November 20,2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC

The name and address of the petitioner is:

Fairfield CT Emergency Services

Attn: Chris Lyddy, Deputy Chief of Police

100 Reef Road

Fairfield, Connecticut 06824

Ph: 203-254-4826

Email: clyddy@fairfieldct.org

Re: Exemption Request under Section 333

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”)

and 14 C.F.R. Part 11, Fairfield CT Emergency Services, the operator of the

DJI Phantom 3 Unmanned Aircraft System (“UAS”), seeks an exemption from the Federal

Aviation Regulations (“FARs”) listed below.

The requested exemption would permit the Town of Fairfield Connecticut Emergency Services to 

operate their DJI Phantom 3 Professional , which weighs under 6.5 lbs and produced by DJI, for Search 

and Rescue, and photography of critical infrastructure:

Search and Rescue for emergency services and operations

Safety and security of critical infrastructure 

Police and Firefighter Training

The DJI Phantom 3 uses an onboard camera to capture high quality digital images of hazardous areas 

and emergency operations areas. Use of the DJI Phantom 3 for aerial emergency operations reduces the 

need to operate conventional aircraft for the same purpose and provides very high quality imagery at a 

fraction of the cost. These savings result in enhanced efficiency and productivity for the affected 

activities, as well as environmental benefits. Additionally, there is increased public safety by using the 

DJI Phantom 3 due to the elimination of pilots operating over hazard zones. 
Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to currently authorized operations using manned aircraft 

and under conditions as may be modified by the FAA as required by Section 333.

The regulations from which the exemption is requested are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 91.7(b);

14 C.F.R. 91.9(b)(2);

14 C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(2);

14 C.F.R. 91.417(a).

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rulemaking required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system.” Id. §333(c) (emphasis added)

Applicant interprets this provision to place the duty on the Administrator to not only process 

applications for exemptions under section 333, but for the Administrator to craft conditions for the safe 

operation of the UAS, if it should be determined that the conditions set forth herein do not fulfill the 

statutory requirements for approval. The Federal Aviation Act expressly grants the FAA the authority to 

issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act that includes sUASs, from the requirement that all civil aircraft must 

have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the
Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49

USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Fairfield CT Emergency Services sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They 

operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, 

and move in the vertical and horizontal plane simultaneously. They will operate only in line of sight and 

will operate only within a sterile area. Such operations will insure that the sUAS will “not create a hazard 

to users of the national airspace system or the public.” Specific operational sUASs are the DJI Phantom 

3. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a 

maximum gross weight of 2 pounds 13.1 ounces, a length of 23.2 inches, width of 23.2 inches, height of 

11.8 inches, and a maximum speed of approximately 35.8 MPH. The DJI Phantom 3 UAs are equipped 

with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI Phantom 3

UAs that will be operated by Fairfield CT Emergency Services will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R Part 45, Identification and Registration Marking.

Reform Act Section 333 (b).

Given the small size of the sUASs involved and the restricted sterile environment within which they will 

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant 

sUASs will operate, approval of the application presents no national security issue. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and the significant 

public benefit, including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing UASs, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without 

delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least 

an equivalent or even higher level of safety to operations under the current regulatory structure 

because the proposed operations represent a safety enhancement to the already safe operations 

conducted with conventional aircraft. These limitations and conditions to which Fairfield CT Emergency 

Services agrees to be bound when conducting commercial operations under an FAA issued exemption 

include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.
3. Maximum total flight time for each operational flight will be 45 minutes. Flights will be terminated at 

25% battery power reserve should that occur prior to the 45 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above 

an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and/or the 

Camera Operator.

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s certificate and 3rd class medical 

certificate.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who 

possess the necessary PIC qualifications, is also present (i.e. the Visual Observer), that person can also 

be designated as the PIC.

8. The UAS will only operate within a confined “Sterile Area” of the flight operations area.

9. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s activities. It 

will be mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing.

10. The operator will obtain the consent of all persons involved and ensure that only consenting persons 

will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based 

upon an equivalent level of safety determination.

11. Pilot and observer will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated.

12. Observer and pilot will at all times are able to communicate by voice and/or text.

13. Written and/or oral permission from the relevant property holders will be obtained.

14. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

15. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a 

pre-determined location within the Security Perimeter and land.

16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

size, weight, speed, operational capability, and proximity to airports and populated areas of the 

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.
The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area 

as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and monitored by both the operator, pursuant to the Manual’s requirements, and under the 

requirements and in compliance with local public safety requirements, to provide security for the area 

of operation as is now done with conventional filming. The FAA will have advance notice of all 

operations. These safety enhancements, which already apply to civil aircraft operated in connection 

with motion picture and television production, provide a greater degree of safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued under 

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no 

credible threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial 

external load. The FAA has issued the following exemptions to this regulations Exemptions Nos. 11251.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "lightsport," "experimental," or “provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS 

will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be 

placed. Given the size of the sUAV, two-inch lettering will be impossible. The word “Experimental” will 

be placed on the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the 

UAS as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions, 

but not limited to, Nos. 10700, 8738,

10167 and

10167A, 11256, 11251.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a 

commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot 

and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance. The level of safety

provided by the requirements included in the Manual exceeds that provided by a single individual 

holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the 
operation of the sUAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with a private 

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no 

FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, 

as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless 

there is available in the aircraft a current approved airplane or Rotorcraft

Flight Manual, approved manual material, markings, and placards, or any combination thereof. The 

sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, 

not only because there is no pilot on board, but because there is no room or capacity to carry such an 

item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has 

issued the following exemptions to this regulation, but not limited to: ExemptionNos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700,11251, and 11256.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption 

will be needed. The PIC will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that 

is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and 

remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via radio 

communications. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption 

Nos.5778K & 9862A.The equivalent level of safety provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption 

is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 

AGL, or not more than 200 above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, except for the limited conditions stated in 

the Manual, the UAS will never operate at higher than 400 AGL. It will however be operated in a 

restricted area with security perimeter, where buildings and people will not be exposed to operations 

without their pre-obtained consent. The equivalent level of safety will be achieved given the size, 

weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without 

the required permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the aerial activity, all affected individuals will be aware of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more 

than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently presented with conventional aircraft operating at or below 

500 AGL other industries. In addition, the low-altitude operations of the sUAS will ensure separation 

between these small-UAS operations and the operations of conventional aircraft that must comply with 

Section91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to 

an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS 

altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown 

on the GPS altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after 

that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the sUAS provides approximately 30-50 minutes of powered flight. To meet the 

30-minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 

minutes in length. Given the limitations on the UAS’s proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR 

conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. 

See Exemption 10673 (allowing Fairfield CT Emergency Services to operate without compliance with FAR 

91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners 

or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve 

fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the size 
and speed of the small UAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the 

utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to

45 minutes or 25% of battery power whichever happens first. This restriction would be more than 

adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 

10808, and 11251.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the 

following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) 

of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the 

sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to 

the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11251, and 

11256.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and 

others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these 

sections will not apply to the applicant. The operator pursuant to the flight manual and operating 

handbook will accomplish maintenance. An equivalent level of safety will be achieved because these 

small UASs are very limited in size and will carry a small payload and operate only in restricted areas for 

limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating 

from no higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the

UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best 

suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the
Federal Register, should it be determined that publication is needed:

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9

(b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 

(a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or 

less).

Approval of exemptions allowing commercial operations of sUASs, will enhance safety by reducing risk. 

Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet 

from the subjects being filmed and in extreme proximity to people and structures and present the risks 

associated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large amounts of jet A or 

other fuel. Such aircraft must fly to and from the operational location. In contrast, a sUAS weighing 

fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass 

and lack of combustible fuel carried on board. The sUAS is carried to the operation site and not flown. 

The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated 

with manned aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined 

above, will provide an equivalent level of safety supporting the grant of the exemptions requested 

herein, including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile 

environment and, as a result, are far safer than conventional operations conducted with turbine 

helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior consent 

and knowledge. Filming will be of people who have also consented to being filmed or otherwise have 

agreed to be in the area where filming will take place. The grant of this exemption request will provide 

improved safety in both day and night operations. Satisfaction of the criteria provided in Section 333 of 

the Reform Act of 2012--size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of sight and national security – provide more than adequate 

justification for the grant of the requested exemptions allowing commercial operation of applicant’s 

UAS. It is of note that certain public safety operations may involve advanced monitoring technology such 

as Infrared Red, Night Vision, etc. These specific operations will be governed pursuant to all applicable 

Local, State, and Federal laws regarding search and seizure including court approval of said operations 

via search warrant.

Conclusion

As set forth herein, Fairfield CT Emergency Services seeks an exemption pursuant to 14 C.F.R 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation 

of the DJI Phantom 3 UASs commercially, without an airworthiness certificate, for the limited purpose of 

conducting the aforementioned on-demand commercial sUAS operations that include:
• Public Safety Support Operations

• Filmmaking, cinematography, and videography,

• Wildlife and forestry monitoring,

• Aerial surveying, and

• Construction site inspection and monitoring

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing 

Fairfield CT Emergency Services to safely, efficiently, and economically operate sUASs commercially 

within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, section 333, Fairfield CT Emergency Services respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 14

C.F.R Sections 45.23(b); Part 21; 61.113(a) & (b), 91.7(a); 91.9(b); 91.103(b); 91.109; 91.119;

91.121; 91.151(a); 91.203(a); 91.405(a), 91.407(a)(1); 91.409(a)(1) & (a)(2), and 91.417(a) &

(b), and permit Fairfield CT Emergency Services the DJI Phantom 3 commercially in the United States.

Respectfully Submitted,

Fairfield CT Emergency Services

Chris Lyddy, Deputy Chief of Police

100 Reef Road

Fairfield, CT 06824

203-254-4826

clyddy@fairfieldct.org
APPENDEX A

FAR SUBJECT JUSTIFICATION

14 CFR § 45.23 (b) Requirement to display 

registration number on 

vehicle

Insufficient space on vehicle 

14 CFR Part 21 Aircraft certification 

requirements and procedures

Designed for manned 

aircraft; not suitable for offthe-shelf sUAS

14 CFR § 61.3 Requirement for pilot 

certificate

Part 61 requirements 

designed for manned 

aircraft, not sUAS: petition 

describes training for sUAS 

operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned 

aircraft; not suitable for offthe-shelf sUAS

14 CFR § 91.9 (b) (2) Equipment for manual to be 

available in the cockpit

No one aboard to read 

manual

14 CFR § 91.103 (b) Requirement for crew 

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction

No one on board to operate 

controls

14 CFR § 91.119 Minimum altitudes for safe 

flight

Safety requires operation 

below these altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter

14 CFR § 91.151 (a) Fuel requirements Vehicle does not use fuel

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard

No one aboard to read 

certificates

14 CFR § 91.205 (b) aboard Cockpit instruments No one to read

FAR SUBJECT JUSTIFICATION

14 CFR § 45.23 (b) Requirement to display 

registration number on 

vehicle

Insufficient space on vehicle

14 CFR Part 21 Aircraft certification 

requirements and procedures

Designed for manned 

aircraft; not suitable for offthe-shelf sUAS
14 CFR § 61.3 Requirement for pilot 

certificate

Part 61 requirements 

designed for manned 

aircraft, not sUAS: petition 

describes training for sUAS 

operator

14 CFR § 91.7 (a) Airworthiness requirement Designed for manned 

aircraft; not suitable for offthe-shelf sUAS

14 CFR § 91.9 (b) (2) Requirement for manual to 

be available in the cockpit

No one aboard to read 

manual

14 CFR § 91.103 (b) Requirement for crew 

members to be onboard

Unmanned vehicle

14 CFR § 91.109 Requirement for dual 

controls during flight 

instruction

No one aboard to operate 

controls

14 CFR § 91.119 Minimum altitudes for safe 

flight

Safety requires operation 

below these altitudes

14 CFR § 91.121 Altimeter settings No one aboard to read 

altimeter

14 CFR § 91.151 (a) Fuel requirements Vehicle does not use fuel

14 CFR § 91.203 (a) & (b) Requirement for registration 

and airworthiness certificates 

to be onboard

No one aboard to read 

certificates