1 Jeremy R Skeens, DPT

Jeremy R. Skeens, DPT

10807 N Oakland Ave

Kansas City, Missouri

(402) 587-1548

Jrskeens@gmail.com 

July 21, 2015

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

To Whom It May Concern:

I, Jeremy Skeens, am petitioning for an exemption pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012. I, Jeremy Skeens, an owner and operator of small 

unmanned aircraft, is applying for exemption from the federal aviation regulations (“FARs”) 

listed below so that I, Jeremy Skeens, may operate an unmanned aircraft system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration.

Petition:

Regulations from which the exemption is requested: 14 CFR 61.23(a) and(c) 14 CFR 

61.101(e)(4) and (5) 14 CFR 61.113(a) 14 CFR 61.315(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 

CFR 91.121 14 CFR 91.151(a)(1) 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) to the extent necessary to allow the petitioner to operate the 

DJI Phantom 3 Professional UAS to perform aerial video and photographic collection. 

Regarding the Unmanned Aircraft System:

I, Jeremy Skeens, am petitioning to use the Phantom 3 Professional Unmanned Aircraft System 

to capture aerial photography and videography for commercial use. The DJI Phantom 3 is a 

quad-rotor Unmanned Aircraft System (UAS) weighing less than 3 pounds. The Phantom 3 UAS 

that I will be responsible for also utilizes a mobile ground station. The UAS features a safety 

Return to Home function that in the event of a signal loss, will return to a preset position and 

land. The Return to Home feature can also be triggered manually. The remote connects to your 

phone or tablet and a 720p HD view of everything your camera sees as you fly is displayed live. 

This immersive view streams to you in absolute clarity, enabling safe flying. From takeoff to 

landing, the Phantom 3 responds to commands while automatically handling the most complex 

aspects of safe, stable flight. 
2 Jeremy R Skeens, DPT

Attached, you’ll find a copy of the Phantom 3 Advanced user manual that explains the excess 

safety measures taken to ensure no issues arise.

UAS Operating Parameters & the Unmanned Aircraft PIC:

I will abide by the following additional operating conditions under this exemption, which ensures 

a level of safety at least equal to existing rules:

● Operate UAS below 250 feet AGL and within a radius distance of 1000 feet from the 

controller to aid in direct line of sight visual observation

● Obtain permission from the owner/controller of any vessels, vehicles and structures 

when operations may be conducted closer than 500 feet to any such vessels, vehicles or 

structures; we will conduct a safety assessment of the risk of operating closer to those 

objects and determine that it does not present an undue hazard

● Operate the UAS for 5-15 minutes per flight

● Land UAS prior to the manufacturer’s recommended minimum level of battery power

● Operate UAS during daylight hours 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

● Conduct all operations under the flight safety protocols contained in the operating 

documents and will actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols

● Contact respective airports if operations will be within 5 miles to advise them of his 

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

● Only operate in safe environments that are strictly controlled, are away from power lines, 

elevated lights and airports

● Conduct extensive preflight inspections and protocols, during which safety carries 

primary importance. UAS Pilot in Command (PIC) All PICs will demonstrate the required 

aeronautical knowledge and the ability to safely operate the UAS in a manner consistent

with how the UAS will be operated for the requested exemption, including evasive and 
3 Jeremy R Skeens, DPT

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures

● The pre-flight inspection section in the operating documents will account for all 

discrepancies, i.e. inoperable components, items, or equipment, not already covered in 

the relevant sections of the operating documents 

● I will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements

● I will carry out maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, and alterations will 

be noted in the aircraft records, including total flight hours, description of work 

accomplished, and the signature of the authorized person returning the UAS to service

● Each UAS operated will comply with all manufacturer's Safety Bulletins

● UAS operations will not be conducted during night, as defined in 14 CFR 1.1. All 

operations will be conducted under visual meteorological conditions (VMC)

● The UA will not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart

● If a UA loses communications or loses its GPS signal, it will return to a predetermined 

location within the planned operating area and land or be recovered in accordance with 

the operating documents

● The PIC will abort a flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents

● The PIC will not begin a flight unless (considering wind and forecast weather conditions) 

there is enough power to fly at normal cruising speed to the intended landing point and 

land the UA with 30% battery power remaining

● The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at 

the Ground Control Station of the UAS any time the UAS is operating. These documents 

will be made available to the Administrator or any law enforcement official upon request

● The UA will remain clear and yield the right of way to all manned aviation operations and 

activities at all times

● The UAS will not be operated by the PIC from any moving device or vehicle

● Flight operations will be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 
4 Jeremy R Skeens, DPT

○ a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. We will 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 and/or; 

○ b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission 

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

● All operations will be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

● Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to 

the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

Public Interest: 

Aerial videography and photography for marketing has been around for a long time through 

manned fixed wing aircraft and helicopters. Its cost, however, has been nearly unreachable for 

many small businesses. Granting this exemption to me would allow me to provide this service at 

a much lower cost. My UAS will pose no threat to the public given its small size and lack of 

combustible fuel when compared to manned aircraft. The return to home feature proves to be a 

failsafe plan that will ensure safety is not an issue. 

Conclusion: 

As set forth herein, Jeremy Skeens seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Phantom 3 UAS commercially using aerial photography and videography. 

By granting the 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 myself, Jeremy R. Skeens, to safely and efficiently operate its UAS commercially 

within the NAS.
5 Jeremy R Skeens, DPT

Regards;

Jeremy R. Skeens, DPT