Clinton	E.	Guthrie

5026	Cameron	Rd

Birmingham,	AL	35242

July	20,	2015

VIA	US	MAIL	or	ELECTRONIC	MAIL:

U.S.	Department	of	Transportation

Docket	Management	System	

1200	New	Jersey	Avenue,	SE	

Washington,	DC	20590	

Re:	Exemption Request	under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

FAA	Regulations	and	certain	parts	of	the	FARs.	

Dear	Sir	or	Madam:	

INTRODUCTION	AND	INTERESTS	OF	PETITIONER

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

requirements	 contained	 within	 14	 C.F.R.	 Part 11,	 I	 hereby	 request an	 exemption	

from	 Federal	 Aviation	 Regulations	 (FARs)	 detailed	 below	 for	my	 3D	 Robotics	 Inc.	

(3DR)	X8+	unmanned	aircraft	system (UAS).	

SUPPORT	OF	REQEUST

The	 requested	exemption	would	 support	the use	 of	my UAS for	 commercial	aerial	

photography,	 videography,	inspection	 of private	and	 commercial property,	as	well	

as	 land	 and	 timber	 management.	 The	 3DR	 X8+	 system consists	 of	 a	 lightweight	

battery	operated	aircraft	weighing	less	than	7	pounds,	ground	based	computer and	

handheld	controller,	and	associated	communications	and imaging	equipment.	

REASONS	WHY	THIS	REQUEST	WOULD	BE	IN	THE PUBLIC	INTEREST

A	camera	is	carried	by	the	UAS that	allows	it	to	conduct	precision	photography	and	

inspection.	 The	 high-resolution	 images,	 videos	 and	 data	 will	 provide	 necessary	

information	for	my	business	needs	and	those	of	my	clients to	maintain	and	inspect	

property,	timber,	crops,	and	structures without	disturbing	surface	activities.

REASONS	WHY	THIS	REQUEST	WOULD	NOT	AFFECT PUBLIC	SAFETY

The	 UAS will	 be	 operated	 in	 the	 field	 with	 both	 a	 Pilot	 in	 Command	 (PIC)	 and	 a	

ground-based	Visual	Observer	(VO)	in	accordance	with	the	FAA	Policy	N	8900.227	

Section	 14	 "Operational	 Requirements	 for	 UAS"	 with	 the	 following	 additional	

operating	restrictions:	

1. All	operations	will	occur	in	Class	G	airspace	at	no	more	than	400ft	AGL.

2. Operations	will	be	conducted over	private	property only	with	the	permission

of	the	landowner.
3. All	required	permits	will	be	obtained	from	state	and	local	government prior	

to	operation.

4. The	aircraft	will	not	be	operated	over	dense	urban	or	populated	areas.

5. The	aircraft	will	not	be	operated	within 5	NM	of	an	airport	or	heliport.

6. The	aircraft	will	not	be	operated	at	air	shows	or	over	an	open-air	assembly	of

people.

7. The	aircraft	will	not	be	operated	over	heavy	traffic	roads.

8. Operations	will	be	limited	to	day	and	visual	meteorological	conditions.

9. The	UAS will	remain	within	visual	line	of	sight	at	no	greater	than	400’ above	

ground	level of	the	PIC	at	all	times.

10. While	the	aircraft	is	airborne,	the	VO	will	be	positioned	within	voice	distance	

range	of	the	PIC.	

The	 PIC	 and	 VO	 will	 perform	 routine	maintenance	 and	inspections	 on	 the	 system	

along	with	following	routine	safety	procedures	and	pre-flight	checklist	procedures.

We	submit	that	the	combination	of	strict	operation	under	the	guidelines	established	

in	 8900.227	 and	 the	 aircraft's	 light	 weight,	 historically	 demonstrated	 flight	

performance,	 and	 a	 responsible flight	 crew,	 the	 FAA	 can	 have	 confidence	 that	 the	

operations will	be	conducted	in	a	safe	manner	at	all	times.	

NAME	AND	ADDRESS	OF	PETITIONER

The	name	and	contact	information	of	the applicant	are:	

Clinton	E.	Guthrie

5026	Cameron	Rd

Birmingham,	AL	35242

SECTIONS	OF	14	C.F.R.	FROM WHICH	GUTHRIE	SEEKS	EXEMPTION

The	regulations	from	which	the	exemption	is	requested	are	as	follows:	

14	CFR	Part	21

14	CFR	91.203

14	CFR	45.23,	45.29

14	C.F.R.	91.7(a)	

14	CFR	91.9

14	CFR	61.113(a)	&	(b),	61.133(a)

14	CFR	91.109,	91.119

14	CFR	91.121,	91.151

14	CFR	Subpart	E	(91.401-91.417)

FAA	Policy	8900.227	Paragraph	16(c)(4)	and	Paragraph	16(e)(l)	

EXTENT	OF	RELIEF	AND	REASON	GUTHRIE	SEEKS	RELIEF

Including,	 specific	 request	 for	 extension	 of	 relief	 from	 these	 regulations	 for	 the	

following	reasons:
14 C.F.R.	 91.7(a)	 Civil	 aircraft	 airworthiness	- An	 equivalent	 level	 of	 safety	

will	be	provided	given	the	size	of	the	aircraft	and	the	requirements	contained	

in	 the	 Aircraft	 Information/Owner’s	 Manual	 for	 maintenance	 and	 use	 of	

safety	checklists	prior	to	each	flight.	

14	 C.F.R.	 91.119(c) - Over	 other	 than	 congested	 areas,	 operations	 of	 the	

aircraft	will	be	conducted	at	distances	less	 than	500	 feet	 from	participating	

persons,	vessels,	vehicles	or	structures	that	perform	an	essential	function	in	

connection	with	these	special	purpose	operations.	

14	C.F.R.	91.121	Altimeter	settings - Altitude	of	the	aircraft	will	be	provided	

to	the	PIC	via	radio	communications	telemetry	data	link,	which	links	from	the	

aircraft	to	the	PIC	for	active	monitoring	of	the	aircraft’s	altitude.	

14	C.F.R.	91.151(b)	Fuel	requirements	for	flight	in	VFR	conditions - The	UAS	

will	 not	 begin	 flight	 unless	 (considering	 wind	 and	 forecast	 weather	

conditions)	 there	is	enough	 fuel	 (battery	 voltage)	 to	 fly	 to	 the	 first	point	 of	

attending	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	

least	two	minutes.	

14	 C.F.R.	 91.405(a)	 Maintenance	 requested,	 14	 C.F.R.	 91.407(a)	 Operation	

after	 maintenance,	 preventative	 maintenance,	 rebuilding	 or	 alteration,	 14	

C.F.R.	 91.409(a)	 Inspections,	 14.	 C.F.R. 91.417(a),	 maintenance	 records	 -

Routine	maintenance,	inspections	and	 repairs	will	 be	maintained	 to	ensure	

that	the	UAS	remains	in	optimum	operating	condition	per	details	outlined	by	

the	manufacturer	and	as	new	information	and	guidelines	may	be	updated.	

CONCLUSION

As	 set	 forth	 above,	 I	 hereby	 seek an	 exemption	 pursuant	 to	 14	 C.F.R.	 11.61	 and	

Section	 333	 of	 the	 FAA	Modernization	and	Reform	Act, which	will	 permit	 the	 safe	

operation	 of	 a UAS	 commercially,	 for	 the	 special	 purpose	 of	 conducting	 aerial	

photography	 and	 videography	 along	 with	 aerial	 inspections	 of	 private	 and	

commercial	 properties.	 By	 granting	 this Petition,	 the	 FAA	 Administrator	 will	 be	

fulfilling	 the	 Congressional	 mandate	 of	 the	 FAA	 Modernization	 and	 Reform	 Act	 of	

2012,	 while	 also	 advancing	 the	 interests	 of	 the	 public,	 by	 allowing	 me to	 safely,	

efficiently	and	economically	operate	my UAS	commercially	within	the	NAS.	

Respectfully	submitted,

Clinton	E.	Guthrie
SUMMARY	THAT	CAN	BE	PUBLISED	IN	THE	FEDERAL	REGISTRAR

Clinton	 E. Guthrie seeks	 exemption	 from	 the	 requirements	 of	 14	 C.F.R.	 91.7(a),	

91.119(c),	 91.121,	 91.151(b),	 91.405(a),	 91.407(a),	 91.409(a)	 and	 91.417(a).	 This	

exemption	would	permit	Guthrie	to	operate	his	UAS	to	safely	collect	various	 forms	

of	aerial	images	and	video	for	commercial	use.	

14	CFR	Part	21

14	CFR	91.203

14	CFR	45.23,	45.29

14	C.F.R.	91.7(a)	

14	CFR	91.9

14	CFR	61.113(a)	&	(b), 61.133(a)

14	CFR	91.109,	91.119

14	CFR	91.121,	91.151

14	CFR	Subpart	E	(91.401-91.417)

FAA	Policy	8900.227	Paragraph	16(c)(4)	and	Paragraph	16(e)(l)	

Including,	 specific	 request	 for	 extension	 of	 relief	 from	 these	 regulations	 for	 the	

following	reasons:

14	 C.F.R.	 91.7(a)	 Civil	 aircraft	 airworthiness	- An	 equivalent	 level	 of	 safety	

will	be	provided	given	the	size	of	the	aircraft	and	the	requirements	contained	

in	 the	 Aircraft	 Information/Owner’s	 Manual	 for	 maintenance	 and	 use	 of	

safety	checklists	prior	to	each	flight.	

14	 C.F.R.	 91.119(c) - Over	 other	 than	 congested	 areas,	 operations	 of	 the	

aircraft	will	be	conducted	at	distances	less	 than	500	 feet	 from	participating	

persons,	vessels,	vehicles	or	structures	that	perform	an	essential	function	in	

connection	with	these	special	purpose	operations.	

14	C.F.R.	91.121	Altimeter	settings - Altitude	of	the	aircraft	will	be	provided	

to	the	PIC	via	radio	communications	telemetry	data	link,	which	links	from	the	

aircraft	to	the	PIC	for	active	monitoring	of	the	aircraft’s altitude.	

14	C.F.R.	91.151(b)	Fuel	requirements	for	flight	in	VFR	conditions - The	UAS	

will	 not	 begin	 flight	 unless	 (considering	 wind	 and	 forecast	 weather	

conditions)	 there	is	enough	 fuel	 (battery	 voltage)	 to	 fly	 to	 the	 first	point	 of	

attending	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	

least	two	minutes.	

14	 C.F.R.	 91.405(a)	 Maintenance	 requested,	 14	 C.F.R.	 91.407(a)	 Operation	

after	 maintenance,	 preventative	 maintenance,	 rebuilding	 or	 alteration,	 14	

C.F.R.	 91.409(a)	 Inspections,	 14.	 C.F.R. 91.417(a),	 maintenance	 records	 -

Routine	maintenance,	inspections	and	 repairs	will	 be	maintained	 to	ensure	

that	the	UAS	remains	in	optimum	operating	condition	per	details	outlined	by	

the	manufacturer	and	as	new	information	and	guidelines	may be	updated.