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Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization 

and Reform Act of 2012, Pub. L. No. 112-95 (2012), 126 Stat. 11, the FAA’s general exemption 

authority under 49 USC § 44701(f), and 14 CFR § Part 11, Wayford W. Shrum, (Petitioner), a 

professional aviator and owner of small Unmanned Aircraft Systems, hereby petitions for 

exemptions from 14 CFR Part 21, Subpart H (Airworthiness Certificates), 14 CFR §§ 45.23(b), 

61.113(a)&(b), 91.7(a), 91.9(b)(2), 91.103(b)(1), 91.119(b)&(c), 91.121, 91.151(b), 91.203(a)

&(b), 91.405(a), 91.407(a)(1)&(2), 91.409(a)(1)&(2), and 91.417(a)&(b). If granted, the 

proposed exemptions would allow Petitioner to conduct commercial UAS flight operations in

aerial photography and videography in areas of, but not limited to; real estate, wind farm, cell 

tower and bridge inspections, agriculture, volunteer search and rescue, and, disaster damage 

assessment. All flight operations will be conducted under the conditions outlined herein and as 

may be established by the FAA in granting the above proposed exemptions.

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the FAA Modernization and Reform Act of 2012 (the ‘Reform Act’). This 

law 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 

rulemaking required under Section 333 of the Reform Act. In making this determination, the 

Secretary of Transportation is required to determine which types of UAS's do not create a hazard 

to users of the NAS or the public or pose a threat to national security in respect to the UAS's size, 

weight, operational capability, speed, operation in close proximity to airports and populated 

areas and operation within visual line of sight of the pilot/operator.

NAME AND ADDRESS OF PETITIONER

Wayford W. Shrum

2305 Starshine

Corpus Christi, TX 78414

(361) 992-5494

Point of Contact for this PETITION 

Richard R. Garza

DRONE AVIATION SOLUTIONS, LLC

711 N. Carancahua

Suite 1818

Corpus Christi, TX 78401
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BACKGROUND AND INTERESTS OF PETITIONER

Wayford W. Shrum, Petitioner, is a professional aviator of over 41 years and holder of a private 

airman’s certificate. His experience as a pilot, flight engineer, A&P examiner, (large) UAS 

sensor operator/instructor, ultralight, and RC fixed and rotor-wing pilot will provide for a safe 

and seamless transition from hobby to commercial UAS operations. Petitioner’s knowledge, 

skills and experience in UAS operations in the NAS further support granting of this request. If

granted, this exemption will permit Petitioner to operate the DJI Phantom Vision 2+ and DJI 

Inspire 1 multi-rotor copters, referred to as Petitioner’s UAS, commercially in aerial imaging in 

areas such as construction sites, real estate, wind (turbine) farms, cell tower, pipeline, and bridge 

inspections, search and rescue and disaster damage assessment. Both drones weigh less than the 

55 lbs. that define a small UAS (sUAS).

ABOUT THE UAS

DJI Phantom 2 Vision+ UAS and DJI Inspire 1 UAS

Petitioner seeks an exemption to commercially operate two models of UAS. Both, the DJI 

Phantom 2 Vision+ and the DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with Ground Control Stations (GCS) utilizing electronic tablet or smart phone 

systems. Both are equipped with camera systems for the intended aerial photography and 

videography.

• The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2 pounds 11 

ounces, while having a length of 16 inches, width of 16 inches, height of 11.9 inches, and a 

maximum no-wind airspeed of approximately 54 knots (33.6 mph). 

• The DJI Inspire 1 has a maximum gross weight of approximately 6 pounds 8 ounces, while 

having a length of 17.2 inches, width of 17.8 inches, and a maximum no-wind speed of 79.2

knots (49.2 mph). 

• Both Aircraft are equipped with four main rotors driven by Lithium Polymer battery powered 

electric motors. 

The Petitioner’s UAS’s will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, as well as 14 CFR Part 47, Aircraft Registration. 

Specific operational data on the UAS is contained in DJI product manuals and is available on 

request for both, the DJI Phantom Vision 2+, and the DJI Inspire 1.

SPECIFIC REGULATIONS FROM WHICH RELIEF IS SOUGHT

Petitioner seeks exemption from the requirements of;

14 CFR § 45.23(b)
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14 CFR § 61.113(a)&(b)

14 CFR § 91.7(a)

14 CFR § 91.9(b)(2)&(c)

14 CFR § 91.103(b)(2)

14 CFR § 91.119(b)&(c)

14 CFR § 91.121

14 CFR § 91.151(b)

14 CFR § 91.203(a)&(b)

14 CFR § 91.405(a)

14 CFR § 91.407(a)(1)

14 CFR § 91.409(a)(1)&(2)

14 CFR § 91.417(a)&(b)

1. Petitioner Seeks Exemption from the Requirements of Section 45.23 (b)

Section 45.23, entitled Display of marks, general.

(b) When marks include only the Roman capital letter “N” and the registration number 

is displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable.

2. Petitioner Seeks Exemption from the Requirements of Section 61.113(a) and (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.
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3. Petitioner Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

4. Petitioner Seeks Exemption From The Requirements Of Section 91.9(b)(2) and (c).

Section 91.9, entitled Civil aircraft flight manual, marking, and placard requirements.

(b) No person may operate a U.S.-registered civil aircraft—

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or 

Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof.

(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified 

in accordance with part 45 of this chapter.

5. Petitioner Seeks Exemption From The Requirements Of Section 91.103(b)(2).

Section 91.103, entitled Preflight action states the following, in part:

Each pilot in command shall, before beginning a flight, become familiar with all available 

information concerning that flight. This information must include—

(b) For any flight, runway lengths at airports of intended use, and the following takeoff 

and landing distance information:

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross weight, and wind 

and temperature.

6. Petitioner Seeks Exemption From The Requirements Of Section 91.119 (b) and (c).

Section 91.119, entitled Minimum safe altitudes: General, states the following, in part:

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes:

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over 

any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle 

within a horizontal radius of 2,000 feet of the aircraft. 
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(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be 

operated closer than 500 feet to any person, vessel, vehicle, or structure.

7. Petitioner Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level

of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating--

(1) Below 18,000 feet MSL, to--

i. The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

ii. If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

iii. In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.

8. Petitioner Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions,

subsection (b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the

first point of intended landing and, assuming normal cruising speed, to fly after that

for at least 20 minutes.

9. Petitioner Seeks Exemption from the Requirements of Sections 91.203(a) and (b).

Section 91.151, entitled Civil aircraft: Certifications required, subsection (a) 

and (b), states the following:

(a) Except as provided in §91.715, no person may operate a civil aircraft 

unless it has within it the following: 

(1) An appropriate and current airworthiness certificate. Each U.S.

airworthiness certificate used to comply with this subparagraph (except 

a special flight permit, a copy of the applicable operations specifications 

issued under §21.197(c) of this chapter, appropriate sections of the air 

carrier manual required by parts 121 and 135 of this chapter containing 
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that portion of the operations specifications issued under §21.197(c), or 

an authorization under §91.611) must have on it the registration number 

assigned to the aircraft under part 47 of this chapter. However, the 

airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to 

the aircraft. A revised airworthiness certificate having on it an assigned 

special identification number that has been affixed to an aircraft, may 

only be obtained upon application to an FAA Flight Standards district 

office. 

(2) An effective U.S. registration certificate issued to its owner or, for

operation within the United States, the second copy of the Aircraft 

registration Application as provided for in §47.31(c), or a registration 

certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization 

issued under §91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew.

10. Petitioner Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this

section, have discrepancies repaired as prescribed in part 43 of this chapter.

11. Petitioner Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a) (1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7

of this chapter.

12. Petitioner Seeks Exemption from the Requirements of Sections 91.409(a)(1) and

(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had --
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(1) An annual inspection in accordance with part 43 of this chapter and has been

approved for return to service by a person authorized by § 43.7 of this chapter;

or

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

13. Petitioner Seeks Exemption from the Requirements of Sections 91.417(a) and (b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state

the following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or

approved inspections, as appropriate, for each aircraft (including the

airframe) and each engine, propeller, rotor, and appliance of an aircraft. The

records must include--

i. A description (or reference to data acceptable to the Administrator) of the

work performed; and

ii. The date of completion of the work performed; and

iii. The signature, and certificate number of the person approving the aircraft for

return to service.

(2) Records containing the following information:

i. The total time in service of the airframe, each engine, each propeller, and

each rotor.

ii. The current status of life-limited parts of each airframe, engine, propeller,

rotor, and appliance.

iii. The time since last overhaul of all items installed on the aircraft which are

required to be overhauled on a specified time basis.

iv. The current inspection status of the aircraft, including the time since the last

inspection required by the inspection program under which the aircraft

and its appliances are maintained.

v. The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is required.
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vi. Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until

the work is repeated or superseded by other work or for 1 year after the work

is performed.

(2) The records specified in paragraph (a) (2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft

is approved for return to service.

EXTENT TO WHICH RELIEF IS SOUGHT

1. Extent Of Relief Petitioner Seeks And The Reason Petitioner

Seeks Relief from Section 45.23 (b).

Relief from Section 45.23 (b) entitled Display of marks, general is requested due to the size of 

the UAS and absence of a cabin, cockpit or flight station, which physically limits the location 

and prescribed size of the markings. 

2. Extent Of Relief Petitioner Seeks And The Reason Petitioner

Seeks Relief from Section 61.113(a) and (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot

in command, is requested to the extent necessary to allow a PIC holding a private pilot or

higher level certificate, as well as a current and valid airman medical certificate, and

who has met certain flight-hour and currency requirements, to conduct the proposed UAS

flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that

a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with

any business or employment if: (1) The flight is only incidental to that business or

employment; and, (2) The aircraft does not carry passengers or property for compensation or

hire.

Petitioner submits that all flights of the DJI Phantom Vision 2 + and Inspire 1 UAS,

conducted by the Petitioner pursuant to the grant of this Petition: (1) will be completely and 

deliberately related to Petition’s business; and (2) will not carry passengers or property for

compensation or hire.
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As set forth more fully below, Petitioner submits that an equivalent level of safety will be

maintained because no PIC will be allowed to operate the DJI Phantom Vision 2 + and 

Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements,

demonstrating to Petitioner that the PIC is able to safely operate either the DJI

Phantom Vision 2 + and Inspire 1 UAS in a manner consistent with the operations

specifications as described in this exemption, including evasive and emergency maneuvers,

as well as maintaining appropriate distances from people, vessels, vehicles and

structures.

3. Extent Of Relief Petitioner Seeks And The Reason Petitioner

Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the

extent required to allow Petitioner to determine that the DJI Phantom Vision 2 + and DJI 

Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS

is in compliance with the operating documents (i.e., Petitioner’s DJI Phantom Vision 2 + and 

Inspire 1 User, Maintenance and Safety Manuals).

Petitioner seeks the requested relief because the DJI Phantom Vision 2 + and Inspire 1 UAS

do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H. Therefore, Petitioner will ensure that, prior to every flight, the DJI Phantom Vision 2 +

and Inspire 1 UAS are i n airworthy condition based on the requirements for safe flight 

in the operating documents (i.e., Petitioner’s DJI Phantom Vision 2 + and Inspire 1 User, 

Maintenance and Safety Manuals).

4. Extent Of Relief Petitioner Seeks And The Reason Petitioner

Seeks Relief From Section 91.9 (b)(2).

Relief from Section 91.9, titled Civil aircraft flight manual, marking, and placard requirements 

is requested because the UAS size and configuration has no place to carry a flight manual in the 

aircraft where there is no pilot on board, nor is there room or capacity to carry such an item.

The equivalent level of safety will be maintained by making the User Manual easily accessible 

to the PIC at all times during flight operations.

5. Extent Of Relief Petitioner Seeks And The Reason Petitioner

Seeks Relief From Section 91.103(b)(2)

Relief from Section 91.103, titled Preflight actions is requested as the UAS does not require 

runway nor airport information for takeoff and landing of the UAS. The UAS does not require 

use of an airport or runway, rather it can takeoff and land from a field, parking lot, driveway, 

back yard, etc. In addition, the pilot will perform preflight actions in accordance with the User 

Manual, review safety checklists and weather conditions, and become familiar with the 

surrounding area prior to flight. Any discrepancy in flight hardware, software or flight 

conditions found to be unfavorable for flight will require the flight to be aborted. Flight 

operations will not resume until any hardware, software, physical obstacles, weather, or other 
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unsafe issues are addressed to provide for safe flight. These actions will provide an equivalent 

level of safety.

6. Extent Of Relief Petitioner Seeks And The Reason Petitioner

Seeks Relief From Section 91.119(b) and (c).

Relief from Section 91.119(b) & (c) titled Minimum safe altitudes is requested due to the fact 

that; (b) to be effective, commercial flight operations performed by Petitioner will require closeproximity imaging at distances closer than 2,000’ and lower than 1,000’ AGL, and (c) most 

commercial flight operations by the Petitioner will occur at or below 400’ AGL, or as 

authorized in the Exemption and any related COAs.

An equivalent level of safety will be achieved by engaging the property owners/agents for 

authorization prior to any flight operation. Additionally, the (small) size, speed and mass of the 

Petitioner’s UAS is incapable of causing damage to people or property when compared to a 

manned aircraft performing a similar function.

7. Extent Of Relief Petitioner Seeks And The Reason Petitioner

Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, is requested to allow flight

operations of the DJI Phantom Vision 2 + and Inspire 1 UAS, both of which have no 

altimeter, and which utilize GPS equipment and a telemetry data link to downlink altitude

information from the UA to the PIC at the ground control station (GCS). An equivalent 

level of safety is achieved as the UA’s GPS-derived altitude is set on the ground to

zero feet AGL as part of every pre-flight.

8. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief from

Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Phantom 

Vision 2 + and Inspire 1 UAS during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR). Since Petitioner’s UAS are battery-powered, with a 

maximum flight endurance not exceeding 23 minutes, the requirement of Section 91.151(b) 

becomes impractical. Without relief as requested, the useable flight time of the battery

powered DJI Phantom Vision 2 + and Inspire 1 UAS will severely limit the practicality of the 

proposed aerial imaging flight operations as described in this Petition.

9. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief from

Section 91.203(a) and (b).

Petitioner seeks relief from the provisions of Section 91.203 entitled Civil aircraft: Certifications 

required regarding airworthiness certificates. Given the size and limited operating area(s) 

proposed under the Exemption request, the DJI Phantom Vision 2 + and Inspire 1 UAS make it 
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unnecessary to proceed with the certificate of airworthiness process as established in Part 21, 

Subpart , entitled Airworthiness Certificates. 

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the UAS involved. An analysis of these different criteria demonstrates 

that the Petitioner’s UAS operated without an airworthiness certificate, under the conditions 

proposed in that exemption, will be at least as safe, or safer, than a conventional aircraft with an

airworthiness certificate. 

10. Extent of Relief Petitioner Seeks and the Reason Petitioner Seeks Relief from

Sections 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), and 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, Petitioner requests relief from these

Sections because the DJI Phantom Vision 2 + and Inspire 1 UAS do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom Vision 2 + and Inspire 1 UAS

meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, Petitioner will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and

practices prescribed in the UAS operating documents (i.e., the Petitioner’s DJI Phantom 

Vision 2 + and Inspire 1 User, Maintenance and Safety Manuals).

HOW WILL THIS GRANT BENEFIT THE PUBLIC AS A WHOLE

Granting the present Petition will further the public interest by allowing Petitioner to safely,

and economically perform aerial video and photography o f construction sites, real estate,

events and civic landscape over certain areas of the United States.

Additionally, use of the Petitioner’s UAS will decrease congestion of the NAS, reduce

pollution, and provide significant benefits to the economy. Further, the benefits of Petitioner’s

proposed operation of the DJI Phantom Vision 2 + and Inspire 1 UAS will be realized

without implicating any privacy issues.

1. The Public Will Benefit from Decreased Congestion of the NAS.

The DJI Phantom Vision 2 + and Inspire 1 UAS are battery powered and serve as a safe,

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial

imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an

exemption allowing the use of Petitioner’s UAS would reduce the numbers of manned aircraft

in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in

the air and on the ground.
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Furthermore, by reducing the number of manned aircraft operating in the NAS,

congestion around airports and subsequent ATC workload will be reduced. The

Petitioner’s UAS do not require an airport to takeoff or land.

2. The Public Will Benefit from the Safety and Efficiency of the DJI Phantom Vision 2 + and 

Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Phantom Vision 2 + and Inspire 1 UAS, instead

of manned aircraft, will benefit the public by drastically reducing the levels of air and noise

pollution generated during traditional aerial video and still photography flight operations. By

using battery power and electric motors, the Petitioner’s UAS produce no air pollution, and

is the most viable environmentally conscious alternative to the cabin class, six cylinder

internal combustion engine aircraft that are typically utilized for aerial video and photography,

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The

Petitioner’s UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates

noise pollution, as the UAS are propelled by battery powered electric motors, rather than an

internal combustion engine.

By using the DJI Phantom Vision 2 + and Inspire 1 UAS to perform aerial acquisitions, the

substantial risk to life and property in the air and on the ground, which is usually associated

with traditional manned aircraft flight operations, will be substantially reduced or completely

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the

DJI Phantom Vision 2 + and Inspire 1 UAS (weighing approximately 2.8 pounds at their

maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on

board), has less physical potential for collateral damage to life and property on the ground

and in the air in contrast to a manned aircraft.

3. Performing Aerial Video and Photography Operations with the DJI Phantom Vision 2 + 

and Inspire 1 UAS will Benefit the Economy.

In addition to being safe and efficient, the DJI Phantom Vision 2 + and Inspire 1 UAS are an

economical alternative to using manned aircraft to conduct similar aerial operations. As

such, operation of the DJI Phantom Vision 2 + and Inspire 1 UAS will allow business 

ventures, as Petitioner’s, to remain competitive and contribute to the economic growth of the

U.S. Specifically, with the rising cost of aviation fuel and the Environmental Protection

Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and

operated companies must adopt new and alternative technology in order to remain

competitive. Operating the battery powered DJI Phantom Vision 2 + and Inspire 1 UAS is one

such technology that not only allows companies greater operational flexibility compared to

manned aircraft, but also provides the flexibility without the high operational cost of a

traditional manned aircraft.

By operating small UAS such as the DJI Phantom Vision 2 + and Inspire 1 UAS,

Petitioner can remain competitive, and provide an economic alternative (to manned 

aerial data acquisition) to small and large businesses. This economic aerial 

imaging alternative will provide business savings, greater job stability to employees
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and contractors and will lead to increased economic growth for U.S. businesses. In addition, 

increased local, state, and federal tax revenues may be realized. 

4. There Are No Privacy Issues.

Similar to the manned aerial photography and data acquisition flight operations that have

been conducted for decades, Petitioner’s proposed operation of the D JI Phantom Vision

2 + UAS and DJI Inspire 1 will not pose a threat to privacy. Specifically, the DJI Phantom 

Vision 2 + and Inspire 1 UAS will be operated for commercial purposes 

with very specific photographic data collection of phy sical 

structures, land scape, gatherings of people and events, and 

will require property owner/agent consent and approval as well as local law enforcement

notification, and always in accordance with the FAA Exemption and COA requirements 

and limitations.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY, 

OR HOW THE EXEMPTION WOULD PROVIDE AN EQUIVALENT LEVEL OF 

SAFETY

The operational limitations and requirements of the UAS, as proposed in this exemption request, 

provide for an equivalent or higher level of safety due to the size, mass, speed and altitudes when 

compared to manned aircraft, and also, the piloting certification required in the exemption and 

COA are equal to those currently required for flight in the NAS. These limitations and conditions 

to which the applicant agrees to adhere to when conducting commercial UAS flight operations

under the FAA issued exemption include: 

 The small UAS will weigh less than 55 lbs. 

 The UAS will not be operated at a speed exceeding 50 mph.

 The UAS will be operated at an altitude of no more than 400 feet above ground level (AGL).

 Flights will be operated within line of sight of a pilot and/or visual observer. 

 Maximum flight time for each operational flight will be less than 30 minutes. Flights will be 

terminated at 25% battery power reserve.

 The PIC will hold the required FAA airman medical certificate and/or a valid U.S. driver’s 

license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or 

the Federal Government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

 The PIC will obtain verbal/written consent of all persons involved with the planned operation 

and ensure that only consenting persons will be allowed within 100 feet of the flight 

operation, and the radius may be reduced to 30 feet based upon an equivalent level of safety 

determination, as required under the Operator’s Manual. With the advanced permission or 

direction of the FSDO, operations at closer range may be approved. 
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 The PIC will have been trained in the operation of the small UAS prior to exercising PIC 

duties under this exemption.

 The PIC is responsible for maintaining the UAS to ensure that it is in a condition for safe 

operation. 

 A pre-flight inspection will be performed by the PIC to ensure that the UAS is in a condition 

for safe flight. 

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times. 

 All operations conducted over private or controlled-access property will be done with 

permission from the property owner/controller or authorized representative. Permission from 

property owner/controller or authorized agent will be obtained prior to the planned flight. 

 If the small UAS loses communications or loses GPS signal, the small UAS’ identified in this 

exemption request have the capability to return to a pre-determined location and land 

autonomously. This is a safety feature of the UAS not found in manned aircraft. 

 UAS operations will be aborted if unexpected obstacles, weather, or emergencies are 

encountered.

 No operations will be conducted at night, as defined in 14 CFR § 1.1. 

 All operations will be conducted under visual meteorological conditions (VMC). 

 No operations will be conducted within 5 nautical miles of an airport reference point (ARP) 

as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is obtained or 

otherwise permitted by a COA issued to the exemption holder. 

 No operations will be conducted at night, as defined in 14 CFR § 1.1. All operations will be

conducted under visual meteorological conditions (VMC).

SUMMARY

The following summary is provided for publication in the Federal Register, should it be 

determined that publication is needed: 

Petitioner requests exemptions from the following rules: 

14 CFR § 21, Subpart H; 14 CFR § 45.23 (b); 14 CFR § 45.25; 14 CFR § 45.27; 14 CFR § 

45.29; 14 CFR § 61.113 (a) and (b); 14 CFR § 91.7 (a); 14 CFR § 91.9(b)(2) & (c); CFR § 

91.103(b)(2); 14 CFR § 91.119(b) & (c); 14 CFR § 91.121; 14 CFR § 91.151(b); 14 CFR §

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

and, 14 CFR§ 417 (a) & (b). 

Petitioner seeks an exemption to conduct commercial sUAS flight operations in aerial 

photography and videography in areas of, but not limited to, real estate, wind farm, cell tower 

and bridge inspections, agriculture, volunteer search and rescue, and, disaster damage 

assessment. 

CONCLUSION 
15

Wayford W. Shrum’s Petition for Exemption satisfies the criteria set forth in the FMRA, and 

further, Mr. Shrum’s proposed operations would benefit the public and pose no threat to national 

security. The proposed operations described in this Petition for Exemption are similar to those in 

previously issued grants of exemptions, and it is desired that the FAA grant the requested 

exemptions allowing Mr. Shrum to operate a UAS commercially to perform aerial photography 

and videography. Thank you in advance for your consideration. 

Respectfully submitted,

Wayford W. Shrum