Robert W. Lacy 

2709 Woodshire Dr. 

Arlington, TX 76016 

rlacy@sbcglobal.net 

 

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, Robert W. Lacy, 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, construction, 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.” 

 

Robert W. Lacy plans 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. 

Robert W. Lacy also plans to operate a UAS, the DJI Inspire 1 which is comprised of an unmanned 

aircraft (UA or Inspire 1) and a transportable ground station. The Inspire 1 is referred to as a quadcopter with a maximum gross weight of about 6.5 pounds. It is equipped with four rotors that are 

driven by electric motors powered by batteries. The UA has a maximum airspeed of 22 m/s. 

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: Robert W. Lacy 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 Robert W. Lacy 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. Please contact us at any time if additional information or clarifications are 

needed. 
 

Sincerely, 

 

Robert W. Lacy