U.S. Department of Transportation Docket Management System 1200 New 

Jersey Ave., SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments:

1) Phantom 3 User Manual

2) Pre-flight/flight Checklist

References:

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

matter of the petition of DOUGLAS TRUDEAU

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

matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355 in the matter 

of the petition of FLYING CAM INC

Dear Sir or Madam,

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 Joshua 

Thomas Ford, referred to hereafter as the petitioner, 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, cinematography, videography, 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 the petitioner are drawn from 

references 1-3.
The FARs

The petitioner seeks exemption from the above mentioned FARs for the following 

reasons;

61.113(a) & (b);

The petitioner requests relief in order to facilitate the utilization of an experienced 

UAS operator with the addition of a trained observer. All pre-flight inspection, 

maintenance and flight logs will be saved and made available to the FAA and 

Secretary of Transportation (SoT) for review; with the purpose of safely 

integrating civil UAS operation in the National Airspace System.

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”. The petitioner requests waiver for this condition to allow reasonable 

and responsible operations in areas of subdivisions and neighborhoods if 

required.

The petitioner will primarily operate the UAS between ground level and 200 feet. 

The UAS will be operated over designated properties with the owner’s consent 

and while maintaining a safe distance from persons. The petitioner will compile 

flight data from the logs. This data may assist the FAA in development of 

regulations for commercial operations in low-risk, controlled environments.

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 20 

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), The petitioner 

proposes 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 UAVs are highly successful consumer grade small rotorcrafts 

in the quadcopter configuration with an advertised weight of less than 45 Ounces 

(1280g) designed primarily to carry aloft a high definition camera. It has an 

advertised maximum speed of less than 32 knots (16m/s) and a maximum climb 

rate of less than 1000 feet per minute (5 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 failsafe modes of operation for either loss of RC 

or GPS signal. Altitude is limited by the onboard flight controller at a maximum 

altitude of 500 feet. Battery life limits flight times to approximately 20 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 12 minutes. More information is 

available in attachment 1.

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and 

Limitations section and believes 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 UA 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. These 

documents will be made available to the FAA and SoT to assist in future 
implementation of safety standards and regulations. Flight plans will be 

predetermined to limit the UASs flight time and limit safety concerns. The 

petitioner will take into account distance from persons and potential flight 

obstacles prior to operating the UAS. UAS operation will always be within VLOS 

of the PIC and the observer.

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. Additionally, 

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 videography/photography. Aerial photography is a valuable 

marketing tool that can lead to increased commerce and enhance personal 

photography. Aerial surveying and inspections can increase work site efficiency, 

improve volumetric estimations and reduce risks. The petitioner will provide 

clients with photographic data for these purposes on a ‘for hire’ basis acting as 

an independent contractor. A visual observer will be utilized. Flight data including 

UA flight time, Control Unit operation time, incident, accident, and details 

concerning any deviations from normal operations will be available to FAA for 

use in collecting data regarding the use of UAS as part of this application. This 

data may be submitted to FAA via traditional means or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial 

photography, cinematography, videography, inspections and other flight 

operations”. Specifically, I will use UASs which are equipped with cameras and 

sensors, in order to engage in the following commercial activities:

(a) Video filming by air and photographing for public and private purposes, 

including: television, cinematography, advertising or promotions. Filming and 

Photography will only be conducted with permission and under contract with 

registered owners or with any local government authority and only when safe to 

do so.

(b) Video filming by air and photographing to support professional operations in 

engineering, land surveying and development, architecture, real estate and other 

related professional activities. Filming and Photography will only be conducted

with permission and under contract with registered owners or with any local 

government authority and only when safe to do so. (c) Inspection by air of 

infrastructure such as bridges, highways, and pipelines. These inspections will 

only be done under contract and permission with any registered owners or with 

any local government authority and only when safe to do so. (d) Inspection by air 
of land and residential, commercial and industrial structures, only under contract 

and permission with any registered owners or with any local government 

authority and only when safe to do so. (e) Support provided to search and rescue 

operations and reconnaissance in cases of need, emergency or natural disasters 

only when government authorities have requested it by contract or donation and 

only when safe to do so.

The petitioner's business model is based on the idea of offering ad hoc small 

UAS services to individuals companies and government entities, which wish to 

employ these services as a safe, effective, and legal option to enhance their 

business or hobby. The petitioner has refrained from engaging in commercial use 

of the UAS. The primary purpose of seeking this exemption is to obtain the 

capability to offer those services while remaining in compliance. The petitioner 

has 20 years of videography/photography experience working with community 

organizations, non-profit organizations, private and commercial clients.

Respectfully Submitted,

Joshua Thomas Ford 

2008 15th Street A

Moline, IL 61265

ford@joshuaford.com

309-721-2765