George A. Mercer

523 S Gay Avenue

Callaway, FL 32404

Subject: Exemption Request Under Section 333 of the FAA Reform Act

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, I (George A. Mercer) an independent video 

and photographic service provider, hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of my 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(s) would permit myself to pursue commercial interests in 

providing services to clients using a small advanced sUAV in the following areas:

(a) Real Estate

(b) Marketing

(c) Special events

I affirm that all sUAS flights will occur over private or controlled access property 

and will do so with the property owners’ consent and knowledge and that only 

those individuals who have consented or otherwise agreed to be in stated area 

where such videography will take place.

Regulations from which exemption is requested:

(a) 14 C.F.R. Part 21

(b) 14 C.F.R. 45.23

(c) 14 C.F.R. 91.7

(d) 14 C.F.R. 91.9

(e) 14 C.F.R. 91.109

(f) 14 C.F.R. 91.119

(g) 14 C.F.R. 91.121

(h) 14 C.F.R. 91.151
(i) 14 C.F.R. 91.203

(j) 14 C.F.R. subpart E 91.401-91.417

Unmanned Aircraft System

sUAVs are often seen as superior to helicopters or ground based aerial 

photography systems (i.e. crane, bucket-truck) due to the smaller device, cheaper 

equipment, lower personnel costs, reduced noise, and much smaller environmental 

impact which promotes public safety.

I, George A. Mercer, am petitioning for an exemption to operate a DJI Phantom 2 

with built-in HD camera and GPS safety features which limits flight height 

capability (AGL), limits the distance of flight from its operator, and excludes the 

sUAS from operation within designated Class B, C, and D airspace including nofly zones feature. The DJI Phantom 2 also has failsafe function that is triggered in 

the event communication is lost beween the sUAS and the main controller 

transmitter. In the event of such transmission loss, the sUAS will return to its point 

of takeoff and land safely or within a distance to the operator that transmission and 

control can be regained.

These specifications meet with the Model Aircraft Operating Standards as set forth 

below:

a. The Pilot in Charge (PIC) will only operate the sUAS in line-of-sight of a pilot 

and will operate at sites that are sufficient distance from populated areas within a 

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”.

b. When flying the sUAS within five (5) 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.

c. Maximum flight time for each operation will be 30 minutes.

d. Flights will be terminated when battery levels reach 25%, allowing sufficient 

reserve flight time to safely land the sUAS.

e. The sUAS will be programmed so that 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.
f. Minimum crew for each operation will consist of: sUAS pilot (PIC)b.

g. The sUAS operated by the petitioner weighs less than 25 pounds, including all 

payload (i.e. camera, transmitter, stabilization gimbal).

h. The sUAS will operate at speeds no more than 50 knots, can hover, and can 

simultaneously move vertically and horizontally.

i. Given the small size of the sUAS and the restricted sterile environment with 

which it will operate, the petitioner’s operations will adhere to the Reform Act’s 

safety requirements.

Public Interest:

Granting this request would be in the public interest by offering an effective 

method of commercially offering real estate property and business advertising at a 

reduced cost to clients and a reduced intrusion to the general public by avoiding 

transportation and use of large, unwieldy equipment for the same purpose.

In conclusion, I respectively request exemption under Section 333 to enable myself 

to operate efficient, limited, low-risk commercial sUAS operations for the 

activities stated respecting at all times the space and privacy of the public and its 

property, while maintaining airspace safety.

Sincerely,

 /s/

George A. Mercer

523 S Gay Avenue

Callaway, FL 32404

850-215-4125

mercerg@comcast.net