Jeffrey R Barksdale July 12, 2015

31447 Emperor Dr.

Canyon Lake, California 92587

dba, API Inspection, llc

4051 Barrancas Ave.

Suite G, 114

Pensacola, Florida 32507

Office 510.356.5658

Email: dronesailor@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 2059

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

UAS Training References:

1. DJI Phantom 3 Professional Users Manual V1.2

2. DJI Phantom pilot training guide V1.1

Exemption References:

1. FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter of the

petition of DOUGLAS TRUDEAU

2. FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0508 in the matter of the

petition of ADVANCED AVIATION SOLUTIONS LLC

3. FAA Interim exemption for “Blanket “ 200 foot COA 

Dear Sir or Madam,

The petitioner request that in a manner as described in reference 3, he be granted a “blanket” Certificate of Waiver Authorization for flights at or below 200 feet, that weigh less than 55 lbs., operate

during daylight VFR conditions, operate within visual line of sight conditions of the pilots, and stay

certain distances away from airports and heliports.

Also, in accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section

333 of the FAA Modernization and Reform Act of 2012, Jeffrey R Barksdale dba 

API Inspection, llc, hereafter referred to as the petitioner, requests exemption from the following
sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 91.409(a)(2); 91.417(a) & (b)

in order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by 

the Federal Aviation Administration (FAA).

The Petitioner requests this exemption for the purposes of aerial photography, videography, mapping, crop surveying, inspections and other flight operations that could be performed safely

and more cost effective with the use of UAS at low altitude within the U.S. national airspace

system as compared to a manned aircraft.

Operations will be performed only with the authorization and permission of clients or

their authorized agents in order to facilitate commerce and raise awareness of the beneficial

uses of small unmanned air systems. So long as such operations are conducted within and

under the conditions outlined herein or as may be established by the FAA as required by

Section 333. The conditions identified and proposed by the petitioner are drawn from UAS

references 1 & 2.

The Federal Aviation Regulations (FARs)

The petitioner seeks exemption from the above-mentioned FARs for the following reasons;

Section 61.113(a); 61.113(b)

The petitioner requests relief in order to facilitate the utilization of pilots who hold as a minimum 

a Sport Pilot certificate. Any pilot operating under this exemption would be required to comply 

with all conditions as set forth and in a similar fashion to the previously granted exemptions.

Section 91.119(c)

As referenced in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500

feet to the ground may require that the UAS be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. The petitioner requests

waiver for this condition to allow reasonable and responsible operations in but not limited to, areas of

subdivisions and neighborhoods if required.

Section 91.121

As referenced in Exemption 11138 (DOUGLAS TRUDEAU) section 19.121 

is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS

with a barometric sensor (or ultrasonic sensors when indoors) for altitude information.
Section 91.151(a)

As referenced in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has

been granted for manned aircraft to operate at less than the prescribed minimums, including

Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted

in Exemption numbers 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides

battery power remaining in percent to the PIC. The UA batteries provide approximately 20

minutes of powered flight. Information provided in the operating documents discusses

procedures regarding remaining battery power management. Those documents contain a

condition in which the PIC will initiate a landing procedure when battery remaining reaches a

specified level. Given the limitations on proposed operations and the location of proposed operations,

the FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable.

Section 91.405(a); 91.407(a)(1); 91.409(a)(1), 91.409(a)(2); 91.417(a); 91.417(b)

As referenced in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect

and ensure that the UAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and the

conditions and limitations specified, describing the requirements for maintenance, inspection,

and record keeping, were sufficient to ensure that safety would not be adversely affected.

UAS; DJI Phantom 3 Professional

The requested exemption would permit commercial operation of the DJI Phantom 3 Professional, which is less than 55 lbs. and travels at less significantly less than 87 knots, by Jeffrey R Barksdale 

dba API Inspection, llc.

Petitioner would perform services that produce high quality still photographs and videos taken by the 

onboard camera and enhance his existing inspection capabilities.

The use of UAS for aerial services reduces the need to utilize conventional manned aircrafts

for the same purpose at a fraction of the cost, increased efficiency and productivity.

Since the UAS is electric there is an almost 100% decrease in fuel emissions providing significant environmental benefits.

Operations under the exemption will be subject to strict operating requirements and

conditions that equal or exceed the equivalent level of safety to currently authorized operations

using manned aircraft.

Conditions may be modified by the FAA as required by Section 333.

The UAS will be operated under controlled conditions at low altitude (200ft or less) 

in airspace that is limited in scope, as described herein; it will have automated control features,

as described in the referenced manuals.
The UAS will be operated by the Pilot in Charge (PIC) who possesses, as a minimum, a

Sport Pilot Certificate, a valid US Driver’s License and/or an FAA issued Airman medical certificate.

Finally, the airspace in which the UAS will operate will be Class G airspace.

Approval of these exemptions would thereby enhance safety and fulfill the Secretary of

Transportion’s(the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to

“establish requirements for the safe operation of such aircraft systems in the national airspace system”

The petitioner has reviewed FAA exemptions references 1-3 Conditions and Limitations section

and agrees that the procedures specified therein are reasonable and will be utilized in order to

manage and mitigate risk and ensure public safety. A preflight checklist will be developed and

employed to ensure the UAS airworthiness and will be performed prior to each launch.

Public interest

Use of the UAS’s in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircrafts.

Additionally, use of the UAS in order to facilitate commerce could lead to economic growth.

Operations for this petition will enable service for business and to obtain detailed information that cannot be displayed through ground level access.

The petitioner will provide clients with photographic data for these purposes on a

‘for hire’ basis acting as an independent contractor and the PIC. A visual observer will be utilized.

Conclusion

The petitioner request that in a manner as described in reference 3, he be granted a “blanket” Certificate of Waiver Authorization for flights at or below 200 feet, weight less than 55 lbs., operates during 

daylight VFR conditions, operates within visual line of sight conditions of the pilots, and stays certain 

distances away from airports and heliports.

The petitioner is requesting this exemption for the purposes of “aerial photography, videography,

mapping, surveying, inspection and other flight operations”.

The primary purpose of seeking this exemption is to obtain the capability to offer those

services while remaining in FAA compliance. The petitioner is in the process of obtaining a 

Sport Pilot Certificate, has over 10 years of experience in RC hobbies with 3 years in UAS aviation.

Respectfully requested and submitted,

Jeffrey R. Barksdale

API Inspection, llc