Stephen W. Barrington

2914 Veterans Blvd SE

Massillon, OH 44646

June 30, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 

14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203 (a) and (b); 

14 CFR 91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11, 

Stephen W. Barrington, operator of Small Unmanned aircraft Systems (“sUAS”), hereby applies for an exemption 

from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAS, so long as such 

operations are conducted within and under the conditions outlined herein or as my be established by the FAA as 

required by Section 333. 

This exemption request is made based on information outlined in this petition, as well as the accompanying

aircraft manuals (DJI Phantom 3 Professional http://www.dji.com/product/phantom-3/download and DJI Inspire1 

http://www.dji.com/product/inspire-1/download). The DJI UAS product line was selected because they have a 

proven capability for controlled flight as well as a gyro stabilized flight mode, GPS aided navigation, a compass, 

blinking LED’s on the bottom, a failsafe mode for returning home, and prop guards. These devices are offered for 

general sale around the world and have often been used as Model Aircraft in the USA. In addition, I, Stephen W. 

Barrington, have flown UAS’s in a recreational capacity for several years and have adopted safety protocols and 

controls to avoid and prevent public hazard, as well as manned aircraft hazards/catastrophe. This will act to 

further safety protocols exclusive to lightweight UAS's specific to video and photography usage as I, Stephen W. 

Barrington, record flight data and other information gained through permitted flight operations to share with the 

FAA through any required FAA reports to assist with future protocol and safety regulation.

Commercial operation sUAS, as described herein, which are equipped with cameras and sensors, would operate in 

the following manner: 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land 

surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, 

cinematography and news gathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or 

local government authority. 
4. Aerial video/photography or providing live video feed to assist with search and rescue operations in cases 

of an emergency or natural disaster only when the local authorities or government has requested it by 

contract or donation. 

5. The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of sUAS for the purpose of the safe operation 

of sUAS to enhance the safety of the National Airspace System (NAS) as well as for the protection of the 

persons and property. 

As described fully below, the requested exemption would permit the operation of sUAS under controlled 

conditions in the NAS that would be a) limited b) controlled c) predetermined and d) will provide safety 

enhancements to the already safe operations in the industry presently using conventional aircraft. Approval of 

this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “....establish requirements for the safe operation of such aircraft systems in the 

national airspace system.” 

The name and address of the applicant is: 

Attn: Stephen W. Barrington

Ph: 330-844-3596

Email: sbarrington114@yahoo.com

Address: 2914 Veterans Blvd SE Massillon, OH 44646

Regulations from which the exemption is requested: 

14 CFR Part 21 subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (2) 

14 CFR 91.417 (a) & (b) 

My sUAS are multi-rotor craft weighing no more than 55lbs. including payload. Under normal conditions they 

operate at speeds of no more than 50kts and have the ability hover and move along a vertical and horizontal 

plane simultaneously. They will operate in line of sight and will operate within a closed off and predetermined 

area owned and/operated by the property representative. 
Given the small size of the sUAS and the controlled environment provided the proposed operations will adhere to 

the Reform Act’s safety requirements. The approval of this application presents no national security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in 

environmental impacts, including but not limited to reduced emissions and noise, the grant of the requested 

exemption is in the public interest. Accordingly the applicant requests that the FAA grant the requested 

exemption with minimum delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY/CONDITIONS AND LIMITATIONS

In this grant of exemption, Stephen W. Barrington is hereafter referred to as the operator. 

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the 

immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 Professional and DJI

Inspire 1 when weighing less than 55 pounds including payload. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder 

may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed 

restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating 

airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude 

must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to 

be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s 

FAA-issued airman medical certificate or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of 

sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long 

as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all 

times; electronic messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance 

with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the 

operating documents. The operating documents must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, the conditions 

and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator or any law enforcement 

official upon request. The operator must also present updated and revised documents if it petitions for 
extension or amendment to this grant of exemption. If the operator determines that any update or 

revision would affect the basis upon which the FAA granted this exemption, then the operator must 

petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight prior 

to conducting further operations under this exemption. Functional test flights may only be conducted by 

a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be 

conducted in such a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for 

safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition 

for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment. If the inspection reveals a condition that affects the safe operation of 

the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and 

life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or 

a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a 

possession, or the Federal government. The PIC must also meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under this exemption are permitted 

under the terms of this exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) 

are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 
airport symbol as denoted on the current FAApublished aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud 

or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location 

within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) 

there is enough available power for the UA to conduct the intended operation and to operate after that 

for at least five minutes or with the reserve power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be 

conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or 

amended COA if it intends to conduct operations that cannot be conducted under the terms of the 

attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered 

in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 

CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents 

required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of 

the UAS any time the aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease immediately in a 

manner ensuring the safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating 

closer to those objects and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under 

this exemption. 
27. All operations shall be conducted over private or controlled-access property with permission from the 

property owner/controller or authorized representative. Permission from property owner/controller or 

authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office 

(AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and television filming and 

production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in 

this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a 

written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the 

area of proposed filming. The 3-day notification may be waived with the concurrence of the FSDO. The 

plan of activities must include at least the following: 

a. Dates and times for all flights; 

b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of 

exemption; 

c. Name and phone number of the person responsible for the on-scene operation of the UAS; 

d. Make, model, and serial or N-Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners and/or local officials 

to conduct the filming production event; the list of those who gave permission must be made 

available to the inspector upon request; 

g. Signature of exemption holder or representative; and 

h. A description of the flight activity, including maps or diagrams of any area, city, town, county, 

and/or state over which filming will be conducted and the altitudes essential to accomplish the 

operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be 

involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply 

with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated 

with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of 

an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 
and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria 

demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and 

under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries 

no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety requirements. The FAA will have 

advance notice of all operations. These safety enhancements provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. 

Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the sUAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, 

restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must 

also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable. 

Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have 

no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size 

of the sUAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) 

where the pilot, observer and others working with the sUAS will see the identification of the sUAS as 

“Experimental.” 

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command. 

Pursuant to 14 CFR 61.113 (a), no person who holds a private pilot certificate may act as a pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire. Our sUAS do not carry any pilots or 

passengers nor property therefore I am seeking an exemption to 14 CFR 61.113(a). Although helpful, a pilot’s 

license will not ensure remote control piloting skills. The risks attendant to the operation of sUAS is far less than 

the risk levels inherent in the commercial activities outlined in 14 CFR 61. I feel the operation and limitations set 

forth in the FOM will equate to the safe operation of the sUAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will 

be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size of the aircraft for maintenance and use of safety 

check lists prior to each flight an equivalent level of safety will be provided. 
14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or 

Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current 

approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any 

combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual 

on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the sUAS will have immediate access to it. 

14 C.F.R. § 91.103: Preflight Action. 

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As 

FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. The PIC 

will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft performance data before initiation of flight. 

14 C.F.R. §91.109: Flight Instruction. 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being 

used for flight instruction unless that aircraft has fully functioning dual controls. sUAS and remotely piloted 

aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use 

of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions 

for flight training without fully functional dual controls for a number of aircraft and for flight instruction in 

experimental aircraft. The equivalent level of safety provided by the fact that neither a pilot nor passengers will 

be carried in the aircraft and by the size and speed of the aircraft. 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be 

operated at less than the minimums prescribed, provided the person operating the helicopter complies with any 

route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and 

the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated 

platform from which filming is planned, an exemption may be needed to allow such operations. As set forth 

herein, the sUAS will never operate at higher than 400 AGL with the exception that in circumstances where the 

sUAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, the sUAS will not be 

operated more than 100' above the highest point on the structure. It will however be operated in a restricted area 

with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. 

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location 

where it is operated. No flight will be taken without the permission of the property owner or local officials. 

Because of the advance notice to the property owner and participants in the filming activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented with conventional aircraft operating at or below 

500 AGL. In addition, the low-altitude operations of the sUAS will ensure separation between these small- UAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 
14 C.F.R. §91.121 Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available 

before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety 

check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 30 minutes of powered flight. To meet the 30 minute 

reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. 

Given the limitations on the sUAS’s proposed flight area and the location of its proposed operations within a 

predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the small UAS, in a tightly controlled area where only people and property owners or official 

representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small 

UAS. Additionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will 

be granted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes 

or 25% of battery power— whichever happens first. This restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: 

(1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that 

it is legible to passengers or crew. 

The sUAS fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no 

ability or place to carry certification and registration documents or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the 

pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. 
14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that 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...,” and others shall inspect or maintain the 

aircraft in compliance with Part 43. 

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not 

apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and 

operating handbook. An equivalent level of safety will be achieved because these small UASs are very limited in 

size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The operator 

will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a 

log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

An equivalent level of safety will be achieved because maintenance and inspections will be performed in 

accordance with the sUAS Manufacturer's Manual, as referenced in the Aircraft Operations Manual (AOM). As 

provided in the FOM, the operator will ensure that the sUAS is in working order prior to initiating flight and 

perform required maintenance needed. 

In summary, Stephen W. Barrington 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; 14 C.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 operate my lightweight unmanned aircraft system 

for aerial photography/Inspection/ and other related professional activities, included but not limited to the 

following; Business Operations: over land, waterways, and oceans; operation over/in nonrestricted National 

Parks, National Forests, flight in nonnavigable airspace, using nonintrusive recording devices, operation in 

otherwise unrestricted U.S. States/Territories for aerial videography/cinematography for commercial 

operation and to enhance academic community awareness for those individuals and companies unfamiliar 

with the geographical layout of such areas. Currently, area awareness and real estate aerial 

videography/photography relies primarily on the use of larger aircraft running on combustible fuel, posing 

potential risk to the public. Granting my request for exemption will reduce current risk levels and thereby 

enhance safety. My UAS does not contain potentially explosive fuel, is smaller, lighter and more 

maneuverable than conventional 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. I 

have been analyzing flight information and will compile safety protocols and the implementation of a flight 

operations manual that exceeds currently accepted means and methods for safe flight. Formal collection of 

information shared with the FAA will enhance the FAA's internal efforts to establish protocols for complying 

with the FAA Modernization and Reform Act of 2012. There are no personnel on board my UAS and therefore 

the likelihood of death or serious bodily injury is significantly diminished. The operation of my UAS, weighing 

less than 7 pounds and travelling at lower speeds within limited areas will provide an equivalent level of 

safety as that achieved under current FARs. Accordingly I respectfully request that the FAA grant my 

exemption request and am willing to cooperate in sharing information to benefit the FAA, safety of manned 

aircraft, and the general public at large. 
Due to file size uploading restrictions, the official DJI Phantom 3 manuals can be found at 

http://www.dji.com/product/phantom-3/download and DJI Inspire 1 manuals can be found at 

http://www.dji.com/product/inspire-1/download.

Very Respectfully, 

Stephen W. Barrington

2914 Veterans Blvd SE

Massillon, OH 44646

Sbarrington114@yahoo.com