February 10, 2015

Benjamin Elwin Carraway

390 Seldom Seen Trl

Canton, GA 30115

Cell (770) 595-1875

Email: carraway.ben@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments:

1. 1) Phantom 1 User Manual 

2. 2) Phantom 1 Release Notes 

References:

1. 1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481 in the 

matter of the petition of DOUGLAS TRUDEAU 

1. 2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the 

matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 

1. 3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 

in the matter of the petition of FLYING CAM INC

Dear FAA,

In accordance with the FAA’s Guidelines for Submitting a Petition for

Exemption under section 333 of the FAA Modernization and Reform 

Act of 2012, I, Benjamin Carraway, request exemption from the following 

sections of Title 14, Code of Federal Regulations §§

61.113(a). 61.113(b). 91.119(c). 91.121. 91.151(a). 91.405(a). 

91.407(a)(1). 91.409

(a)(1). 91.409(a)(2). 91.417(a) & (b).

In order to operate small unmanned aircraft systems (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA) for the purposes of 

aerial photography, structural inspections of bridges, pipelines, well and cell towers, 

real estate marketing and surveys and other flight operations that could

be performed safely and more cost effectively with the use of small UAS at 

low altitude within the U.S. national airspace system as compared to a 

manned aircraft. Operations will be performed only at the request of and with 
the authorization and permission of clients or their authorized agents in order 

to facilitate commerce and raise awareness of the beneficial uses of small 

unmanned air systems. So long as such operations are conducted within and 

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

required by Section 333. The conditions identified and proposed by, Benjamin 

Carraway, are drawn from references 13.

The FARs

I, Benjamin Carraway, request exemption from the above mentioned FARs for 

the following reasons.

61.113(a) & (b). I, Benjamin Carraway, request relief in order to facilitate the

utilization of pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots 

operating under this exemption would be required to comply with any conditions as 

set forth and in a similar fashion to the previously granted exemptions. A Visual 

Observer will be used at all times while under this requested exemption.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU),

operations conducted closer than 500 feet to the ground may require that the 

UA be operated closer than 500 feet to essential persons, or objects that would 

not be possible without additional relief. The petitioner requests modification, 

waiver or exemption and clarification concerning the terms “congested areas” 

and “densely populated”. I, Benjamin Carraway, request waiver for this

condition to allow reasonable and responsible operations with safety as my main 

concern in areas of subdivisions and neighborhoods if required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is

inapplicable since the UAS does not have an altimeter and instead utilizes 

electronic GPS with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION

SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at 

less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 

10650. In addition, similar UAS specific relief has been granted in Exemption 

Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides 

battery power remaining in percent to the PIC. The UA batteries provide 

approximately 25 minutes of powered flight. Information provided in the 

operating documents discusses procedures regarding remaining battery power 

management. Those documents contain a condition in which the PIC will initiate 

a landing procedure when battery remaining reaches a specified level. Given the 

limitations on proposed operations and the location of those proposed

operations, The FAA found that a reduced minimum power reserve for flight 

in daytime VFR conditions was reasonable.

91.405(a). 91.407(a)(1). 91.409 (a)(1) & (2). 91.417(a) & (b) As
discussed in Exemption 11138 (DOUGLAS TRUDEAU), I, Benjamin Carraway, 

propose to inspect and ensure that the UAS is in a condition for safe flight in 

accordance with the operating documents. The FAA found that adherence to the 

petitioner’s operating documents and the conditions and limitations specified, 

describing the requirements for maintenance, inspection, and recordkeeping, 

were sufficient to ensure that safety would not be adversely affected.

The UAS

The DJI Phantom 1 is a highly successful consumer grade small rotorcraft in the 

quadcopter configuration with an advertised weight of less than 44 ounces 

(1242g) designed primarily to carry aloft a high definition camera. It has an 

advertised maximum speed of less than 30 knots (15m/s) and a maximum climb 

rate of less than 1200 feet per minute (6 m/s). It is powered by four electric 

motors with a distance between motors of less than 14 inches (350mm) It 

utilizes an internal inertial measuring unit (IMU) with integrated barometric

sensor augmented with global positioning system (GPS) to maintain its 

geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information is 

transmitted back to a ground control station allowing the operator and/or PIC to 

monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle. It has fail safe modes of operation 

for either loss of RC or GPS signal. Altitude can be limited by the onboard flight 

controller and maximum altitude can be preprogrammed by the PIC. Battery life 

limits flight times to approximately 25 minutes. The onboard flight controller will 

warn the pilot via telemetry and external lighting cues before reaching a low 

battery state. An automatic termination of flight and landing will be initiated 

when the battery reaches a predetermined low state. It is anticipated that flights 

will usually last less than 10 minutes. More information is available in attachment 

1.

Risk mitigation

I, Benjamin Carraway, have reviewed FAA exemptions reference’s 13 

Conditions and Limitations section and believe that the procedures specified

therein are reasonable and will be utilized in order to manage and mitigate risk 

and ensure public safety.

A preflight checklist will be developed and employed to ensure that the UAS’s 

airworthiness will be verified before launch. Airworthiness will be maintained by 

performance of routine inspections before each flight, maintaining flight and 

maintenance logs to record time on failure prone components.

I, Benjamin Carraway, understand that the UAS may not be operated within 5 
miles of an airport, and acknowledge that the UAS will absolutely not be flown 

anywhere near this area.

Additionally, I, Benjamin Carraway, will in no scenario allow the UAS to reach 

altitudes above 300 feet. 

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned 

aircraft of greater proportions, carrying a crew and flammable fuel.

In regards to performing inspections of bridges, towers, and natural gas 

pipelines the UAS will minimize the risk to persons attempting to climb these 

structures and photograph problem areas. It will provide a way for companies 

to have their engineers review photographs and provide additional safety to the 

general public in regards to towers failing or natural gas pipelines having 

structural issues. Many of the natural gas pipelines in our area travel in areas 

that are hard to reach by vehicle or foot and if an area is suspected of having 

problems the UAS can reach it to make an assessment easier and safer.

I, Benjamin Carraway, will also make the UAS and myself available to local 

volunteer organizations (for no charge) such as fire departments, local law 

enforcement, etc., to perform search and rescue operations, or other 

similar events as directed by authorities.

In addition the use of the UAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will enable service for property 

owners or their designees seeking an enhanced perspective for characteristics, 

amenities, and benefits of their desired photographic subjects that cannot be 

displayed through ground level photography. Aerial photography is a valuable

marketing tool that can lead to increased commerce and enhance my 

personal photography.

A visual observer will be utilized at all times that the UAS is performing duties 

for compensation and the PIC will hold a Private Pilots license.

Liability insurance will be obtained commensurate with the granting of this 

request for exemption.

Flight data including UAS flight time, Control Unit operation time, incident, and 

details will be recorded for each flight and made available to the FAA at any time 

needed.

Any deviations from normal operations will also be recorded and made available 

to FAA.

Conclusion
I, Benjamin Carraway, am requesting this exemption for the purposes of aerial 

photography of real estate, bridge inspections, land surveying, pipeline 

inspections, tower inspections, and other flight operations.

The reason for such a general and broad based request is that I, Benjamin 

Carraway, wish to utilize a business strategy in order to capitalize on 

opportunities as they may arise in the future without the long turnaround time 

associated with additional exemptions.

My business model is based on the idea of offering small UAS services to 

individuals or companies who wish to employ these services as a safe, 

effective, and legal option to enhance their business and/or prevent 

structural disasters that may influence the general public or individuals.

My personal research shows an upward trending demand for these services 

that currently exists in the real estate market and natural gas market. 

Additionally, other markets are just beginning to realize the need for such 

services.

Several people are offering services such as the above in my area but I have 

refrained for pursuing commercial use of my UAS until the FAA can properly 

authorize me.