James Cordle, Hueytown AL Section 333 Exemption Petition

Page 1 of 10

October 22, 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 Code 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 Regulations (FAR) listed below in 

Item 2. The exemption shall grant permission to operate flights of small unmanned aircraft systems 

(sUAS) - under 55 pounds as defined by FMRA Section 331 - commercially in the National Airspace 

System (NAS) regulated by the FAA.

Commercial sUAS flight operations under this exemption shall be subject to strict requirements and 

conditions set forth by the FAA. The exempted sUAS 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 

sUAS into the NAS as mandated by Congress in FMRA Section 332.

1. Contact Information

James H. Cordle

6422 Aspen Lane

Hueytown, AL 35023-6701

tmpbox13@charter.net

2. Request Exemption from the following 14 CFR Sections

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 (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, propose to utilize the DJI Phantom 3 for commercial operations. I have been 

designing, constructing and flying sUAS for over 3 years and have over 200 hours in the air without any 

public safety incident. The sUAS in my current inventory employ DJI autopilot and master controller 

technology. This technology in conjunction with advanced DJI configuration software, permit the sUAS 

to be prepared 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 Station. 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 Subpart H: Airworthiness Certificates

Concerning airworthiness certificates for flights as indicated in the Subpart H, the sUAS does not carry 

pilots, crew or passengers, any explosives or flammable fuel. There 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 sUAS size, weight, speed and maneuverability, and restricted 

operational boundaries the conditions 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 exemption of an airworthiness certificate in accordance with 14 CFR Part 21 Subpart H.

14 CFR 45.23 (b): Display of marks

The sUAS 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 sUAS 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 regulation previously through Exemption Numbers 11850 and 11645. 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. The sUAS does not carry 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 sUAS is remotely controlled and a

pilot license will not ensure remote control operator skills. Nor does a pilot license ensure an 

understanding of the unique operational aspects associated with the numerous and different sUAS 

designs. Risks of operating the sUAS are far less than the risks of commercial activities outlined in 14 CFR 

Part 61. Allowing a Pilot-in-Command (PIC) with a private pilot license and substantial sUAS flight 

experience, as detailed in similar FAA Exemption 11062, meet or exceeds current safety levels and I 

therefore request an exemption 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 sUAS shall not require 

an airworthiness certificate for the reasons stated above under 14 CFR Part 21 Subpart H. Assuming no 

airworthiness certificate will be issued, no FAR will exist for determining sUAS airworthiness. 

Nevertheless, certain procedures shall be followed prior to each flight to guarantee the sUAS is in 
James Cordle, Hueytown AL Section 333 Exemption Petition

Page 3 of 10

airworthy condition. At a minimum, these procedures shall include the visual inspection of electrical 

and mechanical components, review of flight and maintenance logs, and stringent execution of preflight 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 

business operations the sUAS make possible. 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, marking and placard requirements

The sUAS by definition is unmanned. There are no pilots or crew onboard the sUAS to review any 

documentation. The dimensions of sUAS are insufficient for documentation storage. An equivalent 

level of safety shall be maintained by keeping all relevant materials such as sUAS 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 exemption 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 reviewed and approved prior to liftoff. This shall include but 

not be limited to the following: a weather check with wind speed not to exceed 10m/s (22 mph), 

observe GPS satellite connection, observe sUAS T/R is fully charged, observe applications 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; simulated instrument flight and certain flight tests

By design, the sUAS does not have fully functional dual controls. The sUAS is an unmanned remotely 

operated 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 onboard the aircraft. Many of the sUAS 

features are discussed in further detail in Item 5 below. However, for a more thorough and precise 

description, the 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 altitudes

Concerning the altitude of flight in congested and non-congested areas, the sUAS shall not exceed the 

400 feet altitude limit at any time. Nor, shall the sUAS operate any closer than 500 feet from all nonparticipating 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 complete list of the sUAS no-fly and restricted areas. To further enhance the public safety, 

the sUAS includes a GPS-enabled function for restricting flight altitude and distance. Called a 

“Geofence”, the function restricts the sUAS to a preset three dimensional boundary as measured from 

the Home Point setting. The Geofence can be manually adjusted to prevent accidental access into 

unwanted areas and to avoid any potential obstacles. Utilization of the Geofence function in 

conjunction with the size, weight, speed and maneuverability of the sUAS provide an equivalent or 
James Cordle, Hueytown AL Section 333 Exemption Petition

Page 4 of 10

better level of safety than current manned aircraft operations. I request exemption from 14 CFR 91.119

(b) and (c).

14 CFR 91.121: Altimeter Settings

Pertaining to flight altitude, there is no such Altimeter instrument to physically observe or set such that 

the current altitude status can be confirmed. The sUAS incorporates 3 redundant systems to confirm 

the current value of altitude: GPS, vision positioning, and barometer. The GPS is the primary sUAS 

positioning system. Based on the status of current sUAS operational characteristics, the barometer can 

provide altitude when all other systems are inadequate. The altitude value is down linked from the inflight sUAS 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 exemption from 14 CFR 91.121.

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

With reference to fuel requirements for flight in VFR conditions, relief is required to allow flight 

duration’s representative of the battery powered class. The sUAS incorporates an Intelligent Flight 

Battery (IFB) and an advanced power management system that displays and monitors the level of 

battery power in real-time. Based on the current level, the sUAS automatically takes the appropriate 

action. The Low Battery fail-safe is triggered when power reserves are depleted to a point that may 

affect the safe Return-to-Home (RTH) of the sUAS. If no action is taken by the operator within 10

seconds, a RTH is automatically executed. If a Critical Low Battery fail-safe is triggered, the sUAS shall 

make preparations to land immediately. The sUAS has a maximum flight time of 23 minutes. By 

adhering to the IFB power warnings, an equivalent level of safety can be attained. The sUAS automated 

warnings give ample time to either return to the prearranged landing position or to land immediately. I 

therefore request exemption from 14 CFR 91.151 (a)(1) and (b).

14 CFR 91.203 (a) & (b): Civil aircraft; certifications required

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 point, 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 airworthiness 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 sUAS is in airworthy condition. Flight data is automatically recorded

by the sUAS and includes the aircraft telemetry, status information and other parameters. This data is 

examined preflight to ensure that all sUAS parts remain within manufacturer specifications, and part life 

spans are well within safe limits. 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 problems. The sUAS technology is a 

much cheaper and safer, environmentally friendly choice over the larger manned aircraft currently in 
James 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 remote 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 manned 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 affluent 

businesses, thus limiting their profit and growth potential.

Consider 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 bring affordable sUAS solutions 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 

used to inspect these and similar resources and only upon finding a problem does an individual ever 

need to leave the ground. 

Many resources to be inspected are remote and inaccessible. 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 minimized. The sUAS makes inspection services safer and more efficient, thus bringing

relief to this area of service.

The community is made safer. Each time a large manned aircraft takes flight there is the potential for a 

catastrophic failure. A crash could ignite flammable fuel onboard the aircraft, causing severe damage to 

property surrounding the crash site, not to mention loss of life. If the crash were in a remote area, the 

danger of possibly starting wildfires could put firefighters and wildlife at risk. The mere act of fueling the 

manned aircraft on the ground is a potential 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 alone is cause for concern. The sUAS weight and dimensions 

occupy a much smaller footprint. In the event of a sUAS failure, the 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, the 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 combustible 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, nor is 

there the need for recycling of oil and other lubricants which are potential environmental hazards. 

These factors result in a lower environmental impact to the local ecosystem and wildlife habitat.

By using sUAS to replace large manned aircraft, airport congestion is reduced. 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 lowering 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 least equal to the existing rule

The sUAS operation shall exist strictly according to FAA regulations and the guidelines set forth 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 instances, 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 

Section 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 good weather daylight conditions and not in wind levels 

exceeding 10 m/s or 22 mph.

• The maximum 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 shall only operate in controlled environments and away from power lines, elevated 

lights, and congested areas where plausible.

• All necessary permissions shall be acquired from the authorized representative of any property 

connected with the flight operation.

• Extensive preflight and maintenance checklist are reviewed 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-safe’s and operational control 

systems for maintaining stable and secure flight. The sUAS is one such aircraft that includes 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 systems - GPS and GLONASS - provide real-time position and 

velocity information to the sUAS. 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 minimizing the loss of GPS lock.

• Return-to-home (RTH) facilities allow the aircraft to return home through autonomous or 

manual operation. The sUAS employs a multi-level RTH function: Smart, Low Battery, and Failsafe:

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

the sUAS shall automatically RTH and land if power permits, else the aircraft 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 produces multiple audio and visual warning 

levels and based 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 Battery 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. For a more thorough description see the link for the “User Manual” document located in 

the Appendix.

• Having GPS, the sUAS has an Intelligent Flight Mode that assists the operator with aircraft 

orientation and preset automatic flight maneuvers. The Intelligent Orientation Control (IOC)

modes; Course Lock and Home Point Lock, allows the operator to lock the orientation of the 

aircraft and focus more on other operations. The preset modes Point-of-Interest, Follow-Me 

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 station to monitor flight parameters 

and aircraft telemetry. The sUAS allow the operator to see and hear video and audio in realtime 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 during 

flight operations.

• Unprecedented control systems allow the sUAS to manage flight operations with simple manual 

intervention. With a single button tap on the T/R the Auto-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 automatically hover in place at the current altitude. With the aircraft now 

stable, the operator can regain 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 documentation 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 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 (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).

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 videography, 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 each instance the exemption applied to an aircraft 

weighing less than 55 pounds, 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, eliminating 

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 certificate. 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 factors are a more effective use of technology and enhancement to public safety.

Using 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 approval.

In particular, more recent exemptions - searched and found at “Authorizations Granted via Section 333 

Exemptions” - 12904, 12871 and 12859 apply to the proposed sUAS the DJI Phantom 3.

In addition, the national security 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 sUAS into the NAS as soon as practicable. The granting of this exemption shall expedite 

the process mandated by Congress in the FMRA but not at the expense of public safety. As 

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.

There 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, in accordance with 14 CFR 11.81 and FMRA Section 333, respectfully request that the 

FAA Administrator grant this petition for exemption and allow myself to commercially operate sUAS in 

the NAS. Furthermore, I shall strictly obey any FAA guidelines and restrictions imposed by the granting 

of this exemption 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 Professional/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

PIC 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