John W. Lewis

5960 Siegen Lane

Apt 5207

Baton Rouge, La 70809

E-Mail: johnlewis1@me.com

Ph: (225) 910-3394

To Whom It May Concern,

This petition is being submitted on my behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 

11, John W. Lewis, a freelance photographer, hereby applies for an exemption from the Federal Aviation 

Regulations (FARs) listed below to allow operation of my Small Unmanned Aerial Vehicle (sUAV) commercially 

in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with 

and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit John W. Lewis to pursue his commercial interests in providing services to 

clients using a sUAV for taking photographs for Real Estate purposes, weddings, birthday parties and other social 

events. John W. Lewis states that all sUAV flights will occur over private or controlled access property and will do 

so with the property owner's consent and knowledge and that only people who have consented or otherwise have 

agreed to be within the SUAV’s radius during photography applications.

John W. Lewis has demonstrated the ability to safely and effectively fly the sUAV DJI Phantom 3 which will be 

used for all commercial and private purposes. John W. Lewis complies with all local ordinances and laws regarding 

the operation of the sUAV, and adheres to all weather and environmental restrictions or limitations in reference to 

the operations of sUAV’s. John W. Lewis has been in the amateur photography business for nearly 5 years, and has 

extensive experience safely flying other DJI brand sUAV’s for hobby and recreational purposes. John W. Lewis has 

logged nearly 2000 hours safely operating sUAV’s, ranging from many brands, with a specialty in DJI products. 

All flights will occur in ordinance with any state or local laws regarding privacy. I, John W. Lewis, am seeking the 

exemption because I am committed to complying with all of the rules, limitations, guidelines, and future legislation 

set forth by the FAA. I agree to operate the sUAV in the manner that I have described, and for the purposes that I 

have described. Without the exemptions request granted, I would be unable to safely and effectively run my new 

business, and it is my intention to comply with the FAA and obtain an exemption of the following regulations.

I have included a list of regulations from which I seek exemption, and a complete list of responsibilities that I 

assume. I have also included information regarding the aircraft, safety and public benefit.

These are the following regulations from which I seek exemption:

14 C.F.R. Part 21

14 C.F.R. 91.103(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.203(a) & (b)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. 91.401 – 91.417

1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize 

risk to the NAS or to persons and property on the ground. Specifically, petitioners should describe 
the design and operational characteristics for the type(s) of UAS they intend to operate, e.g. aircraft 

performance and performance limitations, operating procedures, and aircraft loading information in 

as much detail as possible.

a. The sUAV will never be flown at heights above 400 ft, with the vast majority taking place below

200 ft. My sUAV is equipped with GPS and GLONASS dual-positioning, making it and the 

operator completely aware of it’s location at all times, within 0.5-1.0 m. There is a ground station 

for take-off. This will be a recorded take-off point that the sUAV will automatically return to for 

safe landing. This feature is especially beneficial in a low-battery situation. The sUAV is 

equipped with sensors that make spatial calculations in real-time to offer the safest flight possible. 

The intelligent battery system on the sUAV continuously calculates it’s distance from the take-off 

point and the amount of power needed to return to safely land at the take-off point. The 6-axis 

gyroscope and accelerometer relays even the slightest changes in tilt and movement, offering an 

unprecedented level of control. Internal ESC’s (Electronic Speed Controls) maintain stable, 

predictable flight speed. The sUAV has a top speed of 35 mph. The weight of the sUAV is 1216 

grams, or roughly 2.7 lbs. The max flight time of the sUAV is 23 minutes. 

2. Petitioners should describe any procedures they would implement, such as pre-flight inspections, 

maintenance, and repair, to ensure that the UAS is in a condition for safe flight.

a. The sUAV shall only be operated on and flown over private property and with the owner’s 

consent. There will be a thorough pre-flight inspection conducted on my private property of the 

take-off platform and the aircraft. The sUAV will always be flown in a wide open area. There will 

also be a test flight conducted on my property prior to any operations to ensure proper function 

and safety of the aircraft, and that all electronic devices are functioning appropriately. All 

necessary maintenance will be carried out in my shop to the standards of the sUAV manufacturer. 

All pre-flight inspections and testing will be repeated after any maintenance or service to the 

aircraft, and prior to any commercial flight operations.

3. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and 

associated equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies 

with Federal Communications Commission (FCC) or other appropriate government oversight 

agency requirements. 

a. The sUAV operates on a RF spectrum of 2.4-2.485 Ghz. The ground station operates on either a 

900mhz or 2.4Ghz RF. The Wi-Fi video link has an operating frequency of 2.4-2.483 Ghz. The 

sUAV is in compliance with all current FCC rules and regulations and meets all current FCC 

requirements. 

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible 

for the operation of the UAS.

a. The SUAV PIC will hold at least a Sport, Recreational or Commercial pilot’s license. The PIC 

must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. 

The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license 

issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 

in an aircraft in which the PIC is rated on his or her pilot certificate. The PIC operating the sUAV 

will be required to have a minimum of 100 hours of flight experience with the sUAV used for 

operations. The PIC must also have a minimum of 40 hours total flight time with the airplane that 

was flown to achieve their license. 

5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible 

for the operation of the UAS. 

a. The PIC must hold a current FAA airman medical certificate or a valid U.S. driver’s license issued 

by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government.

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how 

the proposed operation(s) would not adversely affect safety, or how they would provide a level of 
safety at least equivalent to that provided by the rule from which exemption is sought. Petitioners 

should address any plans to implement clearly defined operational borders and procedures to ensure 

public safety, which includes persons and property both in the air and on the ground. 

a. The Specifications Of The DJI Phantom 3 Demonstrate Its Safe Characteristics.

The sUAV does not create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security considering its size, weight, speed, and operational capability.

b. The DJI Phantom 3 Autonomous Flight And Navigation Modes Enable The sUAS To 

Remain Within A Defined Operational Area.

The DJI Phantom 3 may be operated in both manual and fully autonomous flight modes. There 

will be pre-defined flight zones set that the sUAS will not be able to fly out of. 

c. The DJI Phantom 3 Is Designed For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Phantom 3 does not reacquire control link data from the GCS

(Ground Control Station), the sUAS will assume that the Control Link is lost and the sUAS will 

return to the home position (i.e., failsafe mode) via GPS and GLONASS, and will descend to the 

takeoff position.

d. The sUAS will always be operated within VLOS of the PIC, never at altitudes higher than 400ft, 

and never within 25ft of any structure. The sUAS will never be flown within 5 nautical miles of 

any airport, helipad or other airport facility. The sUAS will be flown according to all rules and 

regulations set forth by the FAA.

e. All persons within the pre-defined flight area will be notified of the operation.

f. The intended operation of the sUAS will be for Real Estate photography and special events 

photography and videography, such as: weddings, birthday parties, social gatherings. 

g. There will be a spotter present during all flights to assist in the detection of other aircraft. 

7. Petitioners should specify the proposed maximum operating speed and altitude, and describe 

minimum flight visibility and distance from clouds for their intended operation(s). Petitioners should 

describe potential hazards and safety mitigations associated with these proposed conditions.

a. Maximum operating speed of the DJI Phantom 3 is 35 mph. Typical operating speed will be much 

less, around 15 mph. Altitude of the sUAS will never exceed 400 ft. The sUAS will never be 

operated in any visibility of less than 15 nautical miles. The sUAS will never be flown at an 

altitude high enough to be near any clouds. All proposed hazards will be mitigated by following 

the rules and regulations set forth by the FAA in 14 C.F.R, listed in this petition and within the 

DJI Phantom 3 Operator’s Manual, which is attached. 

8. Petitioners should describe the characteristics of the area of intended operation(s) and the associated 

potential hazards, in accordance with the statutory mandate under Section 333.

a. The intended flight operations will largely take place over private property, and only with 

approval from the land owner. If any operations of the sUAS take place in any public area, all 

personnel within that area will be notified and made aware of safety measures set in place and all 

pertinent information regarding the operation of the sUAS. All local laws and regulations will be 

followed during public sUAS operations. Any public operation of the sUAS will only be carried 

out after permission is granted by local authority and all rules and regulations set forth by that 

local authority will be followed.

9. Petitioners should describe if they intend to operate in the proximity of any airports, in accordance 

with the statutory mandate under Section 333 regarding proximity to airports.

a. No operations of the DJI Phantom 3 or any other sUAS will be carried out within the proximity of 

any airport. All operations will be carried out following the regulations set forth by Section 333. 

10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the statutory 

mandate under Section 333(b)(1). Petitioners should describe how they intend to comply with his 

mandate. 

a. The sUAS will always be operated within VLOS of the PIC. This will be accomplished with the 

assistance of the Spotter that will be present during all sUAS operations. The PIC will be held 

accountable by the Spotter to always maintain a VLOS with the sUAS. The PIC will operate the 

sUAS according to all FAA Section 333 guidelines pertaining to VLOS.
11. Petitioners should describe any procedures they would implement for conducting a preflight safety 

risk assessment to determine that the UAS is in a condition for safe flight (14 CFR § 91.7(b)) and that 

the planned operation can be completed safely.

a. Preflight inspection of aircraft rotors, camera and gimbal assembly will be carried out in my work 

shop prior to all flight operations in accordance with all manufacturer requirements and 

suggestions. Preflight inspection along with a test flight will be carried out on John W. Lewis’ 

private property prior to any commercial operation. Prior to any commercial operation, a preflight 

safety meeting will be conducted with the PIC and Spotter to address any potential safety hazards, 

obstructions, atmospheric visibility, weather conditions and any other factors involved with the 

specific task. 

12. The FAA intends to require entities who obtain an exemption under this process to also obtain a 

Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization prior to 

conducting operation(s) in the NAS.

a. If an exemption is granted to me through this petition, John W. Lewis will obtain a COA from the 

FAA Air Traffic Organization prior to conducting any operations in the NAS. 

I have also attached a copy of the DJI Phantom 3 Safety Guidelines. All rules, regulations and limitations 

set forth in the included document will be adhered to. 

Thank you for your time in reviewing my petition and it is my great hope and desire that you grant me 

exemption so that I can safely and effectively operate my new business for the good of my customers and the 

economy.

Sincerely,

John W. Lewis


The PIC will adhere to the following rules and responsibilities:

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when weighing less than 55

pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to

amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are permitted with proper 

permissions from motion-picture provider. SUAS must be insured or insurance provided by motion-picture provider 

prior to any on-set flights

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use

either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will

the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft

manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be

reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be

able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued

airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight

(VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC

always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic

messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and

cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the

duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the

conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents.

The operating documents must be accessible during UAS operations and made available to the Administrator upon

request. If a discrepancy exists between the conditions and 4 limitations in this exemption and the procedures

outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.

Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update

or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and

revised documents to the Administrator or any law enforcement official upon request. The operator must also

present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the

operator determines that any update or revision would affect the basis upon which the FAA granted this exemption,

then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office

(AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics,

e.g., replacement of a flight critical component, must undergo a functional test flight prior to conducting further

operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain

at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose

an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe

operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for

safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, items,

or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit

requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.
13. Under this grant of exemption, a PIC must have a minimum of 1 years worth of advancd sUAS flying experience 

and training using the DJI Inspire 1. PIC must hold a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC and sUAS must be fully 

insured through the current sUAS insurer AerialPak, if there should be a change in insurance providers this 

exemption must be resubmitted.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for

the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and

determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated

under this exemption are permitted under the terms of this exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all

persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not

authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current

FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as

denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement

with the airport management must be made available to the Administrator or any law enforcement official upon

request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when

visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location

within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is

enough available power for the UA to conduct the intended operation and to operate after that for at least five

minutes or with the reserve power recommended by the manufacturer if greater.

21. All aircraft operated in accordance with this exemption must be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45,

Subpart C. Markings must be as large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required

under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time

the aircraft is operating. These documents must be made available to the Administrator or any law enforcement

official upon request.

23. The UAS must remain clear and give way to all manned aviation operations and activities at all times.

24. The UAS may not be operated by the PIC from any moving device or vehicle.

25. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and

structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the

UAS, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and b.

The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those

objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that

it does not present an undue hazard. The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

26. All operations shall be conducted over private or controlled-access property with permission from the property

owner/controller or authorized representative. Permission from property owner/controller or authorized

representative will be obtained for each flight to be conducted.

27. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational

area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24

hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained
on the NTSB Web site: www.ntsb.gov.