June 29, 2015

Mr. Matthew McCourtney

PO Box 1198

Woodcare, CA 94973

Dear Mr. McCourtney:

This letter is to inform you that we are unable to process your request for an exemption from 

Title 14, Code of Federal Regulations (14 CFR). It explains why we can not process your 

request and what you should do in the next 30 days.

Why We Can Not Process Your Request

We entered your March, 23, 2015 exemption request into the public docket (No. FAA-2015-

0715), but we are unable to process your request any further. The information you sent does

not comply with the requirements of § 11.81 (copy enclosed). For us to consider the request 

any further, you must send us all of the following:

 The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief.

 The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole.

 The reasons why the exemption would not adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you 

seek an exemption.

 Any additional information, views, or arguments available to support your request.

What You Should Do

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. Please note that § 11.63(d) requires you to send your 

petition for exemption at least 120 days before the proposed effective date of the exemption.
2

If We Do Not Hear From You

If we do not hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677.

Sincerely,

/s/

Brenda Robeson

Program Analyst, Airmen and 

 Airspace Rules Division

Enclosure
6/29/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­0715­0001 1/2

Matthew McCourtney - Exemption/Rulemaking

This Other document was issued by the Federal Aviation

Administration (FAA)

For related information, Open Docket Folder

Content

I would like to request exemption to personally conduct flights

with my UAS for commercial purposes. I have been flying UAS

crafts for over 4 years and have have hundreds of logged

successful flight hours. In addition I have 10 years of helicopter

aerial photography experience with over 500 hours of flight. I am

the solo operator of the company so I will be the only PIC for

UAS flights. My assistant helps me transport the craft and helps

with keeping the landing and take off area safe and clear.

I have owned and operated my photography company for 15

years. As an architectural photographer, the necessity to capture

images from low elevations (typically under 100 feet of height) is

a key aspect of my business. In addition to specializing in

architectural photography, I offer my services to high end Real

Estate listing helping them capture images of unique and large

properties where low elevation aerial photography is a must. The

jobs I am getting requests for are large estates or vacant land in

which the UAS is actually kept over their private property. I do

not foresee flying an any congested areas such as big cites or

anywhere near airports. My helicopter experience has really help

me understand the necessity and safety of the NAS, especially

under 500 feet of elevation.

As mentioned before, my UAS flights are close range and low

elevation and all within line of sight. I have set my UAS to not be

able to fly over 200 feet in elevation and max distance of 400

feet away from the original take off location. The exemption I am

requesting would be to capture bird's eye views of homes and

property that would be done within these set perimeters. Under

200 feet of elevation and within 400 feet of take off location on

private property.

I own 4 DJI Innovation UAS crafts all of which meet all federal

regulations concerning Radio Frequency and FCC

complacence. I have dialed down the gains on all of the

crafts allowing to fly slower and more stable than they come

stock. Max speed is set to 20 MPH on all crafts and max

elevation is set to 200 ft. This enable me to captures slow,

Comment Period Closed

ID: FAA­2015­0715­0001

Document Information

Date Posted:

Mar 23, 2015

Show More Details

Submitter Information

Submitter Name:

Matthew McCourtney

Mailing Address:

P.O. Box 1198

City:

Woodacre

Country:

United States

State or Province:

CA

ZIP/Postal Code:

94973

Comments

0

Docket Information

This document is contained in

FAA­2015­0715

Related Dockets:

None

Related RINs:

None

Comments Received*
6/29/2015 Regulations.gov ­ Other Document

http://www.regulations.gov/#!documentDetail;D=FAA­2015­0715­0001 2/2

smooth motion. My newest and now primary UAS is the DJI

Inspire 1. The craft allows me to predetermine max altitude,

distance and speed controls all while providing camera and

location data streamed back to a iPad. The craft has battery data

streamed back to the iPad so you have complete knowledge of

battery strength during flight and has a built in battery warning

which is set to 30 percent. As the PIC I have this data in front of

me while flying. In addition the Inspire one has built in limitations

on air space and no fly zones built into the actual craft. Not

allowing a pilot to accidentally fly into close or regulated air

space. All of these new tools help build a extremely reliable and

safe repeatable flying experience. In the last 4 years of UAS

flighting, the new Inspire one has taken the guess work out of

UAS operation and allowed the PIC to take total control of the

craft and it's functions in a very simple and portable set up. I

have over 50 hours on the Inspire one craft and 100s of hours

logged on the other 3 DJI crafts.

In addition to the pre set safety regulations on my Inspire 1, I

preform a pre flight inspection consisting on of the following

steps prior to each and every flight. Physical inspection of the

craft. Propeller inspection and inspection of the propeller locks

installed and full, fresh battery installation. Once the craft is

powered up on a flat smooth surface, I perform a compass

calibration, aircraft to radio verification along with data linking

such as GPS coordinates and battery status. Once all of those

items are cleared I lift the aircraft up about 10­15 feet and do a

full operation check on the input sticks to make sure the craft is

responding correctly. After that I do another GPS lock and begin

flight. Flights are typically 10­12 mins long and I have 4 spare

batteries for additional flights enabling me to use a fresh new

battery for each flight.

Prior to flying UAS I used a flight simulator at a local hobby shop

and then purchased one for my computer. Both simulators

allowed me to use the remote control to actually fly the aircraft

and learn the flight characteristics of the aircraft. After 10 hours

of simulator training I began flying the actual craft in very

controlled environments until all the aircraft characteristics where

fully understood, I have completed these steps with all 4 UAS.

In addition I have read the usage and owners manuals for all of

the UAS crafts familiarizing myself with each craft. As you can

see pilot training in both flight and craft have been thoroughly

covered to ensure the maximum safety of both the craft and the

environment in which the craft operates.

In complice to all FAA guidelines and in spirt of safe UAS

operation, I hope you consider my request for exemption as I

honor a safe and compliant flight operations.

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