THOMAS SLED

3013 Canton Hills St

Henderson NV 89052-6921

tsled@earthlink.net

702.616-2464 House

704.692-1104 Cell

U.S. DEPARTMENT of TRANSPORTATION

Docket Operations M-30

1200 New Jersey Ave SE

Room 12-140 West Building 

Washington DC 20590-0001

27 October 2015

Subject: Exemption Request to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from:

14 CFR 21 subpart H Certification & Airworthiness

14 CFR 61.113(a) & (b) Commercial Pilot Privileges & Limitations

14 CFR 45.23(b) Aircraft Markings

14 CFR 91.7(a) Airworthiness Certificate

14 CFR 91.9(b)(2) On Board Manuals

14 CFR 91.103(b)(2) Preflight Actions

14 CFR 91.109 Flight Instruction

14 CFR 91.119 Minimum Safe Altitudes

14 CFR 91.121 Altimeter Settings

14 CFR 91.151 Fuel Requirements Under VFR

14 CFR 91.203 On Board Certificate & Registration

14 CFR 91.405 Required Maintenance

14 CFR 91.407 Operations After Maintenance

14 CFR 91.409 Maintenance Inspections

14 CFR 91.417 Maintenance Records

Dear Sir or Madam,

Petitioner Thomas Sled hereby petitions the Secretary of Transportation and Federal Aviation 

Administration for exemption to the above referenced, and below more fully described, Federal Aviation

Regulations that currently may or may not apply to allow commercial operation of designated UAS, 

provided such operations are conducted within and under the conditions outlined by your “Grant of 

Exemption Letter” and any new regulations that are issued in the future.

Petition Based Upon Prior Exemptions

This petition is based, in part, upon prior exemptions that have been granted similar relief, numbers 

11062, 11109, 11112, and 11213.
Identification of Petitioner

Petitioner Thomas Sled is a retired military officer, who served as a helicopter pilot in the Vietnam 

conflict. Petitioner Thomas Sled has built three Experimental aircraft in the past 16 years, they have 

been inspected by FAA inspectors, and the Petitioner Thomas Sled has registered them with the FAA 

(N4357S, N3722T, N5122T) and been certified Repairman Experimental Aircraft Builder on them. 

Petitioner Thomas Sled holds a Private Pilot Certificate # 2692359 Rotorcraft-Helicopter with Sport 

Pilot endorsement Airplane Single Engine Land.

Summary of Regulations of Which Relief Is Requested

14 CFR 21 subpart H Certification & Airworthiness: Petitioner Thomas Sled seeks relief from this 

section because of the extreme small size and load caring ability of the UAS.

14 CFR 61.113(a) & (b) Commercial Pilot Privileges & Limitations: Petitioner Thomas Sled seeks relief 

from this section and to allow him as a Private Pilot, acting as PIC, to use the UAS for commercial 

flights listed latter in this petition. With the knowledge of a certified Private Pilot and a seasoned UAS 

pilot and not caring passengers the level of safety expected by this section will be met.

14 CFR 45.23(b) Aircraft Markings: Petitioner Thomas Sled seeks relief from this section until such 

time as the regulations for UAS are established and accepted by the Federal Aviation Administration 

regarding this section, at that time Petitioner Thomas Sled will fully comply with them.

14 CFR 91.7(a) Airworthiness Certificate: Petitioner Thomas Sled seeks relief from this section until 

such time as the regulations for UAS are established and accepted by the Federal Aviation 

Administration regarding this section, at that time Petitioner Thomas Sled will fully comply with those.

14 CFR 91.9(b)(2) On Board Manuals: Petitioner Thomas Sled seeks relief from this section because 

of the extreme small size and load caring ability of the UAS. All manuals and maintenance records for 

a UAS will be kept in a binder with the PIC.

14 CFR 91.103(b)(2) Preflight Actions: Petitioner Thomas Sled seeks relief from this section but will 

follow the pref light requirements as spelled out in the manufactures manuals of the UASs to insure 

safety of flight and of the UAS. With UAS part of the preflight to to assess the flight area to that end I 

will utilize the new app ( B4UFly ) to check for NOTAMS and proximity to no-fly areas and airports. The

flight area must be assessed for above ground obstructions, trees, antenna, utility poles, lights, wires, 

and lines. As the PIC I will select a safe location for the takeoff and landing so as not to cause any 

undue hazard to people or property on the ground.

14 CFR 91.109 Flight Instruction: Petitioner Thomas Sled seeks relief from this section because there 

is not a PIC on board the UAS, nor dual controls to give flight instruction, so much of this section can 

not be complied with.

14 CFR 91.119 Minimum Safe Altitudes: Petitioner Thomas Sled seeks relief from this section because

the purpose the UAS are used for are contrary to this regulation. All altitude regulations currently 

applying to UAS will be followed as well as any new regulations for UAS when they are established and

accepted by the Federal Aviation Administration regarding this section, at that time Petitioner Thomas 

Sled will fully comply with those.

14 CFR 91.121 Altimeter Settings: Petitioner Thomas Sled seeks relief from this section because there

is no Altimeter on board the UAS as spelled out in this section. The UAS's report back to the ground 

control unit very detailed GPS information which provides the PIC with very accurate AGL altitude.
14 CFR 91.151 Fuel Requirements Under VFR: Petitioner Thomas Sled seeks relief from this section 

because the UAS do not use fuel, they use battery power with a max duration of 30 minutes. For safety

the flights of the UASs will be only to 80% of their batteries power.

14 CFR 91.203 On Board Certificate & Registration: Petitioner Thomas Sled seeks relief from this 

section because of the extreme small size and load caring ability of the UAS. All manuals and 

maintenance records for a UAS will be kept in a binder with the PIC.

14 CFR 91.405 Required Maintenance

14 CFR 91.407 Operations After Maintenance

14 CFR 91.409 Maintenance Inspections

14 CFR 91.417 Maintenance Records

Petitioner Thomas Sled seeks relief from these four sections on Maintenance as written, instead the 

maintenance procedures for each UAS will be followed as spelled out in the maintenance section of the

manufactures manuals for each of the UASs to insure safety of flight and longevity of the UAS. All 

manuals and maintenance records for a UAS will be kept in a binder with the PIC.

Use of the UASs

Here is a list of the possible uses of the UAS:

Low altitude aerial photography and videography

Photography and videography of residents & commercial real estate

Photography and videography of Weddings and other events

Aerial inspections

Aerial crop inspections

Aerial search operations to aid uniformed authorities

Safety and the Community

After receiving the Letter Granting Exemption it is the Petitioner Thomas Sled's intention, to follow the 

rules set down in the Letter Granting Exemption and utilizing the professional training and flight 

knowledge received in Army aviation along with the training and flight experience received in civil 

aviation to use my UASs in the above listed ways always operating in a careful and safe manner. Upon

receiving the Letter Granting Exemption the Petitioner Thomas Sled will contact the local Fire 

Department and local Police Department to explain to them the capabilities of my UASs and making 

them, and myself as PIC, available for remote search and rescue and in any other way the uniformed 

authorities think my UAS and I might aid the community. Utilizing a UAS to accomplish the above 

mentioned tasks is much safer for the community because of the size and design of a UAS as 

compared to a helicopter or fixed wing aircraft. The UAS is not thousands of pounds in weight nor does

it carry hundreds of pounds of volatile fuel posing a danger to people and property in it's flight area, 

similarly there is no comparison in the amounts of exhaust pollution and sound pollution. 

Closing

It is the hope of Petitioner Thomas Sled that this petition will be reviewed and met with favorably 

resulting in a Letter Granting Exemption. If for some reason you might have a question or need some 

additional information from Petitioner Thomas Sled please do not hesitate in contacting me via E-mail 

or by phone. I will respond very quickly.

I understand that with recent announcements by the Secretary of Transportation I can expect new 

regulations for UAS being established soon and when accepted by the Federal Aviation Administration 

Petitioner Thomas Sled will fully comply with all of them. 

Thank you for your time and consideration in this matter.

Thomas Sled
UAS Information

These three UAS are some of the most popular and commonly used, all three incorporate four electric 

motors in a quad configuration utilizing Lithium Polymer Batteries.

Horizon Hobby LLC CHROMA 4K

approx flight weight 3 Lbs with camera

less than 2 cubic feet in size

max speed of 40 mph

DJI Phantom 3 Pro 4K

approx flight weight 3 Lbs with camera

less than 2 cubic feet in size

max speed of 42 mph

DJI Inspire 1

approx flight weight 7 Lbs with camera

less than 2 cubic feet in size

max speed of 48 mph

Manuals & Specification Data Sheets

The manuals and specification data sheets for the three UAS are given here in URL format to save 

paper and to insure that the most current revisions are referenced.

Horizon Hobby LLC CHROMA 4K

http://www.horizonhobby.com/pdf/BLH8675-manual-EN.pdf

http://www.horizonhobby.com/pdf/BLH8600-Chroma_LED_reference_card-EN.pdf

DJI Phantom 3 Pro 4K

http://www.dji.com/product/phantom-3/spec

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en_0915.pdf

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Release_Note_en_9.9.pdf

DJI Inspire 1

http://www.dji.com/product/inspire-1/spec

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.pdf

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf