R. W. Zollinger Consulting Engineers, Inc.

Environmental Management Consultants Phone: (412) 264-7776

1408 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 Perimeter and land. It will also have the capability to abort a flight 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

412-720-3313 (mobile)

Richard W. Zollinger, PE

Principal Environmental Engineer

412-841-7383 (mobile)

rzoll710@aol.com