Richard King 

14 78 Gunnison St. 

Mt. Pleasant, SC 29466 

843-475-4271 

mckelvie3 7 @gmail.com 

I, Richard King, owner and operator of a DJI Phantom 3 Professional am submitting 

an Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from: 

14 C.F.R. Part 21, 

14 C.F.R. 45.23(b ), 

14 C.F.R. 61.113(a), 

14 C.F.R. 91.7(a), 

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

14 C.F.R. 91.119(c), 

14 C.F.R. 91.121, 

14 C.F.R. 91.151(a)(1), 

14 C.F.R. 91.203(a) and (b), 

14 C.F.R. 91.40S(a), 

14 C.F.R. 91.407(a)(1), 

14 C.F.R. 91.409(a)(1) and (2), 

14 C.F.R. 91.417(a) and (b). 

in order to conduct Commercial UAS operations that will include aerial 

photography, aerial videography, and aerial inspection of Real Estate, and 

Commercial Structures in the NAS as regulated by the FAA. 

Richard King is an Airline Transport Pilot, rated pilot and operator of a DJI Phantom 

3 Professional UAS. Due to my background as a Real Estate agent and Photographer, 

I would use the UAS to conduct aerial photography and surveying which was 

previously done in manned aircraft. Given the UAS's inherent advantages and 

margins of safety over using manned aircraft to conduct the photography and video, 

I am requesting an Exemption Request Pursuant to Section 333 of the FAA Reform 

Act. 

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

"Reform Act") and 14 CFR Part 11, Richard King, operator of Unmanned Aircraft 

Systems (UAS), hereby applies for an exemption from the listed Federal Aviation 

Regulations ("F ARs") to allow commercial operation of designated UAS, provided 

such operations are conducted within and under the conditions outlined herein or 

as may be established by the FAA as required by Section 333. 

Commercial operation of an UAS, as described herein, which are equipped with 

camera(s) and sensors, would provide professional services in the following areas: 
1. Aerial photography and/or video for public and/or private use including real 

estate, architecture, land surveying, engineering and other related professional 

activities. 

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

television, public events, cinematography and newsgathering. 

3. Aerial inspection/photography of residential/ commercial structures under 

contract with the owners or local government authority. 

4. Aerial inspection/photography of residential/ commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the local 

authorities or government has requested it by contract. 

6. Training to persons individually or belonging to both private andjor public 

organizations to increase awareness and improve safety for current and future UAS 

operations within theNAS. 

I plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an 

unmanned aircraft and a transportable ground station. The Phantom 3 is referred to 

as a quad-copter with a maximum gross weight of about 3 pounds. It is equipped 

with four rotors that are driven by electric motors powered by batteries. The UA has 

a maximum airspeed of 16 mfs. 

Given the small size of the UAS 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 ofUASs to commence. 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: Richard King 

proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations 

provide for an exceptional level of safety to operations. These limitations and 

conditions to which Richard King agrees to be bound when conducting commercial 

operations under an FAA issued exemption including: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. (Day VMC conditions) 

3. Maximum total flight time for each operational flight will be 20 minutes. 

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

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

6. UAS operator will be trained and certified in the proper safety and operations. 

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

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

9. Ifthe 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. 
10. The UAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies. 

Accordingly, 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. We look forward to working with your 

office. A copy of the DJI Phantom 3 User Manual is available upon request. 

Public InterestThe planned UAS user will increase ground safety for aerial mapping, photography 

and surveying operations. This type of data collection has previously been done by 

manned aircraft or by individuals on the ground. Both are more time consuming and 

are more expensive than using a UAS. Use of manned aircraft poses enhanced risk to 

the pilot and onboard crew, who would be several hundred feet in the air. 

The enhanced safety and reduced environmental impact achieved using a UAS and 

carrying no passengers or crew, rather than a manned aircraft of significantly 

greater proportions, carrying crew in addition to flammable fuel, gives the FAA good 

cause to find that the UA operation enabled by this exemption is in the public 

interest. 

With the exemptions of the mentioned rules I will be seeking to make my drone 

photography jvideography services available to the public. Alternatively the public 

had seeked to use helicopters and aircraft to achieve what I can offer in a safer, 

more cost efficient manner. By not using fuel, flying at safe heights and strictly 

following the usage recommendations from DJI and the regulations as set forth by 

the FAA. 

Exemptions Requested Below: 

14 C.F.R. Part 21: Airworthiness Certificates 

Given the size and limited operating area associated with the aircrafts to be 

utilized, an exemption from Part 21 meets the requirements 

of an equivalent level of safety under Part 11 and Section 3 3 3 of the reform Act. 

In all cases, an analysis of these criteria demonstrates that the UA operated 

without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than conventional aircraft 

operating with an airworthiness certificate without restrictions and conditions 

proposed. 

14 C.F.R. 45.23: Display of marks: general 

The UAs will not have a cabin, cockpit, pilot station, fuselage, boom, or tail on 

which to mark certain words or phrases. Further, the two-inch lettering is difficult 

to place on such a small aircraft with dimensions smaller than the minimal 

lettering requirement. 

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in 

command 

The FAA has previously declared that additional manned airship experience of a 

commercially certified pilot would not correlate to the airmanship skills necessary 

for similarly proposed operations in previously issued exemptions to this 
regulation through Exemption Nos. 11062 and 11138. However, I am an ATP 

(Airline Transport Pilot) Rated Pilot and do carry a Class 2 Medical Certificate. 

14 C.F.R 91.7: Civil aircraft airworthiness 

Currently, since there is no certificate applicable to the UAS in question, this 

regulation is inapplicable. 

14 C.F.R. 91.9 (b)(2): Civil aircraft flight manual, marking, and placard 

requirements 

Requires an aircraft flight manual in the aircraft, however there are no pilots or 

passengers on board this aircraft and given its size, this regulation is 

inapplicable. An equivalent level of safety will be achieved by maintaining a 

safety /flight manual with the operator. 

14 C.F.R. 91.119(c): Minimum safe altitudes 

UAS will not operate any higher than 400 feet at ground level. I will not fly over 

congested areas. I will plan operations beforehand, for proper flight safety, and 

proper height analysis as to avoid collisions. 

14 C.F.R. 91.121: Altimeter settings 

The UAS utilize electronic GPS with a barometric sensor. An equivalent level of 

safety will be achieved by using this. 

14 C.F.R. 91.151(a)(1): Fuel Requirements for flight in VFR conditions 

The UAS that I will fly are powered by electricity, using lithium polymer batteries 

that currently have a flight limit of approximately no more than 20 minutes. 

Therefore, due to the limitations of the batteries, it is currently impossible to 

comply with part 91.151. 

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required 

Currently, there are no procedures for providing airworthiness certificates for the 

mentioned UAS. However I will always fly safely while having the manuals with me 

at all times during operation. 

14 C.F.R. 91.405(a): Maintenance Required, 

All maintenance will be accomplished according to manufacture based 

recommendations. 

14 C.F.R. 91.407(a)(1): Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, 

14 C.F.R. 91.409(a)(1) and (2): Inspections & 

14 C.F.R. 91.417 (a) and (b): Maintenance records 

Maintenance inspections may be required and should be granted since they only 

apply to aircraft with an airworthiness certificate. However I, will 

perform preflight inspections of the UAS before each flight as outlined in the 

operating documents and will also follow manufacturer 

recommendations from said operating documents. 

Sincerely, 

Richard King 

14 78 Gunnison St 

Mt. Pleasant, SC 29466