## R**. W. Zollinger Consulting Engineers, Inc.**

**Environmental Management Consultants Phone: (412) 264** **- 7776**  **1 4**  **08 Coraopolis Heights Road**  **Fax: (412) 264 -** **2558 Moon Township, PA 15108**  **E -** **Mail** : **rzoll710@aol.com**
July 26 , 2015 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12
- 140 1200 New Jersey

Avenue, SE Washington, DC 20590 **SUBJECT: Amendment To**  **Exemption** To Whom It May

Concern: The petitioner RW Zollinger Consulting Engineers would like to make an amendment to: FAA Exemption #11338 Regulatory

Docket No. FAA
-2015
-0021. **Changes to Exemtion:** 1. Include DJI	Phantom	3	Aircraft Unmanned Aircraft System The UAS proposed by

the petitioner is a proprietary design, conceived and constructed by DJI, and referred to as the DJI Phantom 3
. This aircraft has four rotors and four motors in a quadcopter configuration (X4). The petitioner states that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (PL 112
- 95). The petitioner further states that UAS operated without an airworthiness certificate in the restricted environment and under the conditions and limitations proposed by the petitioner will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate issued under 14 CFR part 21, Subpart H and not subject to the proposed conditions and limitations.

 The petitioner states that the unmanned aircraft (UA) to be operated under this request is less than 10 lbs with equipment loaded, flies at a speed of no more than 30 knots, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively

within private property.US Dept. of Transportation

Docket Operations July 26, 2015 Page 2

 The petitioner states that they will be operating their UA within Visual Line of sight. The operator will maintain visual contact with the UA without the aid of binoculars or any other method to see the UA
.
 The petitioner further describes that, in the event the UAS loses communications or its GPS signal, the UA will have the capability to return to a pre -determined location within the Security

P erimeter and land. Itwill also have the capability to abort a f

light in the event of unpredicted obstacles or emergencies. The DJI Phantom has a failsafe function preloaded from the manufacturer.

 The petitioner also states that the unmanned aircraft will be flown under 400 ft
. AGL. The DJI Phantom has an altitude read out which will be displayed on a video monitor along with a separate display on an IPAD. The altimeter will be **reset** to ground level at an altitude of zero feet. This will be part of a before flight checklist. A pre- flight, before takeoff checklist will be read and complied with for every flight. All of the flights will be operated in Class G airspace at this time. If flights occur under the shelf or inside Pittsburgh class B airspace. A COA application will be submitted. Notification to the local FSDO will be complied with. After communication with the FSDO appropriate local air traffic control will be notified for and appropriate NOTAM to be filed.

 The petitioner states that the radio remote control that operates the UA is in FCC compliance. The device complies with part 15 of the FCC rules. Sincerely,
Charles Zollinger, PIC Commercial Pilot 412
-72 0
- 3313 (mobile) Richard W. Zollinger, PE Principal Environmental Engineer 412
- 841
-7383 (mobile) rzoll710@aol. com