January 13, 2016

U.S. Department of Transportation 

Docket Management System

1200 New Jersey Ave. SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir or Madam:

Much time and research was put in to this petition without the assistance of 

professional legal consultants.

Pursuant to Section 333 of the Federal Aviation Administration (FAA)

Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, 

Justin Deierling and Adam Deierling hereby apply for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of our 

Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) so long as such operations are conducted 

with and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

This exemption will allow Adam Deierling and Justin Deierling to gather an array 

of imagery and data from our Unmanned Aircraft System in a safe an economical 

way. Our areas of proposed operation include the following:

Event Photography/Videography

 Weddings

 Parties

 Public events (festivals, marathons, fireworks etc.)

 Real estate (commercial, residential, farms, etc.)

 Motion picture productions

 Commercial and corporate productions 

 Virtual tours

 Construction

 Landscapes (golf course, farms, etc.)

Public Safety
January 13, 2016

 HAZMAT scene surveillance

 Fire scene surveillance

 Training videos

 Building inspection

 Pipeline Inspection

Aircraft Type & Specifications:

Make: DJI

Model: Phantom 3

Weight: 2.82 pounds

Diagonal Size: 23.23 inches

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

Justin and Adam Deierling are seeking relief from all FARs above preventing 

applicant from conducting aerial photography and video at levels less than 400 

feet above ground level (AGL). The UAS to be used is a DJI Phantom 3. At 2.82

pounds, the weight of the UAS meets the definition of “small unmanned aircraft” 

found in section 331 “The Reform Act”. The maximum speed of the UAS is 35.8

miles per hour. The UAS is battery powered with no combustible fuels onboard. 

Maximum flight time for this particular UAS is 25 minutes battery life, and all 

flights to be terminated with 25% battery life remaining. Given the size, weight, 
January 13, 2016

speed, and limited operating area associated with the aircraft to be utilized we

find this exception to be reasonable with an equivalent, or greater, level of safety 

to be reached by the operator.

Safety 

Being that I, Justin Deierling, hold a private pilot's license and work in the public 

safety field, I know safety is paramount. I, along with Adam Deierling, will be 

operating every flight with extreme caution. Each scheduled flight will be met 

with an extensive plan that begins days prior to takeoff. This planning will 

include, but is not limited to: obtaining permission from required parties, 

identifying known hazards in the area, monitoring weather, and identifying if the 

area is within 5 miles of the airport. We will use all tools and resources available

including ForeFlight on an iPad with GPS and the FAA application "B4UFLY." If it is 

found that flight is required within 5 miles of an airport or helipad, permission will 

be requested with the airport and/or governing FAA control center and proper 

communication will be established. The planning will continue to the day of the 

event on which a safety briefing, including all parties involved, will be held. The

briefing will include, but not limited to, "fly no fly" decisions (based on 

meteorological conditions and last minute safety issues), discussion of the flight 

plan, assurance that all permission and required paperwork are on hand,

preflight inspections, calibration of the aircraft and any last minute discussion 

necessary for safe flight. During operation, we will comply to all safety regulations

required by the FAA. The UAS visual observer will be in voice distance of the pilot 

in command (PIC) at all times to ensure the safest operation of flight.

In regards to the safety of the aircraft itself, we have done an ample amount of 

research and feel that we have chosen a drone that is among the safest in its

class. The DJI Phantom 3 is completely under control of the operator, however, 

the drone has automatic safety features that make sure each flight is operating 

safely at all times. These features include a "failsafe system", "geofence" 

technology, and "auto-return home” in the event of communication failure.
January 13, 2016

Public Interest

By being granted this exemption, we will be able to utilize an unmanned aircraft 

that is both economical and safe to the public and the environment. With this 

drone, we will provide a service to the public which will allow them to view,

market, and promote their property, movies, products and events in a unique and 

affordable way. Most importantly, we will be able to provide service to 

emergency responders by flying in to areas to gather air samples and inspect

hazardous scenes in which human life could potentially be at risk.

We thank you for your time and consideration. 

Justin Deierling- Private Pilot/ Owner of SkyBuddy, LLC

PilotJD01@hotmail.com

Adam Deierling- Videographer/ Owner of Saturn Entertainment Studios

Adam@SaturnEStudios.com