Robert Frank 

R Frank Photography

4320 Miller Ave

Erie, PA 16509

814-520-3985

rob@rfrankphotography.com

Re: Exemption Request Section 333 of the FAA Reform Act

Dear Sir/Madam I am submitting this petition on my own, on the behalf of my company 

R Frank Photography, without the aid of legal council.

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

Act), and 14 C.F.R. Part 11, R Frank Photography (RFP) which is owned and operated 

by Robert Frank, a sole proprietor LLC, operating in the State of Pennsylvania.

Robert Frank who has been building and operating Small Unmanned Aircraft Systems 

for the past 5 years, wishes to apply for an exemption from the Federal Aviation 

Regulations (FAR) listed below to allow operation of our sUAS 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.

The requested exemption would permit RFP to pursue its commercial interests in 

providing services to companies interested in aerial data that can only be captured by 

using newly developed sUAS in the following areas:

 Surveying and 3D aerial mapping

 Agriculture crop assessment and growth patterns

 Golf course management

 Insurance company claim assessment

 Special events

 Construction site and ecological impact assessment

RFP asserts that all sUAS flights that will occur over private or controlled access 

property will do so with the property owner’s consent and knowledge and that only 

people who have consented or otherwise have agreed to be in the area where flight 

activity is taking place. Additionally, I have extensive flight time logged with sUAS 

devices. Our observers will attend ground school to be taught the rules and regulation 

as they pertain to operating private aircraft under Visual Flight Rules (VFR) over civilian 

population areas as described and set forth in the Aeronautical Information Manual.

The substance of this request is essentially the same as that granted to Falcon 

Sky Cam Regulatory Docket No. FAA-2014-0884 in that RFP is engaged in aerial 

photography and videography of land, buildings, and insurance claims, by using remote 

controlled sUAS to see the condition of fields, crops, ecological impact, and financial 

losses do to destruction by fire and other natural disasters, without the need to drive 
over or climb on the property being so assessed. RFP has a sUAS equipped with 

cameras for aerial photography including video and still pictures and special lens 

adaptations to make them very accurate in the 3 D mapping activity. In doing so we 

have the ability to produce high-resolution photography of remote locations that would 

be difficult or dangerous to reach on foot. This would be especially problematic while 

doing loss claim work for insurance companies. RFP’s exemption request would permit 

us to operate lightweight, unmanned (remotely controlled in line of sight) sUAS’s in 

tightly controlled and limited airspace. Predetermined, specifically marked areas of 

operation as well as Global Positioning Satellite (GPS) navigation maps which 

incorporate restricted, no fly zones and control zones of airports, will allow EAI to 

operate within current safety parameters as well as the new ones being implemented.

The Extent of Relief EAI Seeks and Its Justification for Such Relief:

Regulation from EAI request exemption:

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

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. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. (91.401-91.417)

Unmanned Aircraft System

sUASs are seen as a better photographic platform to helicopters because these smaller 

devices are less expensive, they produce less noise, and they have much less 

environmental impact and are less likely to cause injury to the public and or property.

I am petitioning for exemption to enable EAI to operate DJI Phantom 3, equipped with a

proprietary 3 axis gimbal and camera system. This sUAS has a built in capacity to limit 

the height it flies above the ground, to limit the radius of the distance it flies from the 

operator and to exclude it for Class B, C, and D airspace including No Fly Restricted 

Zones. The Phantom 3 also has the failsafe feature of the Naza-M autopilot system 

which means when the communication between the main controller and the transmitter 

is lost, the Phantom will return to the home starting point and land safely.

The above specifications meet with the Model Aircraft Operating Standards as set 

below:

The petitioner will only operate its sUAS in line of sight of a pilot/observer and will 

operate at sites that are sufficient distance from populated areas within the sterile area 

described in the FOPM. Such operations will insure that the sUAS will not create a 

hazard to users of the national airspace or the public.
When flying sUAS within 3 miles of an airport, airport operators will be notified and 

the operator will give the right of way to avoid flying in the proximity of full scale aircraft.

Maximum flight time for each operational flight will be 25 minutes.

Flights will be terminated at 25% battery power reserve should that occur prior to the 

30 minute limit.

The sUAS will be programmed so it will not be operated at an altitude of no more than 

400 feet AGL, and not more than 200 feet above a fixed platform from which operations 

are conducted.

The minimum crew for each operation will consist of the sUAS pilot and the Visual

Observer.

The sUAS will weigh less than 55 pounds including its payload of camera and gimbal.

The sUAS will fly no more than 50 knots and can hover plus move horizontally and

vertically.

Given the small size of the sUAS, and the restricted airspace within which it will 

operate, I believe our sUAS operations will comply with both the spirit and the rules 

intended by the Reform Act safety requirements.

As part of this request for exemption, RFP gives personal assurance that all persons 

involved in aerial operations have completed sUAS education and training including all 

applicable regulations and guidance documents.

I respectfully request exemption under Section 333 to enable RFP to operate efficient, 

limited, low risk commercial sUAS operations for the activities stated, respecting at all 

times, the space and privacy of citizens and property as we keep our skies safe.

Sincerely yours,

Robert Frank

R Frank Photography

4320 Miller Ave

Erie, PA 16509

814.520.3985

rob@rfrankphotography.com