Geoffrey P. Armstrong

6617 Peppermill Dr

Las Vegas, NV 89146

(702) 569-8975

silverado595@gmail.com

Dear Sir or Madam: 

This petition is being submitted on my behalf without legal counsel or consulting services. 

I am a Commercial, Instrument Rated FAA Helicopter and Airplane Pilot, Certificate # 2932656

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 

11, Geoffrey P. Armstrong, an FAA rated Helicopter and Airplane Commercial Instrument Pilot and freelance 

multimedia producer, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below 

to allow operation of our Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

The requested exemption would permit Geoffrey P. Armstrong to pursue his commercial interests in providing 

services to clients using a small advanced sUAV in the following areas: Real Estate, Marketing, Land Management/

Surveying, and Special Events. Geoffrey P. Armstrong states that all sUAS flights will occur over private or 

controlled access property and will do so with the property owner's consent and knowledge and that only people 

who have consented or otherwise have agreed to be within the UAS’ radius during filming and photography 

applications.

Geoffrey P.Armstrong has demonstrated the ability to safely and effectively fly the sUAS DJI S900 which will be 

used for all commercial and private purposes. Geoffrey P.Armstrong complies with local ordinances and laws 

regarding the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in 

reference to the operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy.

I, Geoffrey P. Armstrong, am seeking the exemption because I am committed to complying with all of the rules, 

guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the manner that I 

have described, and for the purposes that I have described. Without the exemption request granted, I would be 

unable to safely and effectively run my business, and it is my intention to comply with the FAA and obtain an 

exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of 

responsibilities I assume as operator; it also contains information regarding the aircraft, public benefit and safety 

features, and similar petitions requests granted.

Regulations from which exemption is requested: 

14 C.F.R. Part 21 

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. 91.109 

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) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

1. Operations authorized by this grant of exemption are limited to the DJI S900 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 4 limitations in this exemption and the procedures

outlined in the operating documents, the conditions and limitations herein take precedence and must be followed.

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. 5

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 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. 6

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 (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.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 

11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering platform 

due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller 

environmental impact which promotes public safety. 

Geoffrey Armstrong is petitioning for an exemption to operate a DJI S900 with a built-in stabilized HD camera and 

GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of 

the distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace 

including a no-fly zone feature. 

The DJI S900 also has a failsafe function that is triggered in the event communication is lost between the sUAS and 

the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If the 

connection is restored, the PIC can regain control of flight and land manually. 

These specifications meet with the Model Aircraft Operating Standards as set below: 

 The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will operate at sites that are

`sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations will ensure

that the sUAS will "not create a hazard to users of the national airspace system or the public."
 When flying the sUAS within three (3) miles of an airport, airport operators will be notified and the operator will

give the right-of-way to avoid flying in the proximity of full-scale aircraft. Maximum flight time for each operation

will be 30 minutes.

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the

sUAS.

 The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not more

than 200 feet above an elevated platform from which videography is planned.

 Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer, and the camera operator.

 The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate.

 The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and

stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically and

horizontally.

 Geoffrey P. Armstrong being a licensed FAA Helicopter and Airplane Commercial Instrument rated Pilot will 

follow and adhere to the Reform Act's safety requirements. 

If you have any question or need additional information, please contact me at

silverado595@gmail.com or (702) 569-8975

Thank you

Geoffrey Armstrong