Michael Sutton

1 Cassie Lane, Merrimack NH 03054

603-320-0473

msuttongnv@gmail.com

I am requesting relief from 14 CFR part 21 requested to operate an unmanned aircraft system 

(UAS) to conduct aerial photography and videography for real estate, architecture, land 

surveying, engineering and other related professional activities; for television, public events, 

cinematography and news gathering; for inspection/photography of structures and infrastructure; 

for providing live video feed to assist with search and rescue operations.

I am requesting an exemption in accordance to Section 333 of Public Law 112−95 in reference to 

49 U.S.C. § 44704 as my craft meets all requirements. They are both under 55lbs (well under 

20lbs), have telemetry and data logging. Safety provisions are built in and adhered to (return to 

designated area when power is low or on request, GPS, Flight logs, pre-flight checks, regular 

maintenance). If I am granted an exemption, it would benefit numerous businesses in my area 

that do not have other options for aerial inspection of roofs or real estate companies that need 

aerial property assessments and any law enforcement agencies that need aerial recon and search 

assistance. By having an exemption my perspective clients would have piece of mind that all 

safety precautions and laws are followed as they will want these services and we get requests 

daily. 

The UAS craft we would be using is the DJI Inspire 1 and the 3D Robotics Solo (also known as 

the 3DR Solo). 

Both UAS crafts have telemetry built in. Both crafts have flight log recording on board and to 

the controller where the info is stored and cannot be tampered with. The crafts both have built in 

HD cameras and transmission links to the controllers where all video is stored. The crafts both 

have dynamic return to home and return to designated area should there be any issues with power 

etc. The crafts both have live map and radar and features a robust GPS system. The DJI Inspire 

1 craft weights 6.4lbs and the 3DR Solo weighs in at 3.9lbs. The craft has programmable safety 

perimeters built in to restrict altitude and distance. The crafts both have No Fly Zone restrictions 

programed and locked. The crafts both feature return to home at designated perimeter settings. I 

have both set to 30% and I never fly on batteries with less than 90% capacity. Both crafts run on 

5.8Ghz transmitters and both feature restrictions for limited flight distance and height built into 

and locked via the software which is required to fly. I plan on flying well under the 400’

imposed ceiling and never over crowds of people. Neither craft can go faster than 50mph which 

is well below the requirement. I operate with Visual Line Of Sight and Visual Observer at all 

times.

Maintenance. The crafts are maintained on a regular basis and pre-flight checks evaluate 

hardware and software before every flight. New props are used on every tenth flight. New 

batteries are used every six months and the old ones are recycled. Each craft also gets a post 

flight check. 
In summary I am looking for a Section 333 Exemption with relief from 14 CFR part 21. I plan 

on using the DJI Inspire 1 and 3D Robotics Solo lightweight quadcopters to conduct aerial 

photography and videography for real estate, architecture, land surveying, engineering and other 

related professional activities; for television, public events, cinematography and news gathering; 

for inspection/photography of structures and infrastructure; for providing live video feed to assist 

with search and rescue operations. Each craft is under 10lbs, has an abundance of safety 

measures and adjustable perimeters built in. Each craft has an intelligent control system that 

records both video and flight log data. Each craft has a dynamic return to home feature and 

monitoring of power, direction and visuals. Each craft will be operated well below the 400’

ceiling requirement. Each craft receives a pre and post flight check along with regular 

maintenance. I have already registered with the FAA UAS registration. My N Number is on 

each craft. My UAS Certificate Number is FA3AAEKXRR