Jan 21,2016

Dear Sir or Madam: This application is being submitted on my own behalf without legal counsel 

or consulting services. 

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

and 14 C.F.R. Part 11, Greg R Myers, of Myers Associates , operator of Small Unmanned 

Aircraft Systems (“SUASs”) equipped to conduct aerial photography and videography, hereby 

applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of its SUASs, 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 

333.1 

As described more fully below, requested exemption would permit the operation of small, 

unmanned and relatively inexpensive SUAS under controlled conditions in airspace that is 1). 

Limited 2). Predetermined and 3). controlled. The proposed exemption, if approved would allow 

Myers Associates to conduct commercial operations of small unmanned aircraft systems 

(“UAS”) meeting or exceeding all of the operational and safety requirements Congress has set 

forth in Section 333. 

Myers Associates is an Security Consulting company that plans to exploit the capabilities of 

Unmanned Aerial Systems to offer a multitude of services, including: Security evaluations and 

inspections -

- Aerial surveying - Search and Rescue - Event Photography /Videography - Agriculture 

purposes - Real Estate Photography - Aerial filmmaking and photography - Construction site 

inspections and monitoring - Wildlife and forestry monitoring - Educational and research 

operations - Business Advertising 

Statutory Authority Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems”, 

provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in 

the NAS. Section 333(a) states that the FAA “shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before completion of the 

(comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance 

required by section 334 of this Act.” In Section 332(b)(1), Congress made it clear that Section 

333 provides a mechanism for “expedited operation authorization” if several factors are met. 

Petitioner meets all requirements to permit FAA approval of commercial UAS operations. 

The Petitioner Requests Relief From the Following: Regulations from which the exemption is 

requested: 

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 

C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 

91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 

2 

14 C.F.R. 91.215 14 C.F.R. (91.401 - 91.417) 

Unmanned Aircraft System 

SUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper 

equipment and personnel cost, reduced noise and as such, a much smaller environmental 

impact which promotes public safety. 

We are petitioning for exemption to enable Myers Associates, to operate a DJI Phantom 3 
equipped with three-axis gimbals and using High-Def. cameras. These SUAS have a built- in 

capability to limit the height it flies above the ground, to limit the radius of the distance it flies 

from the operator and to exclude it from Class B, C and D airspace including a no fly zone 

feature. The Phantom 3 have the failsafe function of the Naza-M autopilot system, which 

means when the communication between the Main Controller and the transmitter is 

disconnected, the outputs of all command sticks from controller will go to the center position. If 

the GPS signal is good enough, the system will automatically trigger Return to Home and will 

land safely. 

The above specifications meet with the Model Aircraft Operating Standards as set below: 

• Myers Associates, will only operate its SUAS in line of sight of a pilot and/or observer and will 

operate at sites that are a 'sufficient distance' from populated areas within the sterile area 

described in the FOPM. Such operations will insure that the SUAS will "not create a hazard to 

users of the national airspace system or the public." 

• When flying SUAS within 3 miles of an airport, airport operators will be notified and the 

operator will give the right of way to avoid flying in the proximity of full-scale aircraft. • 

Maximum flight time for each operational flight will be 30 minutes. • Flights will be terminated at 

25% battery power reserve should that occur prior to the 30 minute limit. 

• The SUAS will be programmed so that it will not be operated at an altitude of no more than 

200 feet AGL.

• Minimum crew for each operation will consist of the SUAS Pilot, and Visual Observer. 

 

• The SUAS operated by the petitioner weighs less than 55 pounds, including the payload (i.e. 

camera, lens, and gimbal). 

• The SUAS will operate at speeds of no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally. 

• Given the small size of the SUAS and the restricted sterile environment within which they will 

operate, our SUAS operations adhere to the Reform Act's safety requirements. 

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel, it operates at lower altitudes with no people on board and will 

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 25 minutes, 

this offers little or no risk to national security. 

Low level oblique photos and video from several angles are far more effective than ground 

based imagery for displaying the characteristics of large, complex properties with several 

buildings and large trees. The applicants in the past have chartered 2-seat full-sized helicopters 

for this purpose, which has proven more costly than many potential clients have been able to 

afford. The benefits of reduced cost and improved quality of presentation from the UA will be 

valuable to and benefit many buyers and sellers of real property. 

Additionally, we request that we be allowed to use our system to benefit first responders nearby 

who might require assistance, including fire fighters, the police, the sheriff, etc. all while 

remaining subject to all limitations cited in this application as we do so. 

 a. No flight will be made with a Gross weight exceeding 55 pounds; 

 b. All operations must occur in FAA Class G airspace at no more than 200 ft. AGL, at an 

airspeed of no more than 50 knots and no further than 1.5 NM from the PIC; 
 c. All operations must utilize a visual observer (VO). The VO and PIC must be able to 

communicate by voice at all times during a flight operation. 

 d. Operations will be restricted to flights over private property with the permission of the 

property owner. 

 e. All required permits/licenses will be obtained from state and local government prior to 

operation.

 f. Myers Associates will not operate over densely populated areas 

 g. Myers Associates will not be operating over any open-air assembly of people.

 h. Myers Associates will not be operating within 5 NM of an airport or heliport. 

We respectfully request exemption under Section 333 to enable Myers Associates, to operate 

efficient, limited, low-risk commercial SAUS operations for the activities stated respecting at all 

times the space and privacy of citizens and property whilst keeping our skies safe. 

Sincerely, 

Greg R Myers. DBA Myers Associates

607-343-0154