U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave. 

SE Washington, DC 20590 

Re: Petition of Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from certain parts of the FARs 

Attn: To whom it may concern 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, Martin Unrue, a 

professional photographer, hereby applies for an exemption from the listed Federal Aviation Regulations to allow him to 

operate a small Unmanned Aircraft System ("sUAS") under the conditions and limitations set forth in this Petition. 

The requested exemption would permit the operation of a small, unmanned and relatively inexpensive sUAS under 

controlled conditions in airspace that is (1) limited, (2) predetermined, and (3) in mostly rural and sparsely populated 

areas. Approval of this exemption would thereby enhance safety and fulfill the FAA Administrator's responsibilities to 

"...establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) 

of the Reform Act. 

The name and address of the applicant is 

Martin Unrue 

4285 Wilding Road 

Ravenswood, WV 26164 

Phone:304-532-4861 

Email: martinunrue@yahoo.com 

Regulations from which the exemption is requesting: 

14 CFR Part 21 

14 C.F.R. § 45.23(b) 

14 CFR § 61.3 

14 C.F.R. § 91.7 (a) 

14 CFR § 91.9 (b) (2) 

14 C.F.R. § 91.103 

14 C.F.R. § 91.109 

14 C.F. R. § 91.119 

14 C.F.R. § 91.121 

14 CFR § 91.151 (a) 

14 CFR § 91.203 (a) & (b) 

14 CFR § 91.205(b) 

14 CFR § 91.215 

14 CFR § 91.405 (a) 
14 CFR § 407 (a) (1) 

14 CFR § 409 (a) (2) 

14 CFR § 417 (a) & (b) 

The Appendix describes the FARs from which an exemption is requested and summarizes the justification for each 

requested exemption. The Petition is submitted to fulfill Congress' goal under 

Section 333(a) through (c) of the Reform Act, which directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rule 

making required under Section 332 of the Reform Act. In making this determination, the Administrator must determine 

which types of sUAS do not create a hazard to users of the NAS or the public or pose a threat to national security in light 

of the following: 

• The sUAS size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). 

If the Administrator determines that such vehicles "may operate safely in the national airspace system, the Secretary 

shall establish requirements for the safe operation of such aircraft in the national airspace system." Id. § 333(c) 

(emphasis added). 

The Secretary has delegated his aviation authority to the Administrator of the FAA. 

The Federal Aviation Act expressly grants the FAA the authority to grant exemptions from its regulatory requirements 

for civil aircraft, a term defined under §40101 of the Act, which includes sUA'Ss. The Administrator may grant an 

exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 

44702-44716 of the Federal Aviation Act if Administrator finds the exemption in the public interest. 49 U.S.C. § 44701(f) 

See also 49 USC § 44711(a); 49 USC § 44704; 14 CFR §91.203 (a) (1). 

I, Martin Unrue, the petitioner has had an interest in photography for over 40 years. The last 15 years I have put much 

time and effort into expanding my skills and techniques. I have always attempted to stay on the leading edge of the 

technology available. I have been employed and made my living since 1983 as a steel design CAD draftsman. This line of 

work has made me very aware of many safety considerations by following required OSHA and MSHA standards. These 

same safety themes I have always carried over to my photography practices. 

I often volunteer my photography skills and time for charity work. Photographing programs, school functions, local 

concerts and events have been the majority of what I have done for the past 5 years. I have also spent time 

photographing base jumpers on a volunteer basis. This work has furthered my respect for situations that require utmost 

attention and respect for ones surroundings. I live in a very rural area and have done much research of any and all flight 

restrictions in this area as I have learned the flight characteristics and safety procedures of flying a sUAS. 

After hearing from several acquaintances whom had viewed my aerial photos I have been approached by a few local 

people who would like for me to photograph and or video of their rural properties. I also have developed a plan to 

supply real estate agents within our area high quality video tours and photos of rural farms and properties to be used as 

part of their listings. I am also looking in touch with organizers of local events to give them access to general overall 

vlews of their events, all while being done in a safe manner. By being granted the requested 333 exemption I will be able 

to provide needed visual tools not available before. 
The sUAS I choose was a DJI Phantom 2 Vision +. My reasons behind this choice were many, safety in flight, stability, 

"First Person View". I have flown 20+ hours with it over my private property in order to gain experience under all 

conditions. This area is heavily wooded with numerous structures. I have used this area to learn how to fly under less 

than ideal situations while still being in a safe manner and under controlled conditions. 

For safety of aIl concerned before each flight I do a full check of all systems involved in the Phantom, including but not 

limited to: weather conditions, any other unauthorized people in the area, GPS signal, Wi-Fi connection, battery strength 

on aIl devices, mechanical shape of the Phantom, etc. The sUAS has been configured with a maximum height of 400(-) 

feet and a horizontal range of 2500 feet, these parameters allow a safe Iine of sight flight area. 

With all of the Phantoms built in fail safes, it is a very safe sUAS. By using the built-in safety functions (return to home 

with signal loss, GPS, exclusions of Class B, C, & D airspace, return to home upon low battery of 30%) along with practice 

and learning drills to handle adverse situations I have become a safe and very observant operator. 

When flying sUAS within 5 miles of an airport, airport operators will be notified and the operator will give the right of 

way to avoid flying in the proximity of full-scale aircraft. 

• Maximum flight time for each operational flight will be 20 minutes. 

• Flights will be terminated at 30% battery power reserve should that occur prior to the 20 minute limit. 

• At all times the sUAS will remain in visual contact of the operator, Martin Unrue. 

• AII usage will utilize the Person in Control (Martin Unrue) and an additional visual observer. 

• Any additional permits, Iocal or state will be obtained before the project is undertaken. 

• AII flights will be held well under 400 feet, at an airspeed of well under 20 knots, and also well below a 

maximum distance of'/: nautical miles. 

The Petitioner's proposed operations satisfy the criteria provided in Section 333 of the Reform Act relating to size, 

weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security. The Petition justifies grant of the requested exemptions allow the Petitioner to obtain aerial 

photography with his sUAS, Phantom 2 Vision Plus. 

• Real Estate Photography 

• General Aerial Photography 

• Event Photography 

Thanks, 

Martin Unrue 

4285 Wilding Road 

Ravenswood, WV 26164 

304-532-4861 

martinunrue@vahoo.com