U.S. Department of 

Transportation Docket 

Management System

1200 New Jersey 

Ave., SE Washington 

DC20590

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

Regulationsfrom: 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)

To whom it may concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part 11,

Douglas Glen Thompson, operator of an Unmanned Aircraft System (UAS), hereby applies for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of UAS, so long as such operations are 

conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section

333.

Name and Contact Information of Applicant:

Douglas Glen Thompson

3465 Fort Avenue. APT 112

Lynchburg, VA. 24501

(434)382-9216

DGThompson7@yahoo.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)

Scope of Operations:

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and sensors, would operate in 

the following manner:

 Aerial video/photography/inspection or providing live video feed to assist with search and rescue

operations/damage assessment in cases of an emergency or natural disaster when local authorities/private 

individuals/organizations or government has requested it by contract or donation.

 The ability to offer training to persons individually or belonging to both private and/or public 

organizations that have interests in the use and application of a UAS for the purpose of the safe 

operation of a UAS to enhance the safety of the National Airspace System (NAS) as well as for the 
protection of the persons and property.

 Aerial inspection/photography of residential/commercialstructures under contract with the owners or 

local government authority.

 Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines and cell towers.

As detailed below, the requested exemption would permit the operation of a UAS under controlled conditions in the NAS

that would be a) limited b) controlled c) and will provide safety enhancementsto the already safe operationsin the industry 

presently using conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill 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.

UAS to be used:

Douglas Glen Thompson will operate the DJI Phantom series of remote control model aircraft. Specifically the Phantom 

1 v.1.1.1, Phantom 2 Vision +, and Phantom 3 Advanced/Pro. (Note: All Phantom models are based upon the same 

airframe and control technology with similar specifications and performance.) As well as the DJI Inspire 1.

UAS Model Specifications

Phantom 1 Phant. 2 Vision Phantom 3 Inspire 1

Weight (w/ Batt. And 1250g 1242g 1280 g 2935 g

Diagonal Size (motor- 350mm 350mm 350mm 581 mm

Max Ascent Speed 6m/s 6m/s 5 m/s 5 m/s

Max Descent Speed 6m/s 2m/s 3 m/s 4 m/s

Max Speed 10m/s 15m/s 16 m/s 22 m/s

Operating Temperature 0°C-50°C 0°C-40°C 0°C - 40°C 0°C - 40°C

Operating Freq. Band 2.4 GHz 5.8 GHz 2.4 GHz 2.4 GHz

Battery 2200 mAh 5200 mAh 4480 mAh 4500 mAh

Manufacturers Operating Manuals:

Phantom 1 v.1.1.1 Manual

http://download.dji-innovations.com/downloads/phantom/en/PHANTOM_Advanced_Manual_en.pdf

Phantom 2 Vision + Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manual_v1.

8_en.pdf

Phantom 3 Advanced/Pro Manual

http://download.dji-innovations.com/downloads/phantom_3/jp/Phantom_3_Professional_User_Manual_v1.0_jp.pdf

Inspire 1 Manual

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf
National Security

The small size of these UAS and the limited scale of operationsin conjunction with adherence to the Reform Act’s safety 

requirements present no national securityissues.

Public Interest

Services utilizing small UAS for aerial photography, videography, surveying, mapping, equipment inspections and 

auditing provides a much lower cost and higher level of safety to the public due to the small scale of aircraft relative to 

full scale aircraft operations.

Operational Safety Requirements

 The UAS will not be operated at a speed exceeding 50 mph.

 The UAS will be operated at an altitude of no more than 200 feet above ground level (AGL).

 The UAS will be operated within visual line of sight (VLOS) of the PIC at all times. Thisrequires 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.

 All operationsmust 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 operatoris responsible for maintaining and inspecting the UAS to ensure that it isin a condition for safe operation.

 Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight.

 PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will 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 PICisrated on his or her pilot certificate.

 No operations will be conducted at night, as defined in 14 CFR§ 1.1. All operations will be conducted under visual 

meteorological conditions (VMC).

 No operations will be conducted 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.

 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 beconducted.
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 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 certificatesissued

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 externalload.

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).

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. Douglas Glen Thompson may achieve an 

equivalent level of safety as achieved by current Regulations because the applicant’s UAS do not carry pilots, passengers, 

or property. The risks attendant to the operation of UAS is far less than the risk levels inherent in the commercial activities 

outlined in 14 CFR 61. The PIC of the UAS will have appropriate certifications as listed above in the operational safety 

requirements. I feel 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 AircraftAirworthiness.

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 check lists 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 

approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination

thereof. The UAS, given its size and 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. § 91.103: PreflightAction.

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 manufactures operatingmanuals.

14 C.F.R. §91.109: FlightInstruction.

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 smallsize and low speed of the aircraft.

14 C.F.R. §91.119: MinimumSafe 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 200 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 200 AGL with the exception that in circumstances where the UAS is used to survey or photograph a structure whose 

height exceeds 200 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-obtainedconsent.

The equivalent level of safety will be achieved given the size, weight, 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 participantsin any operational 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 AltimeterSettings.

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 departure 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 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.F.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 battery powering the UAS provides approximately 30 minutes of powered flight. To meet the 30 minute 

reserve requirement in 14 CFR §91.151, UAS flights would be limited to approximately 10 minutesin length. 

Given the limitations on the UAS’s proposed flight area and the location of its proposed operations within a

predetermined area, a longer time frame for flight in daylight or twilight VFR conditions is reasonable. 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, with less than 30 

minutes of reserve fuel, 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. Additionally, limiting UAS flights to 10 minutes would greatly reduce the utility 

for which the exemption will be granted. Applicant believes that an equivalent level of safety can be achieved by 

limiting flights to 30 minutes or 25% of battery power— whichever happens first. This restriction would be 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 providesin 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 no more than 55 lbs. 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 section and Part 43 apply only to aircraft

with an airworthiness certificate, these sections will 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 200 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.
This application for exemption respectfully submitted by: 

Douglas Glen Thompson

3465 Fort Avenue. APT 112

Lynchburg, VA. 24501

(434)382-9216

DGthompson7@yahoo.com