UASPhotography, LLC

Curtis Chandler, President

142 Hidden Trail 

Pendergrass, GA 30567

chandler.curt@gmail.com

FAA

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140

Washington, DC 20590

To whom it may concern:

I am writing pursuant to the FAA Modernization and Reform Act of 2012 ( Reform Act), and the 

procedures contained in 14 C.F.R. 11, to request that UASPhotography, LLC, an owner and 

operator of small unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) 

listed above so that UASPhotography, LLC may operate its small unmanned aircraft I 

lightweight unmanned aircraft system (UAS) commercially in airspace regulated by the Federal 

Aviation Administration (FAA); as 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. 

I am a FAA licensed private pilot with single engine instrument rating with over 950 hours. I 

have been a private pilot since 1986 and I have a current 3rd class medical certificate.

With my clear understanding of FAA rules, my awareness of operational and restricted airspace, 

my experience as a pilot license holder (even though The FAA is lowering the credential bar to 

include sport pilot certificates), and my attitude of safety first when it comes to flight operations, I 

believe I should be granted an exemption.

My request for a waiver of the section is not for operations for the purpose of “closed-set motion 

picture and television filming” but are identified below. 

My request is to operate Unmanned Aerial Systems (UAS) for commercial purposes. 

Specifically, to “record digital video data and other aerial photography data of real estate, 

insurance and general arial photography. Which will include residential, farms and land to assist 

an owner in the promotion of their improved/unimproved parcel of land, and inspection of 

damaged property such as roofing systems and or timber survey, for ultimate disposition and 

sale or purchase or other promotional purposes, such as a business wanting to promote its 

facilities using aerial images.”

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I am currently seeking exemption from: 14CFR 91.7(a); 91.9(B)(2); 91.103; 9l.109; 91.119 (c); 

91.121; 91.J 51(a)(l); 91.203(a)(b); 91.405(a); 91.407(a)( l); 9l.409(a)(l)and(2); 91.417(a)&(b); 45.23(b); 

Part 21; 61.l 13(a)(b) 

“The petitioner is seeking an exemption to operate an unmanned aircraft system (UAS) under 

the new FAA “Summary Grant” approach, announced April 9th, 2015 http://www.faa.gov/news/

updates/?newsId=82485 that will help speed up Section 333 exemption approvals for many 

commercial UAS operators prior to finalizing the small UAS proposed rules published this past 

February. It is my understanding that the FAA will still review each Section 333 petition 

individually. However, I am hoping that the agency will accept my particular petition, and include 

it in the next summary grant, and issue me an exemption on the presumption that the FAA has 

“already granted a previous exemption similar to this request”. 

The new interim policy includes the granting of a Certificate of Waiver or Authorization (COA) for 

flights at or below 200 feet to any UAS operator with a Section 333 exemption for aircraft that 

weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, 

operate within visual line of sight (VLOS) of the pilots, and stay certain distances away from 

airports or heliports such as 5 nautical miles (NM) from an airport having an operational control 

tower; or 3 NM from an airport with a published instrument flight procedure, but not an 

operational tower; or 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or 2 NM from a heliport with a published instrument flight procedure. It is also 

understood that the “blanket” 200- foot COA allows flights anywhere in the country except 

restricted airspace and other areas, such as major cities, where the FAA prohibits UAS 

operations. 

UAS Description: 

I am asking for an exemption for UAS up to 55 pounds because I will be using DJI Phantom 2 

Vision+ and/or DJI Phantom 2 Vision and/or DJI Phantom 3. The differences in these are 

camera options not flight systems.

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 distance from 

the pilot.Additional Points: 

It is my hope that you find that the enhanced safety achieved using an unmanned aircraft with 

the specifications described by the petitioner which carries no passengers or crew, rather than a 

manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, 

gives the FAA good cause to find that the UAS operation enabled by this exemption is in the 

public interest. 

Flight Operations: I am well aware of conducting safe flight operations and planning flight 

paths that minimize any overflight of crowds. 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. 

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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 

current criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 

(including new interim policies) 

Safety is of paramount importance to UASPhotography, LLC. We endeavor to help integrate 

UAS into the NAS (national air space) by performing our services with the utmost concern for 

the safety of our operators, the general public and property. To achieve this, UASPhotography, 

LLC has instituted several flight parameters, conditions, guidelines and limitations to adhere to 

before, during and after flight operations - all of which are outlined in the UAS User Manual I 

Operators Manual. These conditions are based off of Part 333 exemptions that have already 

been approved by the FAA and have been integrated into our operations: 

- The UAS will not exceed a ground speed of 50 knots. - All operations will remain below 400’ 

AGL.

- The UAS will weigh less than 55 lbs.

- All operations will remain in VLOS. 

- All operations will utilize a VO. This VO will always be able to communicate verbally with the 

PIC.

- The operator must follow the procedures as outlined in its operator's manual. (listed herein as 

Protocols & Procedures & DJI User's Manual and Operators Manual). 

- Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. 

Any UAS that has undergone maintenance or alterations that would affect the UAS operation or 

flight characteristics must undergo a functional test flight in accordance with operators manual. 

-The operator must follow the manufacturer's UAS aircraft component, maintenance, overhaul, 

replacement, inspection and life limit requirements. 

-The PIC will must possess at least a private pilot certificate and at least a third-class medical 

certificate and also meet flight review requirements specified in the 14 CFR 61.56. 

- Prior to operations the PIC will undergo UAS specific training for type (multi-rotor), make and 

model aircraft and log hours appropriately. PIC will also maintain proficiency and currency 

(every 90 days) with UAS. Keeping with a manner consistent with 14 CFR 6l.51(b). 

 - PIC & VO will have successfully completed a qualification process, as outlined in the 

operator’s manual. Completion of this qualification process will be documented. 

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 - The UAS will not be operated directly over any person, except authorized and 

consenting flight personnel. 

 - The PIC & VO will ensure that no unauthorized persons are allowed within 200' (or a 

distance deemed safe and practical due to 

physical terrain constraints) of the flight area except those consenting flight personnel. 

- If UAS loses communication or loses it GPS signal, the UAS must return to a predetermined location within the security perimeter and land or be recovered in 

accordance with operator's manual. 

- The UAS must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with operators manual.

-The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations.

- All operators will comply with all manufacturers Safety Bulletins. 

- Before conducting operations, the radio frequency spectrum used for operation and 

control of UAS will comply with Federal Communications Commission (FCC). 

-Prior to the planned operation (3 days) the operator will contact the local Flight 

Standards District Office (FSDO) (that has jurisdiction of the area) in writing and cover 

the plan of activities for the flight operation. 

- The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC at 

the ground station during all operations. 

- The UAS will remain clear and yield the right of way to all other manned operations and 

activities at all times. 

- All operations will be conducted under VFR (visual flight rules) and no night operations 

during night as defined in 14 CFR 91.151 

 - The UAS will not be operated by the PIC from any moving device or vehicle. 

 - The UAS will not be operated less than 500 ‘ below or less than 2,000’ horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

 - The UAS will not operate in Class B, C, or D airspace without written approval from the 

FAA. The UAS will not operate within 5 nautical miles of the geographic center of a nontowered airport. 

 - Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA's UAS Integration Office (AFS-80) within 24 hours. 

 - Accidents will be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB website. The petitioner will outline in this document: 

 

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1. Request for exemptions by Part and Subpart 

 2. Petitioners protocols and procedures for operations 

 3. The Unmanned Aircraft System (UAS) 

 4. The Public Interest 

 Requests For Exemption by Part and Subpart 

14 CFR 91.7(A) Airworthiness Certificate; 

Prohibits the operation of an aircraft without an airworthiness certificate. Petitioner 

requests exemption based on previous exemption no. 11138. The FAA has ruled that this 

make and model of aircraft (UAS) does not require an airworthiness certificate. 

14 CFR 91.9(B) (2) Aircraft Flight Manual 

Requires an aircraft flight manual in the aircraft. As there are no pilots or passengers aboard 

and given the size of the UAS, this regulation is inapplicable. An equivalent level of safety will be 

achieved by maintaining a manual at the flight operations center. The FAA has previously issued 

exemptions to this regulation no. 10700 and 32827. 

14 CFR 91.103 Pre-flight; 

No approved Aircraft Flight Manual on board the aircraft. The petitioner asserts that an 

equivalent level of safety will be achieved by the PIC taking all pre-flight actions set forth in the 

operating documents including weather, flight battery requirements, landing and take-off 

distances and aircraft performance data before initiation of each flight. 

14 CFR 91.109 Flight Instruction;

There are no dual controls available for flight instruction. 14 CFR 91.119 (C) Minimum Safe 

Altitudes; 

States that no person may operate an aircraft below the following altitudes: over other than 

congested areas, an altitude of 500' above the surface, except over open water or sparsely 

populated areas. In those cases, the aircraft may not be operated closer than 500' to any 

person, vessel, vehicle, or structure. 

The petitioner will not operate any UAS over an altitude of 400' AGL. The majority of the 

operations proposed will operate between 0 to 200' AGL as this usually provides the best angle 

of capture for the type of photography and videography operations proposed. 

The UAS utilized for this exemption is of exceptionally light weight and is not capable of speeds 

over 30 knots. The UAS is equipped with GPS guided auto pilot with a return home function in 

case loss of control by the PIC and is powered by sealed batteries thereby reducing the chance 

of post impact fire to nearly zero. 

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There will be cases when the 500' distance from structures will need to be exempted. (Example: 

Aerial Video of a 2 story home roof to determine and or document extent of storm damage.) In 

this type of operation every assurance will be made to keep persons outside of a reasonable, 

safe, clear area of operations and will only be conducted with the express permission of the 

property owner. See Protocols and Procedures Section. 

The petitioner will implement procedures and policies to ensure that any person in the general 

vicinity of operations will be aware of such operations and ensure that all non-essential 

personnel are cleared of the area of operations to the extent possible. 

The petitioner therefore requests relief in part from 14CFR 9 l .11 9(C) 

14 CFR 91.121 Altimeter Settings; 

The petitioner requests relief from 91.121 for the following reason. The UAS is equipped with 

GPS derived altitude capability, however due to the limited altitude requested in this exemption, 

the FAA has previously granted Exemption for these types of operations. Reference Exemption 

No. 11138 

14CFR 91.15l(a)(1) Fuel for Flight; 

No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) unless there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruise speeds. 

(a)(l) During the day to fly for at least 30 minutes. 

The petitioner requests relief from 91.15l (a) due to the fact that the UAS is equipped with a 

battery and percentage indicator system. The UAS has a flight capability on full charge of 

approximately 25 minutes depending on camera usage and other variables. The petitioner has 

established that the maximum flight will be 15 minutes on a fully charged battery. This 

constitutes landing with approximately 25 percent fuel remaining. The petitioner believes that 

this follows the spirit and intent of the rule with a great margin of safety. 

No UAS operations will be conducted at night, as defined by Federal Aviation Regulations. 

14 CFR 91.203(a)(b) Carrying of civil aircraft Certifications and Registrations; 

Provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for 

the same reasons described above. Operations manuals and Safety Procedures will be 

maintained at the UASPhotography, LLC home office with copies of same traveling with the PIC. 

14 CFR 91.405(a) Maintenance required; 

The petitioner requests relief in part from 91.405(a)(l) based on the Protocols and Procedures 

Section on Maintenance and Maintenance Records. Also reference Exemption No. ll138 

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14 CFR 91.407(a)(l) 

Operation after maintenance, preventive maintenance, rebuilding, or alteration; 

The petitioner requests relief from 91.407(a)(l) based on the Protocols and Procedures Section 

on Maintenance, Return to service after maintenance, and Maintenance records. Reference 

Exemption No. 11138 

14 CFR 91.409(a)(l)(2) Inspections; 

The petitioner requests relief from 9l.409(a)(1)(2) based on the Protocols and Procedures 

Section on Inspections. Reference Exemption No. 11138 

14 CFR 91.417(a)(b) Maintenance records;

The petitioner requests relief from 91 .417(a)(b) based on the Protocols and Procedures Section 

on Maintenance records. 

14 CFR 45.23(b) Marking of the Aircraft; 

Applicable codes of Federal Regulation require aircraft to be marked according to certain 

specifications. UASPhotography, LLC UAS's are, by definition, unmanned. They therefore do 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,two 

inch lettering is difficult to place on such small aircraft. Regardless, UASPhotography, LLC will , 

if required , mark its UAS's in the largest possible lettering by placing the " N "number on its 

fuselage as required by 14CFR 45.29 (f) so that the pilot, technician, spotter and others working 

with the UAV will see the markings. The FAA has previously issued exemptions to this regulation 

through Exemption No 10167 and 10700 

14 CFR 21, Sub Part H Airworthiness Certificates; 

Entitled Airworthiness Certificates, set forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR 91.203(a)(l). The size, weight and enclosed 

operational area of UASPhotography, LLC UAS permits exemption from Part 21 because 

UASPhotography, LLC UAS meet an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 USC 44701(f)) and Section 333 of the Reform Act. Both 

pieces of the legislation permit the FAA to exempt UAS from the airworthiness certificate 

requirement in consideration of the weight, size, speed, maneuverability and proximity to areas 

such as airports and dense populations. UASPhotography, LLC UAS meet or exceed each of 

the elements. 

14 CFR 61.l 13(a)(b) Private Pilot Privileges and Limitations PIC; 

Private pilots are limited to non-commercial operations. UASPhotography, LLC can achieve an 

equivalent level of safety as achieved by current Regulations because UASPhotography, LLC 

UASs do not carry any pilots or passengers. Further, while helpful, a pilot license will not ensure 

remote control piloting skills, though UASPhotography, LLC pilot vetting and training program 

will. Further, private pilot licensees will operate UASPhotography, LLC UASs with the same skill. 

Further the risk attendant to the operation of UASPhotography, LLC UAS is far less than the risk 

levels inherent in the commercial activities outlined in CFR 61. Thus, allowing UASPhotography, 

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LLC to operate its UAS with a private pilot as the pilot in control will exceed current safety levels 

in relation to CFR 61.l 13(a)(b). 

PROTOCOLS AND PROCEDURES FOR UAS OPERATIONS 

 A. Preflight 

 B. Area Security 

 C. Limitations of Operations 

 D. Airworthiness 

 E. Maintenance and Records 

 F. Pilot in Command Requirements 

 G. Visual Observer and Requirements 

 H. Reporting of Incidents and Accidents 

A. Preflight Inspection of UAS 

( I ). Preflight of the Unmanned Aerial System will follow the instructions in the DJI instruction 

and User Manual. The Pilot in Command will certify that a preflight inspection has been 

accomplished with the date and time and signature in the UAS logbook. The preflight shall 

include the aircraft, transmitter, and batteries, motors, rotors, landing gear, camera and gimbal 

mount. As a part of the preflight the Pilot in Command will assure that weather conditions, area 

security, and any other information essential to safe operation has been obtained. 

B. Area Security 

( 1 ). The PIC of the UAS will ensure that the operational area for the purposes of UAS flight 

shall be cleared of all nonessential persons at all times the UAS is in flight. Additionally all 

nonessential persons shall be required to remain clear of the operations area by a minimum 

distance of 200' (or by as much as practical) during operations. PIC shall ensure that cones and 

clearly marked signs are posted at all ingress \ egress points to the operations areas. These 

signs will be of white background with red lettering stating the following: "Unmanned aircraft 

operations underway. Please remain clear." 

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(2). In the event of a breach by nonessential persons into the operations area during the flight of 

UAS, the PIC shall immediately terminate flight operations until such time as the area can be 

cleared of these persons. 

(3). The UAS area of operation is defined as the horizontal flight path(s) of the UAS as well as 

the Vertical flight path and Maximum altitude to be reached. Additionally, the area between the 

UASs current position and its Home location is also considered operational area as it will 

proceed direct to its home location in the event of loss of ground control. 

C.Limitations of Operations 

(1) The UAS shall be operated i n Day time only, as defined by 14 CFR 

(2) UAS night operations are prohibited.

(3) The UAS shall be operated by VLOS at all times 

(4) A Visual Observer shall be utilized at all times and must maintain VLOS at all times.

(5) The UAS shall remain within 1 000' horizontal distance of the PIC at all times.

(6) The UAS to be utilized is the DJI Inspire Unmanned Aircraft System. No other systems will 

be operated. (7) The UAS will have an altitude restriction of 400ft AGL.

(8) The UAS will not be operated at a speed exceeding 30 Knots. 

(9) Operations Documents will be accessible to the PIC at all times and must be accessible 

during UAS operations and made available to the Administrator on request. 

(10) PIC must inspect and ensure that UAS and ground control station is in airworthy condition 

prior to each operation; if determined un-airworthy, all operations will be suspended until such 

time as necessary maintenance has been performed and the UAS is determined to be in a safe 

condition for flight. 

(11) An operational flight test is required after any maintenance or alterations that may affect 

UAS operation or flight. 

(12) UAS maintenance must follow manufactures aircraft and component, maintenance 

overhaul, and replacement, inspection, and life limit requirements. 

(13) The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance and inspection, and 

alterations must be noted in the aircraft records including total flight hours, description of work 

performed, and the signature of the authorized person returning the UAS to service. 

(14) UAS must comply with all Manufacturers' Safety Bulletins.

(15) An authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections. 

(16) UAS must by operated by a PIC possessing at least a Private Pilot Certificate, with most 

appropriate Class and Category and at least a current Third Class Medical. 

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(17) PIC must meet the flight review requirements of 14 CFR 61.56 in an aircraft in which the 

PIC is rated. 

(18)Prior to operations for which exemption is requested the PIC must have accumulated and 

logged ,in a manner consistent with 14 CFR 61.5l(b), a minimum of 25 hours of total time as a 

UAS rotorcraft pilot including at least 10 hours of UAS multi-rotor.

(19) Prior to operations the PIC must have accumulated and logged a minimum of 5 hours as a 

UAS pilot in make and model listed in exemption. PIC must log at a minimum 3 takeoffs and 

landings in the preceding 90 days to meet currency requirements. 

(20) PIC is required to operate the UAS in accordance with 14CFR 91.119. 

(21) No UAS operation within 5 nautical miles of a controlled airport reference point as denoted 

on a current FAA chart. 

(22) No operations are allowed in the surface areas of Class B, C, and D airspace or in 

restricted airspace. 

(23) No operations are allowed if the return home function and\or auto pilot are, or are 

suspected to be malfunctioning. 

(24) UAS shall not be operated from a moving platform of any type.

(25) No operations shall be conducted without an appropriate Certificate of Authority issued by 

the Administrator. 

(26) A Visual Observer shall be utilized at all times when operating the UAS. 

(27) Should the PIC or Visual Observer detect that a manned aircraft is being operated in close 

proximity to the operations area, the UAS shall give right of way to the manned aircraft, and the 

PIC shall cease operations and land until such time as the manned aircraft has cleared the 

area. 

(28) UAS will not be operated any closer than 100' to any structure without the express 

permission of the structure I building I property owner.

(29) The UAS will be limited to 18 minutes of flight or 25% of battery power, whichever occurs 

first. 

D. UAS Airworthiness 

(1). The PIC shall ensure that the UAS is in an airworthy condition before each flight. 

Airworthiness shall be determined by a preflight inspection in accordance with DJI operating 

documents and any and all applicable Federal Aviation Regulations, and any additional 

requirements as defined by the Administrator. PIC shall document each preflight inspection by 

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date, Aircraft total Flight time to date, any discrepancies noted ,and signature and certificate 

number. Any discrepancy noted shall be addressed before UAS operation. 

E. UAS Maintenance and Records 

(l). The operator shall maintain aircraft maintenance logbooks. Each V AS shall have its own 

and separate maintenance log book. DJI documents, handbooks, user manuals ,supplements, 

Safety Bulletins, etc., shall be the only approved documents for performing 

repairs,maintenance,inspections,overhauls,or replacement of life limited components. A record 

of each preflight inspection will additionally be recorded in these logbooks. The preflight 

inspection must be conducted by the PIC for that operation. Preflight sign-off shall include at 

least the following information: date of operation, Aircraft Total time , aircraft serial or operating 

number, PIC signature and certificate number. 

Example: Preflight inspection completed, No defects noted. 1-1-15, AC FIT 50.l hours,VAS 

number 1, 

(2). Any required maintenance, inspection, alteration or repair must be completed by an 

approved person. At the completion of this work the approved person must make an entry in the 

aircraft log book that at least includes: Date, Aircraft serial or operating number, brief description 

of the discrepancy, inspection, alteration or repair, the reference material used as guidance for 

the repair, statement approving the aircraft for return to service, and signature of person who 

completed the work.

Example: 1-1-15 UAS #XXX, 50. hours,replaced number 3 rotor with new rotor, in accordance 

with DJI Inspire User Manual. Flight or ops check completed. Aircraft is approved for return to 

service. PIC signature and certificate number.

(3).Maintenance records shall be kept with the UAS at all times and shall be made available to 

any authorized agency or the Administrator upon request. 

F. Pilot in Command Requirements 

(1).The Pilot in Command shall hold at least a Private Pilot Certificate and a current Third Class 

Medical whenever conducting operations. Operator prefers that the Certificate be in the most 

appropriate Class and Category to the UAS being operated.

(2). The Pilot in Command shall have accumulated and logged a minimum of 200 flight cycles 

and 25 hours of rotorcraft UAS flight time before performing any operation for which exemption 

is requested.

(3). The Pilot in Command shall have at least 5 hours in make and model before performing any 

operation for which exemption has been requested.

(4).The Pilot in Command shall perform a pre-flight inspection before each flight is conducted,

(5).The Pilot in Command shall observe all Federal Aviation Regulations at all times with the 

exceptions of the exemptions

requested by the operator. In those cases the Pilot in Command shall adhere to company 

operating standards or Federal Aviation Administration Limitations placed upon exemptions, 

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whichever is more stringent.

(6). The Pilot in Command will not operate the UAS without a Visual Observer present. (7). The

Pilot in Command must have 3 takeoff and landings within the preceding 90 days.

(8). The Pilot in Command must maintain a record of flight information to establish currency and 

that he or she meets the requirements of this section.

(9). The Pilot in Command will utilize eye protection in the event that sun glare would reduce 

YLOS operations. 

G. Visual Observers: Responsibilities and Requirements 

(1). A Visual Observer shall be used during any and all operations of the UAS System.

(2). The Visual Observer shall maintain verbal communication with the PIC at all times during 

UAS operation.

(3). The Visual Observer shall maintain Visual Contact with the UAS at all times. In the event 

that Visual Contact is lost the VO will notify the PIC who will immediately cease operations and 

land the aircraft.

(4). The Visual Observer shall also help the PIC maintain area of operations security and ensure 

that all non-essential persons remain clear of the area of operations. In the event of a breach by 

unauthorized person(s) the VO shall notify the PIC and operations will cease immediately.

(5).The Visual Observer shall also assist the PIC in looking for manned aircraft traffic near the 

operations area. If manned aircraft traffic is observed near the operations area, the VO will 

notify the PIC who will immediately cease operations and land the UAS. (6). The VO will utilize 

eye protection in the event that sun glare would reduce VLOS operations. 

H. Reporting of Incidents and or Accidents 

Any incident or accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defined by the applicable COA will be reported within 24 hours to: 

FAA UAS Integration Office (AFS-80) Accidents: National Transportation Safety Board 

(www.ntsb.gov.) 

The Public Interest 

The request for this exemption is in the Public Interest as it is safe to assume that there are 

many consumer applications for the services that can be provided by UAS. It is clear that the 

Congress of the United States, the business sector, and the consumer want to integrate UAS 

into the NAS and utilize their unique and cost effective capabilities. It is also in the Public 

Interest that many of the low level flight operations now conducted by manned aircraft could be 

accomplished with these light, fire resistant and environmentally friendly unmanned aircraft that 

can operate at a fraction of the cost to both the operator and consumer. These aircraft can be 

operated without risk of loss to life or limb, and without significant financial impact to the 

operator or any person or property on the ground in the event of the loss of an aircraft. Utilizing 

these UAS will create a safer more productive work environment, reduce environmental 

pollution and have a positive impact on the local community which is in the Public Interest. 

Finally, the petitioner believes that granting this exemption would help to further by 

Administrative process the integration of UAS systems and the possibility to help create 

additional regulations and guidance to be used as these systems become more widely utilized.

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Please forward any comments or questions you may have to chandler.curt@gmail.com.

Sincerely,

UASPhotography, LLC

Curtis Chandler, President

142 Hidden Trail

Pendergrass, Ga 30567

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