August 21, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Petition of The Dorothy Marcille Wood Foundation for Exemption 

Pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012.

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, The 

Dorothy Marcille Wood Foundation (DMWF), hereby applies for an exemption from Federal Aviation 

Regulations (FARs) identified below, to allow commercial operations of small unmanned aerial system 

(i.e.,UAS).

This exemption is in accordance with protocols outlined in this petition for exemption, the enclosed, 

the DJI UAS manufacturer's operations and/or instructions manual, DJI UAS User’s Manuals, DJI UAS 

Quick Start Guides, and any other requirements established by the FAA pursuant to Section 333 of 

the Reform Act.

This exemption would permit commercial operation by DMWF, which uses the DJI Phantom 2 Vision 

Plus to conduct agricultural and conservation research, real estate photography and videography, local 

promotional photography and videography to promote tourism, education and training. DMWF’s

operation under the exemption will be subject to strict operating requirements and conditions to 

ensure safety at all times and under conditions as may be modified by the FAA as required by Section 

333.



DMWF will be operated under controlled VFR conditions at low altitude in airspace that is permitted in 

accordance with DMWF’s approved Certificate of Authorization (COA). Finally, the FAA ATC will approve 

the airspace in which the UAS will operate in advance.

DMWF respectfully submits this request for an exemption because it wishes to operate a UAS. The 

operations DMWF will be conducting will be in lieu of comparatively hazardous operations now 

conducted by others using fixed wing and rotary conventional aircraft. The FAA can have confidence 

that the operations will be conducted at an equivalent level or greater level of safety than those 

providers. Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to 
“establish requirements for the safe operation of such aircraft systems in the national airspace system.”
For your convenience, DMWF has organized this Exemption request as follows:

I. Petitioner's Description

II. Relevant Statutory Authority

III. Qualifications for Approval Under Section 333 of the Reform Act

IV. Description of Proposed Operations

V. Regulations From Which Exemption is Requested

VI. Public Interest

VII. Privacy

VIII. Federal Registry Summary

IX. Conclusion

I. Petitioner's Description:

DMWF, headquartered in the Fort Worth, Texas is a company that wishes to provide UAS support to 

parks and recreation, private lands conservation, conservation data gathering, real estate photography 

and videography, local promotional photography/videography in a compliant and safe environment – to 

further promote wildlife conservation, agriculture, economic growth and education. DMWF plans on 

providing a wide range of services to benefit our community as the UAS market expands.

DMWF’s goal is to operate in an accident-free environment by:

• Demonstrating a commitment by the petitioner to operate in a compliant manner.

• Identify hazard and risk while eliminating or controlling all these risks. Petitioner will 

intervene and report when unsafe work practices or conditions appear to exist.

• Train all support personal involved in flight operations to perform at the highest standard level.

The contact information for Petitioners is as follows: 

DMWF

2912 Willing Ave

Fort Worth, TX 76110

www.dmwoodfoundation.org

Staff:

Laura Wood

Cell: 817-716-3963

laura@dmwoodfoundation.org

Casey Cunningham

Cell: 210-632-4241

casey@dmwoodfoundation.org

II. Relevant Statutory Authority:

This petition for exemption is submitted to fulfill Congress' goal in passing Section 333(a) through (c) of 

the Reform Act. Congress has directed the FAA "to safely accelerate the integration of civil unmanned 
aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA 

Administrator is to consider whether certain unmanned
aircraft systems may operate safely in the National Airspace ("NAS") before completion of the formal 

UAS rulemaking, based on the following considerations:

• The UAS's size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within the visual line of sight of the operator.3

If the Secretary determines that such vehicles "may operate safely in the National Airspace System, 

the Secretary shall establish requirements for the safe operation of such aircraft in the National 

Airspace System".

Additionally, the FAA Administrator has general authority to grant exemptions from its safety 

regulations and minimum standards when the Administrator decides a requested exemption is in the 

public interest. A party requesting an exemption must explain the reasons why the exemption:

(1) would benefit the public as a whole, and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by its terms, includes exempting civil aircraft, as the term is defined under 40101 of the 

Act, from the requirement that all civil aircraft must have a current airworthiness certificate and 

those regulations requiring commercial pilots to operate aircraft in commercial

service:



The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a)

or (b) of this section or any of sections.



III. Qualifications for Approval Under Section 333 of the Reform Act

The proposed operations in this petition for exemption qualify for expedited approval under 

Section 333 of the Reform Act.

The proposed operations would permit DMWF the use of small UAS under controlled conditions in 

airspace that is: (1) predetermined; and that (2) provides an Increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used by others to accomplish the same purpose.
DMWF will use UASs that are multirotor, weighing less than 55 pounds including payload. They will 

operate, under normal conditions, at speeds not to exceed 50 mph. The multirotor has the capability to 

hover and move in the vertical and horizontal plane. DMWF’s UASs will operate in line of sight and 

during daylight hours. Real Help Inc will operate at or below 400 feet AGL. All required permissions and 

permits would be obtained from territorial, state, county or city jurisdictions, Including local law 

enforcement, fire, or other appropriate governmental agencies prior to operating a UAS.



Given the small size of the UAS involved and the environment within which they will operate, this 

DMWF exemption falls within the zone of safety and demonstrates an equivalent level of safety, in 

which Congress desired the FAA to permit commercial UAS operations by exemption pending 

completion of formal rulemaking. Also, due to the size of the UAS and the confined area in which the 

UAS will operate, approval of the application presents no hazard in the NAS.

Considering the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the 

significant public benefit, the grant of the requested exemptions is also in the

public interest.





IV. Description of Proposed Operations

To assist the FAA in its safety assessment of DMWF’s proposed UAS operations, below is a summary of 

operational limitations and conditions that will ensure an equivalent or higher level of safety to 

operations conducted under current regulatory guidelines:

1. The UAS will weigh less than 55 pounds.

2. Flights will be operated within line of sight of the “Pilot in Command” (PIC) and visual observer.

3. Maximum total flight time for each operational flight will be limited to the amount of time 

the UAS can be flown and still maintain a reserve battery power of no less than 25%.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Flights will be operated at a lateral distance of least 100 feet from any inhabited structures, 

buildings, vehicles, vessels, people not associated with the operation or who have not signed 

a waiver in advance of the operation.

6. Minimum crew for each operation will consist of the UAS PIC (and a Visual Observer/ Camera 

Operator when appropriate).

7. The UAS PIC will be the petitioner Laura Wood and/or Casey Cunningham.

8. DMWF will designate a PIC for each mission.

9. The UAS will operate only within a confined safe and uncongested area.

10. Prior to the operations at a particular location, a site inspection will be conducted. On the day 

of the mission the management person with operational control and the PIC will concur on 

performing the mission after reviewing all safety issue compliance.

11. Prior to initiating each mission a briefing will be conducted in regard to the planned UAS 

operations. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safe and uncongested area be present for this briefing.
12. DMWF crew will use a safety and airworthiness checklist.

13. The UAS will be maintained in compliance with the manufacturer’s guidelines.

14. In the event of an accident involving a DMWF UAS, petitioner will cease operations and 

report the accident to the NTSB and AFS-80.

15. PIC and VO will at all times be able to communicate by voice.

16. PIC, Camera Operator, VO, and Operational Personnel will have been trained and tested by the 

petitioners.

17. All required permissions and permits would be obtained in advance from territorial, state, 

county or city jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies.

18. In compliance with approved exemption, DMWF management will submit a written “Plan of 

Activities” to the local Flight Standards District Office (FSDO) having jurisdiction over the area of 

proposed filming three days in advanced of operations during film or movie productions.

19. If the UAS loses communications signal, the UAS will have the capability to return to a perdetermined location within the safe and uncongested area.

20. Contingency plans will be in place to safely terminate flight if there is a loss of 

communication between the pilot and the observer.

21. The UAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

22. DMWF will assure no individuals’ privacy is violated.

23. Procedures have been established to contact ATC prior to operating in airspace other than G.

24.



V. Regulations From Which Exemption is Requested



A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in 

Command

B. 14 CFR § 91.103: Preflight Action

C. 14 CFR § 91.113: Right-of-Way Rules

D. 14 CFR § 91.119 (c): Minimum Safe Altitudes

E. 14 CFR § 91.121: Altimeter Settings

F. 14 CFR § 91.151(b): Fuel Requirements for Flight in VFR Conditions

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance 

Inspections



A. 14 CFR § Part 61.113 (a) and (b) Private Pilot Privileges and Limitations; Pilot in

Command



Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft 

that carries a pilot, passengers, and cargo, the DJI sUAS’s are remotely controlled with no passengers or 

property of others on board. Real Help Inc respectfully proposes that the FAA should take into account 

the characteristics and procedures of the particular UAS.
DMWF proposes that the actual operation of the DJI UAS does not require the Pilot to hold a private 

pilot certificate. DMWF instead proposes the following requirements:

• Pilot in Command Requirements:

1. The PIC must have accumulated and logged a minimum of five hours as UAS 

pilot with the make and model of UAS to be utilized for operations under the 

exemption and three takeoffs and landings in the preceding 90 days.

2. The PIC must have successfully completed the qualification process as

required by the petitioner, to include a knowledge and skill test.

B. 14 CFR § 91.103: Preflight Action



DMWF requests an exemption from the preflight actions requirements of 14 CFR 91.113

that prescribes the preflight actions under which aircraft may operate:



The Petitioner shall, before beginning a flight, become familiar with all available information 

concerning that flight.

a) Flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, 

battery charge levels alternatives available if the planned flight cannot be completed, and any 

known traffic delays of which the pilot in command has been advised by ATC;

b) For every flight the following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing 

takeoff and landing distance data is required, the takeoff and landing distance data contained 

therein; and

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other 

reliable information appropriate to the aircraft, relating to aircraft performance under 

expected values of airport elevation and runway slope, aircraft gross weight, and wind and 

temperature.

DMWF will not operate UAS’s under IFR conditions, or when the ceilings are below 1000 feet and 

the visibility is below 3 statute miles. DJI’s UAS’s do not have published approved Airplane or 

Rotorcraft Flight Manual containing takeoff and landing distance data.

Equivalent Level of Safety

The PIC along with the person having operational control must assure that the weather will be

adequate to complete the mission in VFR condition. 

C. 14 CFR 91.113: Right-of-Way Rules
DMWF requests an exemption from 14 CFR 91.113 Right-of-way rules, requiring vigilance by each 

person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives 

another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, under, 

or ahead of it unless well clear.

DMWF will operate small pilotless UAS’s and cannot comply with these rules as they have been 

written.

Equivalent Level of Safety



DMWF will operate UAS’s at or below an altitude of 400 feet AGL, well below the normal operating 

altitude of other aircraft. DMWF specifies that a PIC with experience will perform each mission and 

have knowledge of the avoid rules. It’s the responsibility of the PIC to cease operations and land the 

UAS immediately whenever and aircraft comes into the vicinity creating a potential threat or safety 

concern. Operations will not recommence until the potential threat is clear or safety concern has been 

resolved.

D. 14 CFR. § 91.119: Minimum Safe Altitudes

DMWF requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that 

prescribes the minimum safe altitudes under which aircraft may operate:

• Over any congested area of a city, town, or settlement, or over any open air assembly of 

persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

• Over other than congested areas at an altitude of 500 feet above the surface, except over 

open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 (d) allows for a helicopter to operate at less than those minimum altitudes when it can 

be operated "without hazard to persons or property on the surface," provided that "each person 

operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by 

the FAA."

To provide the intended operations, the UAS is normally operated below 400 feet AGL. Additionally, 

due to the nature of the proposed operations, the UAS will maintain a lateral distance of at least 100 

feet from inhabited structures, buildings, vehicles, and vessels, and from people not associated with 

the operation.

Equivalent Level of Safety

Compared to flight of normal aircraft, DMWF multi-rotor aircraft weigh less than 55 pounds, and given 

the lack of flammable fuel, any risk associated with these operations is far less than those that 

presently exist with conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS, as well as the location where it is operated. As set forth in the 

Operations Manual, the UAS will be operated in a safe and uncongested area, where buildings and 

people will not be exposed to operations without their
pre-obtained consent. Because of the advance notice to the property owners and participants, all 

affected individuals will be well aware of the planned flight operations.

Furthermore, by operating at such lower altitudes, the UAS will not interfere with aircraft that are 

subject to the minimum safe altitude regulations. Finally, the successful safety record of the DJI UAS’s 

demonstrates that the UAS can be safely used at these lower altitudes and closer operating 

environments.

E. 14 C.F.R. § 91.121: Altimeter Settings

DMWF seeks an exemption from 14 CFR 91.121, which requires a person operating an aircraft to 

maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the 

departure airport or barometric pressure. An exemption is required because the sUAS does not have 

a barometric altimeter, but rather a GPS altitude read out.

Equivalent Level of Safety

An equivalent level of safety will be achieved by following these procedures: 1. DMWF will confirm 

the altitude of the launch site shown on the GPS altitude indicator before flight. 2. Moreover, the PIC 

will use the GPS altitude indicator to constantly monitor the UAS's height, thus ensuring operation at 

safe altitudes.

F. 14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

DMWF requests an exemption from 14 CFR § 91.151(a)'s fuel requirements for flight in VFR conditions. 

Section 91.151 states:

a) No person may begin 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 25 minutes; or

(2) At night, to fly after that for at least 45 minutes.





The batteries powering DMWF’s UAS’s provide approximately 10-18 minutes of powered flight. To 

meet the 30 minutes reserve requirement in 14 CFR 91.151, UAS flights could not be conducted. Given 

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

predetermined area, a safety margin based on a reserve amount of battery life is needed.



DMWF will not be conducting any UAS flights at night.

Equivalent Level of Safety



An equivalent level of safety will be achieved because the operations will be conducted on-site without 

significant transit time by the UAS. All flights will be planned to terminate with no less than 25% 

reserve battery power still available. This restriction would be more than adequate to return the UAS 

safely to its planned landing zone from anywhere in its confined area of
operation even in the event of an unexpected occurrence. Operation of the UAS with less than 30 

minutes of reserve fuel does not include the type of risks that Section 91.151(a) was intended to 

alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the 

landing zone. Moreover, operation will be limited to controlled areas where only people and property 

owners, or official representatives will be allowed.

G. 14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b): Maintenance Inspections



DMWF also seeks an exemption from the maintenance inspection requirements contained in 14 CFR 

91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b). These regulations specify maintenance and 

inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) (stating that each owner or 

operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections...have discrepancies repaired as prescribed in part 43 of this chapter"). 

An exemption to these regulations is needed because Part 43 and these sections only apply to aircraft

with an airworthiness certificate, which the UAS will not have.

Equivalent Level of Safety



An equivalent level of safety will be achieved because maintenance and inspections will be performed 

in accordance with the DJI User’s Manuals. 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. 

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.



If mechanical issues arise, the UAS's size and carrying capacity, and the fact that flight operations will 

only take place in pre-designated areas for limited periods of time during daylight hours, creates less 

risk than that associated with conventional rotorcraft performing the same operation.



VI. PUBLIC INTEREST



Granting DMWF an exemption furthers the public interest. National policy set by Congress favors 

early integration of UAS into the national airspace in controlled, safe working environments such as 

those propose in this petition. DMWF would like to help facilitate safe integration of UAS’s into 

mainstream USA in the following areas:

• Agriculture and Conservation

DMWF would introduce and demonstrate to landowners of all types that the UAS can aid 

commercial agriculture, land management and conservation efforts by assessing land use 

practices, mapping flood zones, conducting wildlife counts and more. The UAS can fly pre-saved 

missions via the fully automated ground station, which allows for time-lapse photos of fields, 

crops and known land tracts. It also can accurately recreate the same pattern during all seasons, 

providing invaluable data for land and soil management. Using HD video, HD photos, and IR 

cameras allows for detailed analysis and recording. With photo
rendering software, 3D maps and GIS software, DMWF’s UAS can be used in conjunction with 

time-lapse photos to create highly detailed maps for erosion, flood mapping and other critical 

aspects of land management. 

• Real Estate

The UAS can be used in all areas of real estate, including agricultural, vacant land, commercial, 

residential and industrial properties. Using a UAS, real estate professionals can create 

promotional videos, photos and unique shots that normal camera aspects cannot capture. The 

remote platform is great for new planning, zoning and large developments. Simple and easy-touse video and photos allow for multiple height pictures and elevation views. Additionally, the 

UAS enables construction companies to safely and affordable get a “bird’s eye view” of their 

project and progress. 

• Movies and Videography

Whether the shot requires unique views and expansive panning or extreme altitude with 

radical views, the UAS is designed to hold up under demanding conditions. Because of the 

autopilot feature with pre-designed mission management and R/C control interrupt, the pilot 

and camera operator can easily create the ultimate shot with HD video or HD still photos. 

When working close in on a closed set the hazards to the actors are greatly reduced due to 

the size of the UAS.

 Natural Resource Professionals

Many government agencies, be it state, local or federal, are limited in funding for the major 

expense of chopper time, whether it be for prescribed fires, gathering data from wildlife 

surveys, or promoting the beauty of land conservation through film. DMWF’s use of the UAS 

allows us to affordably assist these various agencies in getting the information they need 

affordably and faster. 

VII. Privacy



DMWF knows that many individual have concerns about privacy from the operations of UAS’s. DMWF

has created a privacy notice that informs residents, commercial property owners, churches, schools, 

and governmental organizations of our intent to conduct commercial drone operations in proximity to 

their property.


VIII. Federal Registry Summary
Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed:

Real Help Inc seeks an exemption from the following rules:

14 CFR Part 61.113 (a) and (b); 14 CFR 91. 103; 14 CFR 91.113; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR; 91.409(a)(2); 14 CFR 91.417(a) and (b).

Approval of this exemption request allows DMWF to conduct commercial operations with small and 

lightweight unmanned aerial systems. DMWF’s vision is to enhance safety of UAS operations in the NAS 

while reducing risk to the general public and property owners.

The DJI UAS, weighing less than 55 pounds and powered by batteries, eliminates virtually all of the risk 

given the reduced mass and lack of combustible fuel carried on board. The UAS is transported to the 

designated mission area and set up there. The UAS will carry no passengers or crew and, therefore, 

will not expose them to the risks associated with manned aircraft flights.

The operation of this small UAS will provide an equivalent level of safety, supporting the grant of the 

exemptions requested herein, including exempting the applicant form the requirements of several 

regulations and allowing commercial operations. These lightweight UAS's operate at slow speeds, close 

tot he ground and in a safe and uncongested environment. As a result, they are far safer than 

conventional aerial survey and inspection operations conducted with fixed wing aircraft or helicopters.

If additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned.

Laura Wood, Owner/Petitioner

DMWF

Cell Phone: 817-716-3963

Email: laura@dmwoodfoundation.org

Casey Cunningham, Project Manager/Petitioner

DMWF

Cell Phone: 210-632-4241

Email: casey@dmwoodfoundation.org