Robert William Skrob

1390 Timberlane Rd, Tallahassee, FL 32312

(507) 697-5762 skrobmedia@gmail.com

I formally petition the Federal Aviation Administration (FAA) for an 

exemption from part 21, subpart H; and Sections 45.23(b), 

61.113(a) and (b), 91.7(a), 91.119 (c) 91.121, 91.151(a), 91.203(a) 

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

of Title 14, Code of Federal Regulations (14 CFR). 

Outlined below are the descriptions of the parts, subparts and 

sections in which I request exemptions and my reason for 

requesting the exemptions. 

Part 21 prescribes the procedural requirements for issuing and 

changing design approvals, productions approvals, airworthiness 

certificates, and airworthiness approvals. 

Section 45.23(b) prescribes that 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. 

Section 61.113(a) and (b) prescribes that— 

(a) no person who holds a private pilot certificate may act as a 

pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire; nor may that person, for 

compensation or hire, act as pilot in command of an aircraft. 
(b) a private pilot may, for compensation or hire, act as pilot in 

command 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. 

Section 91.7(a) prescribes that no person may operate a civil 

aircraft unless it is in an airworthy condition. 

Section 91.119 prescribes that, except when necessary for 

takeoff or landing, no person may operate an aircraft below the 

following altitudes: 

(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. 

(1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each 

person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be 

operated at less than the minimums prescribed in paragraph (c) 

of this section. 

Section 91.121 requires, in pertinent part, each person operating 

an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or 

an appropriate altimeter setting available before departure.” 

Section 91.151(a) prescribes that no person may begin a flight in 

an airplane 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, 

(1) during the day, to fly after that for at least 30 minutes 

[emphasis added]. 

Section 91.203(a) prohibits, in pertinent part, any person from 

operating a civil aircraft unless it has within it (1) an appropriate 

and current airworthiness certificate; and (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). 

Section 91.203(b) prescribes, in pertinent part, that no person 

may operate a civil aircraft unless the airworthiness certificate 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. 

Section 91.405(a) requires, in pertinent part, that an aircraft 

operator or owner shall have that aircraft inspected as prescribed 

in subpart E of the same part and shall, between required 

inspections, except as provided in paragraph (c) of the same 

section, have discrepancies repaired as prescribed in part 43 of 

the chapter. 

Section 91.407(a)(1) prohibits, in pertinent part, any person from 

operating an aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under § 

43.7 of the same chapter. 

Section 91.409(a) (2) prescribes, in pertinent part, that no person 

may operate an aircraft unless, within the preceding 12 calendar 

months, it has had an inspection for the issuance of an 

airworthiness certificate in accordance with part 21 of this 

chapter. 
Section 91.417(a) and (b) prescribes, in pertinent part, that— 

(a) 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. 
(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. 

Robert Skrob’s exemption requests from the above are 

detailed below: 

Unmanned Aircraft System: 

Robert Skrob plans to operate a UAS, the PHANTOM 3 

Professional and PHANTOM 4, which is comprised of an 

unmanned aircraft (UA or PHANTOM). The PHANTOM 3 

Professional and PHANTOM 4 is a quad-copter with a gross 

weight of about 3 pounds. It is equipped with four rotors that are 

driven by electric motors which is powered by batteries. The UA 

has a maximum airspeed of 44 mph. 

Robert Skrob plans to use this UAS in aerial cinematography and 

photography on non profit promotion materials, stock 

photography, enhancing real-estate listings and other such tasks 

for businesses in the greater Tallahassee, FL area which could 

benefit from an aerial view for their planning of future expansions 

and/or advertising of their products or business. For most 

businesses and real estate professionals in the area, standard 
aerial photography has been very cost prohibitive. The economic 

impact of being able to assist your business using aerial 

photography would be substantial. 

The use of this UAS in the above named applications greatly 

reduces risk to the public and property as there is no fuel carried 

by the PHANTOM 3 Professional and PHANTOM 4, aircraft noise 

is greatly reduced as opposed to a standard aircraft or rotorcraft 

both of which require numerous passes or extended lengths of 

hover time to accomplish the same task as the Phantom can in 

only a few minutes. The Phantom only weighs about 3 pounds 

and is by far a much smaller hazard to persons or property than a 

standard aircraft or helicopter in the event of a catastrophic inflight failure. 

There is no higher priority for Robert Skrob other than the safety 

of the public and property. 

Robert Skrob makes the following representations of its 

operation in which to abide by to ensure these exemptions if 

granted, will provide a level of safety at least equal to existing 

rules: 

The PHANTOM 3 Professional and PHANTOM 4 will only be 

operated by, a pilot with completed at a minimum, 25 hours of 

documented flight time using the PHANTOM 3 Professional and 

PHANTOM 4 with focus being: 

	 	 a.) Collision avoidance 

	 	 b.) Loss of C2 link procedures as outlined in the Operators 

manual for the PHANTOM 3 Professional and PHANTOM 4 

	 	 c.) Identification of inflight hazards i.e. aerial wires, birds in 

the area, changing weather etc. 
	 	 d.) Estimating distance from objects, persons, vehicles and 

vessels. 

	 	 e.) Communication with the spotter(s) 

	 	 f.) Completed the DJI PHANTOM 3 Professional and 

PHANTOM 4 pilot training guide 

	 	 g.) The ability to recognize persons or objects that are not 

part of the intended and permitted part of the project that 

enter the 500 foot operational area unless such persons or 

objects are deemed permitted by the owner or controller of 

the property or area and the PIC makes a safety 

assessment of the risk of operating closer and it does not 

pose undue or significant risk. 

	 	 h.) The ability to quickly and safely land the PHANTOM 3 

Professional and PHANTOM 4 in the event of intrusion into 

the safe zone. 

1.) A complete pre-flight systematic check by the PIC of the 

Phantom’s physical condition,i.e. props, prop guards, 

landing gear, position indicator lights, battery capacity and 

overall airframe condition. If any of the above are not within 

the manufacturers minimum standards no flight will take 

place until such time as the issue(s) is repaired to 

manufacturers standards.

2.) Written documentation of each physical inspection and 

repairs if any, by the PIC (pilot in command) will be kept with 

the Phantom and will be on-site and available for review. 
3.) Software in relation to the Phantom’s operation will be 

checked for proper function. The most current DJI Pilot APP 

and the current firmware will be installed to assure the most 

up to date safety features. 

4.) Prior to every flight, the compass on the PHANTOM 3 

Professional and PHANTOM 4 will be calibrated as to 

ensure precision location. 

5.) Robert Skrob will ensure the altimeter setting on the 

PHANTOM 3 Professional and PHANTOM 4 is that of AGL 

(above ground level) rather than GPS or barometric pressure 

derived settings. 

6.) Every safety feature offered through the DJI Pilot APP will 

been abled for every flight, every time. 

Please refer to the attached User Manual (EN) v1.2 PDF file 

starting at page 39 for a description of the following safety 

features: 

- Enable GPS Home Point 

- Compass calibration 

- Low battery auto go home 

- Dynamic home point 

- Current RTH (return to home) altitude (AGL) 

- Low battery alarm 

7.) Use of the DJI Pilot App GUI (graphical user interface) 

Refer to attached User Manual (EN) v1.2 PDF for detailed 

descriptions starting at page 34.
Of particular interest are the following: 

- Flight attitude and radar function 

- Flight parameters-RTH (return to home) altitude, horizontal 

distance from home point, altitude-vertical distance from home 

point, speed-horizontal flying speed. - Flight Battery Level 

indication 

-There is a built in preflight checklist within the DJI vision APP 

which is completed prior to each flight. 

- Aircraft GPS Status-Robert Skrob’s PHANTOM 3 Professional 

and PHANTOM 4 will not fly with less than (7) GPS Satellites 

available. 

- Hide or show flight parameters- Robert Skrob’s PHANTOM 3 

Professional and PHANTOM 4 will ALWAYS fly with parameters 

displayed in order to assist in maintaining safe distances from 

persons and objects and to adhere to the flight plan. 

8.) Robert Skrob will operate with a minimum of (1) one, trained 

spotter for every flight. “Trained” meaning familiarization with the 

Phantom Professional, its abilities according to the operators’ 

manual as well as the abilities of PIC. Spotters will participate in 

documented training developed in-house prior to being allowed 

on the flight line. Training will consist of, at a minimum the 

following: 

a) The ability to roughly identify minimum distance from objects 

b) The ability to quickly recognize unusual flight maneuvers/

attitudes of the PHANTOM 3 Professional and PHANTOM 4

c) The ability to communicate with the PIC the visual limitations 

and to never let the PHANTOM 3 Professional and PHANTOM 4 

out of the visual capabilities of the PIC and the spotter(s).

d) The ability to recognize persons or objects that are not part of 

the intended and permitted part of the project that enter the 500 

foot operational area unless such persons and objects are 

deemed permitted by the owner or controller of the property or 

area and the PIC makes a safety assessment of the risk of 

operating at a closer range and it does not pose undue or 
significant risk to those persons or objects.

e) The ability to accurately describe to the PIC, the orientation of 

the Phantom in relation to the pre-set home point as well as the 

direction of travel.

f) The training will take place under strict, safe conditions away 

from persons or large obstacles. I.e. large open fields. 

9.) Prior to each flight, the PIC and the Spotter(s) will performa 

pre-flight briefing detailing the estimated flight distance, 

estimated flight level AGL and the goal of the particular flight. 

Each preflight briefing will be documented by the PIC to include 

flight details, pilot name, spotter(s) name, weather details, time 

and date. 

Written and/or verbal consent will be obtained from the person/

business requesting the flight. 

A post-flight briefing will also be conducted and documented 

with the PIC and the The Documented Pre-flight, the raw pictures 

and/or the raw video footage as well as the post-flight brief and 

written consent will be kept by Robert Skrob for a period of at 

least (2) years. 

Robert Skrob believes that given the size, weight, speed, and 

limited operating area associated with the PHANTOM 3 

Professional and PHANTOM 4, requests an exemption from 14 

CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 

(a) and (b) (Certifications required), subject to certain conditions 

and limitations, is warranted and meets the requirements for an 

equivalent level of safety under 14 CFR part 11 and Section 333 

of P.L. 112-95 (Section 333). 

Robert Skrob requests exemption from § 45.23 Marking of the 

aircraft. The PHANTOM 3 Professional and PHANTOM 4 does 

not have a cabin, does not have a cockpit or a pilot station. 

Minimum sized lettering and wording are difficult to place on the 

PHANTOM 3 Professional and PHANTOM 4. Robert Skrob will 
affix a sticker on the unit which will clearly and conspicuously 

include the FAA UAS registration number and contact information 

in case of aircraft loss. 

Robert Skrob requests an exemption from §§ 91.405(a), 91.407(a) 

(1), 91.409(a) (2) and 91.417(a) and (b) Maintenance inspections 

and feel it should be granted since they only apply to aircraft with 

an airworthiness certificate. Robert Skrob has developed 

maintenance inspections and documentation methods for the 

PHANTOM 3 Professional and PHANTOM 4 from personal 

experience as well as the manufacturer’s user manual. (See 

attached pdf user manual) 

Robert Skrob requests relief from § 91.119(c) because the aircraft 

will be operated at altitudes below 300 feet AGL. Section 

91.119(c) states that no person may operate an aircraft below the 

following altitudes: 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. Robert Skrob will operate pursuant to the following 

restrictions related to § 91.119: 

-Operate in reasonably safe environments that are closely 

monitored by ground assistants and signage placed in locations 

that would be considered reasonable locations for pedestrians, 

vehicles or vessels to enter the area. 

-Within 5 miles of airports and congested areas. Congested 

areas will be defined by VFR charts as well as by contacting the 

local FSDO (flight standards district office) 

-Conduct all operations under Robert Skrob’s guidelines 

contained in the operating documents and will analyze flight data 

and other sources of information such as the manufacturer’s 

website to constantly update and enhance safety. 
-Contact respective airports if operations will be within 5 miles to 

advise them of estimated flight time, flight duration, elevation of 

flight and other pertinent information deemed important by the 

airport. 

- Always obtain all necessary permissions prior to operation. 

Permissions include but are not limited to a (COA) and a request 

for a (NOTAM) as well as permission from the property owner or 

person in control of the property and when practical will be in 

writing and kept on file for 2 years for review. If it’s not possible 

to obtain written permission, the PIC will document in writing 

how permission was obtained i.e. phone call with date, time and 

party information. 

Robert Skrob requests relief from 14 CFR 91.121 Altimeter 

Settings. Robert Skrob’s PHANTOM 3 Professional and 

PHANTOM 4 has a barometric altimeter and GPS derived altitude 

capabilities. The FAA requires any altitude reported to ATC to be 

in feet AGL. Robert Skrob will set the altimeter on the PHANTOM 

3 Professional and PHANTOM 4 to zero feet AGL rather than 

local barometric pressure or field altitude before flight. 

Robert Skrob requests relief from § 91.151 (a) Fuel requirements 

for flight in VFR conditions based on the following: 

No fuel is used in the PHANTOM 3 Professional and PHANTOM 4 

but it is battery operated. Batteries have, in our experience have 

about 20 minutes of quality flying time. In the interest of safety, 

Robert Skrob generally lands with 35% of battery remaining 

which gives about 9 minutes of flying time per battery. The 

PHANTOM 3 Professional and PHANTOM 4 has an audible 

battery state warning system. Robert Skrob will always follow the 

manufactures minimum battery warning which is 30% remaining. 

There is also an on-screen warning of not enough battery to 

return to home message if flight distance has exceeded battery 

capacity. In this event, an emergency landing would be made as 

soon as safe and practical. The PHANTOM 3 Professional and 
PHANTOM 4 also has an automated function which results in 

immediate landing when a low battery is detected. Researching 

previous relief requests, relief has been granted for manned 

aircraft to operate at less than prescribed minimums, including 

Exemption Nos. 2689, 5745, and 10650. In addition, similar UASspecific relief has been granted in exemption Nos. 8811, 10808, 

and 10673 for daytime, VFR conditions. Robert Skrob will adhere 

to all VFR minimums as well as VMC conditions when planning 

and/or executing any flights. There is little purpose for aerial 

video or pictures if the weather is less than desirable. Following 

VFR minimum standards will at least ensure a safe flight. Wind 

and forecast weather will be a key in deciding suitable 

conditions. Local weather can be attained from the nearest 

airport by using AWOS. No flight will take place in any condition 

that would potentially be outside of the PHANTOM 3 Professional 

and PHANTOM 4 capabilities in wind. Robert Skrob will always 

fly within its 30% minimum remaining battery life at its first 

intended landing point. 

If there are any areas that have not been addressed, please 

contact me for supplemental information. 

Sincerely, 

Robert William Skrob

1390 Timberlane Rd, Tallahassee, FL 32312

(507) 697-5762 skrobmedia@gmail.com