June 29, 2015 

Federal Aviation Administration 

Document Management Facility 

United States Department of Transportation

1200 New Jersey Avenue SE 

West Building, Ground Floor, Room W12-140 

Washington, DC 20590

To Whom it May Concern

I am submitting my petition for exemption for the operation of Unmanned 

Aerial Systems (UAS) under Section 333 of the Federal Aviation 

Administration Modernization and Reform Act of 2012 (FMRA). My request, 

on behalf of myself, Joel M. Killingsworth d.b.a. DroneDogs is seeking a 

waiver of the below sections of 14 CFR for the purpose of unmanned aerial 

system (UAS) operation in public. 

The scope of the requested operation will be limited to aerial photography 

and videography of real estate properties (residential and commercial) on 

behalf of the seller, seller’s agent, or developer in order to promote the 

property for sale or use. 

Recognizing the importance of safety, it is my intent to operate in full 

compliance of any federal law, state law, and local ordinances that pertain 

to or extend to the commercial operation of unmanned aerial systems 

(UAS) for the purpose of aerial photography with emphasis on safety and 

privacy. This includes but is not limited to acquiring the necessary 

operating permits, and waivers. As the holder of a Commercial certificate 

with a Multi-engine and Instrument ratings, as well as two Second-inCommand (SIC) Type Ratings, experienced in Part 121 operations, I 

recognize the importance of operating within the specifications of Federal 

Aviation Regulations (FARs) and the limitations of the operations manual, as 

Joel M. Killingsworth

713.471.1369 matthewkillingsworth@gmail.com 2450 Oak Hill Circle #2432, Fort Worth, TX 
well as creating a system of internal safety-focused operating procedures. 

For this reason, initially I will remain the sole operator of any unmanned 

aerial system (UAS) operated under the authority of this exemption. Should 

it later be determined more operators are needed, a list of minimum 

requirements (outlined below) will be used to ensure a high level of safety 

is demonstrated at all times. If necessary, I will re-petition to include any 

added operators should our needs call for it. All unmanned aerial systems 

(UAS) acquired and used on my behalf will follow, except whereas 

requested for exemption all Federal Aviation Regulations (FARs) with 

regard to its operation. This includes but is not limited to maintaining in 

working order all systems and accessories associated with the UAV, preflight and post flight inspection, speed, altitude and meteorological 

condition adherence, and utilizing all available resources prior to a flight to 

determine safe operation is feasible. Additionally in an effort to maintain 

transparency both with our customers and the FAA, we intend to maintain 

records of maintenance performed on our systems as well as records of 

flight available on request. 

As is the basis of this petition, I am seeking exemption from 14 CFR part(s) 

21, Subpart H, 27, 45.23(b) 45.27(a), 61.113(a)(b), 61.133(a), 91.7(a), 

91.9(b)(2), 91.103, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a)(b), 

91.319(a)(1),91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a)(b) in order 

to legally comply with Federal Aviation Regulations (FARs) with regard to 

commercial unmanned aerial system (UAS) operations. 

The intended UAV platform selected for use in accordance with the 

requested exemption is the DJI Inspire 1. I have chosen this platform 

because it meets the FAA guidance on weight and speed restrictions as 

well as possesses safety features with regard to controllability. The Inspire 1 

weighs under 7 lbs and operates at or below 55 mph. Although Visual Line 

of Sight is required at all times, the Inspire 1 possesses the ability to 

monitor its flight path in real time via a relay of its onboard camera to a 

monitor possessed by the operator. This allows for additional situational 
awareness for the operator who may be unable to detect an obstacle from 

ground level. 

The following will comprise the manner in which we plan to operate should 

growth be necessary. Included are PIC/Observer requirements as well as 

the operating limitations of the unmanned aerial system (UAS). 

Pilot (PIC) and Observer minimum requirements: 

• Private Pilot Certificate required 

• Clean airman file to include no certificate or enforcement action, verified during 

interview process 

• Previous UAV experience (desired) 

• Knowledge of FAR’s, weather, good aeronautical decision making (ADM) 

Photographer/Videographer 

• Previous professional photographer/videographer experience required 

• Previous aerial photography experience (desired) 

• Private Pilot certificate (desired) 

Unmanned Aerial System (UAS) operating limitations: 

The DJI Inspire 1 will be operated in accordance with the manufacturers specifications and 

individually set limitations meant to exceed and enhance those outlined by the 

manufacturer and Federal Aviation Regulations (FARs). Our UAS will operate in VMC 

conditions at all times under Visual Line of Sight (VLOS) . Additionally we will operate at a 

speed of less than 87 kts. (100 mph) and below 400 feet AGL. We will prohibit operations 

over large populated areas, and refrain from operating in areas that pose a risk to life or 

property. No operations will be permitted in adverse weather to include winds in excess of 
10 mph. All unmanned aerial system (UAS) operations will be conducted by myself acting 

as the operator and a qualified visual observer (VO) 

I am requesting my petition for exemption be considered under the FAA 

Summary Grant which aims to streamline the exemption process by 

identifying our request as similar in nature to previously granted requests 

for unmanned aerial system (UAS) operations. 

Based on careful research and consideration of the types of systems and 

operations we wish to conduct, it is our belief we can operate safely and at 

no risk to the public while following all applicable Federal Aviation 

Regulations (FARs) and guidance for Unmanned Aerial Systems (UAS). It is 

our wish to be a model for UAS operation in the early stages of this 

technology for commercial use, and demonstrate its capability as a safe 

alternative to manned flight. 

Regards, 

_______________________ 

Joel M. Killingsworth 

Founder, DroneDogs