December 14, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washing ton, DC 20590 

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 and 

Part 11 of the Federal Aviation Regulations. 

Name and Address of Petitioner: 

Tirnothy A. Lilley 

PO Box 1482 

Savannah GA 31402 

912-507-1048 

TimothyLilley66@Gmail.com 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 

C.F.R. Part 11, Timothy A. Lilley, the Petitioner, request exemption from the following Federal Aviation 

Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace 

System. 

The Petitioner holds an Airline Transport Pilot Certificate Airplane Multiengine Land; Rotorcraft Helicopter 

Certificate number 3220309 

The Petitioner maintains a current Medical Certificate Second Class 

Regulations from which the exemption is requested: 

14CFR 21 H 

14 CFR 45.23 (b) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b) 

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) & (b) 

14 CFR 91.417 (a) & (b) 

The Petitioner wishes to be granted the exemption for use of the UAS of commercial operations list 

below. 

Applications and Operations: 

Aerial photography and video for; 

Real estate marketing 

Landscape photography 

Construction site inspections 

• Special event coverage 

Aerial survey 

• Promotional videos 

Cinematography 

The Petitioner believes the use of the UAS's is more economical and safer to use for the aforementioned 

purposes. Use of the UAS rather than a manned aircraft is more economical to the consumer, and 

beneficial to the general public due to its srnall size, low noise and minimal potential for accident. 

Characteristics of the Aircraft: 
The UAS to be used is the DJI Phantom 3 Pro 

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation Regulations: 

The Petitioner requests an exemption from the following regulations as well as any additional 

regulations that may technically apply to the operation of UAS's. 

14 CFR 21 H: Airworthiness Certificates 

Certification Procedures for Products and Parts 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness certificate as granted in 

Exemption No. 11623, 11650, 11664 and 11734. 

14 CFR 45.23 (b): Marking of the Aircraft 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXP=RIMENTAI..." in letters 

at least 2 inclies high near the entrance to the cabin, cockpit, or pilot station. 

Reason for Exception 

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have not entrance to the cabin, cockpit or pilot station on which the work "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 (t). 

The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 

and 10167A. 

14 CFR 91.7 (a): Civil Aircraft Airworthiness 

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy 

condition. 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness certificate, however the 

petitioner will ensure airworthiness through the combined use of the manufacture's Operations Manual 

and preflight checks. 

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

This regulation provides that no person may operate an aircraft unless a current, approved fiight manual 

is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual 

information is available to the aircrew while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry documentation; the documentation would 

not be available to the crew. 

Reason for Exception 

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. The FSS has issued the following 

exemptions to this regulation: Exemption #8607, 8737, 8738, 9299, 9299A to iist a few. 

14 CFR 91.103 (b): Preflight action 

This regulation requires each pilot in commend 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 petitioner will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before initiation of flight. 

14 CFR 91.121: Altimeter Settings 

This section requires that each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating below 

18,000 feet MSL. 

Reason for Exception 

Most UAS do not have a barometric altimeter. It does have a GPS that will calculate altitude. The 
Petitioner will limit flights to a maximum altitude of 400 feet AGL as granted in Exemption No. 11623 

11664, and 11734. 

14 CFR 90.151 (a) Fuel Requirements for Flight in VFR Conditions 

Fuel requirements for flight in VFR conditions: (a) No person may begin a fliglit 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. 

Reason for Exception 

The UAS provides a low battery warning to indicate when you should return the UAS to the launch point. 

In addition, a"low" and "critical" battery level warnings and implemented a"return to Home" (or "Go 

land") action in these situations. The Petitioner will not initiate a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and all flights will be conducted during daylight hours and at times not to be a nuisance to 

others. 

14 CFR 91.203 (a) &(b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

- No person may operate a civil aircraft unless it has an appropriate and current 

airworthiness certificate. 

- 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 19.715 

is displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

Reason for Exception 

To obtain an equivalent level of safety and meet the intent of 91.203, documentation will be housed at a 

ground control point where the pilot is flying the UAS for immediate access to the extent they are 

applicable to the UAS's. In doing some research the FAA has issued numerous exemptions to this 

regulation. 

14 CFR 91.405 (a): Maintenance Inspections 

Each owner or operator of an aircraft- (a) 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. 

Reason for Exception 

The Petitioner shall inspect the aircraft prior to every flight. The Petitioner also will follow the 

manufacturer's recommended preflight checklist and make any repair necessary before flights occur. 

The Petitioner will also maintain a log of any maintenance or repairs performed. 

14 CFR 91.407 {a) {1): Maintenance 

Operation after maintenance, preventative maintenance, rebuilding or alteration: (a) No person may 

operate any aircraft that has under gone maintenance, preventative maintenance, rebuilding, or 

alteration unless (1) it has been approved for return to service by a person authorized under 43.7 of this 

chapter. 

Reason for Exception 

The Petitioner who has the responsibility for the operation and safety of the UAS will follow the 

manufactures suggested replacement parts. 

14 FR 91.409 (a){I) & (2): Inspections 

Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had (1) an annual inspection in accordance with 

part 43 of this chapter and has been approved for return to service by a person authorized by 43.7 of 

this chapter; or (2) An inspection for the issuance of an airwor'thiness certificate in accordance with part 

21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for 

any inspection required by this paragraph unless it is performed by a person authorized to perform 

annual inspections and is entered as an "annual" inspection in the required maintenance records. 

Reason for Exception 

The Petitioner will follow manufacturer's suggestions to ensure that the UAS is in a condition for safe 

flight at all times. 
14 CFR 91.417 (a) &(b): Maintenance Records 

Except for work performed in accordance with 91.411 and 91.413 each registered owner or operator 

shall keep the following records (1)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)(vi) for the periods specified in paragraph (b) 

of this section: ( 1) (2) (3) 

Reason for Exception 

The Petitioner will keep a record of all repairs and modifications. The Petitioner also proclaims to use 

approved manufactured parts for all repairs and modifications. 

In Conclusion: 

I, Timothy A. Lilley, the Petitioner request for exemption from the above mentioned Federal Aviation 

Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace 

System for commercial purposes. The best safety practices and procedures wiil be followed while operating 

the DJ I Phantom 3 Pro. 

Sincerely, 

~ 

imothy A. Lilley 

PO Box 1482 

Savannah GA 31402 

912-507-1048 

TimothyLilley66@Gmail.com