8350 US Highway 23 North  Delaware, OH 43015  Phone: 740.726.2000  www.bensenfireandsafety.com

September 7, 2015

Petition for Exemption 14 CFR § 11.81

Exemption petition under SEC 333

Name: Thomas A. Bensen - Bensen Fire & Safety Consulting

Address: 8350 US Highway 23 North, Delaware, Ohio 43015

Phone: 740-726-2000

Email: tbensen@bensenfireandsafety.com

The specific section or sections of 14 CFR from which you seek an exemption;

Petition for Exemption under Sec 333

The extent of relief you seek and the reason you seek the relief;

Sec 333 prohibits the use of a UAS for commercial purposes on private property. I am an

experienced UAS pilot and am petitioning for an exemption to provide a commercial

service to private land owners, insurance companies, private companies and public safety 

entities who wish to obtain and capture aerial photos and videos of said property for 

purposes including but not limited to real estate listings, insurance property claims, public 

safety emergencies and non-emergencies as specifically requested by the authority having 

jurisdiction and for use as a marketing tool for businesses. I would like to be able to 

accept payment for these services therefore making this a commercial use of a UAS.

How your request would benefit the public as a whole;

My request benefits the public as a whole by providing an opportunity for small business 

owners, real estate agents, and others who wish to document their land or property to take 

advantage of the technology that now exists in the form of UAS’s and allows them to do 

so using an experienced UAS Pilot that understands how to safely operate such 

technology.

Reasons why the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to the existing rule;

Being an experienced UAS pilot, firefighter, and police officer, I have an understanding 

and appreciation for potential risk to the safety of the public, therefore, I would be a good 

candidate for exemption of Sec 333 while not putting Air Safety in any accelerated

risk. The specific UAS (including DJI Phantom series products and DJI Inspire) I am 

seeking exemption for have many safety features, including SAFE technology and GPS 

navigating. When flying for this commercial purpose I would be flying at a maximum 

altitude of 40 meters and flying mostly vertically for the purposes of taking photos, 

decreasing the risk of any interference. My general knowledge of the aviation safety 

systems implemented by the FAA would be used to ensure that safety would not be 

affected by my operations. I intend to fly in primarily GPS Safe Flight:

Flight Mode – GPS Attitude Mode (Default) I This mode allows the UAS to lock on a 

home GPS position as a failsafe to prevent loss of radio control of the UAS due to 
8350 US Highway 23 North  Delaware, OH 43015  Phone: 740.726.2000  www.bensenfireandsafety.com

unwanted interference or loss of power. Also includes built in no-fly zones to restrict 

flight over airports, and other sensitive locations.

I intend to follow these suggested safety regulations

• Always keep aircraft in sight and under control.

• Always keep people and pets at least 35 feet (10 meters) away when the battery is 

connected.

• Keep children out of the vicinity of this product at all times.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.

• Always remove batteries before disassembly.

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.

• Always remove batteries after use.

• Always have a first aid kit with you.

• Always have an appropriate fire extinguisher with you.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

A summary we can publish in the Federal Register Federal Register —

I, Thomas A. Bensen of Bensen Fire & Safety Consulting am seeking an exemption of 

the FAA’s Sec 333 rules that does not allow the use of an Unmanned Aircraft to be used 

for Commercial purposes in regards to National Airspace Safety. I am simply petitioning 

for an exemption to provide a commercial service to private land owners and companies 

who wish to obtain and capture Aerial photos and videos of said property for purposes 

including real estate listings, insurance property claims, public safety emergencies and 

non-emergencies as specifically requested by authority having jurisdiction and for use as 

a marketing tool for businesses. Being an experienced UAS pilot, firefighter, and police 

officer, I have an understanding and appreciation for potential risk to the safety of the 

public, Therefore, I would be a good candidate for exemption of Sec 333 while not 

putting Air Safety in any accelerated risk. The specific UAS (including DJI Phantom 

series products and DJI Inspiro) I am seeking exemption for have many safety features, 

including SAFE technology and GPS navigating. When flying for this commercial 

purpose I would be flying at a maximum altitude of 40 meters and flying mostly

vertically for the purposes of taking photos, decreasing the risk of any interference. My 

general knowledge of the aviation safety systems implemented by the FAA would be 

used to ensure that safety would not be affected by my operations. 

Any additional information, views, or arguments available to support your request;

I am fully aware of the preflight safety checks and procedures implicated in the operation 

manual for the above mentioned UAS and intend to implement preflight safety checks 

and utilize the safety technology provided with this unit. I intend to only fly in nonpopulated, residential or rural areas and stay clear of all utility lines etc. I intend to be 
8350 US Highway 23 North  Delaware, OH 43015  Phone: 740.726.2000  www.bensenfireandsafety.com

fully aware of my surroundings at all times and to only fly the unmanned aircraft within a 

visual line of sight and only in Visual Flight Conditions.

UAS Specifications:

DJI Inspire 1: http://store.dji.com/product/inspire-1?from=buy_now#/spec

DJI Phantom 2 Series: http://www.dji.com/product/phantom-2/spec

General Safety Precautions and Warnings I intend to Follow

• Always keep a safe distance in all directions around your model to avoid collisions

or injury. This model is controlled by a radio signal subject to interference from many

sources outside your control. Interference can cause momentary loss of control.

• Always operate your model in open spaces away from full-size vehicles, traffic and 

people.

• Always carefully follow the directions and warnings for this and any optional support 

equipment (chargers, rechargeable battery packs, etc.).

• Always keep all chemicals, small parts and anything electrical out of the reach of 

children.

• Always avoid water exposure to all equipment not specifically designed and protected 

for this purpose. Moisture causes damage to electronics.

• Never place any portion of the model in your mouth as it could cause serious injury or 

even death.

• Never operate your model with low transmitter batteries.

• Always keep aircraft in sight and under control.

• Always move the throttle fully down at rotor strike.

• Always use fully charged batteries.

• Always keep transmitter powered on while aircraft is powered.

• Always remove batteries before disassembly

• Always keep moving parts clean.

• Always keep parts dry.

• Always let parts cool after use before touching.

• Always remove batteries after use.

• Never operate aircraft with damaged wiring.

• Never touch moving parts.

If you want to exercise the privileges of your exemption outside the United States, 

you must state the reason.

I have no intention of using this exemption outside the United States