U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Petition for

Section 333 Exemption

1 November 2015 

Petitioner: 

Endless Aerial, LLC 

Matthew McGowan, CEO

PPL # Pending

Mechanic # 3707672

44210 Fine Circle

Lancaster, CA 93536

Cell: 661 609-3593 

Email: mattmcgowan23@hotmail.com

To Whom It May Concern, 

In the interests of performing commercial UAS operations, I submit this petition for 

exemption pursuant to Section 333; FAA Modernization and Reform Act of 2012, Public Law 112-95 

FEB. 14, 2012, Section 333. I request this exemption in order to operate the followings UAS: DJI 

Inspire 1 Professional Quadcopter Aircraft, DJI Phantom 3 Quadcopter, 3DR Solo Quadcopter, 3DR 

X8 Octocopter, 3DR Aero-M fixed wing UAS in order to provide services for profit including aerial 

photography, aerial cinematography, aerial filming and photography for real estate, television 

broadcast, construction firms, agricultural modeling, crop monitoring operations, aerial mapping, 

special events to included but not limited to weddings, private or public parties/events, business 

advertising, promotional events, geological surveying, and environmental studies. 

The ability to provide these services to businesses and individuals will benefit them by 

opening up opportunities they otherwise did not have prior to UAS technology. Traditional methods 

of aerial photography/videography are simply not viable options for the average consumer/small 

business as they are costly and involve greater risks to everyone involved; i.e. the use of larger 

aircraft carrying humans and flammable fuel. By utilizing UAS, the same results can be achieved

with much safer conditions. Also, utilizing this technology allows for greater efficiency and finance

management for the small business, potentially increasing their chances of success and in turn 

benefitting the local economy as a whole. 

Prior to each flight/operation of the UAS, I will conduct a Pre-Flight Safety Inspection. 

Flights will not take place over densely populated areas or private property without the owners' 

permission. The UAS will only be operated within visual line of sight and will not be flown near 

airports or above 400 feet. All preventative maintenance will be completed in accordance with 

manufacturer specifications. Any and all repairs beyond the scope of aircraft specific manuals will be 

performed only by the manufacturer authorized repair facilities.

As an FAA certified Airframe Mechanic and Private Pilot, I am acutely aware of the personal 

responsibility, attention to detail and ethics required for safe and successful aircraft operation. I 

have been fortunate enough to spend my aviation career working for companies like General Atomics 

Aeronautical systems and Northrop Grumman (among others) where I have been involved with 

highly scrutinized operation of military grade UASs including MQ-1 Predator, MQ-9 Reaper and 

MQ-8 Firescout. Through these experiences, I know what is required of a professional UAS

operator/technician, and can perform these operations in manner conducive to the responsible 

growth of the UAS industry within the NAS. The safety of the American public both on the ground 

and in the airspace above are my utmost priority. The aviation skills, ideals and knowledge I possess 

(and continue to grow) are passed on to my employees and embodied within my company, Endless 

Aerial, LLC. 
The specific sections of 14 C.F.R from which I am seeking exemption are as follows:

14 C.F.R. Part 21; CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS 

14 C.F.R. 45.23(b); Display of marks; general. 

14 C.F.R. 61.101(e)(4), & (5); Recreational pilot privileges and limitations. 

14 C.F.R. 61.113(a) & (b); Private pilot privileges and limitations: Pilot in command. 

14 C.F.R. 61.133 (a); Commercial pilot privileges and limitations.

14 C.F.R. 61.23(a) & (c); Medical certificates: Requirement and duration. 

14 C.F.R 91.7(a); Civil aircraft airworthiness. 

14 C.F.R. 91.9(b)(2); Civil aircraft flight manual, marking, and placard requirements. 

14 C.F.R. 91.109(a); Flight instruction; Simulated instrument flight and certain flight tests. 

14 C.F.R. 91.103; Preflight action.

14 C.F.R. 91.119; Minimum safe altitudes: General. 

14 C.F.R. 91.121; Altimeter settings. 

14 C.F.R. 91.151(a); Fuel requirements for flight in VFR conditions. 

14 C.F.R. 91.203(a) & (b); Civil aircraft: Certifications required. 

14 C.F.R. 91.405(a); Maintenance required. 

14 C.F.R. 91.407(a)(1); Operation after maintenance, preventive maintenance, rebuilding, or 

alteration.

14 C.F.R. 91.409(a)(2); Inspections.

14 C.F.R. 91.417(a) & (b). Maintenance records. 

UAS Specifications

In an effort to maintain clarity within this petition, I have included external links to manufacturer 

spec sheets and information for each aircraft. At these “information portals” are operational 

instructions, data and guidelines presented as intended by the manufacturer. At these external 

links, information is provided in a detailed, organized and concise manner which cannot be recreated 

in the format of this document.

 DJI Inspire 1 

Gross weight (w/battery): 6.47 lbs

Maximum Speed: 49 mph

http://www.dji.com/product/inspire-1/spec

 DJI Phantom 3 

Gross weight: 2.82 lbs

Maximum Speed: 35 mph

http://www.dji.com/product/phantom-3/spec

 3DR X8

Gross weight: 5.6 lbs 

Maximum Speed: 65 mph

Portal: http://3drobotics.com/x8/info/?_ga=1.262684748.1525891504.1446397572

 3DR Solo

Gross weight: 3.9 lbs 

Maximum Speed: 55 mph

https://3drobotics.com/kb/solo/

 3DR Aero-M

Gross weight: 6.8 lbs 

Maximum Speed: 33 mph

Specs: https://3drobotics.com/wp-content/uploads/2014/10/Aero-M-Spec-Sheet-v3.pdf
Portal: https://3drobotics.com/kb/aero-m/

Thank you for your time and consideration on this important request. Please advise me if any 

additional information is required. 

Respectfully, 

Matthew McGowan 

PPL# Pending Arrival

Mechanic# 3707062

CEO, Owner/ Operator

Endless Aerial, LLC