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Michael Scott Reeves

8134 North 70th East Ave

Owasso, OK 74055

October 30, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington DC 20590

Reference: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from certain parts of the FARs.

Dear Sir or Madam:

Michael Scott Reeves (hereinafter Mr. Reeves) seeks exemption from the requirements listed in this 

document to operate a small Unmanned Aircraft System (sUAS) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Mr. Reeves to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial videography and 

photography for real estate, infrastructure and construction inspections, public events, sporting events,

mapping, surveying, marketing and training.

I. NAME AND ADDRESS OF THE PETITIONER

The name and address of the Petitioner and point of contact is:

Michael Scott Reeves

8134 North 70th East Ave

Owasso, OK 74055

918-630-7611

MScottReeves@me.com

II. REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED

Mr. Reeves requests exemption from the following applicable regulations, pursuant to the 

Administrator’s authority to grant exemptions contained in 49 U.S.C. §106(f), 40113, and 

44701: 

 14 CFR 61.23 (a) and (c)

 14 CFR 61.101 (e)(4) and (5)

 14 CFR 61.113 (a)

 14 CFR 61.315 (a)

 14 CFR 91.7 (a)

 14 CFR 91.119 (c)

 14 CFR 91.121
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 14 CFR 91.151 (a) (1)

 14 CFR 91.405 (a)

 14 CFR 91.407 (a)(1)

 14 CFR 91.409 (a)(1) and (2)

 91.417 (a) and (b)

III. PROPOSED UAS

Mr. Reeves seeks the above exemptions to operate DJI Phantom 3 and DJI Inspire 1 sUAS’s

for compensation or hire within the NAS. These sUAS’s are a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet or smartphone systems. The DJI Phantom 3 has a maximum gross weight of 

approximately 2 pounds 13 ounces, while having a length of 16 inches, width of 16 inches, 

height of 8 inches, and a maximum speed of approximately 30 knots. The DJI Inspire 1 has a 

maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, 

height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 3 

and DJI Inspire 1 sUA’s are equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors.

The sUAS’s that will be operated by Mr. Reeves will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and 

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Mr. Reeves operation of sUAS’s meets the conditions 

of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H.

Mr. Reeves requests relief from Sections 91.405(a), 91.407(a) (1), 91.409(a) (1) & (a) (2), and 

91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. Mr. Reeves submits that the requested relief is 

proper since an equivalent level of safety will be ensured. Mr. Reeves will use experienced 

personnel or technicians to perform maintenance, alterations, or preventive maintenance 

on the sUAS’s using the methods, techniques, and practices prescribed in the operating 

documents.

Mr. Reeves seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the sUAS’s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Mr. Reeves will ensure that the sUAS’s are in condition for safe 

operation, prior to every flight, by determining that the sUAS’s are in compliance with the 

operating documents and that the aircraft is in a condition for safe flight including a 

thorough preflight inspection.

Mr. Reeves also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the sUAS’s will not have a typical barometric altimeter onboard.
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However, altitude information will be provided to the PIC via GPS equipment and radio 

communications telemetry data link, which downlinks from the sUAS to the GCS for active 

monitoring of the flight path. This altitude information, combined with operations in visual 

line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, Mr. Reeves seeks an exemption from the requirements of Section 91.151(a) (1)

entitled Fuel requirements for flight in VFR conditions. Mr. Reeves submits that safety will 

not be affected by operation of the sUAS’s during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 20-30 minutes. Mr. Reeves will ensure missions are conducted

with sufficient reserve to operate for at least 5 minutes after the intended mission is 

complete.

IV. UAS PILOT IN COMMAND

Mr. Reeves petitions for relief from certain requirements of Section 61.23(a), 61.101(e) 

(4&5), 61.113(a), and 61.315(a) dealing with Certification: Pilots, Flight Instructors, and 

Ground Instructors. In previous petitions for exemption, the FAA has held that a PIC of a 

sUAS holding at least a Sport Pilot certificate and a U.S. Driver’s License, or greater medical 

certification, would not adversely affect safe operations within the NAS or present a hazard 

to people or structures on the ground. For this reason relief is requested.

V. PROPOSED OPERATION(S) OF THE UAS

Mr. Reeves proposes the following guidelines and limitations to ensure safety in the NAS:

1. The DJI Phantom 3 and DJI Inspire 1 will be operated at less than 50 knots groundspeed.

2. The PIC shall operate the DJI Phantom 3 and DJI Inspire 1 at least 500 feet from

nonparticipants.

3. Flights will be operated within unaided visual line of sight of an operator and observer. 

4. All flights will be conducted in daylight, Visual Flight Rules (VFR) conditions. 

5. Flights will be operated at an altitude of no more than 400 feet AGL. 

6. Maximum total flight time for each operational flight will be 30 minutes. 

7. Flights will be terminated at 20% battery power remaining should that occur prior to 30 

minutes. 

8. Minimum crew for each operation will consist of the sUAS Operator, the Visual Observer 

and may include a security coordinator.

9. A briefing will be conducted in regard to the planned sUAS operation prior to each flight. 

All personnel who will be participating in that flight shall be present for the preflight 

briefing. 

10. When necessary, and at least 72 hours prior to flight, the operator will file FAA Form 

7711-1, or its equivalent, with the appropriate Flight Standards District Office. 

11. Observer and Operator will at all times be able to communicate by voice with each 

other. 

12. When necessary, permission from relevant property owners will be obtained. 
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13. If the sUAS suffers a ‘lost link’, the DJI Phantom 3 and DJI Inspire 1 will perform the 

predetermined flight maneuver to land as soon as practical as outlined in the preflight 

briefing. 

14. The operator will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

15. All accidents and incidents shall be recorded in the aircraft log and reported in 

accordance with FAA directives. 

VI. PUBLIC INTEREST 

Granting the present Petition will further the public interest by allowing Mr. Reeves to 

safely, efficiently, and economically perform aerial videography and photography for real 

estate, infrastructure and construction inspections, public events, sporting events, mapping, 

surveying, marketing and training. 

The DJI Phantom 3 and DJI Inspire 1 are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. 

Additionally, conducting these operations with the DJI Phantom 3 and DJI Inspire 1, instead 

of manned aircraft, will greatly 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 sUAS’s produce no air pollution, 

and is the most viable environmentally conscious alternative to the aircraft that are typically 

utilized for aerial video and photography. 

By using the sUAS’s to perform aerial services, 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 sUAS’s have less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations. 

I am prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. We look forward to working with your office. Please contact me at any time if you require 

additional information or clarification.

Sincerely, 

Michael Scott Reeves 

918-630-7611 

MScottReeves@me.com