Page 1 of 10

12/10/15 

Deborah Winkelman: CEO

Thomas Christopher Coyle: President

ArcticZoneDrone LLC 

Physical Address

8749 Cormorant Way

Wasilla AK 99823

Mailing Address:

P.O. Box 879016

Wasilla AK 99687

Cell: 907-317-6432 (Deb)

Cell: 907-250-2565 (Chris)

Office: 907-373-9219

Email: Akdebwinkelman@gmail.com

Akchriscoyle@gmail.com

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, 

DC 2059 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments: 1) Phantom 3 Pro Technical Data 

2) Phantom Inspire 1 Technical Data

3) DJI Safety Tips for Flying in Cold Weather

References: 1) Exemption No. 11409 Regulatory Docket No. FAA-2015-0187 in the matter of the 

petition of WADE BELL. 

2) SkyLynx, LLC petition for exemption letter.

3) Steel City NDT LLC, BlackHawk Aerial Systems petition for exemption letter.
Page 2 of 10

Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 333 of the 

FAA Modernization and Reform Act of 2012, we Deborah Winkelman and Thomas C Coyle, owners of 

ArcticZoneDrone LLC, referred to hereafter as the petitioners, request exemption from the following 

sections of Title 14, Code of Federal Regulations §§ 

14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR 61.113(a); 14 CFR 61.113(b); 14 CFR 91.7(a); 14 

CFR 91.9(b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 

91.151(a); 14 CFR 91.203(a); 14 CFR 91.203(b); 14 CFR 91.405(a); 14 CFR 91.407(a) (1); 14 CFR 

91.409(a) (2); 14 CFR 91.409(a)(2); 14 CFR 91.417(a); 14 CFR 91.417(b); 

In order to operate small Unmanned Aircraft Systems (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) for the purposes of aerial photography, cinematography, video

photography, mapping, crop surveying, inspection and other flight operations that could be performed safely 

and more cost effectively with the use of small UAS at low altitude within the United States national 

airspace system as compared to a manned aircraft. Operations will be performed only at the request of and 

with the commerce and raise awareness of the beneficial uses of small unmanned air systems. So long as 

such operations are conducted within and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333. The conditions identified and proposed by the petitioners are drawn 

from Attachments 1-3. 

The Federal Aviation Regulations (FARs) 

14 CFR Part 21 subpart H 14 CFR 

45.23 (b) 14 CFR 61.113 (a) & (b) 14 

CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 

CFR 91.103 14 CFR 91.109 14 CFR 

91.119 (c) 14 CFR 91.121 14 CFR 

91.151 (a) 14 CFR 91.203 (a) & (b) 14 

CFR 91.405 (a) 14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) (1) 14 CFR 91.409 

(a) (2) 14 CFR 91.417 (a) & (b) 

The petitioner seeks exemption from the above mentioned FARs for the following reasons; 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR §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. 
Page 3 of 10

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 UAS 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 and 

designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled 

and monitored by both the operator and under the requirements and in compliance with local public 

safety requirements. The FAA will have advance notice of all operations. These safety enhancements

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. 

14 CFR §45.23(b): Marking of the Aircraft:

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," "light-sport, 

"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 UAS, 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 UAS marked on its fuselage 

as required by §45.29 (f) where the pilot, observer and others working with the UAS will 

see the identification of the UAS as "Experimental." 

14 CFR §61.113(a) and (b): Private Pilot Privileges and Limitations-Pilot in Command 

The petitioners requests relief in order to facilitate the utilization of pilots, who hold a Private Pilot (or 

greater) certificate. Any pilots operating under this exemption would be required to comply with any 

conditions as set forth and in a similar fashion to the previously granted exemptions. 

14 CFR §91.7(a): Civil Aircraft Airworthiness 

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 for maintenance and use of safety check lists 

prior to each flight an equivalent level of safety will be provided. 
Page 4 of 10

14 CFR §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 UAS, 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 UAS will have immediate access to it.

14 CFR §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 as stated in the FOM in Section 4 under Normal Procedures including 

but not limited to reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation off light.

14 CFR §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. UAS 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. 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 CFR §91.119(c): Minimum Safe Altitudes 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the 

ground may require that the UAS be operated closer than 500 feet to essential persons, or objects that would 

not be possible without additional relief. The petitioner’s requests modification, waiver or exemption and 

clarification concerning the terms "congested areas" and "densely populated". The petitioners request a

waiver for this condition to allow reasonable and responsible operations in areas of subdivisions and 

neighborhoods if required. 

14 CFR §91.121: Altimeter Settings 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not 

have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information.

14 CFR §91.151(a): Fuel Requirements for Flight in VFR Conditions 

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been 

granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 

2689, 5745, and 10650. In addition, similar UAS-specific relief has been granted within Exemption 

Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power 

remaining in percent to the PIC. The UAS batteries provide approximately an average of 25 minutes of

powered flight. Information provided in the Operating documents discusses procedures regarding 

remaining battery power management. Those documents contain a condition in which the PIC will 

initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on 

proposed operations and the location of those proposed operations, The FAA found that a reduced 
Page 5 of 10

minimum power reserve for flight in daytime VFR conditions was reasonable.

14 CFR §9l.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 UAS. An equivalent level of safety will be achieved by keeping these 

documents at the ground control point where the pilot flying the UAS will have immediate access to them;

to the extent they are applicable to the UAS.

91.405(a); 91.407(a) (1); 91.409 (a) (1) & (2); 91.417(a) & (b): Maintenance Inspections as discussed in 

Exemption 11138 (DOUGLAS TRUDEAU), the petitioners proposes to inspect and ensure that the UAS is 

in a condition for safe flight in accordance with the operating documents. The FAA found that adherence to 

the petitioner's operating documents and the conditions and limitations specified, describing the 

requirements for maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would 

not be adversely affected. 
Page 6 of 10

THE SUAS(s) 

DJI Phantom 3 Pro – Serial #P76DCI06011238

The DJI Phantom 3 is a new highly successful consumer grade small rotorcraft in the quad copter

configuration with an advertised weight of 45 Ounces (1280g) designed primarily to carry aloft a high 

definition camera. It has an advertised maximum speed of 31 knots (16 rn/s) and a maximum climb rate of

984 feet per minute (5 m/s). The DJI Phantom 3 is powered by four electric motors with a distance between 

motors of 23.22 inches (590 mm). The DJI Phantom 3 utilizes and internal inertial measuring unit (IMU) 

with integrated barometric sensor augmented with global positioning system (GPS) to maintain its 

geospatial orientation and position. It is controlled primarily through an FCC certified radio control (RC) 

unit. Real time video and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle. It has failsafe modes of operation for either loss of RC or GPS 

signal. Altitude can be limited by the onboard flight controller and maximum altitude can be 

preprogrammed by the PIC. Battery life limits flight times to approximately 23 minutes. The onboard flight 

controller will warn the pilot via telemetry and external lighting cues before reaching a low battery state. An 

automatic termination of flight and landing will be initiated when the battery reaches a predetermined low 

state. It is anticipated that flights will usually last less than I 0 minutes. More information is available in 

Attachment 1 or http://www.dji.com/product/phantom-3/spec. 

DJI Inspire 1 - Serial #W13DCB04020105

The DJI Inspire 1 is DJI's newest and most advanced consumer grade small rotorcraft in the quad copter

configuration with an advertised weight of less than 103.5 Ounces (2935g) designed primarily to carry aloft 

a high definition camera. It has an advertised maximum speed of less than 42.8 knots (22 rn/s) and a 

maximum climb rate of less than 990 feet per minute (5 rn/s). The DJI Inspire I is powered by four electric 

motors with a distance between motors of22 to 22.87 inches (559 to 58Imm). The DJI Inspire I utilizes an 

internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global positioning 

system (GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a ground 

control station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude 

(AGL), distance from PIC, camera imagery, and control camera angle. It has failsafe modes of operation for 

either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately I8 minutes. The 

onboard flight controller will warn the pilot via telemetry and external lighting cues before reaching a low 

battery state. An automatic termination of flight and landing will be initiated when the battery reaches a 

predetermined low state. It is anticipated that flights will usually last less than 10 minutes. More information 

is available in Attachment 2 or http:/ /www.dj i.com/product/inspire-1 /spec 
Page 7 of 10

RISK MITIGATION & SAFETY 

The petitioners have reviewed FAA exemption reference's 1-3 Conditions and Limitations section and the 

procedures set forth will be utilized in order to manage and mitigate risk and ensure public safety. A 

preflight checklist will be developed and implemented to ensure that the UA airworthiness will be 

verified and documented before flight. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on failure-prone 

components. In addition a full safety program will be implemented and followed to ensure that further 

safety precautions are followed during operational flights. Full maintenance procedures (SOPs) as well as 

maintenance frequencies shall be developed and documented to reduce and/or eliminate failures. 

The petitioner’s requests that in a manner similar to reference 3, that the petitioners be allowed to operate 

within 5 miles of an airport provided that; 

"The UA may not operate in Class B, C, or D airspace without written approval from the FAA. The 

UA may not operate within 5 nautical miles of the geographic center of a non-towered airport as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport's management is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator's COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request." 

Operations within 5 miles of an airport are not anticipated to be routine but the petitioners are requesting 

a mechanism to facilitate such activities without requesting a new and separate exemption(s) should the 

need arise. Operations within class B airspace are not requested due to the lack of mode C transponder. 

PUBLIC INTEREST 

Use of specified UAS(s) in lieu of a manned aircraft would enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, carrying a 

crew and flammable fuel. Additionally, use of specified UAS(s) in order to facilitate commerce could lead 

to economic growth. Operations for this petition will enable service for property owners or their designees 

seeking an enhanced perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level video and photography. Aerial photography is a 

valuable marketing tool that can lead to increased commerce and enhance personal photography. Crop 

surveying applications could lead to decreased use of pesticides and fertilizer and conservation of water as 

well as increased crop yields and decreased costs. Aerial surveying and inspections can increase work site 

efficiency, improve volumetric estimations and reduce risks. The petitioners will provide clients with 

photographic data for these purposes on a 'for hire' basis acting as an independent contractor. A visual 

observer will be utilized. Liability insurance will be obtained commensurate with the granting of this request 

for exemption. Flight data including UA flight time, control unit operation time, incident, accident, and 

details concerning any deviations from normal operations will be available to FAA for use in collecting data 

regarding the use of UAS’s as part of this application. This data may be submitted to FAA via traditional 

means, e.g. COA Monthly Reports or other means as required. 
Page 8 of 10

The petitioners will utilize all recommended safety guidelines from the manufactures of the SUAS’s such as 

the following (attachment 3):

DJI Safety Tips for Flying in Cold Weather (DJI News 12-11-15)

Flying DJI aircraft in winter can be fun, but bear in mind that as the temperature drops, so does the battery’s 

performance. It has come to DJI’s attention that several of our users have experienced issues when flying in 

cold weather. These issues include sudden drops in battery voltage, motor output overload and, in some 

cases, even crashing the aircraft. In response, we urge users to read the following tips to ensure flight safety 

when flying in cold weather.

The Intelligent Flight Battery contains a Li-Po battery cell. The performance of the Li-Po battery cell is 

subject to ambient temperature so that the battery drains significantly faster at cold temperatures (15°C). 

When the Intelligent Flight Battery is placed in cold environments, the chemical reactions within the battery 

cell are subdued, leading to increased resistance and eventually a significant drop in battery voltage. The 

drop in battery voltage (below 3V per cell) contribute to two major risks. Firstly, the propulsion system on 

the aircraft can suffer from lack of thrust due to the low voltage. Secondly, the battery will automatically 

shut off because the over-discharge protection will have taken effect. This is a known limitation to all Li-Po 

batteries and many mobile devices that use Li-Po batteries also have the same issue. Note that you might not 

be able to use your mobile device at cold temperatures for the same reason.

Aircraft such as the Inspire 1 and Inspire 1 Pro require more power to sustain flight and carry out maneuvers 

such as climbing at high speeds. At high altitudes where air pressure is low, the motors on the aircraft will 

rotate faster in order to produce enough lift. Consequently, even more power output is required and the 

battery voltage will be more likely to drop to an extremely low level, triggering over-discharge protection. 

Therefore, we strongly recommend that users charge the battery to 100% in order to prevent over-discharge 

protection from triggering.

Follow the tips bellow when you are flying the aircraft:

1.Fully charge the battery before each flight.

2.Allow the battery to warm up to 25°C or more. It is recommended to use the Battery Heater to warm up 

the battery.

3.Hover the aircraft for about a minute to allow the battery to warm up
Page 9 of 10

CONCLUSION 

The petitioners are requesting this exemption for the purposes of "aerial photography, cinematography, 

video photography, mapping, crop surveying, inspections and other flight operations". The reason for such 

a general and broad based request is that the petitioners wish to utilize a business strategy of horizontal 

integration and maximize economies of scope in order to capitalize on opportunities as they may arise in 

the future without the long turnaround time associated with additional exemptions. The petitioner's 

business model is based on the idea of offering ad hoc small UAS services to individuals or companies who 

wish to employ these services as a safe, effective, and legal option to enhance their business or hobby. The 

petitioner's own market research shows pent up demand for these services currently exists in the real estate 

market and other markets are just beginning to emerge. Although video photography and photography are 

included in the request, the primary objective will be aerial survey of farm crops for precision agriculture. 

The petitioners have identified universities and other agencies that could benefit from the operation 

requested in this application. 

Internet research shows that many are currently operating similar UAS in exactly this fashion without, it is 

assumed, FAA authorization. The petitioners have refrained from engaging in commercial use of the UAS. 

The primary purpose of seeking this exemption is to obtain the capability to offer those services while 

remaining in compliance. 

Respectfully Submitted 

Deborah Winkelman 

Thomas Christopher Coyle 
Page 10 of 10