JERRYARNOLD PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321. 328.8962  jarnold88@cfl.rr.com

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal

Aviation Regulations

Dear Sir or Madam:

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

Act"), Jerry Arnold (the "applicant"), operator of an Unmanned Aircraft Systems ("UAS") seeks

an exemption from the Federal Aviation Regulations ("FARs") to allow for commercial

operation for aerial imaging and video for regional tourism, hotels, resorts and real estate

As described herein I, Jerry Arnold, an insured member of the PPA (Professional 

Photographers of America) am experienced in flying hobby quad-copters for recreational

purposes. A professional photographer with over 20 years’ experience, I am also an

experienced photographer/videographer from both fixed winged aircraft and helicopters and 

have provided those services for use by hotels, resorts and travel destinations. 

Applicant:

Jerry D. Arnold

J. Arnold & Associates, Inc. (dba Jerry Arnold Photography)

Attachments

Yuneec Typhoon 500 4K specifications and safety features

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.203 (a) and (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)
 JERRYARNOLD PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321. 328.8962  jarnold88@cfl.rr.com

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) and (b)

Extent of relief I seek, and why 14 CFR Part 21 subpart H

The UAS to be operated carries neither pilot nor passenger and carries no explosive materials

or flammable liquids. Given the size, weight, speed, and limited operating area associated with

the aircraft to be utilized, I request exception. In the restricted environment and under the

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

operating with an airworthiness certificate without said restrictions.

14 CFR 45.23 (b)

Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which tomarket

certain words or phrases. Lettering would be very difficult to place on such a small aircraft and

dimensions would need to be smaller than required minimum. Understanding theimportance

of lettering I will mark my UAS with the largest possible letters by placing the word

"Experimental" or assigned number or name, based on request/ruling of FAA, on UAS fuselage. 

The equivalent level of safety will be provided by having the UAS marked on its fuselage as

required.

14 CFR 91.7 (a)

As there will be no airworthiness certificate for the aircraft, should this exemption be granted,

no FAA regulatory standard will exist for determining airworthiness. Given the size of the

aircraft for maintenance and use of safety check list prior to each flight an equivalent level of

safety will be provided.

14 CFR 91.9 (b) (2)

Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft.

There is no room, capacity, or pilot on board to adequately carry flight manual. Aequivalent

level of safety will be maintained by keeping the flight manual at ground control point where 

the pilot will) have immediate access to it.

14 CFR 91.103

As FAA approved flight manuals will not be provided for the aircraft an exemption will be

needed. Normal procedures including but not limited to; reviewing weather, flight battery

requirement, landing and takeoff distances. An equivalent level of safety will be provided by

preflight protocol to properly match the machine.

14 CFR 91.109

UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is

achieved through the use of a control box that communicates with the aircraft via radio

communications. The equivalent level of safety provided because neither a pilot nor passenger 

will be carried in the aircraft, and by the speed and size of the aircraft.

14 CFR 91.113 (a) and (b)

I can achieve an equivalent level of safety as achieved by current regulations because my UAS

does not carry pilot or passenger. While helpful, a pilot’s license will not ensure remote

control piloting skills.
 JERRYARNOLD PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321. 328.8962  jarnold88@cfl.rr.com

14 CFR 91.121

The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. I 

believe an exemption may be needed. An equivalent level of safety is achieved by the operator

receiving live flight data monitoring and confirming current altitude along with altitude of 

launch site shown on GPS altitude indicator.

14 CFR 91.203 (a) and (b)

Similar to, 14 CFR 91.9 (b) (2), given the size and configuration, the UAS has no ability to carry

certificate and registration documents on the aircraft. There is no room, capacity, or pilot on 

board to adequately such documents. An equivalent level of safety will be achieved by keeping

these documents; to the extent they are applicable to the UAS, at the ground controlpoint 

where pilot has immediate access to them.

14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)

Given these sections only apply to aircraft with an airworthiness certificate, theses sections do

not apply to this applicant. As a safety precaution, operator will perform preflight inspections

and ensure UAS is in working condition before initiating each flight.

Jerry Arnold is seeking relief from all FARs above preventing applicant from conducting aerial

photography and video of real estate taken at levels less than 400ft, at a speed lessthan 50

mph, and with a maximum flight time of 18 minutes,. The drone to be used is a Yuneec 

Typhoon 500 4K. At 60 ounces including battery, the weight of the UAS meets the definition of 

"small unmanned aircraft" found in section 331 "The Reform Act". In order to obtain high

quality photography and video the UAS will be used at speeds less than its top speed of 50

mph. Due to the UASbeing battery powered there are no combustible fuels onboard.

Maximum flight time for this particular UAS is 18 minutes battery life, flights to be terminated 

with 25% battery life remaining . Given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized I find this exception to be reasonable with an

equivalent, or greater, level of safety to be reached by the operator.

Saftey

*Please see attachment "Typhoon" for safety features. Aside from following all safety features 

including maximum 400’ altitude, 5 mile limit when flying near airports, I was given a hands on

training course when I purchased my UAS.

Additionally:

I do not operate within 5 miles of an airport unless prior contact to Air Traffic Control or

the airport manager has been made.

I land my UAS prior to manufacturer recommended minimum level of battery power

I pilot my UAS through remote control by line of sight

My UAS uses GPS and a flight safety feature whereby it returns to a preprogrammed

position and then slowly lands if communication with the remote control pilot is fost

I actively analyze flight data and other sources of information to constantly update and

enhance safety protocol’s.

I conduct extensive pre-flight inspections and protocol, during which safety carries

primary importance.

I always obtain all necessary permissions prior to operation; and,
 JERRYARNOLD PHOTOGRAPHY

1426 victoria blvd  rockledge, fl 3295 5  321. 328.8962  jarnold88@cfl.rr.com

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

danger.

Public Interest

The use of an UAS in tourism provide businesses and local governments with a much

lower cost solution to highlight aspects of their businesses and communities in turn

generating more visitors. UAS in the real estate industry provides both buyers and

sellers a higher level of service. For a buyer a higher level of marketing and advertising

is achieved, appealing to more buyers, resulting in a quicker sale of their home. Quicker 

home sales also help accelerate the economy as a whole. Buyers experience the

benefit of encompassing a whole property, sometimes several acres, in one photo or a

short video. Not only does this benefitthe specific home seller or home buyer, but it

benefits the general public because it is muchmore efficient than traditional ways of

using a plane or helicopter to achieve the same result.We can now provide this level of

service while being conservative with fuel, time, emissions,noise, and other resources. 

Considering size, weight, speed, and absence of combustible fuels, my UAS will pose

much less of a safety concern for the general public when comparedto larger manned

aircraft.

Thank you for your consideration.

Jerry Arnold