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CESAR R. 

MARDIROSSIAN

1202 NW 114TH Ave.

Coral Springs, FL 33071

Cell 754-245-0284

Email: baron4266@yahoo.com

October 22nd, 2015

U.S. Department of 

Transportation Docket 

Management System 

1200 New Jersey Ave., SE

Room W12-140

West Building Ground Floor 

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1) DJI Phantom 3 Professional User Manual V1.0

2) DJI Phantom 3 Professional Release Notes

3) DJI Safety Guidelines Disclaimer

References:

1) FAA Exemption No. 11603, Regulatory Docket No. FAA-2015-0521 in the 

manner of the petition of JOHN KELLER

2) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the

matter of the petition of DOUGLAS TRUDEAU

3) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the

matter of the petition of ADVANCED AVIATION SOLUTIONS LLC

4) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter

of the petition of FLYING CAM INC

Dear FAA,

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, I, CESAR R. 

MARDIROSSIAN, request exemption from the following sections of Title 14, Code 

of Federal Regulations §§61.1 3(a). 61. 3(b). 91.1 9(c). 91.121. 91.151(a). 

91.405(a).91.407(a)(1). 91.409(a)(1). 91.409(a)(2). 91.417(a) &(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, structural inspections of bridges, pipelines, well and cell towers, 

real estate marketing and surveys and other flight operations that could be 
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performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. national airspace system as compared to a manned aircraft. 

Operations will be performed only at the request of and with the authorization and 

permission of clients or their authorized agents in order to facilitate 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 31 conditions identified and proposed by, CESAR R. MARDIROSSIAN, are 

drawn from reference 1.

The FARs

I, CESAR R. MARDIROSSIAN, request exemption from the above-mentioned FARs 

for the following reasons.

I have been a licensed Private Pilot since June of 1988, Certificate # 2400042, hold 

a Current Medical Certificate Third Class 61.1 3(a) & (b). I, CESAR R. 

MARDIROSSIAN, request 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. A Visual Observer will be used at all times 

while under this requested exemption. 91.1 9(c) As discussed in Exemption 11138 

(DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground 

may require that the UA be operated closer than 500 feet to essential persons, or 

objects that would not be possible without additional relief. The petitioner requests 

modification, waiver or exemption and clarification concerning the terms “congested 

areas” and “densely populated”. I, CESAR R. MARDIROSSIAN, request waiver for 

this condition to allow reasonable and responsible operations with safety as my main 

concern in areas of subdivisions and neighborhoods if required.

91.151(a) 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 in Exemption Nos. 881 , 10808, and 

10673 for daytime, VFR conditions. The UAS provides battery power remaining in 

percent to the PIC. The UA batteries provide approximately 23 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 minimum power 

reserve for flight in daytime VFR conditions was reasonable. 91.405(a). 91.407(a)(1). 

91.409 (a)(1) & (2). 91.417(a) & (b) As discussed in Exemption 1 138 (DOUGLAS 

TRUDEAU), I, CESAR R. MARDIROSSIAN, propose to inspect and ensure that the 

UAS is in a condition for safe flight in accordance with the operating documents. The 
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FAA found that adherence to the petitioner’s operating documents and the conditions 

and limitations specified, describing the requirements for maintenance, inspection, 

and record keeping, were sufficient to ensure that safety would not be adversely

affected.

The UAS

The DJI Phantom 3 Professional is a highly successful consumer grade small 

rotorcraft in the quad copter configuration with an advertised weight of 2.82 

pounds (1280g) designed primarily to carry aloft a high definition 4k Resolution 

camera. It has an advertised maximum speed of less than 32 knots (16m/s) and a

maximum climb rate of less than 985 feet per minute (5 m/s). It is powered by four 

electric motors with a distance between motors of less than 14 inches.

It 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 gimbal camera angle. 

It has fail-safe 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 16 minutes. More information is available in

attachment

Risk mitigation

I, CESAR R. MARDIROSSIAN, have reviewed FAA exemptions reference’s 31

Conditions and Limitations section as found in (FAA Exemption No. 11603, Regulatory 

Docket No. FAA-2015-0521in the manner of the petition of JOHN KELLER), and 

believe that the procedures specified therein are reasonable and will be utilized in 

order to manage and mitigate risk and ensure public safety.

A preflight checklist included by attachment as (Safety Guidelines Disclaimer), will 

be utilized as well as other checklists and employed to ensure that the UAS’s 

airworthiness will be verified before launch. Airworthiness will be maintained by 

performance of routine inspections before each flight, maintaining flight and 

maintenance logs to record time on failure prone components.

I, CESAR R. MARDIROSSIAN, request that in a manner similar to reference 4, 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 
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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 I am 

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 the UAS 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.

In regards to performing inspections of bridges, towers, and natural gas pipelines 

the UAS will minimize the risk to persons attempting to climb these structures 

and photograph problem areas. It will provide a way for companies to have their 

engineers review photographs and provide additional safety to the general public 

in regards to towers failing or natural gas pipelines having structural issues. 

Many of the natural gas pipelines in our area travel in areas that are hard to 

reach by vehicle or foot and if an area is suspected of having problems the UAS 

can reach it to make an assessment easier and safer.

I, CESAR R. MARDIROSSIAN, will also make the UAS and myself available to 

local volunteer organizations (for no charge) such as fire departments, local law 

enforcement, etc., to perform search and rescue operations, or other similar 

events as directed by authorities.

In addition the use of the UAS in order to facilitate commerce could lead to 

economic growth. Operations for this petition will enable service for property 

owners or their designates seeking an enhanced perspective for characteristics, 

amenities, and benefits of their desired photographic subjects that cannot be 

displayed through ground level photography. Aerial photography is a valuable 

marketing tool that can lead to increased commerce and enhance my personal

photography.

A visual observer will be utilized at all times that the UAS is performing duties for 

compensation and the PIC will hold a Private Pilots license.

Flight data including UAS flight time, Control Unit operation time, incident, and 

details will be recorded for each flight and made available to the FAA at any time 

as requested.

Any deviations from normal operations will also be recorded and made available 

to the FAA.
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Conclusion

I, CESAR R. MARDIROSSIAN am requesting this exemption for the purposes of aerial 

photography of real estate, bridge inspections, land surveying, pipeline inspections, tower 

inspections, Aerial filming, Aerial videography, and cinematography to enhance academic 

community awareness and photography for coverage of events, enhanced real estate 

listings, structural inspections and other flight operations.

 

The reason for such a general and broad based request is that I, CESAR R. 

MARDIROSSIAN, wish to utilize a commercial business enterprise in order to capitalize 

on opportunities as they may arise in the future without the long turnaround time 

associated with additional exemptions.

The need for Licensed FAA Pilots who have the experience, knowledge and experience of 

operating within The National Airspace System will help ensure the growth of this market 

segment will be successful and in the public interest.

I have been a licensed Private Pilot since June of 1988, Certificate # 2400042, hold a 

Current Medical Certificate Third Class, and have Radio Controlled Aircraft experience 

as well owning various battery operated planes and electric ducted fan jets, as well as 

being a member of the AMA (Academy of Model Aeronautics).

I look forward to helping pave the way for successful UAS Operations within the 

National Airspace System.

Sincerely,

CESAR R. MARDIROSSIAN

1202 NW 114TH Ave.

Coral Springs, FL 33071

Cell 754-245-0284

Email: baron4266@yahoo.com