January 21, 2016

U.S. Department of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE., Washington, DC 20590

Exemption Request under Section 333 

Dear Sir or Madam,

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

Coastal Home Showcase (married couple Sheri Hill & Zachary Hill), the operator of a Phantom 3, seeks 

an exemption from the Federal Aviation Regulations listed below. 

The requested exemption would permit Coastal Home Showcase to operate their UAV which weighs 

1216 grams (2.7lbs) and produced by DJI INC for commercial use in the following areas:

- Real Estate aerial photography & Videography

- Construction surveying & monitoring

- Golf Course photography

-Commercial aerial photography & Videography

- Aerial filmmaking and photography

-Research & Development

With the landowner’s permission the DJI UAV listed above will use an onboard camera to capture Digital 

images for commercial use. The Phantom UAV reduce the need of using conventional aircraft for the 

same purpose and provides very high quality imagery at a much more affordable cost. The UAV, 

powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on 

combustible fuel, it operates at lower altitudes with no people on board and will thereby reduce current 

risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With 

a small payload and maximum flight time of only 20 minutes, the Phantom 3 offers little or no risk to 

national security, personal property, or larger aircraft. Low level oblique photos and video from several 

angles are far more effective than ground based imagery for displaying the characteristics of large, 

complex properties with several buildings· and large trees. These savings result in enhanced efficiency 

and productivity for the activities listed above as well as environmental benefits such as reducing the 

carbon footprint. 

Operations under the exemption will be subject to strict operating requirements and conditions to ensure 

an equivalent level of safety to current authorized operations using manned aircraft and under conditions 

as may be modified by the FAA as required by Section 333. 

As described in this petition the requested exemption would authorize commercial operations of aerial use 

using the Phantom UAV which at 2.7lbs fall well under guidelines set by the FAA. The phantom UAV 

will be operated under controlled conditions: 
- Operator has over 50 hours of UAV flight experience 

- Low altitude of less than 400 AGL (most of commercial use is under 200 AGL) 

- Automated control features listed below. 

- GPS lock at all times with safe Return to home functionality

- Speeds not to exceed 20 mph

- Line of Sight operations at all times 

- First Person view capabilities for added safety 

The Regulations from which this exemption is requested are listed below: 

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)

THE APPLICATION LEGAL STANDARD UNDER SECTION 333 Coastal Home Showcase submits 

that grant of this exemption application for use of the Phantom 3 quadcopter in commercial Photography 

and Videography will advance the congressional mandate in Section 333 of the Reform act to accelerate 

the Introduction of UAV’s into the national airspace system (NAS) if it can be accomplished safely. This 

law directs the secretary of transportation to consider whether certain UAVs may operate safely in the 

NAS before completion of the rulemaking required under Section 333 of the reform act. In making this 

determination, the secretary is required to determine which types of UAVs do not create hazard to users 

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

-The UAVs size, weight, speed and operational capacity 
-Operations of the UAV in close proximity to airports and populated areas 

-Operations of the UAV within Visual Line of Sight of the Operator 

Reform Act 333(a)(1). If the Secretary determines that such vehicles “may Operate Safely in the national 

airspace system. The Secretary shall establish requirements for the safe operations of such aircraft in the 

NAS. 

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 by 40101 of the Act, from 

requirement that all civil aircraft must have a current airworthiness certificate and those regulations 

requiring commercial pilots to operate aircraft in commercial service. 

The grant of the requested exemption is in the public’s interest based on the clear direction in section 333 

of the reform act; The additional authority 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 and cost savings associated with transitioning the UAV

for aerial photography.

Grant of the exemption to Coastal Home Showcase will be subject to the following mandatory conditions, 

which are based upon operating conditions set forth for operation of UAV by public entities pursuant to 

certificates of authorization:

- All operations to occur in class G airspace - Operations to avoid congested or populated areas, which are 

depicted in Yellow on VFR charts - Operations to be conducted over private or controlled-access property 

- Permission from land owners/controller required before commencing and flight - Operations to occur 

during Visual Flight Rules Meteorological conditions - Aircraft to remain within Visual Line of Sight 

(VLOS) - Operations to occur during daylight hours - Above ground Level altitude to be restricted to 400 

Ft - All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth 

of runway centerline measured from Runway Threshold (Phantom Products have GPS data within the 

controller to warrant no fly zones to airports) - 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 

Operator Requirements 

Coastal Home Showcase respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAV. Certain UAVs, such as the DJI Phantoms are characterized by a 

high degree of pre-programmed control and various built in technical capabilities that limit potential for 

operation outside of the operating conditions set forth above. 

The DJI Phantom UAV has semi-autonomous navigation and control systems comprised of a ground 

control station, GPS stabilization and Auto-Pilot system. In the case of an unplanned event, the operator 

can allow the aircraft to follow the pre-programmed evasive maneuvers from the control unit or enable 

assisted steering for direction control and Return to Home takeoff point. 
Pre-Flight Checklist 

The checklist below is an important requirement before each and every flight, to ensure safety. We have 

been preforming these procedures and have been successful with no errors or accidents during flight. 

- Make sure that all UAV propellers are snug tight. - Check battery levels before takeoff (controller and 

UAV; Never launch on less than half battery) - Inspect that there are no debris in the motors or gimbal 

areas) - Attach and power up the FPV screen and controller) - Power up the UAV. - Wait for UAV and 

controller to sync and connect to no less than 10 satellite signals. (this ensures safe locking of location for 

return to home and stable hovering) - Prior to powering on the motors, make sure to be in an open area 

free from people, animals, power lines and large interfering objects. 

Sincerely,

Coastal Home Showcase

Sheri Hill & Zachary Hill

41 Whitecap Way

Miramar Beach, FL 32550 

850-830-5067

coastalhomeshowcase@gmail.com 

Phantom 3 Quick User Manual:

http://dl.djicdn.com/downloads/phantom_3_standard/en/Phantom_3_Standard_Quick_Start_Guide_en_20

1509.pdf
EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Coastal Home Showcase requests an exemption from the following regulations as well as any additional 

regulations that may apply to the operation of the UAV:

14 CFR Part 21, Airworthiness Certificates

Establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to 

work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental 

certificate be issued for the DJI Phantom 3 under either or both of the following provisions:

21.191 Experimental certificates. Experimental certificates are issued for the following purposes: (a) 

Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft 

installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show 

compliance with the airworthiness regulations including flights to show compliance for issuance of type 

and supplemental type certificates, flights to substantiate major design changes, and flights to show 

compliance with the function and reliability requirements of the regulations. Since the experimental 

certificate can be used for commercial purposes such as market surveys, sales demonstrations, and 

customer crew training, we would expect that an experimental certificate would permit our commercial 

purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under 

strict operational requirements.

Combined with the UAV's lightweight, being constructed primarily of carbon fiber and plastic, we 

propose that the UAV will be at least as safe, if not safer, than a conventionally certificated aircraft 

performing the same mission. If an experimental airworthiness certificate is not appropriate for this 

application, then we request an exemption of 14 CFR Part 21, Subpart H. and the requirement for 

airworthiness certificate in general. Citing the equivalent level of safety outlined in the previous 

paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. 

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in 

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The UAV does not 

have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration 
number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the 

word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot 

In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch 

will be able to see the designation. Additionally, we feel that the permanent placard discussed in the 

previous paragraph will provide the aircraft's registration information at the ground station. Finally, we 

will display at the ground station a high contrast flag or banner that contains the words "Unmanned 

Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM 

of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin. 

14 CFR 61.113 Private pilot privileges and limitations Pilot in Command and 61.133 Commercial pilot 

privileges and limitations.

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command 

of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command 

of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for compensation or

hire. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by 

the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 

Subparagraph (b) even though the intent of this application is to conduct a business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no such 

certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is 

in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is 

available to the aircrew while operating the aircraft. We request an exemption to this requirement since 

the aircraft is not only too small to carry documentation, the documentation would not be available to the 

crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we 

propose that a current, approved UAV Flight Manual must be available to the crew at the ground station 

anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests 

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls." The UAV System ground based control station 

consists of a small hand-held radio transmitter and while it does not offer a second set of "controls", both 

the student and instructor can, and will, operate the single set of controls simultaneously. With both 
student and instructor having "hands-on" the controls during flight, we feel that this technique meets the 

intent 91.109 and provides an equivalent level of safety. · 

91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the 

aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the 

typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it 

would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over 

property or persons where permission has been obtained and careful pre-planned has been performed. The 

aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of 

the UAV, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which 

should be considered in granting the exemption. ·

CFR 91.121 Altimeter settings. 

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting 

available within 100 NM of the aircraft. The UAV will always fly below 400 feet AGL and will not need 

to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level 

altimeter measurement above the takeoff point is transmitted via radio from the UAV on-board computer 

to the display screen held by the PIC, providing a constantly updated AGL readout. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day-VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. 

We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to 

landing. The UAV is battery operated and the maximum duration of flight from a single battery charge is 

18 minutes with a 20% reserve. Since the aircraft will never fly more than 1/8 NM from the point of 

intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement 

of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation 

with the word "energy".
14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to the 

aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides 

that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew." At a maximum gross weight of 2.7 pounds, the UAV is too small to carry 

documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and· meet the intent of 91.203, we propose that documents deemed appropriate 

for this aircraft by the FAA will be located with the crew at the ground control station and available for 

inspection upon request. In order to identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the 

following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations.

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that 

the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and 

inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be 

authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed inspections after every two 

hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a 

propeller, checking electrical connections and updating software and firmware for the on-board computer. 

The manufacturer or their designated repair facility will perform all other maintenance. The PIC will 

document work performed in accordance with 91.417. We feel that due to the size, construction, and 

simplicity of the aircraft, the PIC can ensure an equivalent level of safety. 

Safety and Benefits of the UAV

Coastal Home Showcase will be using the UAV in a variety of applications that generally require 

expensive full-size manned aircraft to complete. Small, light, unmanned aerial vehicles offer exceptional

benefits over the use of full-sized manned aircraft for electric power line inspection, oil/gas pipeline 

inspection, advanced agriculture, film and still photography, just to name a few. Replacing significantly 

larger manned aircraft carrying crew and flammable fuel with small UAV carrying no passengers or crew 

creates a much greater margin of safety for the pilots and crew. By granting Coastal Home Showcase, 

including Sheri & Zachary Hill, the requested exemptions, the FAA will help drive development of safe 

and successful commercial UAV operations and will advance the public knowledge base for such 

operations. Coastal Home Showcase is committed to promoting the UAV research efforts of policymakers 
including the FAA &NASA by sharing data from its commercial UAV operations and serving as a 

resource for future UAV research operations. Thus, the FAA has good cause to grant this Petition.

Conclusion

As pointed out in this application, the UAV which our company would use, under authorization by the 

US DOT-FAA, is a small, light-weight device operated within the line of sight of the Pilot-in-Command 

(PIC), less than 400 feet above the ground and outside 5 miles from any airport, helipads, military bases, 

spaceport, or other location with aviation activities, unless the air traffic control authorities (ATC) have 

been notified and have authorized each flight within a radius of this distance.

Our DJI Phantom 3 has proven capability for controlled flight. They are devices offered for sale on the 

everyday market around the world and have often been used as Model Aircraft in the USA. We are 

certain that the studies conducted until now by the FAA, about Section 332, Public Law 112 -95, 2014, 

have already provided you with the assurances on the airworthiness of small UAS such as ours.

For the foregoing reasons, the exemptions requested herein should be granted and Coastal Home 

Showcase should be permitted to conduct small UAV operations in accordance with its manuals and all 

other operating parameters deemed necessary and appropriate by the FAA. The submission of this 

application and its contents is the best demonstration that indeed it is possible to pursue the authorization 

process so that some small UAVs may be used for legitimate commercial activities and under reasonably 

safe conditions.