July 29, 2015 

James Sharp

21642 Brixham Run Loop

Estero, FL. 33928

jim@mevoimage.com

FAA

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140 Washington, DC 20590 

To whom it may concern, Re: Docket Number FAA-2015-0150 

I would like to start by giving a brief description of myself. I am a 48 year old married 

man, and I consider myself a professional adult and a responsible member of the 

community. I am hoping to take piloting an unmanned aerial system beyond the point of 

hobby and into a professional occupation. I have spent the past 7 years of my life in the 

field of real estate photography. I am the sole owner of Jim Sharp Photography in 

Estero, FL. And at many times in possession of private, privileged, and extremely 

confidential information, which entitled me to a huge level of professional trust with my 

customers. Prior to that in the mid 1990’s I was a Production Director with Beasley 

Broadcasting of SW. FL.

I have been interested in remote control quadcopters since they began making them 

more user friendly. I have purchased a DJI Phantom Series as well as Inspire Series and 

have flown it for many hours and feel very experienced with it. They are a fun and very 

addictive system with the potential to be a valuable business tool. What could be a better 

way to make money doing something that I consider fun? I began taking pictures with a 

camera attached to it not long after I purchased it. I took pictures for numerous family 

functions and looked into doing it professionally, for real estate. 

In Southwest Florida, there is an extremely large amount of real estate bought and sold, 

and having an extra tool available to offer a real estate company in this competitive 

market, I hope will help effectuate a sale, and would be an affordable way of providing 

such a service. 

I found that there was not really any way of doing it professionally because the rules had 

not been written. I kept checking back periodically and eventually found my way here. I 

got wind of a realtor just getting an approved COA and jumped at the opportunity. My 

petition is basically going to shadow that of Mr. Trudeau. After reading over his grant of 

exemption, he has described basically everything I wish to do. I am not a realtor 

however, and if and when I were to receive a grant of exemption, I would take on a 

position of photographer, videographer, and 

editor. I do not have a business yet but receiving a grant would be the final step before 

starting one. I also plan to purchase an additional (new version of the DJI Phantom) and 

different model of quadcopter to use than that of Mr. Trudeau. Same manufacturer as 
his, but a more advanced and updated system. It has not been released to the public yet 

but will be soon, maybe by the time you read this. It is also manufactured by the same 

company that made my first quad, the original DJI phantom. I have funding resources 

available to me, and by the time I would receive exemption, I should already have many 

more hours of flight time with the UAS. I will begin the petition for exemption below: 

To the Federal Aviation Authority (FAA), 

I hereby request exemption from part 21, subpart H; and Sections 45.23(b), 61.113(a) 

and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and 

(b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of 

Federal Regulations (14 CFR). 

I support my request with the following information: 

I plan to operate a UAS, the DJI Inspire 1, which is comprised of an unmanned aircraft 

and a transportable ground station. The Inspire 1 is referred to as a quad-copter with a 

maximum gross weight of about 3 kilograms. It is equipped with four rotors that are 

driven by electric motors powered by a battery. The UA has a maximum airspeed of 22 

m/s. The quad has a built in high definition camera. I plan to operate the UA over various 

areas near Southwest Florida to enhance real estate listing videos and photographs. I 

make the following representations of operational enhancements which I propose to 

abide by to ensure this exemption will provide a level of safety at least equal to existing 

rules: 

• I will only operate in reasonably safe environments that are strictly controlled, are away 

from power lines, elevated lights, airports and actively populated areas; and 

• I will conduct extensive preflight inspections and protocols, during which safety carries 

primary importance. 

I state that given the size, weight, speed, and limited operating area associated with the 

aircraft to be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness 

Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain 

conditions and limitations, is warranted and meets the requirements for an equivalent 

level of safety under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333). 

I request an exemption from § 45.23 Marking of the aircraft because his UA will not have 

a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, I 

state that two-inch lettering is difficult to place on such a small aircraft with dimensions 

smaller than the minimal lettering requirement. Regardless of this, I state that I will mark 

his UAS in the largest possible lettering by placing the word “Experimental” on its 

fuselage as required by § 45.29(f) so that he or anyone assisting him as a spotter will 

see the markings. 

I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) 

and (b) Maintenance inspections may be required and should be granted since they only 

apply to aircraft with an airworthiness certificate. However, I state that as a safety 

precaution I will perform a preflight inspection of his UAS before each flight as outlined in 

my operating documents. 

UAS Pilot in Command (PIC) 

I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial 

operations, however I can achieve an equivalent level of safety as achieved by current 

regulations because my UAS does not carry any pilots or passengers. Further, I state 

that, while helpful, a pilot license will not ensure remote control piloting skills. I further 

indicate that the risks of operating a UAS are far less than the risk levels inherent in the 

commercial activities outlined in 14 CFR part 61, et seq., thus I request an exemption 

from § 61.113 Private Pilot Privileges and Limitations: Pilot in command.

Regarding UAS operational training, I have flown numerous practice flights in remote 

areas as a hobbyist simulating flights for future commercial use to gain familiarization 
with the characteristics of his UAS’ performance under different temperature and 

weather conditions. I have also practiced computerized simulated flights to maintain 

adequate skills and response reflex time.

In a supplemental request to the FAA, I request consideration of a 120 day temporary 

airman certificate in accordance with § 63.13, to allow time to obtain a private pilot 

certificate or to allow the FAA time to establish minimum UAS airman certification

standards. 

UAS Operating Parameters

I will abide by the following additional operating conditions under this exemption: 

• operate my UAS below 300 feet and within a radius distance of 1000 feet from the 

controller to both aid in direct line of sight visual observation; 1

• operate the UAS for 3-7 minutes per flight;

• land my UAS prior to the manufacturer’s recommended minimum level of battery 

power; 

• operate my UAS only within visual line of sight (VLOS);

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers 

and then slowly lands if communication with the remote control pilot is lost;

• conduct all operations under my own personal and flight safety protocols (including 

posting a warning sign reading: “Attention Aerial Photography in Progress – Remain 

Back 150 feet”) contained in the operating documents and will actively analyze flight 

data and other sources of information to constantly update and enhance my safety 

protocols;

• contact respective airports if operations will be within 5 miles to advise them of my 

estimated flight time, flight duration, elevation of flight and other pertinent information;

• always obtain all necessary permissions prior to operation; and

• have procedures in place to abort flights in the event of safety breaches or potential 

danger. 

I note that § 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. I assert that since there is currently no certificate applicable to my operation, 

this regulation is inapplicable.

I note that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since 

there are no pilots or passengers on board his aircraft and given its size, this regulation 

is inapplicable. I further indicate an equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station. 

I note that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it 

allows helicopters to be operated at lower altitudes in certain conditions. I state that I will 

not operate his UAS above the altitude of 300 feet above ground level (AGL) and will 

also only operate in safe areas away from the public and traffic, thus “providing a level of 

safety at least equivalent to or below those in relation to minimum safe altitudes. I assert 

that given the size, weight, maneuverability, and speed of my UAS, an equivalent or 

higher level of safety will be achieved. 

I note that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic 

GPS with a barometric sensor. 

Public Interest 

I state that aerial videography and photography for geographical awareness and for real 

estate marketing has been around for a long time through manned fixed wing aircraft 

and helicopters, but for small business owners, its expense has been cost-prohibitive. 

Granting this exemption to myself would allow me to provide this service at a much lower 

cost. 

Further, I would like to indicate my small UAS will pose no threat to the public given its 

small size and lack of combustible fuel when compared to larger manned aircraft. I 
would also like to state that the operation of my UAS will minimize ecological damage 

and promote economic growth by providing information to companies or individuals 

doing business in the Southwest Florida region. 

Conclusion 

I would like to conclude by saying thank you for your consideration and time reading this 

petition. This has been a desire of mine since quadcopters became available to the 

public. I have only flown as a hobby to not break any laws until with hopes to become 

commercial. I see nothing but positive coming from it from this new technology. The 

state of Florida makes money from the sale of real estate. The realtor would have an 

advantage because of a much clearer view of properties. The consumer gets a better 

look at things. I get to pursue hopefully a new career and be a pioneer in a virtually new 

field of photography. All along the way, the federal government collects taxes from all of 

us. The economy benefits with very little risk of accidents and/or damages from these 

flyovers. 

Thank you again. Very respectfully, James Sharp