July 29, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

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

Aviation Regulations from: 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)

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

CFR Part 11, Scott Donovan, Private Pilot Certificate #3443493, operator of Unmanned Aircraft Systems 

(UAS), hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow 

commercial operation of designated UAS, provided such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333.

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

would provide professional services in the following areas:

1. Aerial photography and/or video for public and/or private use including real estate,

architecture, land surveying, engineering and other related professional activities

2. Aerial video and/or photography for public and/or private use including television, public

events, cinematography and newsgathering.

3. Aerial inspection/photography/data collection of residential/commercial structures under 

contract with the owners or local government authority.

4. Aerial inspection/photography/data collection of residential/commercial utility infrastructure 

including but not limited to electrical power lines, wind turbines and cell towers.

5. Aerial video/photography or providing live video feed to assist with search and rescue

operations in cases of an emergency or natural disaster only when the local authorities or

government has requested it by contract or donation.
As described fully below, the requested exemption would permit the operation of designated UAS as set 

forth in this document under controlled conditions in the NAS that would be a) limited b) controlled c) 

predetermined and d) safe. Approval of this exemption would increase public awareness of UA 

operations and enhance safety to aid in fulfilling 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.”

I plan to operate a UAS, the DJI PHANTOM 3 Professional which is comprised of an unmanned aircraft

(UA or Phantom 3) and a transportable ground station. The Phantom 3 is referred to as a quad-copter

with a maximum gross weight of about 3 pounds. It is equipped with four rotors that are driven by

electric motors powered by batteries. The UA has a maximum airspeed of 16 m/s. I also plan to operate 

a UAS, the DJI Vision which is comprised of an unmanned aircraft and a transportable ground station. 

The Vision is referred to as a quad-copter with a maximum gross weight of about 6.5 pounds. It is 

equipped with four rotors that are driven by electric motors powered by batteries. The UA has a 

maximum airspeed of 22 m/s. 

Also, given the small size of the UAS’s involved and the restricted controlled environment within which 

they will operate, the applicant fits within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UASs and the controlled areas in which the relevant 

UASs will operate, approval of the application presents no national security issue. Given the following, 

the grant of the requested exemptions is clearly in the public interest: Scott Donovan proposes that the 

exemption requested herein apply to civil aircraft that have the characteristics and that operate with the 

limitations listed herein. These limitations provide for an exceptional level of safety to operations. These 

limitations and conditions to which Scott Donovan agrees to be bound when conducting commercial 

operations under an FAA issued exemption including:

1. Operate only in VFR conditions

2. 5 nautical miles (NM) from an airport having an operational control tower; or 3 NM 

from an airport with a published instrument flight procedure, but not an operational 

tower; or 2 NM from an airport without a published instrument flight procedure or 

an operational tower; or 2 NM from a heliport with a published instrument flight 

procedure

3. The UAS will weigh less than 55 lbs.

4. Flights will be operated within line of sight of operator.

5. Maximum total flight time for each operational flight will be 30 minutes.

6. Flights will be terminated at 15% battery power reserve.

7. Flights will be operated at an altitude of no more than 200 feet AGL

8. UAS operator will be trained and certified in the proper safety and operations of the 

UAS.

9. The UAS will only operate within a controlled area as defined in the Procedures.

10. The operator will post advisor notice around the controlled area.

11. The operator will have been trained in operation of UAS generally and received upto-date information on the particular UAS to be operated as required.

12. If the UAS loses communications or loses its GPS signal, the UAS will have capability 

to return to a pre-determined location within the Security Perimeter and land.
13. The UAS will have the capability to abort a flight in case of unpredicted obstacles or

emergencies.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption and are 

prepared to modify or amend any part of this request to satisfy the need for an equivalent level of 

safety. We look forward to working with your office. Please contact us at any time if additional 

information or clarifications are needed.

Sincerely,

Scott Donovan, Digitally

730 East Kingston Avenue

Charlotte, NC

(704)344-0733

FAA Certificate #3443493

Private Pilot

NC Drivers License #6236252

Expires 03/17/2023