Federal Aviation Administration Exemption

Petition for Exemption under Section333

FAA Modernization and Reform Act of 2012

Submitted by: Kevin W. Glenn

2913 Palace Place

Murfreesboro, TN 37129
Contact Information

Kevin W. Glenn

2913 Palace Place

Murfreesboro, TN 37129

Cell #: 615-427-2609

Email: kglen08@comcast.net

Dear Sir or Madam:

I am writing pursuant to the FAA Modernization and Reform Act of2012 (the 

"Reform Act") and the procedures contained in 14 C.F .R. 11, to request that Kevin 

W. Glenn, owner and operator of a small UAS, be exempted from the Federal 

Aviation Regulations (FAR's) listed below. The exemption is needed in order to 

operate a small lightweight unmanned aircraft system (UAS) commercially in 

airspace regulated by the Federal Aviation Administration (FAA). These operations 

will be conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.§11.81.
Stipulating that these small drones are Ultralight aircraft, many of the rules and regulations necessary to keep 

a separation from other manned aircraft are already in effect.

1. No person may operate an ultralight vehicle except between the hours of sunrise and sunset. 

2. Notwithstanding paragraph (1) of this section, ultralight vehicles may be operated during the twilight 

periods 30 minutes before official sunrise and 30 minutes after official sunset or, in Alaska, during the period 

of civil twilight as defined in the Air Almanac, if: a. The vehicle is equipped with an operating anti-collision light 

visible for at least 3 statute miles; and b. All operations are conducted in uncontrolled airspace. 

3. Each person operating an ultralight vehicle shall maintain vigilance so as to see and avoid aircraft and shall 

yield the right of-way to all aircraft. 

4. No person may operate an ultralight vehicle in a manner that creates a collision hazard with respect to any 

aircraft

5. No person may operate an ultralight vehicle over any congested area of a city, town, or settlement, or over 

any open air assembly of persons. 

6. UAS can only be operated in Class G airspace a. No person may operate an ultralight vehicle within Class A, 

Class B, Class C, or Class D airspace or within the lateral boundaries of the surface area of Class E airspace 

designated for an airport unless that person has prior authorization from the ATC facility having jurisdiction 

over that airspace 

7. Any person operating an ultralight vehicle under this part shall, upon request, allow the Administrator, or 

his designee, to inspect the vehicle to determine the applicability of this part. 

8. No person may operate an ultralight vehicle in prohibited or restricted areas unless that person has 

permission from the using or controlling agency, as appropriate. 

9. No person may operate an ultralight vehicle in areas designated in a Notice to Airmen under §91.137, 

§91.138, §91.141, §91.143 or §91.145 of this chapter, unless authorized by: a. Air Traffic Control (ATC); or b. A 

Flight Standards Certificate of Waiver or Authorization issued for the demonstration or event. 

10. The pilot or operator of an ultralight vehicle must, upon request of the Administrator, furnish satisfactory 

evidence that the vehicle is subject only to the provisions of this part. 

11. No person may operate any ultralight vehicle in a manner that creates a hazard to other persons or 

property. 

12. No person may allow an object to be dropped from an ultralight vehicle if such action creates a hazard to 

other persons or property. 

13. No person may conduct operations that require a deviation from this part except under a written waiver 

issued by the Administrator. This section mandates that several aspect of Section 107 be waived ensuring 

proper registration of UAS being used in a commercial enterprise and that the PIC is properly experienced.

Stipulating these small UAS as ultralight aircraft an Airman certification is not required. By stipulating 

that the knowledge test portion of the air certification is enforced, all operators will be required to understand 

the requirement to keep UAS away from manned aircraft and the rules in which they will operateensuring 

public safety
Mission Statement

“To serve our clients with high quality aerial Photography and Videography by 

operating a UAS in a safe and professional manner”

Intended UAS Use

To produce aerial photos and/or video of real estate for the purpose of marketing 

or inspection of the real estate.
Equipment to Be Used

DJI FC40

Operating Temperature

-10°C ~ 50°C

Power Consumption

3.12W

Take-off Weight

<1200g

Hovering Accuracy (GPS Mode)

Vertical: 0.8m

Horizontal: 2.5m

Max Yaw Angular Velocity

200°/s

Max Ascent / Descent Speed

6m/s

Max Flight Velocity

10m/s

Diagonal distance (motor center to motor center)

350mm

Phantom Prop Guard

Weight(Single):18.7g

Size(Single): Angle(155.0°) Radius(112.32mm)

Whole Size with Four Prop Guards: 575.5mm
Aircraft Maintenance

To ensure safe operation of the UAS a preflight inspection will be performed and 

strictly followed to look for any damage or deterioration of any parts on the UAS. 

*A Safety checklist has been created to use before any flight is proceeded with.
Safety Concerns

Section 333 of PL 112-95 directs the FAA to evaluate, at a minimum the UAS’s size, 

weight, speed, operational capability, proximity to airports, proximity to 

unpopulated areas, and operation within visual line of sight (VLOS). I will use 

airframes which are already in operation in the NAS, a standard exists for 

permissible operation as the FAA has previously granted exemption to other 

operators and has not ruled against their operation by hobbyists. I will operate 

within VLOS at all times. Because of the relatively light weight of my aircraft and 

the precautions I will take to exclude nonparticipating and non-consenting 

persons, my operations will not pose a threat to national security, persons on the 

ground, or other aircraft operating in the NAS. 

I will operate the UAS well within the parameters of the devices’ operational 

envelope, terminating the operation with a conservative power reserve or in the 

event of an abnormality. Because of the UAS’s nimble flight characteristics, it has 

the ability to provide a level of safety greater than that which could be 

accomplished using a manned aircraft in the same operation. I will operate within 

VLOS, below 400 feet AGL, greater than 3 nautical miles from any airport, and will 

only operate over property where they have received express permission from the 

owner or governing agency. 

To capture high resolution images and video, operational conditions will be closely 

monitored because aerial photos and inspections need to be performed in the 

best light. 

1. Sunny Weather is Highly Preferred

2. Little to No Cloud Cover 

3. Zero to Low Wind Speeds 

4. High Visibility Conditions 

No Night-Time Operations are scheduled

These standards I mention in my petition will ensure safety of the flight crew, 

bystanders, and protection of property. 
Privacy Concerns

During flight operations, privacy concerns are of the highest priority. 

I will have a Seller/Property Owner signed letter authorizing the UAS's 

use for marketing purposes. (Form 1A-2015). 

Neighboring parcels or properties: During each flight operation, the UAS 

pilot will be extremely mindful of neighboring parcels to not film, record, 

or take pictures of people and property without their written and signed 

consent.

Homes and properties with acreage have a higher degree of uncertainty 

when trying to determine lot lines, boundaries, proximity to neighboring 

properties than a suburban home. Also, people looking to purchase a 

home with acreage, or a larger lot, have a higher degree of interest on 

knowing were the approximate lot lines are from an aerial perspective. 

That is why homes and property with acreage makes more sense to film 

with a UAS. 

Homes with View & Waterfront 

People looking to purchase and/or sell a home, or a property, with a 

view, or on waterfront, want to see the home or property from an aerial 

perspective and to be showcased in this format. This is part of property 

owner profile. In addition, even though neighboring parcels might be 

shown in the picture and video, the neighboring properties will only be 

included if it is necessary to the subject property's marketing materials.
Pilot Qualifications

Current Pilot — Kevin W. Glenn

Has been training with the current DJI FC40 Aircraft for 6 months. 

I have been flying drones as a hobby for the last 2 years and have accumulated 

several hundred hours of flight time.

Training will consist of the following:

_ Watch Online Training Videos 

_ Watch Online Training Videos for Specific Type of Filming Needs 

_ New Pilots will Shadow and Act as Current Pilots Spotter for 3 Months Prior to 

First Flight Operations. 

_ Attend Upcoming, and Local UAS Courses 

_ Every Pilot Will Follow the Flight Plans and Schedules Set Forth in the Document. 

To make sure pilot(s) stay current with rules, laws, safety techniques, filming 

practices, pilot(s) are required to take at least 1 continuing course offered through 

a 3rd party every year and provide Kevin W. Glenn with proof of course attended.
Pre-Flight Checklist

Flight Operation Location: 

Pilot: 

Date: 

_Conduct Walk-around of Flight Area. 

_Identify Potential Hazards with Spotter. 

_Locate Safe Launch & Landing Area. 

_Set Spotter (Spotter May Change Location due to Filming Angle) 

_Secure all Pets 

_Request all Non-Essential Personnel to Remain Behind Pilot 

_Unpack All Equipment from Transportation Case 

_Power Up Remote (Check if fully charged)

_Power Up GoPro (Check if Fully Charged)

_Initiate Video Recording 

_Power up UAS Launch UAS 

_Conduct Flight Operations 

_Land UAS in Designated Landing Area 

_Power down UAS 

_Turn Off Video Recording 

_Power down GoPro Power down Remote 

_Put All Equipment Back in Transportation Case

_Schedule Basic Visual Maintenance after Flight
Kevin W. Glenn

2913 Palace Place

Murfreesboro, TN 37129

Cell — 615-427-2609

RE: Authorization to Record Video & Photograph Property 

I, , legal seller and/or representative, authorize and 

give permission to Kevin W. Glenn to record video and photograph the property 

commonly known as: 

_____________________________________________________________

The recorded video and photography is to be used in a manner consistent with 

current real estate marketing strategies and advertising techniques. 

Sincerely, 

Signature ______________________ Date ________________

Signature ______________________ Date_________________

Form 1A-2015