U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, S.E. West Building Ground Floor, Room W12-140 

Washington, DC 20590 

RE: Petition for Exemption under Section 333 of the FAA Modernization and 

Reform Act and Part 11.81 of the Federal Aviation Regulations 

Docket ID:________________

June 3, 2015 

Petitioner: 

Ghost Drone Imaging 

Alex Pace

Charles Pace

1945 Barnstormer Dr.

Blue Ridge, TX 75424

Tel.: 4692076475

Email: alexandergpace@yahoo.com & charliepacejr@yahoo.com

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 

11.81, Ghost Drone Imaging, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") 

to allow commercial operation of its small, unmanned aircraft for general photography and real estate 

applications. All operations shall be conducted within and under the conditions and limitations outlined previously 

by the FAA as required by Section 333 and conducted in compliance with the attached operator’s manuals. No 

commercial operations have been conducted thus far and will not be conducted until a petition is granted. 

1. Sections from which exemptions are sought: Application is hereby made for exemption from: 

a. 14 CFR Part 21, subpart H 

b. 14 CFR Part 61.113(a) and (b) 

c. 14 CFR Part 91: 

i. 91.103

ii. 91.105 

iii. 91.109(a)

iv. 91.119 

v. 91.121 

vi. 91.151

vii. 91.203 (a) & (b)

viii. 91.405 

ix. 91.407 

x. 91.409 

xi. 91.417 
2. Relief sought: 

a. Ghost Drone Imaging wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to 

include (but not be limited to) general photography and real estate. 

This relief is sought because commercial use of sUAS is currently prohibited by law unless performed under an 

exemption. 

b. This exemption will cover use of the following airframes, all of which will weigh less than 55 pounds including 

payload and energy sources: 

i. DJI Phantom 3 Professional (see www.dji.com/product/phantom-3)

ii. DJI Phantom 2 (see www.dji.com/product/phantom-2) 

iii. Other models to be added by future amendment to this exemption. 

3. Public benefit: 

a. Use of UAS technology to obtain imagery, information and data currently obtained by use of manned flight or 

manual methods: 

i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due 

to other dangerous activities that can be avoided.

ii. Reduces the cost of obtaining such information, which benefits consumers and the economy. 

iii. Reduces environmental impact by eliminating sources of hydrocarbon emissions from manned aircraft. 

4. Safety not adversely affected: 

a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, Subpart C. 

b. Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair and 

maintenance work will be conducted or approved by qualified personnel such as those authorized by DJI (or 

equivalent), and will require a test flight after such work. Records of all maintenance and repair work will be kept 

in a maintenance log for each aircraft. 

c. All flight operations will be conducted by at least two individuals (PIC and observer) who will maintain verbal 

communication capability with each other at all times during the flight, and who will remain stationary on the 

ground during the flight operations: 

i. A Pilot In Command (PIC) who possess the following credentials: 

1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the TSA

2. A Third Class medical certificate issued under 14 CFR 67. 

3. A bi-annual flight review under 14 CFR 61.56 

4. Successful completion of a UAS knowledge test in a specified form. 

5. At least 25 hours of flight experience in a UAS rotorcraft (or UAS fixed-wing in the case of fixed-wing flight 

operations under this exemption). Such hours may be gained during flights under this exemption if a safe distance 

is maintained from persons in accordance with 14 CFR 91.119. 

6. At least 5 hours of flight experience and 3 takeoffs and landings in make and model being flown in the prior 90 

days. Such cycles and hours may be gained during flights under this exemption if a safe distance is maintained from 

persons in accordance with 14 CFR 91.119. 

ii. A Visual Observer. 

iii. A Sensor Operator as necessary. 

d. All flight operations will be conducted in accordance with valid Certificates of Authorization. 

e. All flight operations will comply with the following: 

i. The manufacturers’ user manuals. 

ii. Ghost Drone Imaging’s Flight Operations and Procedures Manual (FOPM) and Aircraft Flight Manuals (AFM) 

which include lost communication and other emergency and safety procedures. 
iii. Conducted in VMC conditions during daylight hours. 

iv. PIC and VO will maintain VLOS at all times. 

v. Pre-flight inspections (including ground control station, if any) and safety risk assessments will be conducted 

prior to each flight. 

vi. Flight altitudes will remain below 400 feet above ground level. 

vii. Flight ground speeds will not exceed 50 knots. 

viii. Not intrude into Class B, C or D airspace, or published approach, SID or STAR, or take place within 5 nautical 

miles of an airport. 

ix. Not be made near persons as required in 14 CFR 91.119 and not over persons on the ground without their prior 

permission. 

x. Each flight will be logged in both the PIC’s logbook and the aircraft logbook. 

xi. Not exceed 75% of the battery or fuel capacity of the aircraft, or 20 minutes, whichever occurs first. 

xii. Any incidents will be reported immediately. 

xiii. Any applicable local FSDO requirements.

xiv. All other applicable regulations concerned with the operation of aircraft. 

f. Aircraft will use FCC compliant 2.4 GHz for command & control of the aircraft with well-defined and tested lost 

link procedures. 

Please advise us of any additional information or changes that may be required. 

Sincerely, 

Alex Pace

Charles Pace

Ghost Drone Imaging