December 05, 2015

Petition of Steven L Dobyns, Realtor and ATP certified pilot with 

CL-65 Type Rating, for Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012. 

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 and 14 CFR Part 11, Steven L Dobyns, hereby 

applies for an exemption from Federal Aviation Regulations 

(FARs) identified below, to allow commercial operations of small 

unmanned aerial system (i.e., sUAS).

This exemption is in accordance with protocols outlined in this 

petition for exemption, the enclosed, the DJI UAS manufacturer's 

operations and/or instructions manual, DJI UAS User’s Manuals, 

DJI UAS Quick Start Guides, and any other requirements 

established by the FAA pursuant to Section 333 of the Reform 

Act.

This exemption would permit commercial operation by Steven L 

Dobyns, which uses DJI Phantom 3 Professional, and DJI 

Phantom 2 Standard to conduct real estate photography and 

videography, local promotional photography and videography, and 

aerial mapping and survey. Steven L Dobyns’ operation under the 

exemption will be subject to strict operating requirements and 

conditions to ensure safety at all times and under conditions as 
may be modified by the FAA as required by Section 333.

UAS’s operated by Steven L Dobyns will be operated under 

controlled VFR conditions at low altitude in airspace that is 

permitted in accordance with Steven L Dobyns’ approved 

Certificate of Authorization (COA). 

Steven L Dobyns respectfully submits this request for an 

exemption because it would enhance services provided to clients 

in the selling of their real estate properties. The FAA can have 

confidence that these operations will be conducted at the highest 

level of safety and only with written approval of property owners. 

Steven L Dobyns has thousands of hours of Pt.121 experience 

and will conduct these operations with same level of safety. 

For your convenience, Steven L Dobyns has organized this 

Exemption Request as follows: 

 I. Petitioner's Description

 II. Description of Proposed Operations

 III. Regulations From Which Exemption is Requested

 IV. Public Interest 

 V. Privacy

 IX. Conclusion 

I. Petitioner's Description:

Steven L Dobyns is Realtor in Cincinnati, Ohio and member of the 

Cincinnati Board of Realtors and wishes to provide aerial 

photography and videography to aid in selling real estate, with the 

possibility of providing data to mapping and surveying 
professionals and crop information to local farmers. Steven L 

Dobyns intends to operate in a compliant and safe environment. 

and plans on providing a wide range of services as the sUAS 

market expands.

Steven L Dobyns welcomes the opportunity to consult with FAA 

staff in order to address any issues or concerns that this proposal 

may raise that they believe may require modification.

II. Description of Proposed Operations

Steven L Dobyns will use UASs that are multi-rotor, weighing less 

than 55 pounds including payload. They will operate, under 

normal conditions, at speeds not to exceed 50 mph. The multi 

rotors have the capability to hover and move in the vertical and 

horizontal plane. Additionally the DJI Spreading Wings has 

redundancy built in that allows it to maintain safe flight even with 

the loss of a motor. They will be operated in “line of sight” and 

during daylight hours. Steven L Dobyns will operate at or below 

400 feet AGL. All photography taken will be with the written 

permission of the homeowner and used to help market and sell 

that property. All required permissions and permits would be 

obtained from territorial, state, county or city jurisdictions, 

Including local law enforcement, fire, or other appropriate 

governmental agencies prior to operating a sUAS.

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 grant of the 
requested exemptions is also in the public interest.

Below is a summary of operational limitations and conditions that 

will ensure an equivalent or higher level of safety to operations 

conducted under current regulatory guidelines: 

1. The sUAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of the PIC and visual 

observer.

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

limited to the amount of time the sUAS can be flown and still 

maintain a reserve battery power of no less than 30%.

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

AGL.

5. Flights will be operated at a lateral distance of least 100 feet 

from any inhabited structures, buildings, vehicles, vessels, people 

not associated with the operation or who have not signed a waiver 

in advance of the operation.

6. The sUAS PIC will be the petitioner Steven L Dobyns, ATP 

Rated.

7. The sUAS will operate only within a confined safe and noncongested area.

8. Prior to the operations at a particular location, a pre-flight 

inspection of the vehicle will be conducted and analysis of the 

current weather conditions to make certain the flight will be safe.

9. Steven L Dobyns will use a safety and airworthiness checklist. 

10. The sUAS will be maintained in compliance with the 

manufacturer’s guidelines. 

11. All required permissions and permits will be obtained in 

advance from territorial, state,

county or city jurisdictions, including local law enforcement, fire or 

other appropriate governmental agencies.
12. If the sUAS loses communications signal, the sUAS will have 

the capability to return to a pre-determined location within the safe 

and non-congested area.

13. The sUAS has the capability to abort a flight in case of 

unpredicted obstacles or emergencies.

14. Steven L Dobyns will assure no individuals’ privacy is violated.

15. Procedures have been established to contact ATC prior to 

operating in airspace other than G. 

16. All operations will utilize a visual observer. the UAS will be 

operated within VLOS of the pic and VO at all times. The PIC and 

VO will be able to communicate at all times. Steven L Dobyns will 

be the PIC and will ensure that the VO can perform the duties 

required of the VO.

III. Regulations From Which Exemption is Requested

A. 14CFR 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a),

91.407(a)(1), 91.409(a)(1) and (a)(2), and 91.417(a) and (b)

IV. PUBLIC INTEREST 

The service provided by this photography will benefit the public 

and will done safely. 

They will dramatically enhance the marketing efforts of the people 

selling the properties. They’ll be able to show angles and 

features that can’t be captured by normal cameras. And they’ll 

help buyers get a better eye on what they’re wanting to buy.

These photos will be taken only in safe conditions at low altitudes.
V. Privacy 

Steven L Dobyns will only photograph property with written 

permission of the owners.

VI Conclusion

Steven L Dobyns

8955 E Kemper Rd

Montgomery, OH 45249

513-328-8229

sldobyns@gmail.com

ATP Rated Pilot

Realtor, Comey & Shepherd Realtors