PhytosRx:

Roger Northrop

Exemption request to section 333 of the FAA Reform Act of 2012

Dear Sir or Madam:

In regards to section 333 of the FAA Reform Act of 2012 and C.F.R Part 11. My

registered business PhytosRx, owner and operator. PhytosRx would like to move into 

the Small Unmanned Aircraft Systems (UASs), requests to be exempted from the 

Federal Aviation Regulations (FARs) listed below so that PhytosRx may operate UASs

commercially in airspace regulated by Federal Aviation Administration; as long as such 

operations are conducted under the conditions of the FAA that are required by section 

333.

PhytosRx is owned by Roger Northrop, and is the business name that I use

when building software, as well as graphic design work. PhytosRx has been moving 

into aerial photography and the aerial video photography market. I Roger Northrop 

have over 150 hours of flight time with the DJI Phantom series drones, and all of the 

work that I have done to date has been for personal enjoyment and education of how 

to properly and safely fly a drone. All of my flights will adhere to the FAA’s Flight 

Photography Standard Operating Procedures (SOPs).

My contact info:

Atten: Roger Northrop

Address: 14 South George Street, Mount Prospect IL, 60056

Phone: 847-530-2510

Email: rogerpn@phytosrx.com

Drone registration number: FA3MTECXY9
The exemption that I am asking for would permit the operation of any of the DJI 

Phantom 3 Series drones, as well as the DJI Inspire series drones under controlled 

conditions for commercial use by Roger Northrop. PhytosRx requests with respect to 

the FAA to grant an exemption to the following specific sections of the Title 14 Code 

of federal Regulations allowing it to operate the DJI Phantom 3 series as well as the DJI 

Inspire series drones which are light weight UAS’s for commercial use.

14 CFR 21, subpart H, 14 CFR 45.23(b), 14 CFR 91.7(a), 14 CFR 91.9(b)(2), 14 CFR 

91.103(b), 14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CRF 91.151(a), 14 CFR 

91.203(a)&(b), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 

91.417(a)&(b), 14 CFR 61.113(a)&(b)

PhytosRx submits this application in accordance with the Reform Act, 112 P.L. 95 331-

334, seeking relief from any currently applicable FARs operating to prevent commercial 

cinematic and other flight operations within the national airspace system. The Reform 

Act in Section 332 provides for such integration of civil unmanned aircraft systems into 

our national airspace system as it is in the public’s interest to do so. PhytosRx, uses 

the DJI Phantom 3 series as well as DJI Inspire series UASs that meet the definition of 

“small unmanned aircraft” as defined in Section 331 and therefore the integration of the

ultra-light weight UAS is expressly contemplated by the Reform Act. PhytosRx would 

like to operate its ultra-light weight UAS prior to the time period by which the Reform 

Act requires the FAA to promulgate rules governing such craft. The Reform Act guides 

the Secretary in determining the types of UAS's that may operate safely in our national 

airspace system. Considerations include: The weight, size, speed and overall 

capabilities of the UAS's; whether the UAS will be operated near airports or heavily 

populated areas; and, Whether the UAS will be operated by line of sight. 112 P.L. 95

333 (a). Each of these items are in favor of an exemption for PhytosRx. PhytosRx UASs

utilizes four (4) counter-rotating propellers for balance, control and stability. Their UAS 

is equipped with GPS and auto return safety technology. Weighing less than ten (10) 

pounds (far below the maximum 55 pound limit); including camera. 
Considerations when Operating

Starting the spring of 2016 PhytosRx would be taking aerial photography / video of

• Car dealerships

• Golf courses

• Industrial Business Parks

• Business real estate

• Landscapes

• Real estate property

• Indoor Auditoriums / Stadiums (Not occupied by people)

• Indoor large open spaces (Not occupied by people)

Consideration of Risk Management

• All flights are operated with in line of sight

• Flights will take place during the daytime

• Flights will terminated once the battery reaches 20%

• Flights will be operated below 400 feet

• Full site surveys will be conducted prior to the flight

• All photography and video will obtain a verbal and written consent prior to flights

• If the UAS loses sight or GPS signal is lost, it will automatically return to the 

home location and land

• If the UAS Battery reaches 20% it will automatically return to the home location 

and land

• UASs are equipped with ‘First-Person-View’ (FPV)

• Fights will be canceled due to high winds, rain, and snow

• UAS’s will have a pre-flight check on all parts, as well as the most recent 

firmware loaded

The DJI Phantom 3 series and DJI Inspire are equipped with sensors for indoor flight for 

safety and control. Any indoor flights will have written permission as well as no people 

are to be in the indoor area where the flight is taking place, except for the pilot.
About Roger Northrop

I have been a recreational photographer for the past 15 years traveling to many 

destinations world wide. At this point in my life, I have the opportunity to begin to make 

a business of it. As I grow older, I need have a way to sustain myself and my wife when 

i am ready for retirement. I have been flying drones now for the past 3 years with over 

200+ ours of flying time, and I am being asked to contract out aerial photography, thus 

the need to request for an exemption. This request of exemption will allow me to build a 

supplementary income once I am at my retirement age.

Benefits for the Businesses and community

• PhytosRx will allow for competition in this growing market, giving businesses a 

choice

• Opportunity for PhytosRx to possibly employ others

• Allow Businesses to present their products with a much better experience to the 

consumer

• Help to push technology of this type forward

Impact on PhytosRx

• If PhytosrRx does not get the exemption, it is possible that it could miss a market 

that is growing, and not allow for a new business to be built with the possibility of 

employing others

•

Sincerely

Roger P. Northrop

PhytosRx

14 South George Street

Mount Prospect IL, 60056