03/02/2016

Edward S. Lampl

462 Biddle Ave.

Pittsburgh, Pa., 15221

412 222 5968

ed@homeplusisus.com

To whom it may concern:

This petition is being submitted on my behalf without legal counsel or consulting services in response to 

letter dated 2/12/2016, requesting additional information for exemption request filed in Docket No. 

FAA-2015-5625 on November 4, 2015.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, 

Edward S. Lampl, home inspector- environmental investigations, hereby applies for an exemption from the Federal 

Aviation Regulations (FARs) listed below to allow operation of our Small Unmanned Aircraft System (sUAS) 

commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are 

conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 

333.

The requested exemption would permit Edward S. Lampl to pursue his commercial interests in providing services 

to clients using a small advanced sUAV in the following areas: Real Estate, Marketing, Land 

Management/Surveying, and Special Events. Edward S. Lampl states that all sUAS flights will occur over private 

or controlled access property and will do so with the property owner's consent and knowledge and that only 

people who have consented or otherwise have agreed to be within the LIAS' radius during filming and 

photography applications.

Edward S. Lampl has demonstrated the ability to safely and effectively fly the sUAS DJI Phantom 3 which will be 

used for all commercial and private purposes. Edward S. Lampl complies with local ordinances and laws regarding 

the operation of sUAS, and adheres to all weather and environmental restrictions or limitations in reference to the 

operations of sUAS.

All flights will occur in ordinance with any state or local laws regarding privacy.

1. Edward S. Lampl is seeking the exemption because I am committed to complying with all of the rules, 

guidelines, limitations, and future legislation set forth by the FAA. I agree to operate the sUAS in the manner that 

I have described, and for the purposes that I have described. Without the exemption request granted, I would be 

unable to safely and effectively run my business, and it is my intention to comply with the FAA and obtain an 

exemption of the following regulations.

The following contains my list of regulations from which I am seeking exemption, and a complete list of 

responsibilities I assume as operator: it also contains information regarding the aircraft, public benefit and 

safety features, and similar petitions requests granted.

Page 1 of 5
Regulations from which exemption is requested:

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

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

14 C.F.R 91.109

14 C.F.R 91.119

14 C.F.R 91.121

14 C.F.R 91.115 (a)

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

14 C.F.R 91.205 (b)

14 C.F.R 91.215

14 C.F.R 91.401-91.417

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES

1.Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 

pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to 

amend this exemption.

2.Operations for the purpose of closed-set motion picture and television filming are not permitted.

3.The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use 

either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case 

will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4.The UA must he operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be 

reported in feet AGL.

5.The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to 

use human vision unaided by any device other than corrective lenses, as specified on the PiC's FAA-issued airman 

medical certificate or U.S. driver's license.

6.All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) 

of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times; electronic messaging 

or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO.

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7.This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the 

conditions and limitations stated in this grant of exemption. Are hereinafter referred to as the operating 

documents. The operating documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption and 

the procedures outlined in the operating documents, the conditions and limitations herein take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator's responsibility to track such revisions 

and present updated and revised documents to the Administrator or any law enforcement official upon request. 

The operator must also present updated and revised documents if it petitions for extension or amendment to this 

grant of exemption. If the operator determines that any update or revision would affect the basis upon which the 

FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The 

FAA's UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., 

replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations 

under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 

feet from other people. The functional lest flight must he conducted in such a manner so as to not pose an undue 

hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe 

operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition 

for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable 

components, items, of equipment. If the inspection reveals a condition that affects the safe operation of the 

UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life 

limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid 

U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an 

aircraft in which the PIC is rated on his or her pilot certificate. 5

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 

61.51(b). Flights for the purposes of' training the operator's PICs and VOs (training, proficiency, and 

experience-building) and determining the PIC's ability to safely operate the UAS in a manner consistent with 

how the HAS will be operated under this exemption are permitted under the terms of this exemption. 

However, training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in 

accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are 

not authorized.

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16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP. The center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. 

The letter of agreement with the airport management must be made available to the Administrator or any 

law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or 

when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is 

enough available power for the UA to conduct the intended operation and to operate after that for at least five 

minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in 

accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to 

conduct operations that cannot be conducted under the terms of the attached COA. 6

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in 

accordance with 14 CFR part 47, and have identification (N—Number) markings in accordance with 14 CFR part 45, 

Subpart C. Markings must be as large as practicable

23. Documents used by the operator to ensure the safe operation and light of the UAS and any documents 

required under CFR 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any 

time the aircraft is operating. These documents must be made available to the Administrator or any law 

enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UA may not he operated by the PIC from any moving device or vehicle.

26. All Flight operations must he conducted at least 500 feet from all nonparticipating persons, vessels, 

vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring 

the safety of nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has 

granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk 

of operating closer to those objects and determined that it does not present an undue hazard. The PIC, VO, 

operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with permission from the 

property owner/controller or authorized representative. Permission from property owner/controller or 

authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational 

area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on 

the NTSB Web site: www.ntsb.gov

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SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 

11109, 11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering platform due 

to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller 

environmental impact which promotes public safety.

Edward S. Lampl is petitioning for an exemption to operate a DJI Phantom 3 with a built-in stabilized HD camera and 

GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit the radius of the

distance it flies from the operator and to exclude it from operations within designated Class B, C and D airspace 

including a no-fly zone feature.

The DJI Phantom 3 also has a failsafe function that is triggered in the event communication is lost between the sUAS 

and the main controller transmitter. At that time, the sUAS will return to its point of takeoff and land safety. If the 

connection is restored, the PIC can regain control of flight and land manually.

These specifications meet with the Model Aircraft Operating Standards as set below:

The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will operate at sites that are 

'sufficient distance' from populated areas within the sterile area described in the FOPM. Such operations will ensure 

that the sUAS will "not create a hazard to users of the national airspace system or the public."

 When flying the UAS within three (3) miles of an airport, airport operators will be notified and the operator will 

give the right-of-way to avoid flying in the proximity of full-scale aircraft. Maximum flight time for each 

operation will be 30 minutes.

 Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land 

the sUAS.

 The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AGL, and not 

more than 200 feet above an elevated platform from which videography is planned.

 Minimum crew for each operation shall consist of: sUAS pilot, a visual sUAS observer and the camera operator.

 The sUAS PIC will be an FAA licensed airman holding a minimum of a Private Pilot certificate and a current 

FAA medical certificate.

 The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, 

and stabilized gimbal).

 The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically 

and horizontally.

Given the small size of the sUAS and the restricted sterile environment within which it will operate, Ed Lampl 

Home Inspections –Environmental testing operations adhere to the Reform Act's safety requirements and to 

follow the user manual instructions (hyperlink below) in UA operation as well.

Page 5 of 5

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.pdf