James Cordle, Hueytown AL Section 333 Exemption Petition

Page 1 of 10 October 2 2

, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request under Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)
and C ode of Federal Regulations Title 14 Part 11

Dear Sir or Madam,

I, James H. Cordle, respectfully petition the Secretary of Transportation and the Federal Aviation Administration (FAA) seeking an exemption from the Federal Aviation Regula tions (FAR) listed below in

Item 2

. The exemption shall grant permission to operate flight s of small u nmanned aircraft systems ( s UAS)

- under 55 pounds as defined by FMRA Section 331

- commercially in the National A irspace System (NAS) regulated by the FAA

.

Commercial s UAS flight operations under this exemption shall be subject to strict req uirements and
conditions set forth by the FAA. The exempted s UAS operations shall ensure an equivalent or better level of safety to current manned aircraft operations and under conditions determined by the FAA as required by FMRA Section 333. A grant of exemption would also serve to expedite integration of civil

s UAS into the NAS as man dated by Congress in FMRA Section 332

.

1. Contac t Information

James H. Cordle 6422 Aspen Lane Hueytown, AL 35023

- 6701 tmpbox13@charter.net

2. Request Exemption fro m the following 14 CFR Sections

14 CFR Part 21 S ubpart 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 (b) ; 14 CFR 91.109;

14 CFR 91.119 (b) & (c) ; 14 CFR 91.121;

14 CFR 91.151 (a ) (1) & (b) ; 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).James Cordle, Hueytown AL Section 333 Exemption Petition

Page 2 of 10 I, James H. Cordle, propos e to ut ilize the DJI Phantom 3 for commercial operations

. I have been designing, constructing and flying sUAS for over 3 years and have over 2 00 hours in the air without any public safety incident. The sUAS in my current invento ry employ DJI autopilot and master controller technology. This technology in conjunction with advanced DJI configuration software, permit the sUAS
to be prepare d for flight. The proposed DJI Phantom 3 is far more advanced with additional built

- in safety features , including a dedicated Transmitter/ Radio (T/R) and Ground S tation. With a communication range of 1.2 miles (2km), the Phantom 3 is suitable for a host of commercial interest and operations . In combination with the sUAS size, weight, speed and restricted operational parameters,
the conditions of the FMRA Section 333 shall be met.

For a more thorough and precise description of the technical and operational aspects of the DJI Phantom 3, please see documentation links listed in the Appendix

.

3. Reason for Relief and Extent of Relief Requested

14 CFR Part 21 S ubpart H : Airworthiness Certificates Concerning a irworthin ess certificates for flight s as indicated in the Subpart H, t he s UAS does not carry pilots, crew or passengers

, any explosives or flammable fuel

. Ther e is no onboard crew training or facilities for passenger exits

. There are no fuel venting or exhaust emissions due to the use of battery powered propulsion. As a result of the s UAS size, weight, speed and maneuverability, and restr icted operational boundaries the conditio ns of FMRA Section 333 are met or exceeded. Under these conditions, the level of safety meets or exceeds that of current manned aircraft operations. I therefore
request an e xemption of an airworthiness certificate in accordance with 14 CFR Part 21 Subpart H.

14 CFR 45.23 (b) : Display of marks
The s UAS is unmanned and does not have a cockpit, cabin, or pilot station on which to market certain words or phrases. The dimensions of lettering, even at minimums are too large for the available limited space. However, I shall comply with the FAA to the best of my ability and identify the s UAS with the largest available lettering that fits in any accessible space to preserve the equivalent level of safety. The
FAA has issued relief from this regulati on previously through Exemption Numbers 11850 and 1 1645

. I therefore request an exemption from 14 CFR 45.23 (b).

14 CFR 61.113 (a) & (b) : Private pilot privileges and limitations: Pilot in command Private pilots are limited to non

- commercial operations. T he s UAS does not ca rry a pilot, crew or passengers, and no flammable fuel . Thus, an equivalent level of safety as defined by current regulations
can be achieved without the need for a commercial pilot license. The s UAS is remotely controlled and a pilot license will not ensure remote contr ol operator skills. Nor does a pilot license ensure an understanding of the unique operational aspects associated with the num erous and different s UAS designs. Risks of operating the s UAS are far less than the risk s of commercial activities outlined in 14 CFR

Part 61 . A llowing a P ilot

- i n

- Co mmand (P IC ) with a private pilot license and substantial s UAS flight experience, as d etailed in similar FAA Exemption 11062, meet or exceeds current safety levels and I therefore request an exemptio n from 14 CFR 61.113 (a) and (b)

.

14 CFR 91.7 (a) : Civil aircraft airworthiness No person may operate a civil aircraft unless it is in an airworthy condition. The s UAS shall not require
an airworthiness certificate for the reasons stated above under 14 CFR Part 21 Subpart H. Assuming no
airworthiness certifica te will be issued, no FAR will exist for determining s UAS airworthiness. Nevertheless, certain procedures shall be followed prior to each flight to guarantee the s UAS is inJames Cordle, Hueytown AL Section 333 Exemption Petition

Page 3 of 10 airworthy condition. At a minimum, t hese procedures shall include the visual insp ection of electrical

a nd mechanical components, review of f light and maintenance logs , and stringent execution of p re

flight checklist

. Flight data is automatically recorded by the sUAS to aid in these efforts. As always, the public safety is the first and foremost responsibility. However, the sUAS represents a substantial investment that is not easily replaced. There is a commitment not only to public safety but to the
bu siness operations the sUAS make possibl e. It is therefore imperative that the sUAS be kept airworthy
at all times. These actions shall preserve or exceed an equivalent level of safety. I therefore request an exemption from 14 CFR 91.7 (a).

14 CFR 91.9 (b)(2) : Civil aircraft flight manual, m a rking and placard requirements

T he s UAS by definition is unmanned . T here are no pilots or crew onboard the s UAS to review any documentation. The di mensions of sUAS are insufficient for documentation storage . An equivalent
level of safety sha ll be maintained by keeping all relevant materials such as s UAS flight and maintenance
manuals on

- site and within reach of the operator and PIC at all times. All materials shall be in a format
suitable for immediate access. I therefore request an exempti on from 14 CFR 91.9 (b)(2).

14 CFR 91.103 (b) : Preflight action FAA approved flight manuals are not available for the sUAS. To sustain an equivalent level of safety

, all information surrounding the flight shall be r eviewed and approved prior to liftoff. This shall include but
not be limited to the following : a w eather check with wind speed not to exceed 10m/s (22 mph),
observe GPS satellite connection, observe s UAS T/R is fully charged, observe app lication s requiring internet connectivity are secure , observe flight battery levels are full

, complete compass calibration, verify that no

- fly zones including airports and restricted areas are known , observe that all manuals are
present, perform maintenance checks

, and guarantee and secure all authorizations and relevant permissions. The link for the “Safety Guidelines and Disclaimer” document located in the Appendix contain a more thorough and precise description. I request relief from regulation 14 CFR 91.103 (b)

.

14 CFR 91.109 : Flight instruction; s imulated instrument flight and certain flight tests By design, the s UAS does not have fully functional dual controls. The s UAS is an unmanned remotely
operat ed aircraft. There are no onboard pilots or crew. From the ground

, a single T/R communicates
with a frequency matched device onboard the aircraft called a Receiver

. The equivalent level of safety and control is maintained by numerous sUAS fail

- safe systems

. Certain systems are available to the operator and/or PIC at the T /R and others are autonomous on board the aircraft

. Many of the sUAS features are discussed in further detail in Item 5 below. However, for a more thorough and precise description, t he link for the “User Manual” document is located in the Appendix. I respectfully request
relief from 14 CFR 91.109.

14 CFR 91.119 (b) & (c) : Minimum safe a ltitudes Concerning the altitude of flight in congested and non

- congested areas, the s UAS shall not exceed the
400 feet altitude limit at any time. Nor, shall t he sUAS operate any closer than 500 feet from all non

participating persons, vehicles, and structures. All no

- fly zones including airports and restricted areas
shall be known and avoided. The link for the “DJI No

- Fly Zones” document found in the Appendix

contains a co mplete list of the sUAS no

- f ly and restricted areas. To further enhance the public safety,

t he s UAS includes a GPS

- enabled function for restricting flight altitude and distance . Called a
“G eofence”, the function restricts the sUAS to a preset three dimensional boundary as measur ed from
the Home P oint setting

. The Geofence can be manually adjusted to prevent accidental access into
unwanted areas and to avoid any potential obstacles. Utilization of the G eofence function in conjunction with the size, weight, speed and maneuverability of the s UAS provide a n equi valent orJames Cordle, Hueytown AL Section 333 Exemption Petition

Page 4 of 10 better level of safety than current manned aircraft operations. I request exemptio n from 14 CFR 91.119 (b) and (c)

.

14 CFR 91.121: Altimeter Settings Pertaining to flight al titude, there is no such Altimeter instrument to physically observe or set such that
the current altitude status can be confirmed. The s UAS incorporates 3 redundant systems to confirm
the current value of altitude : GPS, vision positioning, and b arometer. The GPS is the primary s UAS positioning system. Based on the status of current s UAS operational characteristics, the barometer can provide altitude when all other systems are inadequate. The altitude value is down linked from the in

flight s UA S by telemetry and shown on the ground station display. Considering the multiple systems to
confirm the value of altitude

, and the ground station display for continuous real

- time monitoring, an equivalent level of safety is maintained. I request exemptio n from 14 CFR 91.121.

14 CFR 91.151 (a ) (1) & (b) : Fuel requirements for flight in VFR conditions

With reference to f uel requirements for flight in VFR conditions, r elief is required to allow flight
duration’s representative of the battery powered class. The s UAS incorporates a n Intelligent Flight Battery ( IFB ) and an advanced power management system that displays and monitor s the level of battery power in real

- time. Based on the current level , the sUAS automatically takes the appropriate

action. The L ow B attery fail

- safe is triggered when power reserves are depleted to a point that may affect the safe Return

- to

- H ome (RTH) of the sUAS. If no action is taken by the operator within 10 seconds, a RTH is automatically executed . If a C ritical L ow B attery fail

- safe is triggered, the sUAS shall make preparations to land immediately. The sUAS has a max imum flight time of 23 minutes. B y adhering to the IFB power warnings

, an equivalent level of safety can be attain ed . T he sUAS automated warnings give ample t ime to either return to the prearranged landing position o r to land immediately . I therefore request exemption from 14 CFR 91.151 ( a ) (1) and (b)

.

14 CFR 91.203 (a) & (b): Civil a ircraft ; certifications r equired Similar to 14 CFR 91.9 (b)(2), the sUAS is unmanned. Due to the size and capacity of the sUAS

, there is no ability to carry or display certificate and registration documents onboard the aircraft. An equivalent level of safety shall be achieved by keeping these documents at the ground control p oint

, available to
the operator and PIC at all times

. I request exemption from 14 CFR 91.203 (a) and (b).

14 CFR 91.405 (a), 14 CFR 91.407 (a)(1), 14 CFR 91.409 (a)(2), 14 CFR 91.417 (a) & (b): Maintenance, preventative maintenance, inspections, records
As a result of the sUAS size, weight, speed, maneuverability and restricted operational boundaries the

sUAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. As these FARs only apply to aircraft with an airworthin ess certificate, I respectfully request relief from these regulations. Nevertheless, as stated above under 14 CFR 91.7 (a), certain procedures shall be followed prior to each flight to guarantee the s UAS is in airworthy condition. Flight data is automatic ally recorded by the sUAS and includes the aircraft telemetry, status in formation and other parameters. This data is
examined pre flight to ensure that all sUAS parts remain within manufacturer specifications

, and part life spans are well within safe limit s. Due to the size of the sUAS, weight and the fact the craft can easily land if any mechanical problem is encountered; an equivalent level of safety is maintained.

4. The Public Benefit

The exemption shall provide an alternative solution to traditional pr oblems. The sUAS technology is a much cheaper and safer, environment ally friendly choice over the larger manned aircraft currently inJames Cordle, Hueytown AL Section 333 Exemption Petition

Page 5 of 10 use today

. I propose to use this safer alternative in the aerial photography and videography industry, to provide relief from hazardous and treacherous inspections, and to survey and map r emote and isolated properties.

The sUAS technology brings affordable services to small budget companies. At the present, the only
solution for many of today’s problems involves large man ned aircraft . These aircraft have associative costs that make their usage expensive. These expenses are passed to the consumer when services are rendered. The resulting service is often priced to high for small, cost conscience and less af fluent businesses, thus limiting their profit and growth potential.

Con sider businesses wishing to capitalize on an aerial viewpoint of property. The more affluent business can absorb the huge cost associated with paying large manned aircraft to photograph or video a property. These photographs and videos can then be used in marketing and advertising campaigns to sale the property. Not able to afford this photographic service, the smaller business is at a distinct disadvantage. The exemption allows me to br ing affordable sUAS solution s to these cash strapped
businesses which shall allow them to compete with much larger, well

- financed companies.

Inspection services are not only cheaper, but safer. Once, an individual had to climb cell towers,
residential and building roofs, radio and TV broadcasting antennas, bridges, large solar arrays and wind
turbine farms, and high power line support towers. The risk to life and limb were high. The sUAS can be

u sed to inspect these and similar resources and only upo n finding a problem does an individual ever need to leave the ground.

Many resources to be inspected are remote and inaccess ible. Traveling to and from the job site location
can be time consuming and hazardous . The journey

- on foot or via vehicle

- leaves an impact on the

environment. The sUAS provides a method of pre

- inspecting these isolated areas saving time traveling
to and from the site with little or no risk of peril to the participating individuals. The damage to the local ecology is also mi nimized. The sUAS makes inspection se rvices safer and more efficient , thus bringing
relief to this area of service.

T he community is made safer

. Each time a large manned aircraft take s flight there is the potential for a catastrophic failure. A crash c ould ignite flammable fuel onboard the aircraft

, causing severe damage to property surrounding the cra sh site, not to mention loss of life . If the crash were in a remote area, the danger of possibly start ing wild fires could put firefighters and wildlife at risk. The mere act of fueling the manned aircraft on the ground is a potentia l danger to the local community. The sUAS operates on battery power and carries no flammable fuel onboard and is therefore much safer.

The sheer size of the manned aircraft alo ne is cause for concern. T he sUAS weight and dimensions occupy a much s maller footprint. In the event of a sUAS failure, t he damage to the general population and property is minimized at the point of impact.

From a human safety perspective, the sUAS is a superior alternative. The sUAS is unmanned and has no pilots or crew to protect. In addition, t he sUAS has numerous built

- in fail

- safe procedures and systems to assist the operator and help lower, if not eliminate human pilot error. When taking into account these features with small size, weight, and no combu stible fuel, the public safety is greatly enhanced.James Cordle, Hueytown AL Section 333 Exemption Petition

Page 6 of 10 Noise and air pollution are virtually eliminated in the sUAS

. There are no fossil fuel emissions, n or is
there the need for recycl ing of oil and other lubricants which are potential environmental hazards.
The se factors result in a lower environment al impact to the local ecosystem and wildlife habitat

.

By using sUAS to replace large ma nned aircraft, airport c ongestion is redu ced . Not only is the amount and size of air traffic operating in the NAS reduced, but airport automobile traffic as well. These reductions mean less noise and air pollution to the community and environment. By l owering the amount of congestion, a lower number of aircraft and automobile accidents are possible which should result in improved public safety.

5. Reasons why the exemption would not adversely affect safety, or how the exemption would provide a level of safety at leas t equal to the existing rule

The sUAS operation shall exist strictly according to FAA regulations and the guidelines set f orth by the
FMRA. The list of FAR’s for relief in Section 2 shall not impact public safety as described in Section 3. In

some insta nces, the exempted FAR exceeds the regulations by guaranteeing an equivalent level of safety at or above current manned aircraft operations. To briefly summarize :

**•** The sUAS weighs 1280g or 2.82 pounds, much less than the 55 pound regulation under FMRA

Sec tion 331

.

**•** The sUAS shall operate below the maximum 400 foot altitude.

**•** A visual

- line

- of

- sight (VLOS) with the sUAS shall be maintained by the operator at all times.

**•** The sUAS shall be operated within the VLOS of the PIC and VO at all times.

**•** The maximum flight time of the sUAS is 23 minutes. However, the IFB fail

- safe power level
alerts shall be strictly obeyed , allowing the sUAS to safely return home or land immediately.

**•** The sUAS shall operate only during go od weather daylight conditions an d not in wind levels exceeding 10 m/s or 22 mph.

**•** The max imum operating speed of the sUAS is 16m/s or 35 mph , and a safe operating speed shall
be maintained at all times such that the craft is under stable operating control.

**•** A minimum of 5 miles shall be maintained from any airport

. A distance of 500 feet from bystanders and people not participating in the flight operation shall be maintained where possible.

**•** The sUAS shal l only operate in controlled envi ronments and away fro m power lines , elevated lights, and congested areas where plausible

.

**•** A ll necessary permissions shall be acquired from the authorized representative of any property connected with the flight operation.

**•** Extensive preflight and maintenance checklist are rev iewed prior to each flight operation.James Cordle, Hueytown AL Section 333 Exemption Petition

Page 7 of 10 In addition to the above, certain sUAS enhance safety with built

- in fail

- saf e’s and operational control systems for maintaining stable and secure flight. The sUAS is one such aircraft that include s the following functionality to further enhance public safety :

**•** An automatic flight log that records the details of flight to include route, time, distance, locations and any telemetry such as altitude and speed. This functionality assists in the maintaining of the aircraft hardware to insure a safe range of operational lifetime.

**•** The global satellite navigation system s

- GPS and GLONASS

- provide real

- time position and velocity information to the sUA S. The use of both systems makes available more satellites

– a minimum of 36

- so that lock

- on, hovering and positioning can be fixed more quickly and accurately . The two systems combined increase the number of satellites and coverage available
to the sUAS at any one time , thus minimizi ng the loss of GPS lock

.

**•** R eturn

- to

- home (R TH ) facilities allow the aircraft to return ho me through autonomous or
manual operation. The sUAS employs a m ulti

- level RTH function: Smart, Low Battery, and Fail

safe :

o Smart is activated when the operator taps th e RTH button on the T/R

, t he sUAS shall automatically RTH and land

.

o Low Battery is triggered when power is depleted to a point that may affect the safe RTH
of the aircraft. The operator is alerted and has 10 seconds to decide to proceed with
the flight operations or RTH and land

. If no action is taken the aircraft will RTH and land

.

o Fail

- safe is activated when the T/R signal is lost for more than 3 seconds. The operator may regain control of the aircraft if the T/R signal connection is re

- established. If not,

t he sUAS shall automatically RTH and land if power permits, else the air craft will land immediately.

**•** An Intelligent Flight Battery ( IFB ) monitor’s battery power at all times and calculates the distance from home power continuously. The IFB produ ces multiple aud io and visual warning
levels and b ased on what level of power is current, the sUAS automatically enters one of two
modes:

o Low Battery, described in the previous bullet point.

o Critical Low B attery mode is activated and the sUAS shall descend and land safely. The operator is kept fully aware of the current status of sUAS power at all times.

**•** There are autonomous fail

- safe systems dependent upon battery power and T/R signal

transmission. The IFB and RTH systems described above are at times based upon each other’s

status

. F or a more thorough description see t he link for the “User Manual” document located in the Appendix.

**•** Having GPS, t he sUAS has an Int elligent Flight M ode that assists the operator with aircraft orientation and preset automat ic flight maneuvers . T he Intelligent Orientation Control (IOC)
mode s ; Course Lock and Home Point L ock

, allows the operator to lock the orientation of the
aircraft and focus more on other operations

. The preset modes P oint

- of

- In terest, Follow

- M e and Waypoints allow the aircraft to operate automatically with each maneuver offering unique advantages

.

**•** Multiple flight antennae, one in each leg, help ensure the aircraft is always connected

.James Cordle, Hueytown AL Section 333 Exemption Petition

Page 8 of 10 **•** A mobile application that connects the sUAS to a ground sta tion to monitor flight parameters and aircraft telemetry. The sUAS allow the operator to s ee and hear video and audio in real

time for ranges up to 1.2 miles or 2 km.

**•** Built

- in No

- Fly Zones and a user programmable Geofence prevent accidental access into
unauthorized and restricted areas.

**•** The sUAS has a unique Beginner Mode to aid novice operators in developing flight control skills.
This is particularly important for that PIC new to the sUAS system. This mode isolates the operator within a specific boundary and prevents contact with unauthorized regions. This is not only useful for developing sUAS skills but can also be used to limit mission boundaries d uring flight operations.

**•** U nprecedent ed control systems allow the sUAS to manage flight operations with simple manual intervention. With a single button tap on the T/R t he A uto

- Takeoff feature allows the sUAS to

turn on its motors and rise to a pre

- set height. It will then hover perfectly in place until directed by the operator on a course of action. Another feature is available when the operator loses
control of the craft during flight. Just by releasing the T/R control sticks at any point during flight, the sUAS will au tomatically hover in place at the current altitude. With the aircraft now stable, the operator can rega in control and make a more composed decision on whether to fly
or land the aircraft.

The above list is by no means exhaustive. For a more complete and thorough explanation of the sUAS capabilities , see the document ation links located in the Appendix.

6. A Summary for the Federal Register

a. The Regulations from which James H. Cordle seeks an exemption:

14 CFR Part 21 S ubpart 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 (b) ; 14 CFR 91.109; 14 CFR 91.119 (b) & (c) ; 14 CFR 91.121; 14 CFR 91.151 (a ) (1) & (b) ; 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 91.4 17 (a) & (b).

b. A brief description of the exemption James H. Cordle seeks: This exemption shall authorize James H. Cordle to commercially operate a small Unmanned Aircraft System (sUAS) that meets or exceeds current manned aircraft operations for the purpose of conducting aerial photography and videogra phy, inspections and surveys over the National Airspace System (NAS) of the United States

.

It is believed that the requested exemption is not a first time or precedent setting circumstance as defined by the FAA. The regulations listed above have previously been granted relief

– and under similar
conditions

- as evidenced by the list of similar exemptions found using the Automated Exemption System (AES)

. These are listed below in item 7. In e ach instance the exemption applied to an aircraft weighing less than 55 poun ds, by definition a sUAS. Even a relatively small search found exemptions using aircraft identical to the one proposed in this request. In the interest of public safety , eliminati ng the potential hazards with regard to manned aircraft operations is advantageous and beneficial.James Cordle, Hueytown AL Section 333 Exemption Petition

Page 9 of 10 7. Any Additional Information, Views, Or Arguments Available

The FMRA Section 333 defines the requirements necessary to operate a sUAS in the NAS without an
airworthiness certificate. As affirmed above, the sUAS size, weight, speed, maneuverability and restricted operational boundaries validate the sUAS meets the conditions of FMRA Section 333 for operation without an airworthiness cert ificate. The explanation above details how the sUAS not only meets, but often exceeds an equivalent level of safety to typical manned aircraft operations. The
resultant factor s are a more effec tive use of technology and enhancement to public safety.

Usi ng the AES

, a simple search found the following exemptions demonstrate the FAA has previously granted relief from the specific FAR’s outlined above: 11850, 11795, 11677, 11645, 11542, 11531, 11529, 11522, 11414, 11217 and 11062

. This is by no means an exhaustive list but only a sample over time to illustrate that the above FAR’s have previously been given relief approv al

.

In particular

, more recent e xemptions

- searched and found at “ Authorizations Granted via Section 333 Exemptions ”

- 1290 4, 12871 and 12859 apply to the proposed sUAS the DJI Phantom 3.

In addition

, the national s ecurity is not an issue as there are no dangerous materials or explosives
carried onboard the sUAS.

Conclusions

The Reform Act passed by Congress has already proclaimed that it’s in the public’s best interest to integrate civil s UAS into the NAS as soon as practicable. The granting of th is exemption shall expedite the process mandated by Congress in the FMRA but no t at the expense of public safety

. A s systematically described above , the sUAS can be included in the NAS without jeopardizing safety.

Furthermore, the above explanation clearly illustrates improvements in areas other than public safety.

T here is less impact on the environment. The use of individuals to perform treacherous tasks is greatly reduced, if not in certain circumstances eliminated. The services rendered are economically superior

.

I, James H. Cordle, i n accordance with 14 CFR 11.81 and FMRA Section 333, respectfully request that the

FAA Administra tor grant this p e tition for exemption and allow myself to commercial ly operat e sUAS in
the NAS. Furthermore , I shal l strictly obey any FAA guidelines and restrictions imposed by the granting
of this exem ption to the best of my ability

.

Sincerely,

James H. Cordle tmpbox13@charter.net

Appendix

The following URLs are provided should the reviewing authority want a more thorough and complete description of the DJI Phantom 3 and its many features and safety subsystems:James Cordle, Hueytown AL Section 333 Exemption Petition

Page 10 of 10 http://www.dji.com/product/phantom

- 3/download/

**•** Phantom 3 Advanced User Manual

**•** Phantom 3 Advanced Quick Start Guide

**•** Phantom 3 Profes sional/Advanced Safety Guidelines and Disclaimer

**•** Phantom 3 Professional/Advanced Intelligent Flight Battery Safety Guidelines

http://www.dji.com/product/phantom

- 3/video

**•** Phantom 3 Video Tutorial

http://flysafe.dji.com/no

- fly

**•** DJI No

- Fly Zones

Glossary

AES Automated Exemption System

CFR Code of Federal Regulations

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

FMRA FAA Modernization and Reform Act of 2012

GPS Global Positioning System

GLONASS Global Navigation Satellite System

IFB Intelligent Flight Battery

IOC Intelligent Orientation Control

NAS National Airspace System

P IC Pilot

- in

- Command

RTH Return

- to

- Home

sUAS small Unmanned Aircraft System

T/R Transmitter/Radio

VFR Visual Flight Rules

VLOS Visual Line

- of

- Sight