July 15, 2015

Exemption No. 12047

Regulatory Docket No. FAA–2015–1532

Mr. Scott Dodson

Vid Flight

6810 High Country Trail

Arlington, TX 76016

Dear Mr. Dodson:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter posted to the public docket on May 9, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Vid Flight (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial photography and inspections.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is the DJI Phantom 2.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

consideration of the size, weight, speed, and limited operating area associated with the 
2

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Vid Flight is granted an exemption from 14 CFR 

§§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the 

extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Vid Flight is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2

when weighing less than 55 pounds including payload. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this exemption.

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

not permitted. 

3. The UA may 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 400 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. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this 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 this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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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 this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this 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 this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, 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 
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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 this 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 

pre-determined 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 this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
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(N−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 this 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this 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.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
I. Name and Information

Scott Dodson

6810 High Country Trail

Arlington, Texas 76016

214-683-1948

scott.dodson@tx.rr.com

Owner, Vid Flight

(a subsidiary of Live It Again Productions, LLC)

All mentions of my name "Scott Dodson" are inclusive of "Vid Flight"

II. The Specific Sections of Title 14 of the Code of

Federal Regulations From Which Scott Dodson Requests

Exemption are:

14 CFR 21;§14 C.F.R. 45.23(b);§14 CFR 61.113 (a) & (b); 14

C.F.R. 91, et seq.;§14 CFR 407 (a) (1);§14 CFR 409 (a) (2);

and, 14 CFR 417 (a) & (b).

III. The Extent of relief Scott Dodson seeks and the Reason He Seeks Such 

Relief:

I, Scott Dodson, submit this application in accordance with the Reform Act, 112 

P.L. 95 §§ 331-334, seeking relief from any currently applicable FARs operating 

to prevent me, Scott Dodson, contemplated commercial cinematic, academic and

other flight operations within the national airspace system. The Reform Act in 

Section 332 provides for such integration of civil unmanned aircraft systems into 

our national airspace system as it is in the public’s interest to do so. 

My, Scott Dodson's, ultra light weight UAS meets the definition of “small

unmanned aircraft” as defined in Section 331 and therefore the integration of my 

ultra light weight UAS is expressly contemplated by the Reform Act. I would like 

to operate my ultra light weight UAS prior to the time period by which the

Reform Act requires the FAA to promulgate rules governing such craft. Thereby, 

providing direct experience and valuable information for formal regulation that 

can be administered uniformly to all UAS aerial video and photography. 

The Reform Act guides the Secretary in determining the types of UAS's that may

operate safely in our national airspace system. Considerations include: The 

weight, size, speed and overall capabilities of the UAS's; Whether the UAS will 

be operated near airports or heavily populated areas; and, Whether the

UAS will be operated by line of sight. 112 P.L. 95 § 333 (a). Each of these items 

reflect in favor of an exemption for me, Scott Dodson. 

My UAS utilizes four (4) counter-rotating propellers for balance, control and 

stability. My UAS is equipped with GPS and auto return safety technology.

Weighing less than five (5) pounds (far below the maximum 55 pound limit); 

including camera with gimbal.
I, Scott Dodson, consider safety as foremost with each flight. My small, 

unmanned aircraft is designed to hover in place via GPS and operate in less than 

a 24 knot (15 mph) wind. For safety, stability and fear of financial loss I will not fly 

in winds exceeding 16 kph (10 mph). Built in safety systems include a GPS mode 

that allows my UAS to hover in place when radio controls are released. With 

three modes to choose from, I utilize the GPS Mode for aerial 

videography/photography. This is the safest, most reliable and stable mode to 

prevent accident and hazard. When pilot communication is lost UAS is designed 

slowly descend to point of take off. I do not operate my UAS near airports, 

Hospitals nor Police heliports, and do not operate near areas where general

public is within fifty to one hundred (50-100) yards depending on location,

conditions and weather. I am constantly on alert for any manned aircraft 

(Police/Medical helicopters, etc.) and prepared to land/abort immediately to the 

nearest and safest ground point should a manned aircraft approach my location

or I suspect manned aircraft may approach near my location.

My UAS is capable of vertical and horizontal operations, and are flown only within 

my line of sight of me, as the remote control pilot, or with my licensed PIC. 

Utilizing battery power rather than combustible fuels, flights generally last 

between three (3) to twelve (12) minutes, with an altitude under two hundred 

(200) feet. I, Scott Dodson, utilize a fresh fully charged battery with each flight as 

a safety precaution; full flight time limit for each battery is twelve (12) to twentytwo (22) minutes as tested. I do not operate my UAS at or below manufacture 

recommend minimum charge levels for operation; preferring to remain well within 

a safe operating range to insure adequate communication between radio control 

and UAS to eliminate potential for crash, loss of control or hazard. Reserve

batteries are at hand with each exercise to insure replacement for sufficient safe 

level of operation. I do not believe in taking risk that may cause a crash, that 

could create hazard to the public/property/manned aircraft, and have no desire to 

lose an investment. I have clocked numerous practice flights in remote areas as 

a hobbyist simulating flights for future commercial use to gain familiarization with 

the characteristics of this specific UAS's performance under different temperature 

and weather conditions. I also practice computerized simulated flights to maintain 

adequate skills and response reflex time, all for the sake of safety.

I, Scott Dodson, am extremely cautious when operating of my UAS/ultra light 

weight unmanned aircraft and will not “create a hazard to users of the national 

airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and

weight of my UAS it falls well within Congress’s contemplated safety zone when it 

promulgated the Reform Act and the corresponding directive to integrate UAS's 

into the national airspace system. Scott Dodson’s UAS, used in hobby flight, has 

a demonstrable safety record and does not pose any threat to the general public 

or national security.
IV. How Scott Dodson’s Request Will Benefit the Public As A Whole:

Aerial videography for geographical awareness and for real estate marketing has 

been around for a long time through manned fixed wing aircraft and helicopters. 

For small budget real estate companies and average homeowners the expense 

of such aerial videography is cost prohibitive. The same is also true for 

construction sites, land surveying, and even location historical documentation. 

Only large companies and high end Realtors or luxury homeowners can afford to 

absorb such expense. Depriving non-luxury homeowners and lower budget 

Realtors and other such companies with needs from a valuable marketing and 

analysis tool. Manned aircraft pose a threat to the public through potential 

catastrophic crash in the North Texas community, each resulting in loss of life, 

and with combustible fuel that exploded and burned on impact. Police, TV and 

radio helicopters have made emergency hard landings within city limits. 

My, Scott Dodson’s, UAS pose no such threat since size and lack of combustible 

fuel alleviates any potential threat to the public. Congress has already proclaimed 

that it is in the public’s interest to integrate commercially flown UAS's into the

national airspace system, hence the passing of the Reform Act. Granting my, 

Scott Dodson’s, exemption request furthers the public interest through 

academic/visual awareness of the geographical benefits in and around the North 

Texas area. My ultra lightweight UAS is battery powered and creates no

emissions that can harm the environment. The consequence of my ultra light 

weight UAS crashing is far less than a full size helicopter or fixed wing aircraft; 

which are heavy, contain combustible fuel and can cause catastrophic

devastation to the public.

The public’s interest is furthered by minimizing ecological and crash threat by 

permitting aerial video/photo capture through my battery operated ultra light 

weight UAS's. Permitting me, Scott Dodson, to immediately fly within national air 

space furthers economic growth. Granting my exemption request substantially 

furthers the economic impact for the North Texas community for companies 

looking to relocate or build in the North Texas area as well as individuals looking 

to relocate for career advancement through academic and geographical 

awareness. Both of which serve as a stimulus to the community.

V. Reasons Why Scott Dodson’s Exemption Will Not Adversely Affect 

Safety Or How The Exemption Will Provide a Level of Safety At Least Equal 

To Existing Rule:

My, Scott Dodson’s, exemption will not adversely affect safety. Quite the 

contrary, for the reasons stated permitting me, Scott Dodson, to log more flight 

time in FAA controlled airspace, with communication with the FAA, will allow me 

to contribute to the innovation and implementation of new and novel, as of yet 

undiscovered safety protocols for Realtors, construction sites, land surveying, 

location historical documentation, and infrastructure inspections that can be 
embraced by the NAR, AAR, and TAR for development in cooperation with the 

FAA. In addition I, Scott Dodson, submit the following representations of

enhancements to current aerial videography and photography for real estate, 

construction sites, land surveying, location historical documentation, 

infrastructure inspections, athletic field marketing and maintenance:

My UAS, a Phantom 2 manufactured by DJI weighs less than 5 pounds complete 

with a small ultra light weight high quality GoPro 3+ Black camera;

§I only operate my UAS below 200 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012); my UAS only 

operates for 12-16 minutes per flight;

§I land my UAS prior to manufacturer recommended minimum level of battery 

power;

§I pilot my UAS through remote control only by line of sight;

§My UAS has GPS a flight safety feature whereby it hovers and then slowly lands 

if communication with the remote control pilot is lost;

§I actively analyze flight data and other sources of information to constantly 

update and enhance safety protocols;

§I only operate in reasonably safe environment that are strictly controlled, are 

away from power lines, elevated lights, airports and actively populated areas;

§I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance;

§I always obtains all necessary permissions prior to operation; and,

§I have procedures in place to abort flights in the event of safety breaches or 

potential danger.

My, Scott Dodson’s, safety protocols provide a level of safety equal to or 

exceeding existing rules. It is important to note that absent the integration of 

commercial UAS into our national airspace system, helicopters are the primary 

means of aerial video and photography for community awareness and 

application. While the safety record of such helicopters is remarkably astounding, 

there have been local incidents involving loss of life as well as extensive property 

damage; it is far safer to operate a battery powered ultra light weight UAS.

§First, the potential loss of life is diminished because UAS's carry no people on 

board and I only operate my UAS in specific areas away from mass populations. 

§Second, there is no fuel on board a UAS and thus the potential for fire or 

explosions is greatly diminished.

§Third, the small size and extreme maneuverability of my UAS allow me to 

remotely pilot away from and avoid hazards quickly and safely.

§Lastly, given its small size and weight, even when close enough to capture 

amazing images, my UAS need not be so close to the objects they are focused 

on through the technology and use of post editing software allowing pan and 

zoom. Accordingly, my UAS has been experimentally operated for

familiarization/competency and will continue to operate at and above current 

safety levels.
VI. A Summary The FAA May Publish in the Federal

Register:

A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The 

Like.

14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation 

to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my, 

Scott Dodson's, UAS permits exemption from Part 21 because my

UAS meets (and exceeds) an equivalent level of safety pursuant to Section 333 

of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) 

and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to 

exempt UAS's from the airworthiness certificate requirement in consideration of 

the weight, size, speed, maneuverability and proximity to areas such as airports 

and dense populations. My, Scott Dodson, current and projected UAS's meet or 

exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no on board pilots or passengers, and given the size of the UAS's, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by

maintaining a safety/flight manual delineating areas of where safety can be 

defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS 

utilizes electronic global positioning systems with a barometric sensor.

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same reasons 

described above. The equivalent level of safety will be achieved by maintaining 

any such required certifications and registrations by me, Scott Dodson.

14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal 

Regulation require aircraft to be marked according to certain specifications. My 

UAS are, by definition, unmanned. They therefore do not have a cabin, cockpit or 

pilot station on which to mark certain words or phrases. Further, two-inch lettering 

is difficult to place on such small aircraft with dimensions smaller that minimal 

lettering requirement. Regardless, I will mark its UASs in the largest possible 
lettering by placing the word “EXPERIMENTAL” on its fuselage as required by 14 

C.F.R. §45.29 (f) so that I the pilot, or anyone assisting me as a spotter with the 

UAV will see the markings. The FAA has previously issued exemptions to this 

regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.

14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC.

Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to noncommercial operations. I, Scott Dodson, can achieve an equivalent level of safety 

as achieved by current regulations because my UAS does not carry any pilots or 

passengers. Further, while helpful, a pilot license will not ensure remote control 

piloting skills. The risks attended to the operation of my UAS is far less than the 

risk levels inherent in the commercial activities outlined in 14 C.F.R. § 61, et seq. 

Thus, allowing me, Scott Dodson, to operate my UAS meet and exceed current 

safety levels in relation to 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. 91.119: Minimum Safe Altitudes.

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. My UAS 

will never operate at an altitude greater than 200 AGL; safely below the standard 

of 400 AGL. I, Scott Dodson, will however operate my UAS in safe areas away 

from public and traffic, providing a level of safety at least equivalent to or below 

those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of my UAS, an equivalent or higher level of safety will 

be achieved.

14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b):

Maintenance Inspections.

The above-cited Regulations require, amongst other things,

aircraft owners and operators to “have [the] 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. . . .” These Regulations only apply to aircraft with an 

airworthiness certificate. They will not, therefore, apply to my, Scott Dodson's, 

UAS. However, as a safety precaution I carefully and thoroughly inspect my UAS 

before and after each flight.

In summary, Scott Dodson seeks an exemption from the

following Regulations:

14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§

61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9

(b)(2); 14 C.F.R. § 91.103(b); 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) and (b); 14 C.F.R. § 91.405 (a); 14

C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R.
§ 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate my, 

Scott Dodson, small unmanned vehicle/lightweight unmanned aircraft vehicle in 

community awareness, grounds and building maintenance, infrastructure 

inspections, real estate operations, and to develop economic platforms for real 

estate to enhance the experience of those seeking to relocate to the North Texas

area. Currently, such aerial videography/photography relies primarily on the use 

of larger aircraft running on combustible fuel. Posing potential risk to the public. 

Granting my, Scott Dodson, request for exemption will reduce current risk levels 

and thereby enhance safety.

My UAS craft do not contain potentially explosive fuel, is smaller, lighter and 

more maneuverable than conventional video and photographic aircraft with much 

less flight time. Further, I operate at lower altitudes and in controlled airspace 

eliminating potential public risk flying to and from established airfields. I, Scott 

Dodson, have been informally analyzing flight information and will compile safety

protocols and the implementation of a flight operations manual for aerial video 

and photographic usage that exceeds currently accepted means and methods for 

safe flight. Formal collection of information shared with the FAA will enhance the 

FAA's internal efforts to establish protocols for complying with the FAA 

Modernization and Reform Act of 2012. There are no personnel on board my, 

Scott Dodson, UAS and therefore the likelihood of death or serious bodily injury is

significantly diminished. My, Scott Dodson's, operation of my UAS, weighing less 

than 5 pounds and traveling at lower speeds within limited areas will provide an 

equivalent level of safety as that achieved under current FARs. Accordingly I,

Scott Dodson, respectfully request that the FAA grant my exemption request and 

am willing to cooperate in sharing information to benefit the FAA, safety of 

manned aircraft, and the general public at large.

Respectfully Submitted,

Scott Dodson, Owner

Vid Flight

Subsidiary of Live It Again Productions, LLC

6810 High Country Trail

Arlington, Texas 76016