Exemption Request for Section 333 of the FAA Reform Act and Part 

11 of the Federal Aviation Regulations from: 14 CFR 21 subpart 

H14 CFR 45.23(b)14 CFR 61.113(a) and (b) 

14 CFR 91.7(a)14 CFR 91.9(b)(2)14 CFR 91.10314 CFR 

91.10914 CFR 91.119(c)14 CFR 91.12114 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) 

Commercial operation of an UAS, as described here, which are 

equipped with a camera and devices (GPS, antenna, programmers) 

that would provide professional services in the following areas:

1. Aerial photography and/or video production for public and/or 

private use including real estate, commercial, surveying, architecture 

and other related professional activities. 

2. Aerial video and/or photography for public and/or private use 

including television, public events and cinematography.

3. Aerial inspection/photography of residential/commercial structures 

under contract with the owners or local businesses.

I plan to operate a UAS, the DJI PHANTOM 2. The Phantom 2 is 

referred to as a quad-copter with an approximate weight of about 3 

pounds. It is equipped with four brushless motors that are driven by 

electric motors powered by batteries. The UAS has a maximum 

airspeed of 15 m/s and has built in geo-fencing – which is programed 

to avoid zones (airports, hotels, stadiums etc.). In addition is 

programmed with established flight limits (under 400ft altitude). 

Also, given the size of the UAS’s involved and the restricted 

controlled environment within which they will operate, the applicant 

fits within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. Also due 

to the size of the UASs and the controlled areas in which the relevant 

UASs will operate, approval of the application presents no national 

security issue. Given the following, the grant of the requested 

exemptions is clearly in the public interest.

1. The UAS will weigh less than 55 lbs.
2. Flights will be operated within line of sight of operator.

3. Maximum total flight time for each operational flight will be 25 

minutes.

4. Flights will be terminated at 15% battery power reserve.

4. Flights will be operated at an altitude of no more than 400 feet 

5. UAS operator will be trained in the proper safety and operations of 

the UAS. 

6. The UAS will only operate within a controlled area as defined in the 

Procedures.

7. The operator will post advisor notice around the controlled area.

8. The operator will have been trained in operation of UAS generally 

and received up-to-date information on the particular UAS to be 

operated as required.

9. If the UAS loses communications or loses its GPS signal, the UAS 

will have capability to return to a pre-determined location within the 

Security Perimeter and land. Which in this event the first procedure 

will be to engaged course lock (return to ‘home-point’ within a 60ft 

radius) then after, proceed with home lock (return above takeoff 

point). In the event that the above procedures fail – the operator will 

activate the ‘fail safe’ option, in which will land the UAS to the ground 

near the takeoff point.

10. The UAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies. 

These new unmanned aircraft (UAS) have several added safety 

mechanisms including but not limited to:

 Ground looking cameras for more stability in flight.

 More accurate GPS systems for greater reliability.

 More reliable lifting motors to run the thrust propulsion systems.

 More reliable computer based Engine Control Units.
 Higher resolution video feeds to ground for greater situational 

awareness.

 More flight data sent to the ground controls for grater situational

awareness.

 More reliable fail safe features for greater safety on the ground.

Therefore, the applicant respectfully requests that the FAA grant the 

requested exemption and are prepared to modify or amend any part 

of this request to satisfy the need for an equivalent level of safety. I 

thank you for your time and look forward to working with the FAA to 

become more knowledgeable and certified in flying UAS’ 

Please contact me through my email (business.aerial@gmail.com) if 

any additional information is needed. 

Respectfully,

Ryan M Curran, Owner

Rise Above Media