Chopit Drones LLC 1 

### Chopit Drones, LLC

2560 W La Palma Ave #228 Anaheim, CA 92801 

### john.tsui@chopitdrones.com

626

- 278

- 7175 18 January 2016

U.S. Department of Transportation
Federal Aviation Administration Docket Operations West Building Ground Floor, Room w12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act and Part 11 of Federal Aviation Regulations

References:

1. FAA Exemption No. 12253 Regulatory Docket No. FAA petition of GERSHWIN

THOMAS STEPHEN

2. FAA Exemption No. 11138, Regulatory Docket No. FAA petition of DOUGLAS

TRUDEAU

3. FAA Exemption No. 11136, Regulatory Docket No. FAA petition of ADVANCED

AVIATION SOLUTIONS LLC

4. FAA Exemption No. 11080 Regulatory Docket No. FAA petition of FLYING CAM

INC

5. FAA Exemption No. 14284 Regulatory Docket No. FAA

– 2015

- 4838 by petition of

SKY LOOK VIDEO

6. FAA Exemption No. 14284 Regulatory Docket No. FAA

– 2015

- 48 40 by petition of

PAUL KATZOFF

7. FAA Exemption No. 1428 9 Regu latory Docket No. FAA

– 2015

- 4854 by petition of

DRONE CONTROL SYSTEMSChopit Drones LLC 2

Dear Sir or Madam:

In accordance with FAA S ection 333 of the FAA Modernization and Reform Act I

, Huo Shin Tsui (a.k.a. John Tsui ) , founder of Chopit Drones LLC , hereafter the petitioner, request exemption from the following sections of Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.7(a); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(1); 91.409(a)(2); 91. 417(a) & (b);

Chopit Drones is seeking exemptions to operate a small Unmanned Aircraft Systems (UAS) (Unmodified DJI Phantom 3 Professional Model ) commercially and safely at

minimum risk in airspace regulated by the Federal Aviation Administration pursuant to Section 333 of the FAA Modernization Reform Act and 14 C.F. R., Part
11, for the purposes of commercial aerial photography, videography, mapping and inspections. Weather permitting, o perations will be performed safely at altitude s less than 4 00 feet (AGL), maintaining visual line of sight (VLOS) within the U.S.

National A irspace

. Operations to be performed under contract over client owned private or controlled access propert y with permission from the property owner or controller or authorized representative ensuring public safety within the conditions outlined herein or as may be established by the FAA

.

The DJI Phantom 3 Professional UAS is comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a transportable Ground Control Station (GCS). The Phantom 3 UA S has: a maximum gross weight of less than 3 pounds; approximate dimensions of 23 inches diagonally across, and height of 7.25 inches; and maximum spee d of approximately 31 knots. The DJI Phantom 3 UA S is equipped with four rotors; each driven by a Lithium Polymer battery powered

electric motor. The UAS and Ground Station based parts of the system will operate

in the in FCC compliant 2.4 GHz ISM band over 7 channels.

The Chopit Drones DJI Phantom 3 UA S Professional operated by Chopit Drones

has an FAA certificate of regist ration :

FAA Small UAS Certificate of

R egistration

CERTIFICATE

HOLDER: Huo Shin Tsui

UAS CERTIFICATE

NUMBER: FA34EAPAHP

ISSUED: 12/31/2015 EXPIRES: 12/31/2018Chopit Drones LLC 3

in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with FAA Identification and Registration Marking requirements

.

In consideration of the size, weight, speed, and limited operating range associated

with th is unmanned aircraft and its operation, Chopit Drones’ operation of the Phantom 3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an air worthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H. Accordingly, Chopit Drones requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements

for maintenance that only apply to aircraft with an airworthiness certificate. Chopit Drones submits that the requested relief is proper since an equivalent level of safety will be ensured. Chopit Drones will perform regular maintenance and preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Phantom 3 UAS User Manual, the Phantom 3 UAS Quick Start Guide, and the Intelligent Flight Battery Safety

Guidelines ( available at this website for viewing or download ; http://www.dji.com/product/phantom ; 1) Phantom 3 Professional User Manual (EN)

v1.2 20150729 ; 2 ) Phantom 3 Professional Quick Start Guide (EN) v1.0 20150520

, and 3) Phantom 3 Safety Guidelines and Disclaimer ) . Chopit Drones will utilize manufacturer authorized support services to perform maintenance, alterations, or preventive maintenance on the UAS. Furthermore, Chopit Drones will document
and maintain all maintenance records for the Phantom 3 UAS.

P etitioner seeks exemption from the above listed FARs for the following

reasons;

61.113(a) & (b); P etitioner requests relief in order to facilitate the use of

Pilots hold ing a P rivate P ilot certificate. Any pilots operating under this exemption would be required to comply with conditions as set forth and in a similar fashion to previously FAA granted exemptions where a PIC must hold either an airline transport, commercial, private, recreational or sport pilot certificate.

Chopit Drones Operators consist of UAS Pilot (Pilot In Command) PIC David Kangas, Co

- Founder and Licensed Pilot

, 1219 Concord Ave.

, Fullerton,

CA 92831

, Tel: 714

- 414

- 8068

, davidkangas@gmail.com and Visual Observer:

Huo Shin Tsui, Founder Chopit Drones LLC, 2560 W La Palma Ave #228

, Anaheim, CA 92801

, 626

- 278

- 7175

, john.tsui@chopitdrones.com

91.119(c) As referenced in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the DJI Phantom 3
Professional Model UA S be operated closer than 500 feet to essential persons, or objects that would not be possible without a dditional relief. The petitioner requests modification, waiver or exemption and clarification concerning the terms waiver forChopit Drones LLC 4

this condition to allow reasonable and responsible operations in areas of subdivisions and neighborhoods if required.

91.7 (a ) Airworthiness Certification

-- The proposed UAS is a DJI Phantom 3
Professional that meets t he statutory criteria provided in Section 333 of Public Law

112−95 ( 49 U.S.C. § 44704, Subpart H )

— Airworthiness Certificates, and any

associated noise certificati on and testing requirements of part 36, has been deemed
not necessary

.

91.121 As referenced in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable

since the UAS does not have an altimeter and instead utilizes electronics with a

barometric sensor for altitude information. Request is similar in material respects to relief previously granted in referenced exemptions.

91.151(a) as discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted in Exemption Nos. 8811,

10808 , and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those

documents contain a condition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VF R conditions was

reasonable.

91.405(a) ; 91.407 (a ) ( 1) ; 91.409 (a ) ( 1) & (2) ; 91.417 (a) & (b) as discussed in Exemption 11138 (DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure that the UAS is in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to the petitioner specified, describing the requirements for maintenance, inspection, and recordkeeping, was sufficient to ensure that safety would not be adversely affected.

The UAS

The DJI Phantom 3 is a successful consumer grade small Quadcopter rotorcraft configuration with an advertised weight of less than 46 Ounces (1280g)

. Designed primarily to carry a high definition camera (Passenger(s) and fuel will not

be carried aloft )

, po wered by four electric motors with a distance between motors of

less than 20 inches. i t utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning system (GPS) to maintain geospatial orientation a nd position. DJI Phantom 3 is controlled primarilyChopit Drones LLC 5

through an FCC certified radio control (RC) unit. Real time video and telemetry

information is transmitted back t he ground control station allowing the operator and/or PIC to monitor battery level, GPS sig nal strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. F ailsafe modes of operation are accomplished for either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum altitude will be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An automatic termination of flight , r eturn and landing will be initiated when the battery reaches a predetermined low state. It is anticipated that flights will usually last less than 10 minutes. More UAS performance information and specifications are available at http://www.dji.com/product/phantom

Risk M itigation

Chopit Drones petitioner has reviewed FAA exemptions reference Limitations section and believes that the procedures specified therein are reasonable and will be utilized in order to manage and mitigate risk and ensure public safety. A Preflight

checklist will be developed and will be employed to ensure that the UA S

airworthiness will be verified before every launch. Airworthiness will be maintained by perf ormance of routine inspections before and after each flight, maintaining flight and maintenance logs to record time on failure prone components.

The petitioner does request that in a manner similar to reference 3, ( FAA Exemption No. 11136, Regulatory Docket No. FAA petition of ADVANCED AVIATION SOLUTIONS LLC) Chopit Drones be allowed to Operate within 5 miles of an airport provided that UA S may not operate within 5 miles of the geographic

center of a non

- towered airport as denoted on current FAA publis hed aeronautical

chart s unless a letter of agreement with that airport operation is conducted in accordance with a NOTAM as required by the operator COA. The letter of agreement with the airport management will be made available to the Administrator upon r equest. Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is requesting a mechanism to facilitate such activities without requesting new and separate exemption(s) should the need arise. Operations within class B a irspace are not requested due to the lack of mode C transponder.

Public I nterest

Use of UAS in lieu of a manned aircraft would enhance safety and reduce

Environmental impact and risk when compared to similar operations conducted
with manned aircraft of greater proportions carrying crew and flammable fuel.Chopit Drones LLC 6

Additionally, use of the UAS in order to facilitate commerce will lead to economic growth , creating jobs while increas ing aerial photography applications . Operations

related to this petition will enable new service s for property owners or their designees seeking enhanced perspective s for characteristics and benefits of their desired photographic subjects that cannot be displayed through ground level videography/photography. Aerial photography is a viabl e imaging technology leading to increased commerce and enhance d photograph ic infrastructure imaging

at low risk

.

Aerial surveying , assessment and inspections will increase work site safety and efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with photographic data for project surveying and inspections

purposes

. Liability insurance will be obtained commensurate with the granting of

this request for exemption. Flight data including UA S flight time, Control Unit operation time, incident, accident, and details concerning any deviations from normal operations will be made available to the FAA for use in collecting data regarding the use of UAS as part of this application. Accidents will be reported to
the FAA UAS Office and NTSB within 24 hours. Performance data may be submitted to FAA via traditional means, e.g. COA Monthly Reports or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of c ommercial aerial photography and videography for mapping, inspections and other flight operations

for construction services wherein petitioner's business involves taking photographs and videos of buildings

, infrastructures, utilities and land for improved
Construction Services on a contract basis while remaining in compliance with all local, state and federal requirements

.

The petitioner has 2 years’ experience in the radio control model aircraft hobby, as

well and a valid driver’s license in the state of California.

Respectfully submitted,

Huo Shin Tsui

, Founder Chopit Drones

, LLC