Richard G. Wright

Commercial Pilot Certificate 2205920

Rotorcraft-Helicopter; Instrument Helicopter

President/Lead Pilot

Just Make A Difference Inc.

DBA Aerobods

1021 Ballew Circle

Fairview, TN 37062

Phone: 615-200-5112

Email: pilot@aerobods.com

October 2, 2015 

U. S. Department of Transportation, Docket Operations   

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 2012 and Part 

11 of the 

Federal Aviation Regulations from: 14 CFR 61.23(a) & (c); 14 CFR 61.101 (e) (4) & (5); 

14 CFR 

61.113 (a); 14 CFR 61.315 (a); 14 CFR 91.7 (a); 14 CFR 91.119 (c); 14 CFR 91.121; 14 

CFR 

91.151 (a) (1); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (1) & (2); 14 

CFR 

91.417 (a) & (b) 

Dear Exemption Manager, 

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

Act) and 14 C.F.R. Part 11, Just Make A Difference, Inc., DBA Aerobods herein after also 

known as Aerobods or the operator, is an operator of small Unmanned Aircraft Systems 

(sUAS) or Unmanned Aircraft (UA). Aerobods is a photography, surveying, mapping, 

technology and services company that plans to exploit the capabilities of UA to offer a 

multitude of services, including: 

• Aerial surveying, mapping and data collection 

• Remote sensing 
• Educational and research operations 

• Wildlife and forestry monitoring 

• Aid in disaster and emergency management and monitoring, civil first response, 

communications relay, search and rescue, monitoring fire hazards, cleanup effort 

supervision, damage assessment and estimation 

• Aid civil engineering: waterways and shipping, forestry, fishery protection, 

pollution control and air sampling and crop performance 

• Railroad and motor vehicle road inspection 

• Telecommunications infrastructure inspection 

• Utility, Energy systems and electrical engineering inspections and asset management 

• Agricultural surveying and produce field management 

• Livestock management and accountability 

• Unmanned aircraft flight school 

• Aerial filmmaking and photography 

• Construction site inspections and monitoring 

• Oil and gas pipeline inspection/patrolling and oil-field inspection 

• Real estate and marketing 

• Aerial event security, surveillance and crowd management 

• Aerial imagery evidence for property insurance claims 

Aerobods hereby applies for an exemption from the listed Federal Aviation Regulations 

(FARs) to allow commercial operation of their UA, with full understanding that operations 

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

the FAA as required by Section 333. As described more fully below, the requested 

exemption would permit the operation of small, unmanned and relatively inexpensive UA 

under controlled conditions in the National Airspace System (NAS) regulated by the 

Federal Aviation Administration (FAA). Approval of this exemption would thereby 

enhance safety and fulfill 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.” Section 333(c) of the Reform Act. 

The name and address of the applicant is: 

Richard G. Wright

Commercial Pilot Certificate 2205920

Rotorcraft-Helicopter; Instrument Helicopter

President/Lead Pilot

Just Make A Difference Inc.

DBA Aerobods

1021 Ballew Circle

Fairview, TN 37062

Phone: 615-200-5112

Email: pilot@aerobods.com
Regulations from which the exemption is requested: 

• 14 CFR 61.23 (a) & (c) – Medical certificates: Requirements and duration 

• 14 CFR 61.101 (e) (4) & (5) – Recreational pilot privileges and limitations 

• 14 CFR 61.113 (a) – Private pilot privileges and limitations: Pilot in command 

• 14 CFR 61.315 (a) – What are the privileges and limits of my sport pilot certificate? 

• 14 CFR 91.7 (a) – Civil aircraft airworthiness 

• 14 CFR 91.119 (c) – Minimum safe altitudes: General 

• 14 CFR 91.121 – Altimeter settings 

• 14 CFR 91.151 (a) (1) – Fuel requirements for flights in Visual Flight Rules (VFR) 

conditions 

• 14 CFR 91.405 (a) – Maintenance required 

• 14 CFR 91.407 (a) (1) – Operation after maintenance, preventative maintenance, 

rebuilding, and alteration 

• 14 CFR 91.409 (a) (1) & (2) – Inspections 

• 14 CFR 91.417 (a) & (b) – Maintenance records 

Regulatory Basis for Exemption Request 

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate safely 

in the national airspace system (NAS) before completion of the rulemaking required under 

Section 332 of the Reform Act. In making this determination, the Secretary is required to 

determine which types of UA do not create a hazard to users of the NAS or the public or 

pose a threat to national security in light of the following: 

• The UA’s size, weight, speed, and operational capability; 

• Operation of the UA in close proximity to airports and populated areas 

• Operation of the UA within visual line of sight of the operator. 

The aircraft intended for use by the operator includes the DJI Phantom 2, DJI Phantom 2 

Vision+ (Plus) & DJI S1000. All of these aircraft have previously been approved by the 

FAA in other applicant’s Section 333 exemptions. Exemptions Nos. 11278, 11275, 11267, 

11260, 11253 and 11230. 

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate 

safely in the national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft in the national airspace system.” Id. §333(c) (emphasis 

added). 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined 
under §40101 of the Act, which includes UA, from the requirement that all civil aircraft 

must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the 

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 

USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Aerobods’ UA are rotorcraft, weighting 55 or fewer pounds including payload. The UA 

operate under normal conditions at a speed of no more than 50 knots and have the 

capability to hover and move in the vertical and horizontal plane simultaneously. The UA 

will be operated only in line of sight and will be operated only within a predetermined and 

protected flight area under the permission of the property representative. The UA will be 

operated under the below listed limitations and conditions to which the operator agrees to 

be bound when conducting commercial operations under an FAA issued exemption, as well 

as any other limitations the FAA may place on future operations. Such operations will 

insure that the UA will “not create a hazard to users of the national airspace system or the 

public as per the Reform Act Section 333 (b). 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the 

proposed operations, and the significant public benefit, including enhanced safety, 

reduction in environmental impacts, including reduced emissions associated with allowing 

UA for aerial data collection, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 

The FAA has issued grants of exemption in circumstances similar in material respects to 

those presented in this petition. In Exemptions Nos. 11280, 11279, 11278, 11275, 11273, 

11271, 11269, 11267, 11260, 11253, 11250, 11230, 11213, 11112, 11109 

Aircraft and Equivalent Level of Safety 

14 C.F.R. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by FAR 

§91.203 (a) (1). The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular UA. In all cases, 

an analysis of these criteria demonstrates that the UA operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least 

as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed. 
The UA to be operated hereunder are rotorcraft weighing less than 55 pounds including 

payload, carries neither a pilot nor passenger. Carries no explosive materials or flammable 

liquid fuels, and operates exclusively within visual line of sight of the pilot in command 

(PIC) and a visual observer (VO). They operate at a speed of less than 50 knots and have 

the capability to hover and move in the vertical and horizontal plane simultaneously within 

a predetermined and protected flight area as described below. Such operations will insure 

that the UASs will not create a hazard to the users of the national airspace system. Unlike 

other civil aircraft, operations under this exemption will be tightly controlled and 

monitored by both the operator and under the requirements and in compliance with local 

public safety requirements, to provide security for the area of operation. The FAA will 

have advance notice of all operations. These safety enhancements provide a greater degree 

of safety to the public and property owners than conventional operations conducted with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of 

these same criteria demonstrates that there is no credible threat to national security posed 

by the UA, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. 

The Secretary of Transportation has previously determined that these aircraft meets the 

conditions of Section 333. Therefore, the FAA has found that request of relief from 14 CFR 

part 21, and any associated noise certification and testing requirements of part 36, is not 

necessary. This has been stated in exemptions to this regulation in Exemptions Nos. 11280, 

11279, 11278, 11275, 11273, 11271, 11269, 11267, 11260, 11253, 11250 and 11230 

The applicant proposes that the exemption requested herein apply to aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide 

for at least an equivalent or even higher level of safety to operations under the current 

regulatory structure. 

These limitations and conditions to which the operator agrees to be bound when conducting 

commercial operations under an FAA issued exemption include: 

1. The UA; DJI Phantom 2, DJI Phantom Vision+ and DJI S1000+ will weigh less 

than 55 pounds including payload. Proposed operations of any other aircraft will 

require a new petition or a petition to amend the exemption. 

2. Operations for the purpose of closed set motion picture and television filming 

are not permitted. 

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per hour). 

The exemption holder may use either groundspeed or calibrated airspeed to 

determine compliance with the 87 knot speed restriction. In no case will the UA 

be operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 200 feet above ground 

level 

(AGL). Altitude must be reported in feet AGL. 
5. The UA must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate or U.S. driver’s license 

6. All operations must utilize a visual observer (VO). The UA must be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO 

may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC must be able to communicate 

verbally at all times; electronic messaging or texting is not permitted during 

flight operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must 

ensure that the VO can perform the duties required of the VO. 

7. The exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in the grant 

of exemption, are hereinafter referred to as the operating documents. The 

operating documents must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in the exemption and the procedures outlined in the 

operating documents, the conditions and limitations therein take precedence and 

must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator or any law 

enforcement official upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect 

the basis upon which the FAA granted the exemption, then the operator must 

petition for an amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight prior to conducting further operations 

under this exemption. Functional test flights may only be conducted by a PIC 

with a VO and must remain at least 500 feet from other people. The functional 

test flight must be conducted in such a manner so as to not pose an undue 

hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure 

that it is in a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine 

the UAS is in a condition for safe flight. The pre-flight inspection must account 

for all potential discrepancies, e.g. inoperable components, items, or equipment. 

If the inspection reveals a condition that affects the safe operation of the UAS, 
the aircraft is prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and aircraft 

components. 

12. Each UAS operated under the exemption must comply with all manufacturer's 

safety bulletins. 

13. A PIC must hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate. The PIC must also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. The 

PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in 

an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates 

the ability to safely operate the UAS in a manner consistent with how the UAS 

will be operated under this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from persons, vessels, vehicles 

and structures. PIC qualification flight hours and currency must be logged in a 

manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training 

the operator’s PICs and VOs (training, proficiency, and experience building) 

and determining the PIC’s ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under this exemption are 

permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, 

proficiency, and experience building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR §

91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. 

All operations must be conducted under visual meteorological conditions (VMC). 

Flights under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted 

on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA 

issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law 

enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

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

PIC. 
18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

predetermined location within the private or controlled access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough available power for the UA to 

conduct the intended operation and to operate after that for at least five minutes 

or with the reserve power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). 

All operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 CFR part 47, and have 

identification (N- 6 Number) markings in accordance with 14 CFR part 45, 

Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the 

UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

aircraft is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all 

nonparticipating persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If 

a situation arises where nonparticipating persons leave such protection and 

are within 500 feet of the UA, flight operations must cease immediately in a 

manner ensuring the safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under the exemption. 

27. All operations shall be conducted over private or controlled access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted. 
28. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

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

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. 

Unless otherwise specified in the grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91. 

14 CFR § 61.23 (a) & (c): Medical certificates: Requirements and duration. 

This regulation sets forth medical certificate requirements for pilots-in-command of 

aircraft in that a holder must have a first-class medical certificate when exercising the PIC 

privileges of an airline transport pilot certificate. Furthermore, the requirement states that 

the PIC must hold at least a second-class medical certificate when exercising PIC privileges 

of a commercial pilot certificate, or must hold at least a third-class medical certificate when 

exercising PIC privileges of a private pilot certificate, recreational pilot certificate, or flight 

instructor certificate. It also states that a person must hold and possess either a medical 

certificate issued under § 61.67 or a U.S. driver's license when exercising the privileges of a 

PIC of a sport pilot certificate in a light-sport aircraft other than a glider or balloon. 

The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s 

certificates (discussed above) to operate a UAS with a U.S. issued driver’s license, in lieu of 

an FAA-issued medical certificate. The FAA is also granting relief from § 61.23(c) to allow 

sport pilot certificate holders to operate aircraft other than LSA with a U.S. issued driver’s 

license. The FAA has issued the following exemptions to this regulation: Exemption 

Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 61.101 (e) (4) & (5): Recreational pilot privileges and limitations. 

This section limits recreational pilots to non-commercial operations and that they may not 

act as pilot in command of a recreational aircraft for compensation or hire, or in the 

furtherance of a business. Unlike a conventional aircraft that carries the pilot and 

passengers, the UA is remotely controlled with no living thing on board. The area of 

operation will be predetermined and in a protected flight area under the permission of the 

property representative, and all flights are planned and coordinated in advance. The FAA 

has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 

11267, 11260, 11256, 11253, 11252, 11240 and 11230. 
14 CFR § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command. 

This section limits private pilots to non-commercial operations and that they may not act as 

pilot in command of an aircraft that is carrying passengers or property for compensation 

or hire. Unlike a conventional aircraft that carries the pilot and passengers, the UA is 

remotely controlled with no living thing on board. The area of operation will be 

predetermined and in a protected flight area under the permission of the property 

representative, and all flights are planned and coordinated in advance. The 

FAA has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 

11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 61.315 (a): What are the privileges and limits of my sport pilot certificate? 

This section limits sport pilots to non-commercial operations and that they may not act as 

pilot in command of an aircraft that is carrying passengers or property for compensation 

or hire, or in the furtherance of a business. They also may not carry more than one 

passenger, fly at night, and under other restrictions that are outside of the scope of 

intended flights of the UA. Unlike a conventional aircraft that carries the pilot and 

passengers, the UA is remotely controlled with no living thing on board. The area of 

operation will be predetermined and in a protected flight area under the permission of the 

property representative, and all flights are planned and coordinated in advance. The FAA 

has issued the following exemptions to this regulation: Exemption Nos.11278, 11275, 11269, 

11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

14 CFR § 91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft for maintenance and use of preflight actions as 

prescribed by the aircraft’s manufacturer prior to each flight, and given the FAA’s prior 

approval of the same types of aircraft to be used in previous exemptions to this 

requirement (as set forth in Exemptions Nos. 11278, 11275, 11267, 11260, 11253 and 11230) 

we believe we can maintain a high standard of safety and due regard as to the aircraft’s 

airworthiness during flight operations. The FAA has issued the following exemptions to 

this regulation: Exemption Nos.11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 

11240 and 11230. 

14 CFR § 91.119 (c): Minimum safe altitudes. 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided the 
person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for UAS that are rotorcraft and the exemption 

requests authority to operate at altitudes up to 200 feet AGL, an exemption may be needed 

to allow such operations. As set forth herein, the UA will never operate at higher than 200 

feet AGL, will always be operated under VLOS of both the PIC and VO, its area of 

operation will be predetermined and in a protected flight area under the permission of the 

property representative, all flights are planned and coordinated in advance and the UA will 

remain clear of, and give way to all manned aviation operations and activities at all times. 

The equivalent level of safety will be achieved given the size, weight, speed of the UA as well 

as the location where it is operated and under the conditions previously stated. Compared 

to flight operations with aircraft or rotorcraft weighting far more than the maximum 

55pounds proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft operating at 

or below 500 feet AGL. In addition, the low-altitude operations of the UA will ensure 

separation between these small- UAS operations and the operations of conventional 

aircraft that must comply with Section 91.119. The FAA has issued the following 

exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 

11253, 11252, 11240 and 11230. 

14 CFR § 91.121: Altimeter Settings. 

This regulation requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the UA may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the 

manufacturer’s published procedures and live flight data monitoring, confirming the 

altitude of the launch site shown on the GPS altitude indicator before flight. In the event 

that the GPS altitude read out system becomes none functional during flight, the UA will 

also have a pre-programmed maximum flight limit of 200 feet programmed into them so 

that they may not fly above unapproved altitude limits. The FAA has issued the following 

exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 

11253, 11252, 11240 and 11230. 

14 CFR § 91.151(a) (1): Fuel Requirements for Flight in VFR Conditions. 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough 

fuel to fly to the first point of intended landing, and, assuming normal cruising speed – (1) 

During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for 

at least 45 minutes.” 
The LiPo battery powering the DJI Phantom 2 & DJI Phantom Vision + UA provides 

approximately 20 minutes of powered flight while the LiPo battery powering the DJI S1000 

provides approximately 30 minutes of flight. The PIC will not begin a flight unless there is 

enough available power for the UA to conduct the intended operation and to operate after 

that for at least five minutes or with the reserve power recommended by the manufacturer 

if greater. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of 

prior exemptions, and that flight with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given the size and 

speed of the small UAS. Similar exemptions have been granted to other operations, 

including Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240 

and 11230. 

14 CFR § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections. 

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in 

compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with 

an airworthiness certificate, these sections will not apply to the applicant. 

An equivalent level of safety will be achieved because these small UASs are very limited in 

size and will carry a small payload and operate only in restricted areas for limited periods 

of time. If mechanical issues arise the UA can land immediately and will be operating from 

no higher than 200 feet AGL and within VLOS of the PIC and VO. Prior to each flight, the 

PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe 

flight. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment. If the inspection reveals a condition that affects the safe

operation of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. 

The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. The FAA 

has issued the following exemptions to this regulation: Exemptions Nos. 11278, 11275, 

11269, 11267, 11260, 11256, 11253, 11252, 11240 and 11230. 

Privacy 

All flights will occur over private or controlled access property with the property 

representative or owner’s prior consent and knowledge. Filming will be of people who have 

also consented to being filmed or otherwise have agreed to be in the area where filming will 

take place. 
All flights will occur in accordance with any state or local laws regarding privacy. 

Additional Views, Information & Summary 

Aerobods has 2 years of experience in unmanned aircraft flight operations and currently 

holds a valid commercial pilot certificate. We understand that safety is paramount, but we 

also know that integrating and operating in congested airspace along with manned aircraft 

is possible without incident. 

Aerobods was established January, 2012. 

As a public benefit Aerobods will advance: 

-Research into future safety guidelines for the use of UAS, 

-Reduction in dangers by limiting the use of larger rotorcraft or fixed-wing aircraft, 

-Reducing carbon emissions, & 

-Advancement of science through advanced data collection 

********* 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 CFR 61.23(a) & (c); 14 CFR 61.101 (e) (4) & (5); 14 CFR 61.113 (a); 14 CFR 61.315 

(a); 14 

CFR 91.7 (a); 14 CFR 91.119 (c); 14 CFR 91.121; 14 CFR 91.151 (a) (1); 14 CFR 91.405 

(a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a) (1) & (2) and 14 CFR 91.417 (a) & (b) to 

operate commercially a small unmanned vehicle (55pounds or less) for the purpose of 

aerial surveying, mapping and data collection; remote sensing; educational and research 

operations; wildlife and forestry monitoring; aid in disaster and emergency management 

and monitoring, civil first response, communications relay, search and rescue, monitoring 

fire hazards, cleanup effort supervision, damage assessment and estimation; aid civil 

engineering: waterways and shipping, forestry, fishery protection, pollution control and air 

sampling and crop performance; railroad and motor-vehicle road inspection; 

telecommunications infrastructure inspection; utility, energy systems and electrical 

engineering inspections and asset management; agricultural surveying and produce field 

management; livestock management and accountability; unmanned aircraft flight school; 

aerial filmmaking and photography; construction site inspections and monitoring; oil and 

gas pipeline inspection/patrolling and oil-field inspection; real estate and marketing; aerial 

event security, surveillance and crowd management and aerial imagery evidence for 

property insurance claims. 
Approval of exemptions allowing commercial operations of UA in the listed industries will 

enhance safety by reducing risk. Conventional flight operations using jet, piston or 

multi-engine powered aircraft occasionally operate at extremely low altitudes to complete 

some of the requested uses and in extreme proximity to people and structures. This 

presents associated risks as these vehicles weigh in excess of 3,000 pounds and carry large 

amounts of jet A or other fuel. Such aircraft must fly to and from the mission location. In 

contrast, a UA weighing fewer than 55 pounds, powered by batteries, virtually eliminates 

all of the above risks given the UA’s reduced mass and lack of combustible fuel carried on 

board. The UA is carried to the mission site. The UA will carry no passengers or crew, 

therefore, the UA will not expose them to the risks associated with manned aircraft flights. 

The operation of small UASs, weighing less than 55 pounds, conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of 

the exemptions requested herein, including exempting the applicant from the requirements 

of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow 

speeds, close to the ground but under 200 feet AGL, and within visual line of sight of the 

pilot in command and a visual observer. As a result, the small UASs are far safer than 

conventional flight operations conducted with large manned aircraft. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, 

speed, operating capabilities, proximity to airports and populated areas, operation within 

visual line of sight, national security and the significant public benefit as well as the positive 

economic impacts – provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant’s UA. Granting Aerobods the 

above exemptions will allow for the expansion of UAS systems into the future, in a 

professional, safety conscious culture steeped in the tradition safe flight and general 

aviation. Aerobods respectfully requests that the FAA grant its exception without delay. 

The FAA has the authority to issue the exemption sought by Aerobods pursuant to the 

Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

Sincerely, 

Richard G. Wright

President, Lead Pilot

Just Make A Difference Inc.

DBA Aerobods

Commercial Pilot Certificate 2205920

Rotorcraft-Helicopter; Instrument Helicopter

1021 Ballew Circle

Fairview, TN 37062

Phone: 615-200-5112