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

Reform Act and Part 11 ofthe Federal Aviation 

September 11, 2015 

Craig Dimmitt 

25614 Ave 220 

Lindsay, CA 93247 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a) and (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) and (b); 14 CFR 

91.405 (a); 14 CFR 91.407 (a) (1) 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417(a) and (b) 

Dear Sir or Madam: 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the ' 6

Refomt Act") 

and 14 CFR Part 11, Craig Dimmitt, operator of Unmanned Aircraft Systems (UAS), hereby applies for an 

exemption from the listed Federal Aviation Regulations ("F ARs") to allow commercial operation of designated 

UAS, provided such· operations. :are~ conducted-within· ·and under. the· 'conditions- outlined herein or as may be 

establishedbytheFAAastequiredbySection3g3. ~~ .. ,.,.,,~,r .. ::!::x~.:, • '·': '' ··· • 

Thank you in advance for your consideration. • T • ~ ·, ~ ~- • ·., 

Commercial operation of a UAS, as described herein,· which will be equipped with cainera(s) and i or· sensors, w'ould 

provide professional services in the following areas: 

1. Aerial photography and/or video for public and/or private use including real estate, architecture, land surveying, 

engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public events, newsgathering, 

and at the request I permission of local authorities, accident and crime scene investigation. 

3. Aerial inspection/photography of residential/commercial structures under contract with the owners or local 

government authority. 

4. Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to 

electrical power lines, wind turbines and cell towers. 

5. Aerial video/photography or providing live video feed to assist with search and rescue opcra:tiorts iti cases·of an 

emergency or natural disaster only when the local authorities or government has requested it by contract or donation. 

As described fully below, the requested exemption would permit the operation of designated UAS as set forth in this 

document under controlled conditions in the NAS that would be a) Limited, b) controlled; c).predetermined, and d) 

..... · .. · ·,, '.) . '.·.·.· i ; 

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safe. Approval of this exemption would increase public awareness of UAS operations and enhance safety to aid in 

fulfilling the Secretary of Transportation's (the FAA Administrator's) responsibilities to " .... establish requirements 

for the safe operation of such aircraft systems in the national airspace system." 

The name and address of the applicant is: 

Craig Dimmitt 

Address: 25614 Ave 220, Lindsay, CA 93247 

Ph: 559-359-8331 

Email: cdquad15@gmail.com 

Regulations from which the exemption is requested: 

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 91.417 (a) & (b) 

Craig Dimmitt will operate the following model UAS: 

3D Robotics Iris+, specifications shown here: 

PRODUCT SPECIFICATIONS 

• 3DR Iris+ 

o Flight Time 

o Up to 22 Minutes 

o Height 

o 210mm (8.25 in) 

o Width Without Rotor Blades 

o 413mm (16.25 in) 

o Diagonal Length Without Rotor Blades 

o 491mm (19.35 in) 

o Propeller Diameter 

o 241mm (9.5 in) 

o Weight Without Battery and Payload 

o 962g (34.0 oz) 

o Battery 

o 5100mAh 3S ll.lV LiPo (included) 

o Charger 

o 3S ll.lV LiPo DC Balancing Smart Charger with AC Adapter 

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o Transmitter 

o 8channel 

2.4GHz 

o 3 Flight Modes 

o Standard, Loiter, & Return to Launch 

o Maximum Flying Height 

o Default 400 Feet Above Ground Level 

o Takeoff Weight With Battery and Max Payload 

o 1600g (56.4 oz) 

o Radio Control Frequency Band 

o 2.4GHz 

Camera I Gimbal System 

o Camera 

o GoPro Hero 4 

o Video Resolution 

o FULL HD lOSOp Adjustable 

60, 50 or 48 FPS 

o Photo Resolution 

o 12 Megapixels 

o Working Temperature 

o 0°C to 50°C 

o Storage (memory) 

o microSD Class 10 ~ 4 to 64GB 

o Height 

o ll5mm (4.5 in) 

o Weight 

o 283g (10.0 oz) 

o Depth 

o 135mm (1.4 in) 

o Width 

o 74mm (2.9 in) 

Given the small size of the UAS in scope and the controlled environment provided, the proposed operations will 

adhere to the, Reform Act's safety requirements. The approval of this application presents no national security issues. 

Regarding the level of safety surrounding the proposed operations and the public benefit, reduction in environmental 

impacts, including but not limited to reduced emissions and noise, the grant of the requested exemption is in the 

public interest. Accordingly, the applicant graciously requests that the FAA grant the requested exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The operation limitations proposed for an equivalent or higher level of safety because operations will further 

enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to 

which the applicant agrees to adhere to when conducting commercial operations under the FAA issued exemption as 

set forth in the Flight Operations Manual (FOM) include: 

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with battery and camera. 

2. The UAS will have a maximum operating speed of no more than 25 mph. 

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3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual Observer (VO). 

4. Maximum flight time for each operational flight will be depending on the UAS model in operation, but will not 

exceed 15 minutes. Flights will be terminated at 25% battery power reserve or 15 minutes of flight time whichever 

occurs first. 

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL). 

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual Observer (VO). 

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have logged a minimum of20 hours on 

the designated UAS. The PIC, Craig Dimmitt, holds a Commercial Pilot's License, No. 1957612. 

8. A safety briefing will be performed prior to each flight consisting of the production activities. 

9. All flight activities will be logged. 

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only. 

11. The flights will occur in Class G airspace no closer than a Smile radius of the geographic center/ Airport 

Reference Point (ARP) of a tower controlled or uncontrolled airport. 

12. The operator will obtain verbal/written consent of all persons involved with the planned operation and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation. The radius may be reduced to 

30 feet based upon an equivalent level of safety determination, as required by the U.S. Department of Transportation 

under the FOM. With the advanced permission of the FSDO, operations at closer range may be approved. 

13. The PIC and VO will have been trained in operation ofUAS and receive up to date information for the particular 

U AS to be operated. 

14. The PIC and VO will be able to communicate by voice and/or radio at all times. 

15. Written and/or verbal permission and permits will be obtained from territorial, state, county or city jurisdictions, 

including law enforcement, fire or other appropriate governmental agencies as appropriate to flight operations. 

16. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the 

capability to return to a predetermined location within a designated location and land autonomously. 

17. The UAS will have the capabiiity to abort a flight in case of emergencies with an automated "Return to Launch,_ 

function. 

18. The UAS will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies such 

as low battery. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness 

Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR 

§91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, 

an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration 

of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular 

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UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor 

passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and 

designated area. 

Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety requirements. These safety 

enhancements provide a greater degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these 

same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry 

a substantial external load. 

14 C.F.R. § 45.23 (b).Marking ofthe Aircraft: The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted 

or light sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on 

that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2inche's nor mOte than 6 

inches high, the words "limited," "restricted," "light sport", "experimental," or "provisional," as applicable. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft: The regulation requires: When marks include only the Roman capital 

letter "N" and the registration number is displayed on limited, restricted or light sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance 

to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words 

"limited," "restricted," "light sport," "experimental," or "provisional," as applicable. Even though the UAS will have 

no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or 

pilot station on which the word "Experimental" can be placed. Given the size of the UAS, two inch lettering will be 

impossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). US Department 

of Transportation February 20, 2015 The equivalent level of safety will be provided by having the UAS marked on 

its fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS will see the 

identification of the UAS as "Experimental." 

14 C.F.R. § 61.113 (a) and (b): 

Private Pilot Privileges and Limitations: Pilot in Command. Pursuant to 14 CFR 61.113 (a) & (b), no person who 

holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property 

for compensation or hire. The proposed UAS operations may achieve an equivalent level of safety as achieved by 

current Regulations because the applicant's UAS do not carry any pilots or passengers or property. The risks 

attendant to the operation ofUAS is far less than the risk levels inherent in the commercial activities outlined in 14 

CFR 61. The PIC of the U AS will be, or be under the direct supervision of, a FAA Certificated Private Pilot with 

current Third Class or higher medical certificate. It is believed that the operation and limitations set forth in the FOM 

will equate to the safe operation of the UAS. 

14 C.F.R. §91.7(a): Civil Aircraft Airworthiness. The regulation requires that no person may operate a civil aircraft 

unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this 

exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the 

aircraft for maintenance and use of safety checklists prior to each flight, an equivalent level of safety will be 

provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may 

operate a U.S. registered civil aircraft ... (2) For which an Airplane or Rotorcraft Flight Manual is not required by 

§21.5 of this chapter, unless there is available in the aircraft a current app::.-oved airplane or Rotorcraft Flight Manual, 

approved manual material, markings, and placards, or any combination thereof. The UAS, given its size and 

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configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot 

on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of 

safety will be maintained by keeping the flight manual at the ground control point where the pilot flying the UAS 

will have immediate access to it. 

14 C.F .R. § 91.1 03: Preflight Action. This regulation requires each pilot in command to take certain actions before 

flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an 

exemption will be needed. The PIC will take all actions as stated in the FOM in Section 4 under Normal Procedures 

including but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight 

14 C.P.R. §91.109: Flight Instruction. Section 91.103 provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. 

UAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio communications. The 

FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and 

for flight instruction in experimental aircraft. The equivalent level of safety is provided by the fact that neither a pilot 

nor passengers will be carried in the aircraft and by the size and speed of the airctaft. ---·- ·--~··-------

14 C.P.R. §91.119: Minimum Safe Altitudes. Section 91.119 establishes safe altitudes for operation of civil aircraft. 

Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this 

exemption is for a UAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption may be needed 

to allow such operations. As set forth herein, the UAS will never operate at higher than 400 AGL with the exception 

that in circumstances where the UAS is used to survey or photograph a structure whose height exceeds 400 feet 

AGL, the UAS will not be operated more than 200 feet above the highest point on the structure. It will however be 

operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, and speed 

of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, 

all affected individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or 

rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft operating at or 

below 500 AGL. In addition, the low altitude operations of the UAS will ensure separation between these UAS 

operations and the operations of conventional aircraft that must comply with Section 91.119. 14 C.F .R. 

§91.121 Altimeter Settings. This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set" ... to the elevation of the depatture airport or an appropriate altimeter setting 

available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

U.S. exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the safety 

check list and live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight. 

14 C.P.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions Section 91.151 (a) prohibits an individual 

from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed -

(1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

Operating the UAS in a tightly controlled area where only people and property owners or official representatives 

who have signed waivers will be allowed does not engender the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS. The applicant believes that an equivalent level of safety can be 

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achieved by limiting flights to 16 minutes or 25% of battery power - whichever happens first. This restriction is 

more than adequate to return the UAS to its planned landing zone from anywhere in its limited operating area. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in 

pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following: (1) An appropriate and current airworthiness certificate .... (b) No person may operate a civil aircraft 

unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued 

under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The UAS fully 

loaded weighs well under the proposed 55lb limit and is operated without an onboard pilot. As such, there is no 

ability or place to carry certification and registration documents or to display them on the UAS. An equivalent level 

of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS 

will have immediate access to them, to the extent they are applicable to the UAS. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These regulations require that 

an aircraft operator or owner "shall have that 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 ... ," and others shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness~certificate;""'lhese sections w1H not 

apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating 

handbook. An equivalent level of safety will be achieved because the UAS is very limited in size and will carry a 

small payload and operate only in restricted areas for a limited period of time. If mechanical issues arise the UAS 

can land immediately and will be operating from no higher than 400 feet AGL. The operator will ensure that the 

UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance 

performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. An equivalent level of safety will be 

achieved because maintenance and inspections will be performed in accordance with the UAS Manufacturer's User 

Manual. As provided in the FOM, the operator will ensure that the UAS is in working order prior to initiating flight 

and perform required maintenance needed. 

Additional Information. 

The applicant, Craig Dimmitt, believes this exemption request and associated safety considerations adequately 

satisfy criteria provided in Section 333 of the Reform Act of2012, providing sufficient justification for the granting 

of commercial operations ofthe applicant's UAS. 

The applicant, Craig Dimmitt, requests your respective approval of this Section 333 exemption petition. 

Thank you for your interest and attention in this matter. Please notify Craig Dimmitt of your decision. 

Sincerely, 

Craig Dimmitt 

25614 Ave 220 

Lindsay, CA 93247 

cdquad 15 @gmail.com 

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