August 3, 2015

Robb Stan.

President, MyitownTv, Inc.

5600 Trail Blvd, Suite 2

Naples, Florida 34108

FAA

Docket Management Facility

U.S. Department of Transportation

1200 New Jersey Avenue, SE

West Building, Ground Floor, Room W12-140 Washington, DC 20590

To whom it may concern, Re: Docket Number FAA-2015-0150

Let me start by giving a brief description of myself. I am a 58 year old married

man, and I consider myself a professional adult and a responsible member of the community. 

I am hoping to take piloting an unmanned aerial system beyond the point of

hobby and into a professional occupation. I have spent the past 33 years of my life in the

field of video production. I am part owner of MyitwonTV Inc., in Naples, FL. MyitownTV is a 

full service video production company. Our client list includes some of the areas most 

prestigious businesses and nonprofit organizations. Most of our clientele are long time 

customers.

Currently, I am in the process of launching a visitors information network and website, 

SWFLTV.

Personally I have purchased a DJI Phantom 3 and have flown it, legally, for many hours and 

feel very experienced with it. I have permission from several of our local government 

agencies to take aerial video and photographs of Collier County and Naples amenities and 

share them on our network and website. Aerial footage of our beaches has been a very 

popular subject.

So far, all of the aerial images that I have captured have been pro-bono. I now realize that 

the quad-copter has great potential for being a valuable business tool. Besides adding a 

unique perspective to the videos we produce for the SWFLTV network it would also provide 

us with an additional production tool to use on our commercial video shoots. 

Another industry that would benefit from our aerial video and photography services is the 

Southwest Florida real estate industry. I have noticed numerous Realtors are using photos 

and videos taken with drones in their listings. I believe my company could take their imagery 

to a whole new level because of my many years of experience in the video production 

industry. We could also enhance their videos including stock footage that we accumulate 

from our SWFLTV network.
I have discovered that it is difficult and confusing of doing it professionally because the rules 

had have not been clear or written. I kept checking back periodically and eventually found my 

way here. If my company was to receive a grant of exemption, I would be the registered pilot 

on record. Along with managed contracting services with qualified operators.

If my company is granted an exemption, I will have accumulated many more hours of flight 

time with the UAS.I will begin the petition for exemption below:

To the Federal Aviation Authority (FAA), I hereby request exemption from part 21, subpart H; 

and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 

91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) 

and (b) of Title 14, Code of Federal Regulations (14 CFR).

I support my request with the following information: I plan to operate a UAS, the DJI 

Phantom 3, which is comprised of an unmanned aircraft and a transportable ground station. 

The Phantom 3 is referred to as a quad-copter with a maximum gross weight of about 1280 g. 

It is equipped with four rotors that are driven by electric motors powered by a battery. The 

UA has a maximum airspeed of 16 m/s. The quad has a built in high definition camera. I plan 

to operate the UA over various areas near Southwest Florida to enhance our tourism videos, 

commercial video productions and real estate videos and photographs. I make the following 

representations of operational enhancements which I propose to abide by to ensure this 

exemption will provide a level of safety at least equal to existing rules:

• I will only operate in reasonably safe environments that are strictly controlled, are away 

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

• I will conduct extensive preflight inspections and protocols, during which safety carries 

primary importance. 

I state that given the size, weight, speed, and limited operating area associated with the 

aircraft to be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness 

Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions 

and limitations, is warranted and meets the requirements for an equivalent level of safety 

under 14 CFR part 11 and Section 333 of P.L. 112-95 (Section 333).

I request an exemption from § 45.23 Marking of the aircraft because his UA will not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, I state that 

two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. Regardless of this, I state that I will mark his UAS in the 

largest possible lettering by placing the word “Experimental” on its fuselage as required by § 

45.29(f) so that he or anyone assisting him as a spotter will see the markings.

I state that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and 

(b) Maintenance inspections may be required and should be granted since they only apply to 

aircraft with an airworthiness certificate. However, I state that as a safety precaution I will 

perform a preflight inspection of his UAS before each flight as outlined in my operating 

documents.

UAS Pilot in Command (PIC)

I assert that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, 

however I can achieve an equivalent level of safety as achieved by current regulations 

because my UAS does not carry any pilots or passengers. Further, I state that, while helpful, 

a pilot license will not ensure remote control piloting skills. I further indicate that the risks of 

operating a UAS are far less than the risk levels inherent in the commercial activities outlined 

in 14 CFR part 61, et seq., thus I request an exemption from § 61.113 Private Pilot Privileges 

and Limitations: Pilot in command.

Regarding UAS operational training, I have flown numerous practice flights in remote areas 

as a hobbyist simulating flights for future commercial use to gain familiarization with the 
characteristics of his UAS’ performance under different temperature and weather conditions. 

I have also practiced computerized simulated flights to maintain adequate skills and 

response reflex time. In a supplemental request to the FAA, I request consideration of a 120 

day temporary airman certificate in accordance with § 63.13, to allow time to obtain a private 

pilot certificate or to allow the FAA time to establish minimum UAS airman certification 

standards.

UAS Operating Parameters 

I will abide by the following additional operating conditions under this exemption:

• operate my UAS below 400 feet and within a radius distance of 1000 feet from the 

controller to both aid in direct line of sight visual observation; 1

• operate the UAS for 3-7 minutes per flight;

• land my UAS prior to the manufacturer’s recommended minimum level of battery power;

• operate my UAS only within visual line of sight (VLOS);

• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers and 

then slowly lands if communication with the remote control pilot is lost;

• conduct all operations under my own personal and flight safety protocols (including posting 

a warning sign reading: “Attention Aerial Photography in Progress – Remain Back 150 feet”) 

contained in the operating documents and will actively analyze flight data and other sources 

of information to constantly update and enhance my safety protocols;

• contact respective airports if operations will be within 5 miles to advise them of my 

estimated flight time, flight duration, elevation of flight and other pertinent information;

• always obtain all necessary permissions prior to operation; and

• have procedures in place to abort flights in the event of safety breaches or potential danger. 

I note that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I 

assert that since there is currently no certificate applicable to my operation, this regulation is 

inapplicable.

I note that § 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there 

are no pilots or passengers on board his aircraft and given its size, this regulation is 

inapplicable. I further indicate an equivalent level of safety will be achieved by maintaining a 

safety/flight manual with the UAS ground station.

I note that § 91.119 prescribes safe altitudes for the operation of civil aircraft, but that it 

allows helicopters to be operated at lower altitudes in certain conditions. I state that I will not 

operate his UAS above the altitude of 300 feet above ground level (AGL) and will also only 

operate in safe areas away from the public and traffic, thus “providing a level of safety at 

least equivalent to or below those in relation to minimum safe altitudes. I assert that given 

the size, weight, maneuverability, and speed of my UAS, an equivalent or higher level of 

safety will be achieved.

I note that § 91.121 Altimeter settings is inapplicable since my UAS utilizes electronic GPS 

with a barometric sensor.

Public Interest

I state that aerial videography and photography for geographical awareness and for real 

estate marketing has been around for a long time through manned fixed wing aircraft and 

helicopters, but for small business owners, its expense has been cost-prohibitive. Granting 

this exemption to myself and my company would allow me to provide this service at a much 

lower cost.

Further, I would like to indicate my small UAS will pose no threat to the public given its small 

size and lack of combustible fuel when compared to larger manned aircraft. I

would also like to state that the operation of my UAS will minimize ecological damage

and promote economic growth by providing information to companies or individuals

doing business in the Southwest Florida region.

Conclusion

I would like to conclude by saying thank you for your consideration and time reading this

petition. This has been a desire of mine since quad copters became available to the
public. I have only flown as a hobby to not break any laws until with hopes to become

commercial. I see nothing but positive coming from it from this new technology. Tourism and 

real estate are two of Southwest Florida's largest industries. Our area would benefit from us 

sharing it's beautiful landscapes and the realtor would have an advantage because of a 

much clearer view of properties. The consumer gets a better overall look at things. My 

company would get to share new technologies and be a pioneer in this virtually new field of 

photography. All along the way, the federal government collects taxes from all of us. The 

economy benefits with very little risk of accidents and/or damages from these flyovers.

Thank you again. Very respectfully, Robb Stan