5/29/2015 

Jason Spradley 

High Above SBC 

6024 Summerville Ln 

Bossier City, LA 71111 

(512) 221-7360 

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U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

To Whom It May Concern: 

I, Jason Spradley, am writing to request exemption from the following 

sections of Title 14, Code of Federal Regulations§§ in accordance with the 

FAA's Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012. 

91.119(c), .91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1), 

91.409(a)(2), 91.417(a)&(b). 

I am requesting this exemption in order to operate small unmanned aircraft 

systems (sUAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) for the purposes of aerial photography / video, real 

estate marketing and surveys, and other flight requests that could be 

performed safely and more cost effectively with the use of s UAS at low 

altitude (below 200 feet) within the U.S. national airspace system as 

compared to a manned aircraft. Such requests will only be performed with 

the authorization and permission of clients or authorized agents of such 

clients. No persons will be included in any photo/video without their 
expressed written permission, which will be kept on file for audit at any 

time by the FAA. 

The following reasons for exemption of the above mentioned Federal 

Aviation Regulations (FAR) are being requested by myself, Jason Spradley. 

> 91.119(c) As determined in the Exemption 11138 (Douglas Trudeau) 

- operations conducted closer than 500 feet to the ground may 

require that the UAS be operated closer than soo feet to essential 

persons or objects that would not be possible without additional 

relief. The petitioner requests modification or exemption and 

clarification concerning the terms congested areas and densely 

populated. I am requesting a waiver for this condition to allow 

responsible operation with extreme safety in areas with housing and 

possible other structures. 

> 91.121 As determined in exemption 11138 (Douglas Trudeau) - is 

nonapplicable since the the sUAS does not use an altimeter but does 

utilize electronic GPS with a barometric sensor for altitude hold and 

information. 

);> 91.151(a) As discussed in exemption 11136 (Advanced Aviation 

Solutions LLC) - prior relief has been granted for manned aircraft to 

operate at less than the prescribed minimums, including exemption 

numbers 2689, 10650, and 5745· Additionally, similar UAS specific 

relief has been granted in exemption numbers 10673, 8811, and 

10808 for daytime visual field of reference conditions (VFR). The 

UAS provides battery power measurement to the radio controller held 

by the person in control (PIC). The UA batteries allow for 

apporoximately 20 minutes of flight. I have attached information on 

UASs that describe in more detail the specifics around battery 

management. They contain process and procedures for the PIC when 

battery reaches a certain level. Understanding the limitations on 

proposed operations and location of said operations, the FAA found 

~ that reduced minimum power reserve for flight in daytime VFR Vl 

~ conditions was reasonable. 0 

~ );> 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), 91.417(a) & (b) ..c ¥ As discussed in exemption 11138 (Douglas Trudeau) - I, Jason 

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Spradley, will personally inspect and ensure that each UAS is in top 

condition for safe flight in accordance with all documents pertaining 

to safe operation. The FAA found that adherence to the petitioners 

operating documents and the conditions and limitations specified, 

describing the requirements for maintenance and record keeping and 

inspection were sufficient to ensure that safety would not be adversely 

affected. 

Description of UAS to be Operated under this Exemption 

The DJI Phantom 3 professional and the Yuneec Qsoo are both 

manufactured by highly successful and safety oriented companies. Both 

UASs fly under 25 pounds and carry high definition cameras. The 

advertised maximum speed is less than 15 miles per hour and is powered by 

four electric motors with a distance of less than 18 inches. They both 

utililize gps and compass orientation for stable flight and the ability to 

knowtheir position at all times. The gps on both UASs also do not allow for 

motors to be initialized within a designated No Fly Zone. Real time video 

that includes telemetry is visible by the PIC at all times. The PIC can 

measure battery level, GPS strength, altitude, distance from PIC, along with 

image from camera at all times. Both units have fail safe modes of 

operation for low battery, loss of gps or loss of signal. In these situations, 

the UAS will return to the point of takeoff and motors will automatically 

disengage. Each UAS can be programmed to limit their altitude and 

distance from PIC before flight. Both units are also limited to 

approximately 20 minutes per battery. Both units also have visible LED 

indicators that let the PIC know of any situation that the PIC might 

determine requires the UAS to return home. Most flights last less than 10 

minutes and more information is available in the attachments that I have 

included with this application for exemption. 

Acknowledgment ofF AA Safety Regulations and Guidelines 

I, Jason Spradley, have reviewed and retained a copy of all FAA regulations 

including those regulations and guidelines based on the premise of safety. I 

find all regulations to be reasonable and I will not only meet, but do my 
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best to exceed all safety regulations as set forth by the FAA. My main focus 

is safety and protection of all persons and property that myself or my UAS 

comes in contact with. I have enclosed documents that include a preflight 

and postflight checklist, but I also have an additional checklist that I use 

before, during and after each flight. All moving parts of the UAS are 

inspected to ensure safety. 

Request for Close Proximity Flight 

I, Jason Spradley, am also requesting to be allowed to operate within 5 

miles of an airport similar to reference number 1, providing that 

"The UA may not operate in Class B, C, or D airspace without written 

approval from the FAA. The UA may not operate within 5 nautical miles 

of the geographic center of a non towered airport as denoted on a current 

FAA published aeronautical chart unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in 

accordance with a NOT AM as required by the operator's COA. The letter 

of agreement with the airport management must be made available to the 

Administrator upon request." 

I have permission of the airport administrator or designated official. I will 

have written permission and a documented flight plan for each flight used 

in this manner. The before mentioned written permission and flight plan 

will be kept on file for audit at any time for the FAA. Flight within 5 miles of 

an airport is rare, but in the area I plan to operate, there are several small 

airports that allow UAS flight within 5 miles with permission as noted 

above. 

Other Interests 

I feel that this exemption will allow me not only the ability to gain 

financially for use at the request of different companies, but it will also 

allow me to help educate the public on the safe use of a UAS under proper 

legal guidelines and safety. I feel that this exemption will also allow me to 

perform tasks that not only could not be performed from the ground, but 

would also allow me to perform tasks that would normally put persons at 

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risk to obtain the same information. Many of the structures I would be 

filming would be hazardous for an individual to access. The use of a UAS 

allows for safe visual inspection of not only property, but buildings and 

other structures as well. 

I can also use the UAS to participate in air shows and displays for no charge 

to show the many uses of this type of aircraft when performed under the 

proper legal guidelines. My services will also be offered to local 

organizations such as schools, fire departments, and police departments as 

long as such requests fall under the rules of the exemption that I am 

requesting along with all other FAA guidelines. 

Operations for this petition will also enhance the economic growth of the 

area in which my company resides. 

Summary 

I, Jason Spradley, am requesting this exemption for the purposes of aerial 

photography and video of, not only real estate, but possibly land 

observation, inspection of construction equipment, towers, and other flight 

operations as requested by clients. I am requesting this exemption for the 

reasons noted above and specifically intended these items to be broad 

based on my business plan to extend operations to different areas based on 

requests by clients. Each request will be analyzed by myself, Jason 

Spradley, to validate that these requests can be done in a safe manner and 

in compliance with all FAA regulations. I also plan to use my business and 

myself as a mentor for other small business owners to educate and to assist 

them in starting their own business in accordance with all FAA regulations 

and laws. I have seen several advertisements of people offering these 

services, as specified above, but I have refrained from pursuing 

opportunities for commercial use of my UAS until I can properly be 

authorized by the FAA. 

Personal Information 

I am a member of the AMA, Member # 1071321. I have been flying RC 

aircraft for over 2 years with no incidence and I am an avid builder of RC 

models to include cars, helicopters, and UASs. I have a passion for the 

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hobby and I have been waiting for the opportunity to possibly turn that 

hobby into a venture that would help support my family. 

Documents Attached 

1. DJI Phantom 3 Professional Safety Guidelines 

2. Yuneec Qsoo Owner's Manual 

3. Yuneec Q500 LED Indicators 

References 

1. FAA Exemption Number 11080, Regulatory Document Number FAA2014-0355 in the matter of the petition of Flying Cam INC 

2. FAA Exemption Number 11136, Regulatory Document Number FAA2014- 0508 in the matter of the petition of Advanced Aviation 

Solutions LLC 

3. FAA Exemption Number 11138, Regulatory Document Number FAA2014-0481 in the matter of the petition of Douglas Trudeau 

Thank you for your consideration of my petition for this exemption. I look 

forward to hearing from you soon. Please do not hesitate to reach out to me 

with any questions or if any additional information is needed. 

Respectfully, 

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