U.S. Department of Transportation, 

Peter P. Miller 

4981 Mallet Hill Dr 

Cincinnati, Oh 45244 

Docket Operations West Building Ground Floor, Room Wl2-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

05/20/2015 

Petition for 333 Exemption 

I, Peter P. Miller, Airline Transport Pilot (airman certificate #3028069), of 4981 

Mallet Hill Dr. Cincinnati Oh. 45244, am petitioning the Federal Aviation 

Administration (FAA) for an exemption from part 21, subpart H; and Sections 

45.23(b), 91.9(b)(2), 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) ofTitle 14, Code of Federal 

Regulations (14 CFR). This proposed exemption would allow me to operate a DJI 

Phantom Vision 3 Quad Copter Unmai:med Aerial System (UAS) for the purpose of 

aerial mapping, videographer arid real estate photography. The use of a UAS for . 

these activities will have a substantial social benefit. It will bring an over-head 

perspective to future customers that were previously only possible through the 

prohibitively expensive use of rotorcraft and fixed wing aircraft with expensive 

camera equipment. I would bring this service at an affordable price and due to the 

simple nature of the UAS, with substantial savings. 

Due to the ever-improving nature of this technology a new UAS can become obsolete 

within a few months of release. I am also seeking an exemption in addition the to 

one listed above, to include other unmanned aerial systems (UAS) that meet the 

operational limitations outlined in the notice of proposed rulemaking (NPRM) 

pertaining to the operation of small unmanned aircraft systems in proposed part 

107 to Title 14 Code of Federal Regulations (14 CFR). 

Safety 

I will utilize my knowledge as a professional pilot to maintain the highest level of 

safety during the proposed use of the UAS. Flight would consist of three parts: 

preflight, flight and post flight. 

The preflight will consist of extensive inspections of the area, the UAS and the 

airspace in which it will be operating. A detailed inspection of the UAS will be 

conducted and all major systems will be examined, including power plant, airframe 

and controls. Any discrepancy will be noted and if the discrepancy affects the safety 

of the flight, the flight will not: corimi.ence. . ' . 

Operations will only cominerice in reasonably saf~ environments that will be strictly 

controlled during the flight of the oAs. The area willbe surveyed for power lines, 
] 

elevated lights and other property with the potential to affect the safety of the flight 

There will be no flights within the proximity of active airports without first 

contacting the appropriate agencies or authorities to ensure the highest level of 

safety and compliance with all regulations. Operations will also not commence 

where there is a reasonable possibility of inadvertent physical contact with the 

populace. 

During the flight portion of the operation, safety will be the primary concern. Given 

the size, weight, speed and limited operating area ofthe UAS; flight will be 

inherently safe. The UAS will not be operated above individuals not associated with 

its operation and care will be given to avoid property that was noted during the 

preflight inspection of the area. 

During the post-flight debrief, all individuals associated with the operation will 

evaluate the success of the operation and address any concerns brought forward 

about the safety of the flight. Any pertinent issues will be noted and action will be 

taken to ensure the safety of future flights. 

Exemptions from regulations 

All proposed exemptions from regulations are listed below and are accompanied by 

reasoning as to why it would be unreasonable to comply with the regulation. 

• 14 CFR § 21 Subpart H: Airworthiness Certificates and 91.203 (a) and (b): 

Certifications required 

o Given the size, weight, speed, and limited operating area 

associated with the aircraft to be utilized, an exemption is requested and 

would meet the requirements for an equivalent level of safety under 14 CFR 

part 11 and Section 333 ofP.L. 112-95 (Section 333) 

• 14 CFR § 45.23: Display of marks; general 

o An exemption is requested because the UAS has no cabin, cockpit or 

pilot station on which to display certain words or phrases. Furthermore, is would be 

unreasonable to mark the aircraft with 2 inch lettering since the airframe has 

dimensions smaller than the minimal lettering requirement I will place the word 

"Experimental" on the airframe of the UAS as required by§ 45.29(t) so that anyone 

assisting as a spotter and I will see the markings. 

• 14 CFR § 91.9 (b) (2): Civil aircraft flight manual, marking and placard 

requirements 

o An exemption is requested from the cited regulations because the UAS 

manufacturer does not supply a flight manual that contains information found in 

manuals supplied by manufacturers of traditional aircraft. Also, due to the size, 

weight, speed and operating area of the aircraft to be utilized it would be unrealistic 

to expect it to. 

• 14 CFR § 91.119: Minimum safe altitudes 

o An exemption is requested from the cited regulations due to the 

purpose that the UAS being used was created for. This UAS is designed for use in an 

environment that is contrary to this regulation. 

Also, the UAS would not be operated at an altitude of more than 5 00 

feet above the surface, as to not interfere with any potential air traffic. • 14 CFR § 

91.121: Altimeter settings 
o An exemption is requested because no pitot static system is installed in the 

aircraft and due to the altitudes is operates at adherence to this regulation would be 

unrealistic and unnecessary. Also, GPS position information is transmitted to the 

aircraft controller, providing much more accurate information than what would be 

shown by a traditional altimeter. 

• 14 CFR § 91.151: Fuel requirements for flight in VFR conditions 

o Due to the nature of the aircraft being used, adherence to the 

regulation would be unrealistic. The UAS has an average flight time of 

approximately 25 minutes and a "return to home" function in the event of an 

impending power failure. Therefore, an exemption from the cited regulation is 

requested. 

• 14 CFR § 91.405(a): Maintenance required, 91.407(a)(1): Operation after 

maintenance, preventative maintenance, rebuilding or alteration, 91.409 (a)(2): 

Inspections, 91.417(a) and (b): Maintenance records 

o Exemptions are requested from the cited maintenance regulations because they 

only apply to traditional aircraft with an airworthiness certificate. 

Qualifications and closing 

By granting me a section 333 exemption I will be able to bring a service to my 

community that before, was associated with high cost and high environmental 

impact. As a professional pilot, the skills and knowledge that I have gained through 

training and experience will add an additional level of safety to the operation of the 

UAS. Coupled with an in-depth knowledge of airspace, Federal Aviation Regulations 

(FARs), safety of flight and science of flight information I believe there should be no 

question as to the soundness of my petition for exemption. 

*Note 

All information regarding the DJI Phantom 3 quad copter can be found on the 

manufacturers webpage below. Model specifications will be submitted with this 

document for ease of reference. 

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

Sincerely,