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 – 2015-4840 by petition of

PAUL KATZOFF

7. FAA Exemption No. 14289 Regulatory Docket No. FAA – 2015-4854 by petition of

DRONE CONTROL SYSTEMS
Chopit Drones LLC 2

Dear Sir or Madam:

In accordance with FAA Section 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, operations will be performed safely at altitudes 

less than 400 feet (AGL), maintaining visual line of sight (VLOS) within the U.S. 

National Airspace. Operations to be performed under contract over client owned 

private or controlled access property 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 UAS 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 speed of approximately 31 knots. The DJI Phantom 3 UAS 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 UAS Professional operated by Chopit Drones 

has an FAA certificate of registration:

FAA Small UAS Certificate of 

Registration

CERTIFICATE 

HOLDER: Huo Shin Tsui

UAS CERTIFICATE 

NUMBER: FA34EAPAHP

ISSUED:12/31/2015 EXPIRES:12/31/2018
Chopit 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 this 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 airworthiness 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. 

Petitioner seeks exemption from the above listed FARs for the following 

reasons;

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

Pilots holding a Private Pilot 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 UAS be operated closer than 500 feet to essential persons, or 

objects that would not be possible without additional relief. The petitioner requests 

modification, waiver or exemption and clarification concerning the terms waiver for 
Chopit 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 the statutory criteria provided in Section 333 of Public Law 

112−95 ( 49 U.S.C. § 44704, Subpart H)—Airworthiness Certificates, and any 

associated noise certification 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 VFR 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), powered by four electric motors with a distance between motors of 

less than 20 inches. it utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to 

maintain geospatial orientation and position. DJI Phantom 3 is controlled primarily 
Chopit Drones LLC 5

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

information is transmitted back the ground control station allowing the operator 

and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance 

from PIC, camera imagery, and control camera angle. Failsafe 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, return 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 Mitigation

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 UAS

airworthiness will be verified before every launch. Airworthiness will be maintained 

by performance 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 UAS may not operate within 5 miles of the geographic 

center of a non-towered airport as denoted on current FAA published aeronautical 

charts 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 request. 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 airspace are not requested due to the lack of mode 

C transponder.

Public Interest

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 increasing aerial photography applications. Operations 

related to this petition will enable new services for property owners or their 

designees seeking enhanced perspectives for characteristics and benefits of their 

desired photographic subjects that cannot be displayed through ground level 

videography/photography. Aerial photography is a viable imaging technology 

leading to increased commerce and enhanced photographic 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 UAS 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 commercial 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