin E. Tyler

18324 West Ocotillo Ave

Goodyear, AZ 85338

• Conduct all operations under my own personal and flight safety protocols 

contained in the operating documents and will actively analyze flight data and 

other sources of information to constantly update and enhance my safety 

protocols. 

• Contact respective airports if operations will be within 5 miles to advise 

them of my estimated flight time, flight duration, elevation of flight and other 

pertinent information. • Always obtain all necessary permissions prior to 

operation.

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

or potential danger.

I state that § 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.

I state that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however 

since there are no pilots or passengers on board his aircraft and given its size, 

this regulation is inapplicable. I further indicate an equivalent level of safety will 

be achieved by maintaining a safety/flight manual with the UAS ground station.

I state that § 91.119 prescribes safe altitudes for the operation of civil aircraft, 

but that it allows helicopters to be operated at lower altitudes in certain 

conditions. 

I state that I will not operate this UAS above the altitude of 200 feet above ground 

level (AGL) and will also only operate in safe areas away from the public and 
Quentin E. Tyler

18324 West Ocotillo Ave

Goodyear, AZ 85338

traffic, thus “providing a level of safety at least equivalent to or below those in 

relation to minimum safe altitudes. I assert that given the size, weight, 

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

will be achieved.

I indicate that § 91.121 Altimeter settings is inapplicable since my UAS utilizes 

electronic GPS with a barometric sensor.

Public Interest

I state that aerial videography and photography for geographical awareness and 

for real estate marketing has been around for a long time through manned fixed 

wing aircraft and helicopters, but for small business owners, its expense has 

been cost-prohibitive. Granting this exemption to myself would allow me to 

provide this service at a much lower cost.

Further, I would like to indicate my small UAS will pose no threat to the public 

given its small size and lack of combustible fuel when compared to larger 

manned aircraft.

I would also like to state that the operation of my UAS will minimize ecological 

damage being battery operated.

(end of petition)
Additionally I have contacted my insurance carrier and once these exemptions 

are approved by the FAA to legally fly the UAS commercially I will be able to 

purchase damage and liability insurance for the UAS operations.

Thank You, 

Quentin E. Tyler