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Kelly Williams November 13, 2015

162 Tesuque Village Rd

Santa Fe, NM 87506

Phone (505)-913-1094

Email: shutterlift@gmail.com

U.S. Department of Transportation Docket

Management System

1200 Ney Jersey Ave, SE

Washington, DC 20590

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

Federal Aviation Regulations

Dear Sir or Madam,

 In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012, I, Kelly Williams, herby 

apply for an exemption from the Federal Aviation Regulations listed below so that I, Kelly 

Williams, may operate UAS commercially in airspace regulated by the Federal Aviation 

Administration. Thank you in advance for your consideration.

I, Kelly Williams, hold a private pilot’s license (Certificate number 3255415) and have 

over 100 hours logged in full-size aircraft and have well over 100 hours of recreational and 

hobby use of my Align m690 Hexacopter , Wall-e 550 quad copter and Ranger EX. The love 

for aviation and film have invoked my desire to operate small unmanned aircraft systems 

commercially in airspace regulated by the Federal Aviation Administration for the 

purposes of aerial photography, cinematography, videography, mapping, crop surveying,

search and rescue, and inspections that can be performed safely and more cost effectively 

with the use of small UAS. Thereby I, Kelly Williams, request exemption from the following 

sections of Title 14, Code of Federal Regulations §§

The conditions identified and proposed by the petitioner are drawn from the references

below:

West Coast Aerial Productions – Exemption No. 13191 Docket ID: FAA-2015-3126

Kyle L. Hughes – Exemption No. 13177 Docket ID: FAA-2015-2684

Bryan Cherry- Exemption No.11405 Docket ID: FAA-2015-0118
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The specific sections of Title 14 of the Code of Federal Regulations from which Kelly 

Williams requests exemptions.

 14 CFR 21 subpart H

 14 CFR 61.113 (a) and (b)

 14 CFR 91.7 (a)

 14 CFR 91.9 (b)(2)

 14 CFR 91.109

 14 CFR 91.119

 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)

Kelly Williams seeks exemption from the above mentioned FARs for the following 

reasons:

14 CFR 21 (H): Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. 

While the FAA continues to work to develop airworthiness standards for Unmanned 

Aerial Systems, we request an experimental certificate be issued for the UAS under 

either or both of the following provisions: 21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft 

equipment, new aircraft installations, new aircraft operating techniques, or new 

uses for aircraft. (b) Showing compliance with regulations. Conducting flight tests 

and other operations to show compliance with the airworthiness regulations 

including flights to show compliance for issuance of type and supplemental type 

certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations.

Since the experimental certificate can be used for commercial purposes such as 

market surveys, sales demonstrations, and customer crew training, we would expect 

that an experimental certificate would permit our commercial purpose as well. The 

aircraft will not carry persons or property, will not carry fuel, and will only fly under 
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strict operational requirements. Combined with the UA’s light weight (being 

constructed primarily of carbon fiber, plastic and foam), I propose that the UA will 

be at least as safe, if not safer, than a conventionally certificated aircraft performing 

the same mission. If an experimental airworthiness certificate is not appropriate for 

this application, then I request an exemption of 14 CFR Part 21, Subpart H, and the 

requirement for an airworthiness certificate in general, citing the equivalent level of 

safety outlined in the previous paragraph.

14 CFR 61.113 (a) and (b): Private pilot privileges and limitations

The regulation provides that no person that holds a private pilot certificate may act as 

pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a 

private pilot to act as pilot in command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or employment; and (2) 

The aircraft does not carry passengers or property for compensation or hire.

I, Kelly Williams (PIC of UAS), have held a private pilot certificate since 2007

(Certificate number 3255415) and will operate the UA solely and with the utmost 

caution and safety. I, Kelly Williams, will take all I learned when getting my private pilot 

certificate and apply it to all UAS operations, following all regulations in place. 

14 CFR 91.7 (a): Civil aircraft airworthiness

The regulation states no person may operate a civil aircraft unless it is in an airworthy 

condition.

As the UA will not be issued an airworthiness certificate, an exemption should be 

granted. A very thorough preflight will be conducted prior to any flight by myself, Kelly 

Williams (PIC). Due to the size, slow speed, low altitude, and short flight times (15min) a 

close eye can be kept on the condition of the aircraft and components throughout the 

flight mission, providing a heightened level of safety.

14 CFR 91.119: Minimum safe altitudes

The regulation establishes minimum safe altitudes in which civil aircraft operate.

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 as well as a airplane 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 
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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 within a security perimeter.

An equivalent level of safety will be achieved given the small size, weight, and speed of 

the UAS as well as operation location. No UAS will fly without the express permission of 

the property owner or local officials. Due to the advanced notice and consent of property 

owners and participants in the filming/photographing activities, all individuals will be 

aware of the planned flight operations. Compared to flight operations with aircraft or 

rotorcraft weighing 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 CFR 91.121: Altimeter settings

This regulation requires each person operating an aircraft to maintain proper altimeter 

settings by setting altimeter to the current reported altimeter settings of a station along 

the cruise route or to the elevation of the departure airport. 

The UA will never fly above 400 feet AGL allowing no need to maintain cruising altitudes 

in order to prevent conflict with other aircraft. The UAS are equipped with barometric 

pressure sensors as well as a GPS altitude readout and an altitude ceiling warning 

system, providing a live feed back to the PIC. This, along with keeping the aircraft within 

visual line of site of PIC, will achieve an equivalent level of safety.

14 CFR 91.151 (a): Fuel requirements for flight in VFR conditions

This regulation provides no person may begin a flight in an airplane under VFR 

conditions unless there is enough fuel on board to fly to the first point of intended 

landing and assuming normal cruising speed to fly at least 30 minutes after that. 

The multirotor UAS are battery operated and have maximum flight times of 13 minutes 

leaving a 20% reserve on a single battery charge. The fixed wing Ranger EX UA has a 

maximum flight time of 45 min landing with 20% reserves. A live feed of battery voltage 

to the PIC will allow for constant monitoring of UAS flight battery voltage during flight. 

Since the air craft will never fly more than 1⁄2 mile from the point of intended landing, a

full battery charge at takeoff as well as monitoring battery voltage throughout the flight,

will ensure that the reserve energy requirements are met in the paragraph. 
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14 CFR 91.203 (a) and (b): Required certifications

This regulation prescribes that no person may operate aircraft without the appropriate 

airworthiness certificate. Subparagraph (b) states that the airworthiness certificate be 

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

Due to the small size and lack of pilot or crew on board, there would be no ability to 

carry certification and registration documents or space to display them on the UAS. An 

equal level of safety will be achieved by keeping these documents on the ground with 

the PIC and crew available for inspection upon request. 

 

14 CFR 91.405 (a), 14 CFR 91.407 (a)(1), 14 CFR 91.409 (a)(1) and (2), and 14 CFR 

91.417 (a) and (b):

These regulations require the owner/operator of an aircraft have the aircraft inspected 

as prescribed in paragraph (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 these sections and part 43 apply only to aircraft with an airworthiness certificate 

these sections will not apply. Maintenance will be accomplished by Kelly Williams in 

accordance with the flight manual and operating handbooks. An equal amount of safety 

will be achieved due to the small size, limited payloads and operating in appropriately 

safe areas with the consent and knowledge of the surrounding people for limited 

amounts of time, in addition to my intimate knowledge of the UAS and their operation.

UAS to be used:

Align 690: The Align m690 is a hexacopter configuration VTOL UA consisting of six rotating 

and counter-rotating props driven by six brushless electric motors. Payload for the Align 

m690 is a DSLR camera, gimbal and video downlink. Total weight including battery, camera 

and gimbal is 15lbs. Maximum flight time is 13 minutes landing with 20% reserves in the 

battery and maximum speed 30mph. It utilizes an internal inertial measuring unit (IMU) 

with integrated barometric sensor augmented with global positioning system (GPS) to 

maintain its geospatial orientation and position. It is controlled by a 2.4Ghz FCC certified 

14-channel radio, manufactured by Futaba, the leading manufacture of RC radios, giving 

the PIC complete control of the aircraft.

In the unlikely event of signal loss from the pilot, the Align m690 will stop moving in flight 

and hold position for 10 seconds while attempting to reestablish a connection with the 
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pilot. If connection is not obtained the UA will initiate a Return To Home (RTH) maneuver 

by lifting up 15 feet, flying back to the takeoff point and landing safely. 

The Align 690 has a live video downlink providing a visual of what the camera sees and 

providing and overlay of the aircraft’s flight parameters including altitude (AGL), satellite 

count, horizontal velocity, vertical velocity, relative direction of aircraft from takeoff point

and battery voltage. 

Wall-e 550: The Wall-e 550 is a quadcopter configuration VTOL UA consisting of four 

rotating and counter-rotating props driven by four brushless electric motors. Payload for

the Wall-e 550 is a GoPro camera, gimbal, secondary CCTV camera, and video downlink. 

Total weight including battery camera and gimbal is 7lbs. Maximum flight time is 15 

minutes landing with 20% reserves in the battery and a maximum speed of 30mph. It uses 

X Aircraft Mini X flight computer that utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to maintain 

its geospatial orientation and position. It is controlled by a 2.4 GHz FCC certified 14-

channel radio, manufactured by Futaba. In the unlikely event of signal loss from the pilot 

the Wall-e 550 will stop moving in flight and hold position for 10 seconds while attempting

to reestablish a connection with the pilot. If connection is not obtained, the UAS will initiate 

a Return To Home (RTH) maneuver by lifting up 25 feet and flying back to the takeoff point, 

landing safely. 

The Wall-e 550 has a live video downlink providing a visual of what the camera sees and 

providing an overlay of the aircraft’s flight parameters including altitude (AGL), satellite 

count, horizontal velocity, vertical velocity, relative direction of aircraft from takeoff point

and battery voltage.

Volantex Ranger EX: The Ranger EX is a fixed wing aircraft to be used primarily for aerial 

surveying of land. The payload for the ranger is a Gopro camera on a gimbal, secondary 

CCTV camera and video downlink. Takeoff weight is 6.5 lbs. with a wing span of 77.9 

inches, with a max flight time of 45 minutes, landing with 20% reserves in the battery and 

max speed of 45 mph. I will use the Eagle Tree Vector flight computer that utilizes an 

internal inertial measuring unit (IMU) with integrated barometric sensor augmented with 

global positioning system (GPS) to maintain its geospatial orientation and position. It is 

controlled by a 2.4 GHz FCC certified 14-channel radio, manufactured by Futaba. In the 

unlikely event of signal loss from the pilot, the Ranger EX will fly back to the point of 

takeoff. Once in signal range the pilot can override the failsafe and land the aircraft safely.

The Ranger EX has a live video downlink providing a visual of what the camera sees and 

providing an overlay of the aircraft’s flight parameters including altitude (AGL), satellite 

count, horizontal velocity, vertical velocity, relative direction of aircraft from takeoff point

and battery voltage.
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The Align m690, Wall-e 550 and Volantex Ranger EX will be operated by myself, Kelly 

Williams, and will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 

14 C.F.R. Part 45, Identification and Registration Marking.

Risk mitigation

I, Kelly Williams, will follow all current and upcoming rules and regulations regarding UAS

provided by the FAA. As a private pilot myself and the son of an ATP commercial pilot with 

a CFII, I know the safety precautions and procedures for flying aircraft and will apply my 

knowledge and practices to all UA operations. I will perform a thorough preflight prior to 

any takeoff and check not only surface weather conditions, but space weather conditions 

for solar activity as well, which can degrade RF reception and GPS accuracy and will not fly 

if there is a KP index higher than 5. No Flight operations will occur one hour after sunset or 

one hour before sunrise or in densely populated areas. If wind speeds are higher than 15 

mph the aircraft will be grounded. Flights will only take place in VFR conditions with no 

less than 3⁄4 mile visibility and will never operate in Class B, C, or D airspace without 

written approval from the FAA. 

Airworthiness will be maintained by performance of routine inspections before and after 

each flight and by maintaining flight and maintenance logs to record time on failure -prone 

components. 

Public benefit 

Aerial photography and videography has been used for decades using helicopters or fixedwing aircraft carrying people and explosive fuel. These methods have limitations and 

dangers that small UAs do not, as well as being very expensive to operate and hire.

The Align m690, Wall-e 550 and Volantex Ranger EX are battery-powered and serve as a 

safe, efficient, and economical alternative to manned aircraft traditionally used to obtain 

aerial imagery. By reducing the amount of large manned aircraft needed to preform aerial 

acquisitions, an exemption allowing the use of the Align m690, Wall-e 550 and Volantex 

Ranger EX UAS would reduce the amount of manned aircraft in the NAS, reduce noise and 

air pollution and increase the safety of life and property in the air as well as on the ground.

In addition to being safe and efficient, the UAS are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such operation of the Align m690 

,Wall-e 550 and Volantex Ranger EX will allow United States citizens like myself to 
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contribute to the growth of the U.S. economy, specifically, with the rising cost of aviation

fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative

technology in order to remain competitive. Operating the battery-powered Align m690, 

Wall-e 550 and Volantex Ranger EX UAS incorporate technology that not only allows

companies greater operational flexibility compared to manned aircraft, but provides such

flexibility without the high operational cost of a traditional manned aircraft. In addition, the 

low operating cost of UAS will allow the opportunity for all business and individuals, small 

and large to afford the use of aerial services thought not to be obtainable. 

By operating the Align 690, Wall-e 550, Volantex Ranger EX UASs, Individuals such as

myself, Kelly Williams, can remain competitive and profitable, and therefore, contributing 

to growth of the U.S. economy.

 

Conclusion

This petition for exemption satisfies the criteria articulated in the section 333 of the 

reform act of 2012 including weight, speed, operating capabilities, proximity to airfields

and populated areas, operation within visual line of site and national security, provide 

more than adequate justification to grant the requested exemptions allowing 

commercial operations of UAS by Kelly Williams in the NAS. I, Kelly Williams, hold a

private pilot certificate (Certificate number 3255415) and a third-class medical, and

exercise the utmost safety and concern when operating any aircraft, UAS and manned,

and will be able to provide services to the public in a safe and cost effective manner in 

compliance with all FAA regulations in place and upcoming.

I thank you for your time and consideration,

Sincerely,

Kelly Williams

Kelly Williams 

162 Tesuque Village Rd

Santa Fe, NM 87506

Phone (505)-913-1094

Email: shutterlift@gmail.com