July 10, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE

Washington, DC 20590

Alexander Bancroft 

617 Wilson Street 

Lafayette, LA 70503 

318-617-8938 

bancroft27@gmail.com

Petition of Alexander Bancroft for Exemption Pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012

Dear Sir or Madam:

I am writing pursuant to Section 333 of the Federal Aviation Administration (FAA)

Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, to request that 

Alexander (Alex) Bancroft, owner and operator of a DJI Phantom 3 Professional 

which is a Small Unmanned Aircraft Systems (sUAS), be exempted form the listed

Federal Aviation Regulations (FARs) to allow commercial operation in airspace 

regulated the FAA. The operations of this sUAS will be conducted within and under 

the conditions outlined herein or as may be established by the FAA as required by 

Section 333. The following aspects of Section 333 of the FAA Modernization Reform 

Act of 2012 should be considered.

In order to meet the requirements of the above act, Alex Bancroft is submitting the 

following information. 

1. Name and Address

2. The specific section or sections of 14 CFR from which Alexander 

Bancroft seek exemption

3. Planned use of his DJI Phantom 3 Professional 

4. How his request would benefit the public as a whole

5. Explanation of how the exemption would provide a level of safety at 

least equal to the existing rule 

6. Federal Register Summary 

7. Link DJI Phantom 3 Professional Manual Download 

8. Link to DJI Phantom 3 Professional specifications 
1. Name and Address 

Alexander Ross Bancroft 

617 Wilson Street

Lafayette, LA 70503

bancroft27@gmail.com

2. The specific section or sections of 14 CFR from which Alexander 

Bancroft seek exemption:

I. 14 § C.F.R. Part 21, Subpart H

II. 14 § C.F.R. 45.23 and 14 C.F.R. 45.29

III. 14 § C.F.R. 61.23

IV. 14 § C.F.R. 61.113(a) and (b) and14 C.F.R. 61.133(a)

V. 14 § C.F.R. 91.7(a)

VI. 14 § C.F.R. 91.9

VII. 14 § C.F.R. 91.103

VIII. 14 § C.F.R. 91.109(a)

IX. 14 § C.F.R. 91.119

X. 14 § C.F.R. 91.121

XI. 14 § C.F.R. 91.151(a)

XII. 14 § C.F.R. 91.203 (a) and (b) and 14 C.F.R. 91. 715

XIII. 14 § C.F.R. 91.205 (b)

XIV. 14 § C.F.R. 91.215

XV. 14 § C.F.R. Subpart E (91.401 – 91.417)

3. Planned use of his DJI Phantom 3 Professional 

Operation of his sUAS, DJI Phantom 3 Professional, would be used 

primarily for private use such as on his hunting property, however Alex 

Bancroft would like to be able to put his sUAS to use commercially as well.

Alex Bancroft hopes to help fund graduate school by obtaining small, lowend, low-income jobs for friends and friends of the family by commercially 

operating a UAS. Areas where his sUAS could be used commercially 

include: Aerial photography and/or video for public and or private use 

including but not limited to golf courses, real estate, agriculture/livestock, 

land surveying, marketing for private businesses and construction sites. 

His sUAS will predominantly be used in south Louisiana where Alex 

Bancroft intends to help farmers with their rice fields and crawfish ponds. 

All of the above uses will only be conducted when requested and approved

by the appropriate landowners. 
4. How his request would benefit the public as a whole

There are many benefits to using a sUAS for commercial use to the 

general public. Some of these benefits include, but are not limited to:

• It can reduce the risk of fatalities that occur on a manned aircraft 

• It will be better for the environment because it will reduce 

hydrocarbon emissions, like those emitted by manned aircraft

• It is more cost effective for obtaining information such as information 

obtained for a farmer over his fields e.g. levee inspections. This 

benefits the consumers and the economy

• These exemptions may not affect the public anyway due to the size, 

weight, and the keeping of the sUAS in visual sight

5. Explanation of how the exemption would provide a level of safety at 

least equal to the existing rule 

Alex Bancroft requests an exemption from the following regulations as well 

as any additional regulations that may technically apply to the operation of 

the DJI Phantom 3 Professional:

I. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 

CFR § 91.203

Section 91.203 requires all civil aircraft to have a certificate of 

airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, 

establishes the procedural requirements for the issuance of Airworthiness

Certificates as required by FAR§ 91.203(a). Given the size of the UAS, its 

very light weight and the limited operating area associated with its 

utilization, it is unnecessary to go through the certificate of airworthiness 

process under Part 21 Subpart H in order to achieve or exceed current 

safety levels.

The Federal Aviation Act and Section 333 of the Reform Act both authorize 

the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the UAS 

involved. An analysis of these different criteria demonstrates that the UAS

operated without an airworthiness certificate, under the conditions 

proposed in that exemption, will be at least as safe, or safer, than a 

conventional aircraft with an airworthiness certificate.
II. 14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of marks; size 

of marks

Because of the size of this aircraft, it is impossible to correctly display the 

appropriate labels mentioned above. 

III. 14. C.F.R § 61.23: Medical certificates: Requirement and 

duration

Alex Bancroft believes that an Equivalent Level of safety can be reached if 

the operator has a valid driver's license. Alex Bancroft believes only a valid 

driver’s license is needed because of the size of the UAS, its structure, the 

limited flight area, and the safety features integrated in the autopilot.

IV. 14 C.F.R. § 61.3: Requirements for certificates, ratings and 

authorizations 14 C.F.R. § 61.113(a) & (b); 14 C.F.R. 

61.133(a): Private Pilot Privileges and Limitations; Pilot in 

Command; Commercial Pilot Privileges and Limitations

Given the safety features of the UAS, Alex Bancroft proposes that 

operators of the UAS should not be required to hold a commercial or 

private pilot certification. The equivalent level of safety will be achieved by 

using the integrated features of the aircraft to maintain a high level of 

safety during the different flight scenarios. Furthermore, the operational 

area is controlled and restricted. In addition, all flights are planned in 

advanced. The level of safety exceeds that of those who hold a commercial 

pilots license and operate a conventional aircraft for hire. 

V. 14 C.F.R. § 91.7(a): Civil aircraft airworthiness

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by 

FAR §91.203 (a) (1). Given the size and limited operating area associated 

with the aircraft to be utilized by the Applicant, an exemption from Part 21 

Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize

the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational 
capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS 

operated without an airworthiness certificate, in the restricted environment 

and under the conditions proposed will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

VI. 14 C.F.R. § 91.9: Civil aircraft flight manual, marking, and 

placard requirements

The equivalent level of safety will be achieved by keeping a hard copy of 

the user manual in close proximity to the operator. The equivalent level of 

safety will be provided by having the UAS marked on its fuselage as 

required by §45.29 (f) where the pilot, observer and others working with the 

UAS will see the identification of the UAS as "Experimental." The FAA has 

issued the following exemptions to this regulation to Exemptions Nos. 

10700, 8738, 10167 and 10167A.

VII. 14 C.F.R. § 91.103 Preflight Action 

 As FAA approved rotorcraft flight manuals will not be used an exemption is 

requested. An equivalent level of safety will be achieved by using the 

manufactures recommend preflight procedures per the information that is 

supplied in the DJI 3 Phantom Professional’s manual. Alex Bancroft will 

take further action by checking weather, flight battery requirements, landing 

and takeoff distances, the environment for where the flying will occur, and 

airspace considerations. 

VIII. 14 C.F.R. § 91.109(a): Flight Instruction

The equivalent level of safety during the in-flight training will be achieved 

by the manufacturer or affiliate providing the training as described in the 

manufacturer's training program and through the use of experienced and 

qualified instructors familiar with the UAS.

IX. 14 C.F.R. § 91.119: Minimum Safe Altitudes

No flight will be taken without the permission of the property owner or local 

officials. Compared to flight operations with aircraft weighing far more than 

those proposed herein and the lack of flammable fuel, any risk associated 
with these operations is far less than those presently presented with 

conventional aircraft. Given the size, weight, and speed of the DJI 

Phantom 3 Professional, an equivalent level of safety will be achieved. The 

UAS will be operated in a uncongested area where consent has been 

granted by exposed people. 

X. 14 C.F.R. 91.121: Altimeter settings

An equivalent level of safety will be achieved by the operator confirming 

the altitude of the launch site shown on the GPS altitude indicator before

flight. Also, the equivalent level of safety will be achieved given the size, 

speed, and weight of the DJI Phantom 3 Professional as well as the 

location of where it is being operated. Alex Bancroft will not fly unless 

permission of the landowner has been granted. Also, the low-altitude 

operations of a UAS will ensure that there is plenty of separation between it 

and a manned aircraft. The UAS does not have a barometric altimeter, 

rather it has a GPS altitude read out, thus exemption is requested.

XI. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR 

Conditions

The DJI Phantom 3 Professional will not be able to take off if the battery 

level is below a certain level (25% battery level). The manufactures have 

added a return to home action in the case that the battery level drops 

below 25%. The DJI Phantom 3 Professional battery provides roughly 20 

minutes of powered flight time 

XII. 14 C.F.R. § 91.203 (a) & (b) and 91.715: Carrying Civil 

Aircraft Certification and Registration and Airworthiness 

Certificates 

An equivalent level of safety will be achieved by keeping these documents 

at the ground Alex Bancroft can have immediate access to them, to the 

extent they are applicable to such UAS. The FAA has issued numerous 

exemptions to this regulation, examples include: Exemption Nos. 9565, 

9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. Because the UAS 

does not have a cabin nor a cockpit entrance, Alex Bancroft is requesting 

exemption from 91.715. 
XIII. 14 C.F.R. § 91.205 (b) Powered civil aircraft with standard 

category U.S. airworthiness certificates and equipment 

requirements

An equivalent level of safety will be achieved by using a video system that 

is displayed to the PIC which includes but is not limited to the following 

parameters: GPS altitude, GPS signal, battery and power remaining, flight 

time, UAS ground speed, etc. 

XIV. 14 C.F.R. § 91.215 ATC transponder and altitude reporting

The UAS will not have sufficient useful load and power supply to operate a 

transponder. To ensure level of safety the UAS will not be operated near a 

public airport. 

XV. 14 CFR Subpart E (91.401 - 91.417): Maintenance, Preventive 

Maintenance, and Alterations

All of the maintenance of the UASs will be performed by the owner 

(operator) according to the manufacturers user manual, which can be 

found at the bottom of this document under #7. Given that these section 

and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the applicant. Maintenance will be performed by 

the operator pursuant according to he flight manual attached at the end of 

this request. 

An equivalent level of safety will be achieved because these small UASs 

are very limited in size and will carry a small payload. They will operate

only in restricted areas for limited periods of time. If do occur the UAS can 

land and will be operating from no higher than 400 feet AGL. Before flying 

again, I will assure that the UAS in good working order as instructed by the 

DJI Phantom 3 Professional manual. 
6. Federal Register Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for 

publication to the Federal Register, should it be determined that publication 

is needed: Alex Bancroft seeks and exemption from the following rules:

14 C.F.R. Part 21, Subpart H; 14 C.F.R. 45.23; 14 C.F.R. 45.29; 14 C.F.R. 

61.23; 14 C.F.R. 61.113(a) and (b); 14 C.F.R. 61.133(a); 14 C.F.R. 91.7(a); 

14 C.F.R. 91.9; 14 C.F.R. 91.103; 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 

14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) and (b); 14 

C.F.R. 91.715; 14 C.F.R. 91.205(b); 14 C.F.R. 91.215; and 14 C.F.R. 

Subpart E (91.401 – 91.417) 

Approval of the above exemption requests will allow Alexander Bancroft to 

commercially operate his small and lightweight unmanned aerial systems, 

DJI Phantom 3 Professional. Alex Bancroft hopes to promote safety and 

help the public and property by reducing hydrocarbon emissions from 

manned aircraft. He also hopes that commercially operating his DJI 

Phantom 3 Professional will help consumers and the economy. 

The DJI Phantom 3 Professional weighs less than 25 pounds (see #8), is 

battery powered, which eliminates hydrocarbon emissions. The UAS 

operates slow speeds (see #8), close to the ground (see #8), in an 

uncongested environment, thus making it safer than conventional manned 

aircraft. The Phantom 3 will be transported to the area of interest and set 

up there before flight. It does not carry any passengers therefore risks 

involved or much less than that of a conventional manned aircraft. The 

UAS will provide a level of safety that is equivalent, if not better, than the 

level of safety of manned aircrafts, thus supporting the grant of exemptions 

requested above and allowing Alexander Bancroft to commercially operate 

his DJI Phantom 3 Professional. 

7. Link DJI Phantom 3 Professional Manual download 

http://www.dji.com/product/phantom-3/download

8. Link to DJI Phantom 3 Professional specifications 

http://www.dji.com/product/phantom-3/spec
If any additional information is need, or if you have any questions about this petition, 

please do not hesitate to contact me. 

Respectfully, 

Alexander Bancroft 

Cell: (318) 617-8938

Email: bancroft27@gmail.com