Petition for Exemption 

Name and Mailing Address of Petitioner

Will Gallagher

Gallagher Studios

2900 Centennial Olympic Park

Austin, Texas 78732

512/775-4966

will@willgphoto.com

1. Request for Exemption

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

ReformAct), and 14 C.F.R. Part 11, Will Gallagher d/b/a/ Gallagher Studios (“Petitioner”) operating 

in the State of Texas, wishes to apply for an exemption from the Federal Aviation

Regulations (FAR) listed below to allow operation of a DJI Inspire 1 sUAS commercially in 

airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA 

as required by Section 333.

1.1 Additional Information. Substantially Identical Granted Exemptions

The substance of this request is essentially identical as that recently granted to:

 R. Frank Photography -- Regulatory Docket No. FAA–2015–4489;

 Falcon Sky Cam -- Regulatory Docket No. FAA-2014-0884.

2. Regulations from Petitioner request exemption:

14 C.F.R. 61.113(a) and (b)

14 C.F.R. 91.7(a)

14 C.F.R. 91.9(b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.205(b)

14 C.F.R. 91.215

14 C.F.R. (91.401-91.417)
2. Extent of Relief Requested and Reason for which Exemption is sought

Petitioner request this exemption to pursue its commercial interests in providing 

services to clients in the following areas:

 Aerial Photography

 Aerial Videography (not closed set Cinematography)

 Surveying and 3D aerial mapping 

 Agriculture crop assessment 

 Golf course management 

 Insurance claim assessment

 Special event photography and videography

 Construction site and ecological impact assessment 

All of Petitioner’s sUAS flights that will occur over private or controlled access property 

will do so with the property owner’s consent and knowledge and that only people who have 

consented or otherwise have agreed to be in the area where flight activity is taking place. All of 

Petitioner’s sUAS flights will meet relevant FAA regulations and guidelines, including the use of 

an appropriately licensed pilot in command and at least one trained observer(s).

3. How this Request would benefit the Public

If the exemption is granted, Petitioner will engage in aerial photography and videography 

of land, buildings, and insurance claims, by using remote controlled sUAS to see the condition of 

fields, crops, ecological impact, and financial losses due to destruction by fire and other natural 

disasters, without the need to drive over or climb on the property being so assessed. RFP has a 

sUAS equipped with cameras for aerial photography including video and still pictures. This will 

benefit the public as a whole because small Unmanned Aircraft Systems (sUAS) are often 

superior photographic platforms compared to helicopters because they are smaller, less 

expensive, produce less noise, have much less environmental impact and are less likely to 

cause injury to people and property.

4. No Adverse Safety Impact/ Equivalent level of Safety

Petitioner will have the ability to produce high-resolution photography of remote 

locations from vantage points that would be difficult or dangerous to access, erect, scale or 

reach on foot. Petitioner’s exemption would permit us to operate lightweight, unmanned 

(remotely controlled in line of sight) sUAS’s in tightly controlled and limited airspace. 

Predetermined, specifically marked areas of operation as well as Global Positioning Satellite 

(GPS) navigation maps which incorporate restricted, no fly zones and control zones of airports, 

will allow Petitioner to operate within current safety parameters as well as the new ones being 

implemented. Such activities are either safer than traditional methods (helicopters, cranes,
scaffolding) or provide an equivalent level of safety as that pertaining to rotor wing aircraft.

4.1 Additional Information. DJI Inspire 1

Petitioner requests to operate a DJI Inspire 1.

This aircraft has essentially similar safety features as the DJI Phantom III that was the 

subject of a grant of exemption in R. Frank Photography -- Regulatory Docket No. FAA–2015–

4489

The DJI Inspire 1 is equipped with a proprietary 3 axis gimbal and camera system. This 

sUAS has a built in capacity to limit the height it flies above the ground, to limit the radius of 

the distance it flies from the operator and to exclude it for Class B, C, and D airspace including 

No Fly Restricted Zones. The Inspire 1 also has the failsafe feature of an autopilot system that

will return to the aircraft to its home starting point and land safely in the event that 

communication between the main controller and the transmitter is lost.

The specifications and operation of the DJI Inspire 1 meet with the Model Aircraft 

Operating Standards as set below:

 The petitioner will only operate its sUAS in line of sight of a pilot/observer and will 

operate at sites that are sufficient distance from populated areas within the sterile 

area described in the FOPM. Such operations will insure that the sUAS will not create a 

hazard to users of the national airspace or the public. When flying sUAS within 3 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 25 minutes.

 Flights will be terminated at 25% battery power reserve should that occur prior to the 

30 minute limit.

 The sUAS will be programmed so it will not be operated at an altitude of no more than 

400 feet AGL, and not more than 200 feet above a fixed platform from which operations 

are conducted.

 The minimum crew for each operation will consist of the sUAS pilot and the Visual

Observer.

 The sUAS will weigh less than 55 pounds including its payload of camera and gimbal.

 The sUAS will fly no more than 50 knots and can hover and move horizontally and 

vertically.
5. Summary for Publication

“Petitioner seeks exemption from the following rules: 14 C.F.R. 61.113(a) and (b);14 

C.F.R. 91.7(a); 14 C.F.R. 91.9(b) (2); 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 

14 C.F.R. 91.151(a); 14 C.F.R. 91.205(b); 14 C.F.R. 91.215; 14 C.F.R. (91.401-91.417).

Petitioner seeks exemption to operate a sUAS as a commercial entity for the purposes 

of aerial photography, videography and other applicable remote sensing operations.”

6. Conclusion

Given the small size of the sUAS, and the restricted airspace within which it will 

operate, I believe our sUAS operations will comply with both the spirit and the rules 

intended by the Reform Act safety requirements.

As part of this request for exemption, Petitioner gives personal assurance that all 

persons involved in aerial operations have completed sUAS education and training including 

all applicable regulations and guidance documents.

I respectfully request exemption under Section 333 to enable Petitioner to operate 

efficient, limited, low-risk commercial sUAS operations for the activities stated, respecting at 

all times, the space and privacy of citizens and property as we keep our skies safe.

Sincerely yours,

Will Gallagher

Gallagher Studios

2900 Centennial Olympic Park

Austin, Texas 78732

512/775-4966

will@willgphoto.com