Matthew Robinson

1030 River Dr.

P.O. Box 175 Princeton, IA 52768 

elevatedphotographyqc@gmail.com

Exemption Request Pursuant to Section 333 of the FAA Reform Act and 

Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H

14 CFR 45.23(b) 14 CFR 61.113(a) and (b)

14 CFR 91.7(a) 14 CFR 91.9(b)(2) 14 CFR 91.103 14 CFR 91.109

14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a) 14 CFR 91.203 

(a) and (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a) (1) 14 CFR 91.409 

(a)(1) and (2) 14 CFR 91.417(a) and (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

(the “Reform Act”) and 14 CFR Part 11, Matthew Robinson, operator of 

Unmanned Aircraft Systems (UAS), hereby applies for an exemption from 

the listed Federal Aviation Regulations (“FARs”) to allow commercial 

operation of designated UAS, provided such operations are conducted 

within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped 

with camera(s) and sensors, would provide professional services in the 

following areas: 1. Aerial photography and/or video for public and/or 

private use including real estate, architecture, land surveying, engineering 

and other related professional activities.

2. Aerial video and/or photography for public and/or private use including 

television, public events, cinematography and newsgathering.

3. Aerial inspection/photography of residential/commercial structures under 

contract with the owners or local government authority. 4. Aerial 

inspection/photography of residential/commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell 

towers. 5. Aerial video/photography or providing live video feed to assist 

with search and rescue operations in cases of an emergency or natural 

disaster only when the local authorities or government has requested it by 

contract or donation. 6. Training to persons individually or belonging to 

both private and/or public organizations to increase awareness and 
improve safety for current and future UAS operations within the NAS. As 

described fully below, the requested exemption would permit the operation 

of designated UAS as set forth in this document under controlled conditions 

in the NAS that would be a) limited b) controlled c) predetermined and d) 

safe. Approval of this exemption would increase public awareness of UAS 

operations and enhance safety to aid in fulfilling the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “....establish 

requirements for the safe operation of such aircraft systems in the national 

airspace system.”

I plan to operate a UAS, the DJI PHANTOM 3 Professional which is 

comprised of an unmanned aircraft (UA or Phantom 3) and a transportable 

ground station. The Phantom 3 is referred to as a quad-copter with a 

maximum gross weight of about 3 pounds. It is equipped with four rotors 

that are driven by electric motors powered by batteries. The UA has a 

maximum airspeed of 16 m/s.

I also plan to operate any publicly available UAS (and a transportable 

ground station(s) that I may own in the future that contributes to the benefit 

of my interests.

Also, given the small size of the UAS’s involved and the restricted 

controlled environment within which they will operate, the applicant fits 

within that zone of safety (an equivalent level of safety) in which Congress 

envisioned that the FAA must, by exemption, allow commercial operations 

of UASs to commence immediately. Also due to the size of the UASs and 

the controlled areas in which the relevant UASs will operate, approval of 

the application presents no national security issue. Given the following, the 

grant of the requested exemptions is clearly in the public interest: James 

Bender proposes that the exemption requested herein apply to civil aircraft 

that have the characteristics and that operate with the limitations listed 

herein. These limitations provide for an exceptional level of safety to 

operations. These limitations and conditions to which James Bender 

agrees to be bound when conducting commercial operations under an FAA 

issued exemption including:

1. The UAS will weigh less than 55 lbs. 2. Flights will be operated within 

line of sight of operator. 3. Maximum total flight time for each operational 

flight will be 30 minutes. 4. Flights will be terminated at 15% battery 
power reserve. 4. Flights will be operated at an altitude of no more than 

400 feet AGL 5. UAS operator will be trained and certified in the proper 

safety and operations of the UAS. 6. The UAS will only operate within a 

controlled area as defined in the Procedures. 7. The operator will post 

advisor notice around the controlled area. 8. The operator will have been 

trained in operation of UAS generally and received up-to-date information 

on the particular UAS to be operated as required. 9. If the UAS loses 

communications or loses its GPS signal, the UAS will have capability to 

return to a pre-determined location within the Security Perimeter and land.

10. The UAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies.

Accordingly, the applicant respectfully requests that the FAA grant the 

requested exemption and are prepared to modify or amend any part of this 

request to satisfy the need for an equivalent level of safety.

With regards,

Matthew Robinson