Summary of Exemption request:

Pursuant to section 333 of the FAA Modernization and Reform Act of 2012, and 

the Federal Aviation Administration’s general exemption authority under Title 49, 

United States Code, Section 44701(f), Fearlé Aerography hereby petitions for 

exemptions from the following Federal Aviation Regulations specified in Title 14 

of the Code of Federal Regulations. 

If these proposals are granted, Fearlé Aerography will be allowed to operate their 

Unmanned Aircraft Systems (UAS) and will allow the following commercial 

applications:

 Commercial Real Estate Videography

 Aerial Mapping

 Commercial Artistic Videography

Fearlé Aerography petitions for a Grant of Exemption so that the company can 

conduct aerial videography and cinematography to enhance aerial mapping and 

augment real estate listing videos. We request exemption from:

o 14 CFR Part 21, Subpart H

o 14 CFR 45.23

o 14 CFR 61.113(a)(b)

o 14 CFR 91.7(a)

o 14 CFR 91.109(a)

o 14 CFR 91.119(c)

o 14 CFR 91.9(b)(2)

o 14 CFR 91.121

o 14 CFR 91.151(a)(1)

o 14 CFR 91. 203(a)(b)

o 14 CFR 91.319(a)(1)

o 14 CFR 91.405(a)

o 14 CFR 91.407(a)(1)

o 14 CFR 91.409(a)(1)(2)

o 14 CFR 91.417 (a)(b)
Information of Applicant:

Fearlé Aerography

Austin Doughty

940 W Round Grove rd.

Unit #2235

Lewisville, TX 75067

817-559-9475

ajdoughty90@gmail.com

Qualifications of Applicant:

 Airline Transport Pilot #3620756

 CFI, CFII, MEI 

 10 years experience of building and operating numerous R/C aircraft. 

 2 years experience of operating drone type aircraft for hobby use. 

Aircraft Overview:

Fearlé Aerography will operate both the Phantom 3 and Inspire 1 UAVs. These 

aircraft are based on a quad rotor design. A lithium polymer battery powers the 

counter rotating electric motors. These drones provide excellent predictability, 

stability, and control. These aircraft have an operational weight of less than 10lbs. 

The aircraft flight endurance is 20 minutes on each battery with a maximum 

airspeed of 20 knots for the phantom 3 and 34 knots for the Inspire 1. These 

drone Aircraft have GPS utilization that allows for accurate physical positioning. 

These aircraft have iPad tablets at the ground control station that allow precise 

airspace positioning. If signal is lost during operations, the drone is capable of 

initiating an automatic return home sequence. Also if the battery level drops

below 20%, the aircraft will execute a return home to base. The aircraft has 

forward and rear position lighting to signal the direction of flight. 
Safety Procedures:

Safety will be our primary goal at Fearlé Aerography. Along with compliance with 

all FAA mandates and regulations for unmanned aircraft, we have adopted our 

own safety procedures. These procedures will include the following safety 

protocols: 

1. All PIC’s will have FAA Commercial Licenses 

2. All PIC’s will be thoroughly trained with FAA Drone regulations 

3. All PIC’s will have current FAA class 3 medicals 

4. All PIC’s will go through the Fearlé Aerography ground training program 

that will teach the operators the specific UAV they will be operating. 

Additionally weather requirements and normal and emergency procedures 

for the UAV will be covered. 

5. We will require all PIC’s to maintain records with regards to currency and 

flight hours in a pilot logbook. 

6. We will have separate maintenance logbooks for each drone which will 

include preventative and corrective maintenance actions performed on the 

drone. 

7. We will require that each PIC will acquire 25 hours UAV time with at least 

10 hours in make and model prior to commencing commercial operations.

8. We will require all PIC’s to have 3 take offs and landings prior to 

commencing any commercial operations. 

9. All PIC’s will be required to check all notams in the operating area prior to 

any commercial flight.

10.Fearlé Aerography will advise local residents or businesses in the 

immediate area of flight that drone operations will be taking place. In 

addition Fearlé Aerography will place signage indicating that UAV flight will

be operating in the immediate area. 

11.All PIC’s will maintain visual line of sight with the drone at all times.

12.In addition to the PIC, we will have a trained safety observer that will be 

proficient in airspace knowledge, emergency procedures, ground 

operations of the UAV, and obstacle awareness. 

13.Prior to any commercial flight, we will develop a flight plan that will be 

strictly adhered to. We will insure all safety precautions will be taken for

each flight.
Regulations:

14 CFR Part 12, Subpart H: Procedural requirements for issuing and changing 

design approvals, production approvals, airworthiness certificates, and 

airworthiness approvals.

Given the size and weight of the Phantom 3 aircraft and the limited operating 

area associated with its utilization, it is unnecessary to go through the certificate 

of airworthiness process under Part 21 Subpart H to achieve or exceed current 

safety levels. 

14 CFR 45.23(a): Display of Marks; General

Because of the size of the aircraft, we propose that 1 inch markings denoting the 

tail number on its fuselage. This is so the pilot, observer, and the ground crew 

personnel will see the aircraft marking to denote the serial number. 

14 CFR 61.113(a) and (b): Private pilot privileges and limitations; Pilot in 

Command

Because there we will not be flying any passengers or property for hire, we feel 

that an operator with a private pilot will be sufficient to carry out the 

responsibilities of the PIC. 

14 CFR 91.7(a): Civil aircraft airworthiness

This regulation requires that no person may operate an aircraft unless it is in 

airworthy conditions. We request an exemption to this regulation because the 

Phantom 3 has no airworthy condition set forth by the FAA. We will also ensure 

that the aircraft is in airworthy conditions at all times and will terminate a flight in 

the event we find it is not airworthy. 
14 CFR 91.119(c): Minimum safe altitudes

This regulations states that no aircraft can be operated over congested areas of a 

city, town, settlement, or over any open air assembly of persons, an altitude of 

1,00 feet above the highest obstacle within a horizontal radius of 2,00 feet of the 

aircraft. Subpart (C) focuses on restrictions of operating at an altitude of 500 feet 

to any person, vessel, vehicle, or structure. 

We will not operate the Phantom 3 near any powerlines/power structures, or any 

congested areas. Because of the size and weight of the Phantom 3, we feel that 

there is very little risk flying less than 500 feet around areas other than congested 

areas. We will ensure that will gain permission to operate within 500 feet of any 

private property. The owners of that property will always be informed of any 

unmanned flight operations. We also feel that operating below 400 feet will be 

the safest cushion for work. We will practice constant airspace awareness to allow 

separation of UAS operations and property.

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

This regulation requires that for any person to operate a US registered civil 

aircraft, there must be a current approved airplane or rotorcraft manual readily 

available. There is no room for any manual to be place on the UAS itself. 

However, a flight manual and any documentation will be made available at the 

ground station of the flight operation. Although there is no FAA approved flight 

manual for the Phantom 3, we will provide the manufacturer user manual and 

check list for safe operation. 

14 CFR 91.109(a): Flight Instruction

This regulation prescribes that no person may operate a civil aircraft that is being 

used for flight instruction unless that aircraft has fully functioning dual flight 
controls. The Phantom 3 has no dual flight controls and we wish to be exempt 

from this rule. 

14 CFR 91.203(a)(b): Carrying Civil Aircraft Certification and Registration 

This regulation states that no person may operate an aircraft unless it has an 

appropriate and current airworthiness certificate. This certificate must be 

displayed in at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

The Phantom 3 has no airworthiness certificate and no place on board to carry 

certification or registration documents to display them. We believe that this 

requirement would not be appropriate. However, we will have all documents and 

certificates applicable at the ground station of operations. 

14 CFR 91.121: Altimeter settings

This regulation requires aircraft operators to maintain cruising altitude or flight 

level by reference to an altimeter. The Phantom 3 uses GPS and internal 

barometric altimeters to determine altitude. This method will be used for 

maintaining level flight. We believe this regulation is not applicable. 

14 CFR 91.151(a)(1): Fuel requirements for flight in VFR conditions 

The Phantom 3 uses battery for its source of power. Therefore, we believe 

exemption should be granted as the regulation is not applicable. However, we will 

ensure that at 30% battery power, the aircraft will return to its point of landing. 

14 CFR 91.405(a): Aircraft Inspection

This requirement states that an aircraft operator or owner shall have that aircraft 

inspected as prescribed in subpart E of the same part and shall have discrepancies 

repaired as prescribed in part 43 of the chapter 4. 
There is no approved maintenance program for the Phantom 3 however, we will 

ensure that it goes through a rigorous annual inspection. 

14 CFR 91.407(a)(1): Approved maintenance

This section states that no person may operate an aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by an authorized person. 

If there is any maintenance that includes a major change of engines or propellers, 

the aircraft will be tested by the PIC in a remote unpopulated location to ensure 

the aircraft is operating safely. 

14 CFR 91.409(a)(2): Routine Maintenance 

This section states that no person may operate an aircraft unless, within the 

preceding 12 calendar months, it has had an inspection for the issuance of 

airworthiness certificate. 

After any major maintenance, the aircraft will undergo a test flight in a remote 

unpopulated area to ensure the aircraft is operating safely. 

14 CFR 91.417(a)(b): Aircraft logbook

This section prescribes that each owner or operator of an aircraft shall keep a 

record of the aircraft. This record will include the time log and maintenance 

records over the lifetime of the aircraft. 

We will maintain an aircraft logbook that will include flight time and any 

maintenance preformed on the UAV. We will be diligent to ensure the accurate 

status upkeep of the maintenance record to include the battery maintenance log, 

software that is current prior to aircraft operation, and ensuring the aircraft is 

safe for flight. 
Summary:

Fearlé Aerography believes that approval from the FAA will allow us to provide 

safe operations of our unmanned drones. With being granted this exemption, we 

will greatly enhance the ability to showcase commercial and residential 

properties. Until recently, potential buyers of these properties can now see these 

properties without physically having to be at the location. We are able to map 

large properties for potential customers, eliminating travel to and from the 

perspective property. Through the FAA exemption process, operators will be 

required to prove standard operating practices and procedures, thereby 

eliminating non licensed hobbyist in the NAS. With these strict guidelines in place, 

we firmly believe this new industry will become a viable commercial industry.