June 12, 2015 

From: Roger Arney E-mail: rogerarney@gmail.com

 2179 Monarch Drive, 

 Wrenshall, MN 55797 

To: U.S. Department of Transportation

 Docket Management System

 1200 New Jersey Ave., SE

 Washington DC 20590

US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA

Reform Act and Part 1 1 of the Federal Aviation Administration. 

I Roger Arney(pilot) (DBA Roger Arney) respectfully request exemption from the 

following regulations for an unmanned aircraft:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61 .113 (a) & (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) & (b)

14 CFR 91 .405 (a)

14 CFR 91 .407 (a) (1 )

14 CFR 91 .409 (a) (2)

14 CFR 91 .41 7 (a) & (b)

I wish to commercially operate an unmanned aircraft, as described herein. To photograph and 

record videos of flower gardens, farmsteads, real-estate for sale, business advertisements for 

newspaper, internet, and hard to get to inspection such as roof damage. Plus search and 

rescue. At this time there would be no television filming per se. 

About the UAV: I bought the UAV in March 2015 and have been flying it as a hobby since.

I currently have more than 20 hours flying time and will have more hours of fight by the time 

I hopefully receive an exemption. 
Picture of Unmanned aerial vehicle.

The Q500 is the UAV itself, the CGO2-GB is the camera and the ST10 is the remote control.
The remote control (ST10) has a first person view but is not sufficient alone for flying. It is 

good for aligning shots, picture or video. Direct visual observation is a must.

As shown here it has GPS, it reads a number of satellites, how many volts (charge) left is the 

flight battery, shows altitude, ground speed, (I haven’t observed more than 25MPH) and 

distance from you. Where it says, “welcome pilot” it will tell you if you are recording video 

or taking a snap shot. The remote sounds an alarm and vibrates when battery is getting low.

Number 19 in the upper left of the display it says “mode” is a 3-position switch that has a 

home mode. Using this will automatically bring the Q500 back to you and land within 26 

feet.

If the Q500 loses contact with the remote it will automatically enter the home mode.
Notice, it gives warning that the aircraft is in a no fly zone. 

Manned helicopters conducting aerial filming can weigh thousands of pounds or more and 

are operated by an onboard pilot, in addition to other onboard crewmembers, as necessary. 

The petitioner’s unmanned aircraft (UA) will weigh less than 4 lbs. with no onboard pilot or 

crew. The pilot and crew will be remotely located from the aircraft. The limited weight 

significantly reduces the potential for harm to participating and nonparticipating individuals 

or property in the event of an incident or accident. The risk to an onboard pilot and crew 

during an incident or accident is eliminated with the use of a UA for the aerial filming

operation. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or 

accident. The petitioner’s UA carries no fuel, and therefore the risk of fire following an 

incident or accident due to fuel spillage is eliminated.

Real estate marketing and personal photography has been around for some time. Using 

manned aircraft is expensive. Many don’t do this because of the cost. This requested 

exemption would enable me to provide this service at a much lower cost increasing economic 

growth. It would also greatly reduce noise and sight signature being a benefit to the public. 
As to safety: 

Prior to flight a safety-airworthiness inspection. Records will be kept for at least one year.

I will operate aircraft no higher than 300 feet and within 1000-foot radius of the pilot.

Always have a visual line of sight with an observer.

Air speed not exceeding 25 MPH.

Daylight flight only.

Obtain consent of property owners before flying over their property. 

Not to fly within 5 miles of an airport unless an agreement with the airport manager is 

obtained.

Aircraft will have identification (N) as large as possible.

The UAV will remain clear of all manned aircraft.

The UAV will not be operated from a moving vehicle of any kind. 

It is recommended not to fly when wind speed is above 12 MPH.

I will keep completely away from stadiums, crowds and traffic.

Flight operations must be conducted at least 300 feet from all nonparticipating persons 

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and 

structures unless:

Barriers or structures are present that sufficiently protect nonparticipating

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

The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission.

Sincerely, Roger Arney