U.S. Department of Transportation 

Docket Management Facility 

1200 New Jersey Avenue, SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

To Sir or Ma'am: 

Andrew P. Kimos 

6765 Larchmont Drive 

Mayfield Hts, Ohio 44124 

n8986j@yahoo.com 

440-221-2687 

December 11, 2015 

In accordance with Section 333 of the FAA Modernization and Reform Act, I hereby apply for an 

exception from Code of Fede~ai·Regulations {CFRs) to allow commercial operation of a Small 

Unmanned Air~raft System (sUAS). These pperations are proposed to be conducted in accordance 

' , , . ' . ' . . I 

wjth.the conditions described, below •. I am an FAA certificated commercial pilot, a currently active 

flight instructor and ground instructor. 

OPERATOR'S NAME AND ADDRESS: 

Andrew P. Kimos 

6765 Larch!'flont Dr!ve 

Mayfield Heights, Ohio 44124 

THE REGULATIONS F'ROM WHICH' RELIEF IS.REduniEn AND 'rAE EXTENT oF· RELrEF REQUESTED: 

14 CFR Part 21 Subpart H -Airworthiness Certificates 

The type of Small Unmanned Aircraft System (sUAS) that I plan to operate, the DJI Phantom 3 

Standard, does not have an Airworthiness Certificate, nor are there plans that I know of for the FAA to 

require airworthiness certificates for this or a similar sUAS. I do not propose to modify my DJI 

Phantom 3 Standard sUAS in any way that would require a special airworthiness certificate. 

14 CFR 91.119{c) - Minimum Safe Altitudes.: General 

My sUAS will not be operated at an altitude above 400' AGL. I request permission to operate the 

sUAS frorl1 0-400' AGL, if all other safety requirements described herein are complied with. 

14 CFR 91.121 -Altimeter Settings 

My sUAS ~illnothav~ an installedaltimeter,will have altitude sensirtgand;GPS navigatiin capability 

to ensure it remains within the altitu~e {AGL} limits prescribed by the operator, Andrew P:;· Ki~$; .. 

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14 CFR 91.151 - Fuel Requirements for Flight in VFR Conditions 
My sUAS will have a published endurance of 25 minutes maximum using battery. power. 

14 CFR 91.405 - Maintenance Required 

I will ensure that the sUAS is maintained in accordance with the manufacturer's recommendations. 

14 CFR 91.407(a)(1)- Operation After Maintenance, Preventive Maintenance, Rebuilding, or 

Alteration and 

14 CFR 91.409(a)(1) and (2) -Inspections 

As the operator of the sUAS, I will ensure that the sUAS is pre-flighted and post-flighted for proper 

systems integrity without the services of an aircraft and powerplant (A&P) certified mechanic. 

14 CFR 91.417(a) and (b)- Maintenance Records 

As the operator of the sUAS, I will keep a log of maintenance without the services of an aircraft and 

powerplant (A&P) certified mechanic. 

HOW THE OPERATOR WILL MAINTAIN AN EQUIVALENT LEVEL OF SAFETY AND NO ADVERSE IMPACT 

TO SAFETY: 

I wlU apply for and affix a registration number to the sUAS per '14 CFR 45.23(b) - Display ofMarks' 

prior to beginning any commercial operations within the sUAS. 

The sUAS will not be operated at a speed higher than 31 knots. 

The sUAS will not be operated above 400' AGL. 

The sUAS will not be operated within 5 nautical miles of any known public airport without specific 

authorization and approval obtained from the involved airport manager. 

All operations will involve a second Visual Observer (VO} for safetY~ 

All operations will remain within the Line of Sight (LOS) of the operator. 

If any adjustments are made to the sUAS, which I do not plan, then I will conduct a functional flight 

test to ensure normal performance characteristics are preserved. 

I will inspect the sUA5 before and after each flight to ensure systems integrity. 

1 will follow all maintenance and overall requirements of the manufacturer. 

1 will have the sUAS operating manual and limitations available during commercial operations, 

including all documents required to maintain safe flight operations. 

1 will conduct all flights in daytime Visual Meteorological Conditions (VMC), and comply with VMC 

cloud clearance requirements. 
The sUAS that I operate will return to its launch location if communications are lost. 

I will abort the flight in the event of unpredicted obstacles or emergencies. 

I will ensure that all operations will be conducted such that at least 5 minutes of reserve battery 

power is available. 

I will obtain an Air Traffic Control Certificate of Waiver or Authorization (CO~) as necessary. 

I will obtain permission to operate the sUAS from the property owner Ja-ontroller or authorized 

representative. Permission will be obtained prior to each flight to be donducted. All operations will 

be conducted over private or controlled access property. 

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I will give way to all manned aircraft operations. , 

I will not operate the sUAS from any moving device or vehicle. 

I will maintain my biennial flight review (BFR) currency and comply with any medicate certificate 

restrictions. 

I will not operate the sUAS within 500' from any non-participating person, vessel, vehicle, or structure 

unless permissions are obtained and barriers are in place to operate within 500' such that persons, 

vessels, vehicles, and structures would be protected by any debris in the event of an accident. I will 

make a safety assessment of any such operations prior to beginning each sUAS flight. 

HOW GRANTING THE EXEMPTION WOULD BE IN THE PUBLIC INTEREST: 

Granting the Exemption would be in the public interest because: 

a. It will avoid the need for fueled and manned aircraft that would otherwise be necessary for 

the Proposed Operations. While exceptionally safe, manned and fueled aircraft operations 

would pose a greater risk to the public if mishaps occur. 

b. It will avoid the need for people to climbabove.;grounc:t--on-structures n:rperforrn similar 

inspections and therefore will eliminate fall hazards to the inspectors. 

THE PROPOSED OPERATIONS: 

The sUAS will be used for aerial assessment of roof materials, aerial video inspection of buildings and 

infrastructure, and for real estate marketing videos. The operations will be conducted as specified in 

the 'equivalent safety' section above, within all authorizations and restrictions issued by the FAA. 

PROPOSED SUMMARY FOR THE FEDERAL REGISTER: 
Petitioner: Andrew P. Kimos, Commercial Pilot 

Sections of 14 CFR Affected: 14 CFR P~rt 21 Subpart H, 14 CFR 91.119(c), 14 CFR 91.121, 14 CFR 

91.151, 14 CFR 91.405, 14 CFf:t 91.407(a)(1), 14 CFR 91.409(a)(1) and (2}, 14 CFR 91.417(a} and (b). 

Description of R~lief Sou~ht: Petitioner seel<s relief from the requirements of 14 CFR Part 21 Subpart 

H, 14 CFR 9\.l:L~~c), 14 Cfr 91.12.1, l4 CFR 91.151, 14 CFR 91.405, 14 CF~ 91.407lt)(1), 1~ CFR 

91.40,9(a)(1) and''(2), 14 CFR 91.4P("J and (b) to conduct commercial activities yVi~~ a srry~ll 

Unmanned Aircraft System (sU~~). The proposed sUAS operations conducted by the petttloner will 

meet or exceed those that the FAA requires for similar operations. · 

THE MAKE & MODEL OF THE AIRCRAFT PROPOS,l!UQ§,(Mf'Of'i)})'S:·.._/ 

'-.;-;.:,.;"; 

sUAS: DJI Phantom 3 Standard 

Weight'(iAtf(Jding battery): 2.71bs 

Maximum Speed: 30.5 knots 

Maximum Operating Altitude: 400' AGL 

Operating Temperature: 0 - 40 degrees C 

I do not plan to exercise an exemption outside of the United States. 

Thank you for your consideration of my petition. 

Sincerely, 

d /4Jl/A!J{;~p;r ~w P.Yimos · 67~5 Larchmont Drive 

Mayfield ~hts, Ohio 

44l\Z4 'I ·: ,,,.,· 

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