FAA

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

Dear Exemption Manager,

Introduction:

I am submitting a Petition for Exemption for Unmanned Aircraft Systems operations. I am seeking 

this exemption primarily so that I may start a small business wherein I am able to sell 

UAS/UAV/RPA footage from my DJI Phantom 3 to real-estate companies. Other applications are of 

course possible however this is my primary focus at this time. It is my understanding that I will 

not be able to create a small business without this exemption. 

As of today, I am delaying the creation of my company, which will be named “I-Spy”, until such 

time as I know it is legal to sell our product. I want to do the process by the book, and have no 

intention of operating outside the law. At the same time, the current restrictions completely 

preempt this venture from taking place. Thus the reason I fervently ask for this exemption. After 

explaining who I am and what I plan to do with the exemption, I am sure you will agree I am a 

qualified candidate who is focused on safety.

About me, the pilot:

I currently work as RPA (UAS/V) pilot with the 119WG/178RS in Fargo, ND which is also where I 

would like to operate my small RPA. I have worked in the RPA field since 2007, first as an 

intelligence analyst, until November 2013 when I began my transition to an RPA pilot. I received 

my RPA wings (Air Force AFSC 18A) in the summer of 2013 and have been flying real world 

missions ever since on a daily basis.

I have over 700 hours of Pilot in Command (PIC) time flying missions all over the world with the 

MQ-1 Predator. As a reconnaissance unit we are consistently training, updating and improving our 

tactics, and developing our airmanship. As an RPA pilot, I am held to the same physical and 

operational standards that all Air Force pilots are.

Exemption request:

My request is for a waiver of the sections identified below in an effort to operate a UAS in use of

Commercial applications for Real Estate and Marketing Purposes, and live sporting events.

This request specifically serves the public and economic interest to aide in the areas stated 

above.

The granting of this exemption would make logical sense because of my professional approach to 

UAS operations, my clear understanding of FAA rules, my awareness of operational and restricted 

airspace, my experience as an RPA pilot, my awareness of and ability to react to emergency 

situations, and my attitude of safety first when it comes to flight operations.

I believe with the granting of this exemption and the additional operational experience I will gain

from flight operations that I will be able to have a much larger impact for the future of UAS. More

flight experience now will be invaluable for us to assist the general public in the future as they 

embark into UAS operations.

I would currently be seeking exemption of:

Section of 14 CFR: parts 21 Subpart H, 27, 45.23(b), 45.27(a), 61.113(a) and (b), 61.133(a),

91.7(a), 91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.319(a)

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

If I have erroneously omitted any other relevant section for our intended operations, please feel

Free to suggest the missing section(s).
Suggested Public Federal Register Summary:

"The petitioner is seeking an exemption to operate unmanned aircraft systems (UAS) with a

maximum weight of less than 55 pounds to perform Professional Marketing Services, Real Estate 

and Live Sporting Events, Etc. Data gathered may include still and moving images captured with 

onboard cameras."

UAS Description:

I am asking for an exemption for a UAS up to 55 pounds because that is currently what the 

standard exemption covers. However, at this time I only have one UAS, a Phantom 3 by DJI which 

is much smaller than 55 pounds.

In the event a loss of communications occurs the craft will rise up vertically to a safe height

before beginning an automatic return to home function. The control signal may be reconnected

in flight and the pilot can take over safe operations again if communication is reestablished.

However in the case of a GPS failure the craft will be able to be manually flown to a safe landing

by the pilot.

The craft operates electrically, carries no flammable fuel, has an integrated GPS pilot system,

provides location information along with height AGL, speed, battery life, has programmed no-fly

zones for controlled airports, and provides direction of travel and distance from the pilot.

Flight Operations:

I am well aware of conducting safe flight operations and planning flight paths that minimize any

over flight of crowds.

Any flight operations in town environments would typically be for close air support for very 

focused events such as sporting, or real-estate marketing. These operations occur in a very

limited area and would not need to overfly densely populated areas in general. Operations would 

be more vertical in nature above the specific event. There would be no need in my opinion to ever 

fly above 200’ AGL.

Our proposed public safety UAS operations are typically conducted at low altitudes less than 200’ 

AGL (within Class G airspace), not over crowds, and not near airports. Additionally, there will be 

no need for any flights including high speeds. Certainly slower than 30mph but most often at 

walking speeds. Flights will end when battery reserve reaches 25 percent. Operations will not 

occur under IFR conditions. In addition, preflight and post-flight checklists and UAS examinations 

will help detect any abnormalities prior to flight and after flight. Any UAS unable to satisfy safety 

checklists will be removed from service until the issue can be resolved. Granting this request 

would not adversely affect safety since operations would be in accordance with current UAS 

rules.

Section 333 Compliance and Appropriateness:

Based on the size of the craft, experience of the pilot, and operational goals, this request

appears to be well suited for approval using the criteria outlined in Section 333 of the FAA

Modernization and Reform Act of 2012 and will move safe flight operations forward in

accordance with the intent of Section 333.

Ongoing Efforts:

We are also keenly aware of the new issues involved in UAS public safety operations and would

greatly like to assist public safety departments to fly with commonsense and safety first in mind.

Many departments I have seen are under the misperception small UAS craft are toys, which they

are not. With your help we hope to obtain this exemption in order to use my exempted flight

experience to help any agencies get off on the right foot, learn what they don't know, and help

them to move forward to operate safer while they utilize the UAS.