US Department of Transportation Exemption Request Pursuant to Section 333 of the FAA 

Reform Act and Part 11 of the Federal Aviation

June 11, 2015

Robert W. Biggs

DBA Phoenix Drone Pros

601 E. Pinto Ct.

Gilbert, AZ 85296

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) 

Dear Sir or Madam:

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

Act”) and 14 CFR Part 11, Robert W. Biggs, DBA “Phoenix Drone Pros,” 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.

Thank you in advance for your consideration.

Robert W. Biggs, DBA

Phoenix Drone Pros
The Unmanned Aircraft (UA) described herein is smaller, lighter and more maneuverable 

than conventional aircraft running on combustible fuel, operates at lower altitudes with no people 

on board and will thereby reduce current risk levels, enhance safety and diminish the likelihood 

of death or serious bodily injury. With a small payload and maximum flight time of only 20

minutes, this offers little or no risk to national security. 

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 of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial inspection/photography 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.

6. Training to persons individually or belonging to both private and/or public organizations

to increase awareness and improve safety for current and future UAS operations within the 

NAS.

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 UAS 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.” 

The name and address of the applicant is:

Robert W. Biggs, DBA Phoenix Drone Pros

Phone: (480) 330-1778

Email: PhoenixDronePros@gmail.com

Address: 601 e. Pinto Ct., Gilbert, Arizona 85296
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)
Robert W. Biggs, DBA Phoenix Drone Pros, will operate one or more of the following

model UAS:

1. DJI T600 INSPIRE 1

The DJI T600 Inspire One manufactured by DJI innovations, is lightweight 4 electric 

motor/rotor, battery operated quadcopter with a 6.5lb gross weight that takes off and lands 

vertically. The Inspire one has a length of 17.3 inches, width of 17.7 inches, height of 11.8 

inches, and a maximum speed of approximately 42 knots. Its avionics suite contains an onboard flight computer with GPS navigation and an Inertial Measurement Unit (IMU) based 

attitude stability system. Also included is a barometric altimeter sensor, compass unit 

ultrasonic altimeter and vision positioning camera. An on-board processor receives signals for 

flight and payload control from a ground-based transmitter/controller/ground station device. 

An on-board telemetry system delivers flight data from the flight computer to the downlink 

radio transmitter to provide the Pilot in Command (PIC) with information such as altitude 

AGL, horizontal and vertical speed, compass direction of flight, bearing and distance to the 

controlling station, current waypoint, battery status, current flight mode, GPS health status, 

datalink status, and GPS position. This data is displayed to the PIC via the Ground Control 

Station (GCS) application running on one or more computer devices such as a smart phone, 

tablet or PC. 

THE GROUND CONTROL STATION/CONTROLLER: 

The DJI UAS products CCAS intends to operate under this exemption use a series of 

components to comprise the Ground Control Station (GCS). The first and primary component 

of the ground segment is a handheld pilot controller and an optional handheld payload 

controller. The pilot controller provides a user interface for flight attitude and altitude 

commands augmented by the UA’s onboard IMU and GPS aided stabilization system. The 

controller also has options for manipulating the flight mode, payload gimbal, camera functions, 

and landing gear if equipped. The Datalink segment is comprised of an uplink transmitter 

command/control link using a frequency range of 2.4GHz to 2.48GHz frequency range with a 

power output of approximately 125mW. The uplink sends flight and payload commands to the 

UA’s autopilot which then processes the commands along with sensor inputs to manipulate the 

motor speed controllers and provide the desired response. The downlink transmitter on the UA 

operates on a 5.728GHz to 5.85GHz and an output power of approximately 25mW. The 

downlink transmitter provides live video from the on-board camera plus all the UA flight data 

described above. Downlink data and video is received by the pilot controller and optional 

payload controller which is then displayed to the PIC and optional PO via an application on a 

handheld device such as a smart phone, tablet or PC. The GCS application also provides a 

heads up display of pertinent flight data and UA status reports along with a moving map 

display. Both the uplink and downlink transmitters have been tested and comply with part 15 

of the FCC rules for a class B digital device.

DOCUMENTATION

The following documents are attached and provided to support this petition. 

 DJI T600 Inspire 1 - Manual Version 1.0

 Preflight Checklist 
Given the small size of the UAS in scope and the controlled environment provided, the 

proposed operations will adhere to the Reform Act’s safety requirements. The approval of

this application presents no national security issues. Regarding the level of safety

surrounding the proposed operations and the public benefit, reduction in environmental

impacts, including but not limited to reduced emissions and noise, the grant of the

requested exemption is in the public interest. Accordingly, the applicant graciously requests

that the FAA grant the requested exemption.

OPERATIONAL PARAMETERS

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed for an equivalent or higher level of safety because 

operations will further enhance the safety of the persons and/or property using conventional 

aircraft. These limitations and conditions to which the applicant agrees to adhere to when 

conducting commercial operations under the FAA issued exemption as set forth in the

Flight Operations Manual (FOM) include:

1. The UAS will weigh significantly less than 55 lbs. It weighs less than 4 pounds with

battery and camera.

2. The UAS, depending on the model in operation, will have a maximum operating speed

of no more than 50mph.

3. Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual

Observer (VO).

4. Maximum flight time for each operational flight will be depending on the UAS

model in operation, but will not exceed 30 minutes. Flights will be terminated at 25%

battery power reserve or 30 minutes of flight time whichever occurs first.

5. Flights will be operated at an altitude of no more than 400 feet Above Ground Level

(AGL) and not more than 200 feet above an elevated platform from which filming is

planned.

6. Minimum crew for each operation will consist of the UAS Pilot and at least one Visual

Observer (VO), and may include a third, but separate, Camera Operator (CO).

7. The UAS pilot will be a designated Pilot in Command (PIC). The PIC will have

logged a minimum of 20 hours on the designated UAS.

8. A safety briefing will be performed prior to each day’s flights consisting of all the days’

production activities.

9. All flight activities will be logged.

10. All flights will occur under Visual Flight Rules Meteorological Conditions (VMC) only.

11. The flights will occur in Class G airspace no closer than a 5-mile radius of the

geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled

airport.

12. Flights will not be closer than a 5 mile radius of the geographic center/Airport.
13. The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO)

no more than 72 hours but no less than 48 hours from planned operation.

14. The operator will obtain verbal/written consent of all persons involved with the

planned operation and ensure that only consenting persons will be allowed within 100 feet

of the flight operation, and the radius may be reduced to 30 feet based upon an equivalent

level of safety determination, as U.S. Department of Transportation required under the

FOM. With the advanced permission of the FSDO, operations at closer range may be

approved.

15. The PIC and VO will have been trained in operation of UAS and receive up-todate information for the particular UAS to be operated.

16. The PIC and VO will be able to communicate by voice and/or radio at all times.

17. Written and/or verbal permission and permits will be obtained from territorial, state,

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

governmental agencies as appropriate to flight operations.

18. If the UAS loses communications with the remote controller or loses GPS signal, the

UAS will have the capability to return to a pre-determined location within a designated

location and land autonomously.

19. The UAS will have the capability to abort a flight in case of emergencies

with an automated “Return Home and Land” function.

20. The UAS will have the capability to abort a flight in case of unpredicted

obstacles, weather, or emergencies such as low battery.
PREFLIGHT CHECKLIST

PRE-FLIGHT CHECKLIST

DJI INSPIRE 1

UAV Number: N-229DP

DEPARTURE

 Batteries fully charged

 Tablet

 Cables

 Safety Vest

 Micro SD Card - Clear

 Laptop

 GoPro

PRE-FLIGHT

 Notify owner and residents

 Check weather, wind < 15mph

 Put on safety vest, signage

 Power ON Hot Spot

 Power ON tablet, connect to Tx

 Power ON Transmitter

 Set antennae

 Power ON Drone

 Exit Travel Mode

 Power OFF Drone

 Insert micro SD card in camera

 Install correct camera lens filter

 Install Camera

 Install propellers, prop locks

 Power ON Drone

 Check flight status on tablet

 Check battery status on tablet

 Clear map

 Set camera mode - 4k or 1080, MP4

 Perform calibration

 Place drone in clear take off area

 TAKE-OFF: Hover, test controls

POST-FLIGHT

 LAND

 Remove propellers, prop locks

 Remove Camera

 Remove micro SD card

 Enter Travel Mode

 Power OFF Drone

 Power OFF Transmitter

 Reset antennae

 Power OFF tablet

 Power OFF HotSpot

 Remove safety vest, signage
SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN 

EXEMPTION 

A. 14 C.F.R. §§ 61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command. 

These regulations limit private pilots to non-commercial operations. Because the UAS will not 

carry a pilot or passengers and be operated within limited areas and altitudes, the proposed 

operations can achieve the equivalent level of safety of current operations by requiring the PIC 

operating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to 

operate this small UAS. 

B. 14 C.F.R. § 91.7(a) Civil Aircraft Airworthiness 

While the UAS will not have an airworthiness certificate in accordance with 14 C.F.R. part 21, 

Subpart H, the airworthy condition of the UAS will be the responsibility of the PIC in accordance 

with 14 C.F.R. § 91.7(b). 

C. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas 

This regulation establishes safe altitudes for operation of civil aircraft over areas other than 

congested areas. PDP requests relief from this section with respect to persons involved in the 

operation as well as vehicles and structures. The UAS will not be operated above 400 feet altitude. 

It will be operated in a defined area where people and buildings will not be exposed to operations 

without their pre-obtained consent. 

D. 14 C.F.R. § 91.121 Altimeter Settings 

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 does not have a barometric altimeter, an exemption 

is requested. The UAS Flight Controller utilizes GPS equipment aided by a static pressure sensor to 

determine and maintain altitude. The aircraft altitude above the takeoff point is provided in the 

video downlink telemetry information and provides sufficient information for the PIC to maintain 

altitudes at or below the 400 foot (122 meter) limitations. April 6, 2015 Page 6 

E. 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 cursing 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.” 

Given that the UAS aircraft only fly for a maximum of 30 minutes and typically carry about 15 

minutes of batter power, an exemption is requested. The UAS operations are always conducted 

within a few minutes of the takeoff and landing point and within a restricted area. BEAP believes 

that terminating the flight with 25% remaining battery power provides an equivalent amount of 

safety that is intended by section 191.151(a). 

F. 14 C.F.R. § 91.405(a) Maintenance Required; 14 C.F.R. § 91.407(a)(1) Operation after 

maintenance, preventative maintenance, rebuilding or alteration; 14 C.F.R. §§ 91.409(a)(1) and (2) 

Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance Records 
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 the sections and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the Petitioner. Maintenance will be accomplished by the operator 

pursuant to the Owner’s Manuals. An equivalent level of safety will be achieved because these 

small UAS are very limited in size and will carry a small payload and operate only in restricted 

areas for limited periods of time. If mechanical issues arise, the UAS can land immediately and 

will be operating from no higher than 400 feet AGL. The operator will ensure that the UAS is in 

working order prior to initial 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. The FAA issued exemption to these regulations in Exemption No. 11062.

Additional Information.

The applicant, Robert W. Biggs, believes this exemption request and associated safety

considerations adequately satisfy criteria provided in Section 333 of the Reform Act of

2012, providing sufficient justification for the granting of commercial operations

of the applicant’s UAS.

The applicant, Robert W. Biggs, requests your respective approval of this Section 333

exemption petition request.

Thank you for your interest and attention in this matter. Please notify Robert W. Biggs of

your actions, and or approvals. Thank You for your interest in this request. Sincerely,

Robert W. Biggs

DBA Phoenix Drone Pros

PhoenixDronePros@gmail.com

601 E. Pinto Ct.

Gilbert, Arizona 85296