Zhili Zhan

Creekcrest Home LLC

7187 Chiming Dr

Duluth, GA 30097

770-329-0273

zzhan8724@gmail.com

Dear Sir or Madam: 

This application is for Petitioning for Exemption under Section 333 as a Civil operator.

1. Sections from which exemptions are sought

1.1) FAA Modernization and Reform Act of 2012, PL 112-95 FEB. 14, 2012, Section 333

1.2) 14 CFR Part 21, subpart H

1.3) 14 CFR Part 61.113(a) and (b)

1.4) 14 CFT Part 91:

1.5) 91.103(b)(2)

1.6) 91.105

1.7) 91.109

1.8) 91.119

1.9) 91.121

1.10) 91.151

1.11) 91.405

1.12) 91.407

1.13) 91.409

1.14) 91.417

2. Relief sought

2.1) Creekcrest Home LLC wishes to operate Unmanned Aircraft Systems for commercial purposes to 

include (but not limited to) the following areas: Real Estate, Marketing, Land Management/Surveying, 

and Special Events. This relief is sought because commercial use of UAS's iscurrently prohibited by 

law unless performed under an exemption.

2.2) This exemption will cover use of the following airframes, all of which will weigh less than 55 

pounds including payload and energy sources:

2.3) DJI Phantom 3 Rotorcraft: Please see

link here for user manual for specifications, navigational guidance, loss link procedures, flight 

termination system. (http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en.pdf)

2.4) Other models to be added by future amendments to this exemption 

3. Public benefit

3.1) Use of UAS technology to obtain imagery, information and data currently obtained by use of 

manned flight or manual methods

3.2) Reduces statistical risk to human life due to manned aircraft accidents, such as

power utility inspections and other dangerous activities requiring scaffolding or rigging for

bridge or building inspections.

3.3) Reduces the cost of obtaining such information, which benefits consumers and
the economy.

3.4) Reduces environmental impact by eliminating sources of hydrocarbon emissions

from manned aircraft.

4. Safety

4.1) Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part 45, 

Subpart C.

4.2) Aircraft will comply with maintenance and inspection requirements of the manufacturer. All repair

and maintenance work will be conducted or approved by qualified personnel and will require a test 

flight after such work. Records of all maintenance and repair work will be kept in a maintenance log 

for each aircraft.

4.3) Prior to each flight, the PIC will conduct a pre-flight inspection to determine safe flight condition .

4.4) All flight operations will be conducted by an individual who will remain stationary on the ground 

during the flight operations.

4.5) All flight operations will comply with the following:

4.6) Aircraft will use 2.4 GHz for control of the aircraft. 

4.7) The manufacturers' Aircraft Flight Manuals and operation guidelines

4.8) If UAS loses communication or loses the GPS signal, the UA will return to home base

or a pre-determined location.

4.9) Conducted in VMC conditions during daylight hours

4.10) PIC will maintain VLOS at all times.

4.11) Pre-flight inspections (including ground control station, if any) and safety risk assessments will 

be conducted prior to each flight

4.12) Flight altitudes will remain below 400 feet above ground level

4.13) Flight ground speeds will not exceed 50 knots.

4.14) Not operate within 5 miles of an airport unless a letter of agreement is obtained.

4.15) Not operate near persons as required in 14 CFR 91.119 and not over persons on the ground 

without their prior permission

4.16) Each flight will be logged in the aircraft logbook

4.17) Not exceed 75% of the battery or fuel capacity of the aircraft.

4.18) Any incidents will be reported within 24 hours of occurrence.

4.19) Comply with any applicable local FSDO requirements.

4.20) All other applicable regulations concerned with the operation of aircraft.