James Addison January 4, 2016

1163 SE 65 Circle

Ocala, FL 34472

813-368-4617

DiveInterval@gmail.com

Petition of James Addison

For Exemption Pursuant to Section 333

Of the FAA Modernization and Reform Act of 2012

Dear Director, Flight Standards Service:

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

I, James Addison, a FAA Certified Pilot 3003048 hereby apply for an exemption from Federal 

Aviation Regulations (FARs) identified below to allow commercial operations of an unmanned 

aerial system (UAS).

The exemption is in accordance with protocols outlined in this petition for exemption, and any 

other requirements established by the FAA pursuant to Section 333 of the Reform Act.

This exemption would permit commercial operations by James Addison, which uses and flies a 

Phantom 2 Vision+ (FAA UAS Certificate Number FA3AYKAFC7) to conduct UAS

photography/videography as requested by a third party, UAS flight training, education, real 

estate photography/videography, UAS demonstration flights, accident investigation 

photography/videography, fire investigation photography/videography,

photography/videography requested by local and state law enforcement agencies, and 

search/rescue operations. I (James Addison) as an FAA Certified Pilot would be subject to the 

strict operating requirements and conditions within the current Section 333 exemption and as 

may be modified by the FAA. This would ensure the same level of safety as is currently 

authorized in manned aircraft as published in the current FARs by the FAA.

I (James Addison) will operate under controlled VFR conditions at low altitude in airspace that is 

permitted in accordance with my (James Addison) approved Certificate of Authorization (COA). 

As an FAA Certified Pilot, and having served as a Lieutenant in the US Army and retired 

Lieutenant from the Honolulu Police Department, I have extensive knowledge of the various 

airspace requirements and will be in a position to not only apply the FARs to my own flying, but 

also pass that knowledge on to others interested in UAS flight. Due to my service in the police 

department and US Army, I also have acquired extensive knowledge in safety procedures and 

protocols that will contribute to my abilities to operate under FAA 333.

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I (James Addison) submit this request for exemption because I operate a UAS in the 

performance of my forensic investigative services where I currently analyze the cause and 

effects that contribute to highway fatalities and serious injuries. I (James Addison) have safely 

operated the UAS system for approximately 2 years in training and investigative procedures and 

I have not had any incidents or complaints regarding the operations of the UAS. Furthermore, I 

provide training and investigative services to various law enforcement agencies in Florida and 

throughout the United States. As a retired Police Lieutenant and FAA certified pilot I have 

confidence that the operations I conduct will have a high level of safety incorporated into my 

operations and will share my knowledge with the various law enforcement agencies. Approval 

of my exemption would thereby enhance safety and the ability to teach safety as well as fulfill 

the Secretary of Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) 

of the Reform Act to “establish requirements for the safe operation of such aircraft systems in 

the national airspace system.”

I (James Addison) have organized this Exemption request as follows:

1) Petitioner’s Description

2) Relevant Statutory Authority

3) Qualifications for Approval Under Section 333 of the Reform Act

4) Description of Proposed Operations

5) Regulations from which this request for Exemption is requested

6) Public Interest

7) Privacy

8) Federal Registry Summary

9) Conclusion

1) Petitioner’s Description:

I (James Addison) am headquartered in Ocala, FL. As an individual, I want to 

commercially provide UAS services to third parties requesting 

photography/videography, flight training, education, real estate 

photography/videography, demonstration flights, accident investigation 

photography/videography, fire investigation photography/videography, 

photography/videography requested by local and state law enforcement agencies, and 

search/rescue operations.

I (James Addison) plan to operate in an accident-free environment by:

a) Following all regulation currently published by the FAA and Section 333

b) Identifying any hazard and risk which would not allow for the safe

operations of a UAS

c) Intervene and report when unsafe flying of others appear to exist

d) Train others in the safe operation of UAS and instruct them in all applicable 

FAA-FARs

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The contact information for Petitioner (James Addison) is as follows:

1163 SE 65 Circle 

Ocala, FL 34472

813-368-4617

DiveInterval@gmail.com

2) Relevant Statutory Authority: This petition for an exemption is submitted to fulfill the 

goal of Congress when it passed Section 333 (a) through (c) of the Reform Act. Congress 

has directed the FAA “to safely accelerate the integration of civil unmanned aircraft 

systems (UAS) into the National Airspace System (NAS) before completion of the formal 

UAS rulemaking, based on the following considerations:

1) The UAS’s size, weight, speed, and operational capability

2) Operation of the UAS in close proximity to airports and populated areas

3) Operation of the UAS within the visual line of sight of the operator

If the Secretary determines that such aircraft “may operate safely in the National Airspace 

System, the Secretary shall establish requirements for the safe operation of such aircraft in 

the National Airspace System”.

Additionally, the FAA Administrator has general authority to grant exemptions from its 

safety regulations and minimum standards when the Administrator decides a request 

exemption is in the public interest. A party requesting an exemption must explain why the 

exemption:

1) Would benefit the public as a whole

2) Would not adversely affect safety and would provide a level of safety equal or better 

than existing rules.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as the term is defined 

under 40101 of the ACT, from the requirement that all civil aircraft must have a current 

airworthiness certificate and those regulations requiring commercial pilots to operate 

aircraft in commercial service:

The Administrator may grant an exemption from a

 requirement of a regulation prescribed under subsection

(a) or (b) of this section or any of the sections.

3) Qualifications for Approval Under Section 333 of the Reform Act: The proposed 

operation in this petition for exemption qualifies for expedited approval under 

Section 333 of the Reform Act. Each of the statutory criteria and other relevant 

factors are satisfied.

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The proposed operations would permit James Addison the use of a UAS under controlled 

conditions in airspace that is:

1) Predetermined

2) Controlled as to access

3) Provides an increased level of safety beyond that existing when fixed or rotor 

wing aircraft that are used to accomplish the same purpose

I (James Addison) use a UAS that is a multi-rotor weighing less than 10 pounds including the 

payload which consist of a gimbaled camera used for photography and videography. The UAS

operates only under normal conditions, at an airspeed not to exceed 35 KPH. The UAS has the 

ability to hover, move in a vertical and horizontal plane, as well as yaw around its vertical access 

while in a hover position. In addition, I (James Addison) will operate in a (not to exceed) line of 

sight mode. The UAS that I (James Addison) operate has a pre-programmed AGL limit of 300 

feet which is 100 feet below the Section 333 altitude height limit. A NOTAM will be filed for 

each flight that operates in controlled airspace and would first be approved by the controlling 

FAA facility. All required permissions and permits would be obtained from the controlling 

government agencies prior to operating a UAS.

Given the small size and light weight of the UAS involved and the environment in which 

operations will take place the exemption that I (James Addison) am requesting falls within the 

zone of safety in which Congress desired the FAA to permit commercial UAS operations by 

exemption pending completion of formal rulemaking. In addition, because of the size, weight 

and qualifications/experience of the operator, approval of this exemption presents no hazard in 

the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed 

operations, and the significant public benefit, the granting of this requested exemption to 

James Addison – a FAA Certified Pilot is also in the public interest.

4) Description of Proposed Operations:

To assist the reviewer of this exemption request, I (James Addison) offer a summary of the 

operational limitations and conditions that will ensure an equivalent or higher level of safety to 

operations conducted under current regulatory guidelines:

a) The UAS used will weigh less than 10 pounds including its payload.

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b) Flights will be within line of sight and at or below 300 feet AGL of the PIC.

c) Maximum total flight time will be limited to 20 min and/or 25% of the 

reserved battery power whichever occurs first.

d) Flights will be conducted at a distance of at least 100 feet from any inhabited 

structure, building, vehicle, vessel, people not associated with the operation 

of the UAS.

e) Minimum crew for each operation will consist of the PIC (James Addison) and 

a designated visual observer.

f) The UAS PIC (James Addison) has undergone comprehensive UAS flight 

training for competency and has studied FAA 333 as well as Part 107 

commercial compliance requirements.

g) James Addison will be the only PIC for each mission associated with this 

exemption request.

h) Prior to each commercial mission at a particular location, a site inspection 

will be conducted to insure that all of the flight requirements associated with 

the Section 333 are met.

i) I (James Addison) will use a checklist and callouts associated with the 

Operations Manual.

j) The UAS will be maintained in accordance with the inspection program 

outlined in the manufacturer’s guidelines.

k) In the unlikely event of an accident, I (James Addison) will cease operation 

and report the accident to the appropriate government authority.

l) The PIC and the Visual Controller will at all times be able to communicate by 

voice. 

m) The PIC and Visual Observer are trained in accordance to FAA, NTSB, and 

AFS-80 best practices.

n) All required permissions and permits will be obtained from the local 

government agencies before a flight is conducted.

o) If the UAS loses communication signal with the flight controller, the UAS will 

have the ability to return to the launch location and land automatically.

p) The UAS has the ability via the PIC controller to abort a flight in case of 

unpredicted obstacles or emergencies.

q) I (James Addison) by following FAA, NTSB, and AFS-80 best practices, will 

assure that no individuals’ privacy is violated.

r) I (James Addison) will contact the controlling ATC facility prior to operating in 

airspace other than G.

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5) Regulations from which this Request for Exemption is requested:

A) 14 CFR – 91.103 – Preflight Action

B) 14 CFR – 91.113 – Right-of Way Rules

C) 14 CFR – 91.119 (c) - Minimum Safe Altitudes

D) 14 CFR – 91.121 – Altimeter Settings

E) 14 CFR – 91.151 (b) – Fuel Requirements for Flight in VFR Conditions

G) 14 CFR – 91.405 (a), 91.407 (a) (1), 91.409 (a) (2), 91.417 (a) and (b) – 

Maintenance Inspections

A. 14 CFR § 91.103: I (James Addison) requests an exemption from the preflight 

actions requirements of 14 CFR 91.113 that prescribes the preflight actions under 

which aircraft may operate:

Each pilot in command shall, before beginning a flight, become familiar with all 

available information concerning that flight. 

a. Flight under IFR or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the planned 

flight cannot be completed, and any known traffic delays of which the pilot in 

command has been advised by ATC; 

b. For any flight, runway lengths at airports of intended use, and the 

following takeoff and landing distance information: 

i. For civil aircraft for which an approved Airplane or Rotorcraft 

Flight Manual containing takeoff and landing distance data is required, 

the takeoff and landing distance data contained therein; and 

ii. For civil aircraft other than those specified in paragraph (b)(1) 

of this section, other reliable information appropriate to the aircraft, 

relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and 

temperature.

I (James Addison) will not operate a UAS under IFR conditions or when the 

ceilings are below 1000 feet and the visibility is below 3 statute miles. 

Equivalent Level of Safety: In adherence to FAA, NTSB, and AFS-80 best 

practices, the PIC will assure that the weather will be adequate to complete the 

mission in VFR condition. 

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B. 14 CFR 91.113: Right-of-Way Rules: I (James Addison) request an exemption from 14 CFR 

91.113 Right-of-Way rules, requiring vigilance by each person operating an aircraft so as to see 

and avoid other aircraft. When a rule of this section gives another aircraft the right-of-way, the 

pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well 

clear. 

I (James Addison) operate a small pilotless UAS and cannot comply with these rules as 

they have been written.

Equivalent Level Safety Flying: I (James Addison) operate a UAS at or below an altitude 

of 300 feet AGL, well below the normal operating altitude of other aircraft. I personally 

oversee each mission and have knowledge of the see-and-avoid rules. A Visual Observer 

will assist the PIC in looking for aircraft entering the operations area. It’s the 

responsibility of the PIC to cease operations and land the UAS immediately whenever 

and aircraft comes into the vicinity creating a potential threat. Operations cannot 

recommence until the threat is clear.

C. 14 CFR. § 91.119: Minimum Safe Altitudes Flying: I (James Addison) request an 

exemption from the minimum safe altitude requirements of 14 CFR 91.119 that 

prescribes the minimum safe altitudes under which aircraft may operate: • Over any 

congested area of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal 

radius of 2,000 feet of the aircraft. • Over other than congested areas at an altitude 

of 500 feet above the surface, except over open water or sparsely populated areas. In 

those cases, the aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum 

altitudes when it can be operated "without hazard to persons or property on the 

surface," provided that "each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA."

To provide the intended operations, the UAS is normally operated below 300 

feet AGL. Additionally, due to the nature of the proposed operations, the UAS

will maintain a horizontal distance of at least 100 feet from inhabited structures, 

buildings, vehicles, and vessels, and from people not associated with the 

operation.

Equivalent Level of Safety: Compared to the flight of normal aircraft, I operate a

multi-rotor aircraft weighing less than 10 pounds, and given the lack of fuel, any 

risk associated with these operations is far less than those that presently exist 

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using conventional aircraft. An equivalent level of safety will be achieved given 

the size, weight, and speed of the UAS, as well as the location where it is 

operated. As set forth in the FAA, NTSB, and AFS-80 best practices, the UAS will 

be operated where buildings and people will not be exposed to operations 

without their pre-obtained consent. Because of the advance notice to the 

property owners and participants, all affected individuals will be well aware of 

the planned flight operations prior to commencement of operations. 

Furthermore, by operating at such lower altitudes, the UAS will not interfere 

with aircraft that are subject to the minimum safe altitude regulations.

D. 14C.F.R. § 91.121: Altimeter Settings: I (James Addison) seek an exemption 

from 14 CFR 91.121, which requires a person operating an aircraft to maintain 

cruising altitude or flight level by reference to an altimeter that is set to the 

elevation of the departure airport or barometric pressure. An exemption is 

required because the UAS does not have a barometric altimeter, but rather a 

GPS altitude read out.

Equivalent Level of Safety: An equivalent level of safety will be achieved by 

following the procedures set forth in the FAA, NTSB, and AFS-80 best practices. I 

will confirm the altitude of the launch site shown on the GPS altitude indicator 

before flight. Moreover, as the PIC, I will use the GPS altitude indicator to 

constantly monitor the UAS height, thus ensuring operation at safe altitudes.

E. 14 CFR 91.151(a) Fuel Requirements for Flight in VFR Flying Conditions: I (James 

Addison) requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight 

in VFR conditions. Section91.151 states: a. No person may begin 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 – i. During the day, to fly after that for at least 30 minutes; or ii. At night, to fly 

after that for at least 45 minutes.

The batteries powering the Phantom 2 Vision+ provide approximately 10 to 25

minutes of powered flight. To meet the 30 minutes reserve requirement in 14 

CFR 91.151, UAS flights could not be conducted. Given the limitations on the UAS

proposed flight area and the location of its proposed operations within a 

predetermined area, a safety margin based on a reserve amount of battery life is 

needed.

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Equivalent Level of Safety: An equivalent level of safety will be achieved 

because the operations will be conducted on-site without significant transit time 

by the UAS. All flights will be planned to terminate with no less than 25% reserve 

battery power still available. This restriction would be more than adequate to 

return the UAS safely to its planned landing zone from anywhere in its confined 

area of operation even in the event of an unexpected occurrence. Operation of 

the UAS with less than 30 minutes of reserve fuel does not include the type of 

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

the UAS, and the proximity of the flight operation to the landing zone.

F. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): 

Maintenance Inspections: I (James Addison) also seeks an exemption from the 

maintenance inspection requirements contained in 14 CFR 91.405(a), 91.407(a) 

(1), 91.409(a) (2), 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating 

that each owner or operator of an aircraft "shall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections have 

discrepancies repaired as prescribed in part 43 of this chapter"). An exemption 

to these regulations is needed because Part 43 and these sections only apply to 

aircraft with an airworthiness certificate, which the UAS will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved 

because maintenance and inspections will be performed in accordance with FAA, 

NTSB, and AFS-80 best practices. The operator will ensure that the UAS is in 

working order prior to initiating flight, perform required maintenance, and keep 

a log of any maintenance performed. 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. If mechanical issues arise, the 

UAS size and carrying capacity, and the fact that flight operations will only take 

place in restricted areas for limited periods of time, creates less risk than that 

associated with conventional rotorcraft performing the same operation.

6) PUBLIC INTEREST: Granting James Addison an FAA exemption furthers the 

public interest. National policy set by Congress favors early integration of the 

UAS into the national airspace in controlled, safe working environments such as 

those propose in this petition. The vision I have is to help facilitate safe 

integration of UAS’s into mainstream USA in the following areas: 

• Photography and Videography where the shot requires unique views. 

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• News Gathering - Similar to movies and videography, each news assignment 

may require a completely different shot or view of a scene. With budgets for 

traditional helicopter use being greatly reduced, the UAS is the perfect solution 

to allow for easy news gathering for a fraction of the cost. The UAS can be 

operated in a sterile area away from the public, while the traditional helicopter 

must operate over persons and property increasing the danger to individuals.

• Real Estate - The UAS can be used in all areas of real estate, including 

commercial, residential and industrial properties. Using a UAS, real estate 

professionals can create promotional videos, photos and unique shots that 

normal camera aspects cannot capture. The UAS creates an easy-to-use video 

and photo platform which enables properties to stand out, providing dazzling 

views that are typically shown via expensive computer animation or costly 

helicopter rentals.

7) Privacy: I (James Addison) am deeply committed to protecting public 

privacy. As a skilled UAS Pilot I am well aware that many individuals have 

concerns about privacy from the operations of UAS’s.

8) Federal Registry Summary: Pursuant to 14 CFR Part 11, the following 

summary is provided for publication in the Federal Register, should it be 

determined that publication is needed: I (James Addison) seeks an exemption 

from the following rules: 14 CFR § 91.103; 14 CFR § 91.113; 14 CFR § 91.119 (c); 

14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR § 91.405(a), 91.407(a) (1), 91.409(a) 

(2); 91.417(a) and (b).

Approval of this exemption request allows James Addison to conduct commercial 

operations with small and lightweight unmanned aerial systems. My singular 

vision is to enhance safety of UAS operations in the NAS while reducing risk to 

the general public and property owners.

The Phantom 2 Vision+ weighing less than 10 pounds and powered by batteries 

and electric motors, eliminates virtually all of that risk given the reduced mass 

and lack of combustible fuel carried on board. The UAS is transported to the 

designated mission area and set up there. The UAS will carry no passengers or 

crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights.

The operation of this UAS will provide an equivalent level of safety supporting 

the grant of the exemptions requested herein, including exempting the applicant 

from the requirements of several regulations and allowing commercial 

operations. The lightweight UAS will operate at slow speeds, close to the ground, 

and in a sterile environment. As a result, it is far safer than conventional fixed 

wing aircraft or helicopters.

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9)Conclusion: For the foregoing reason, it is requested that the regulatory 

exemptions requested herein be granted, and the Petitioner (James Addison) be 

permitted to conduct commercial operations using a UAS based on the 

aforementioned purposes.

If additional information is required, or if you have any questions regarding this Petition 

for Exemption, please contact the undersigned at:

 James Addison

1163 SE 65 Circle

 Ocala, Florida 34472

813-368-4617

DiveInterval@gmail.com

Submitted By: James Addison Dated: January 4, 2016

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