October 7, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE., 

Washington, D.C. 20590 

Re: Exemption Request under Section 333 of the FAA Reform Act Of 2012 and 14 CFR Part 11 of the 

Federal Aviation Regulations 

Dear Sir /Madam: 

Sections for Exemptions Sought: 

Please accept this petition for exemption from Section 333 of the FAA Modernization and Reform Act 

2012 and the 14 CFR part 11, from the Federal Aviation Regulations, FAR, so that I may operate UAS 

commercially in the airspace regulated by the FAA. 

a) 14 CFR Part 21, subpart H 

b) 14 CFR Part 61.113 a and b 

c) 14 CFR Part 91 

d) 14 CFR Part 45.23 

1) 91.103 (b)(2) 

2) 91.105 

3) 91.109 

4) 91.119 

5) 91.121 

6) 91.151 

7) 91.203 

8) 91.207 

9) 91.405 

10) 91.407 

11) 91.409 

12) 91.417 
Relief Sought I Background Experience: 

Relief is sought, as currently, use of commercial drone operations is prohibited. With exemptions 

granted, I will be able to provide the service requested by my customers. 

I William B. Robberson Jr have been a licensed Private Pilot, Certificate# 2665683, with Complex and 

High performance endorsements for over 30 years, as well as a member of the Academy of Model 

Aeronautics for 10 years, license# 245157, and for the past 8 years I have been the pilot for the 

University Of Oklahoma Design Build Fly Drone World Wide competition contest sanctioned by the 

American Institute of Aeronautics and Raytheon. 

I would like to be able to offer my experience as a commercial service to those who are 

needing, to include but not limited to, aerial photography/video, mapping, advertising, 

agricultural management, Fish and Wildlife monitoring, surveys, Forestry Service etc. to 

promote their business or for personal reasons, as well as Search and Rescue, Fire 

Department, Police Department, Highway Patrol etc. or any appropriate law enforcement 

agency that may need my services I experience, to assist them in performing their duties. 

Public Benefit: 

My services, at a greatly reduced cost versus full scale aircraft services, would benefit the 

general public as a whole by allowing a safe, experienced FAA licensed Pilot and Radio 

Controlled Giant Scale Aircraft Pilot, as determined by the Academy of Model Aeronautics, to 

perform the services that they are requesting as detailed by the current FAA notices and 

Regulations. 
Safety: 

I am requesting this waiver for operation of aircraft below the 55 pound limit currently set forth in 

the regulations. 

Only approved radios I transmitters I receivers (currently 2.4ghz or any new technology as 

approved by the Federal Communications Commission, FCC) will be used and where 

applicable, I will utilize redundant back-up systems within the drone to further protect the public, 

property, livestock or other animals. 

I will only fly in designated areas as outlined by the exemption. 

If I am requested for flight operations in areas not covered by the exemption, I will apply for, and 

seek, the Certificate of Waiver or Authorization. (COA) 

I will only fly the aircraft within Visual Line Of Sight (VLOS), or until such time as the FAA 

approves First Person View, FPV, and my application is approved. 

All applicable Flight Standards District Office (FSDO) requirements will be followed. 

All flight operations will be conducted in accordance with valid Certificates of Authorization. 

All drones will be placed on a rotating maintenance schedule, similar to full scale 100 hour 

inspections and or TBO time limits as detailed by the manufactures manual. 

I will not be operating the drone outside the United States. 

Thank you for your consideration. If any additional information is requested or clarified, please contact 

me at the contact information listed below. 

~0_ ~ ./7.-4--1~ 

William B Robberson Jr 

P.O.Box 97 

Arcadia, Oklahoma 73007 

Email: alOhog@hughes.net 

Phone: 405-830-6559