David Lee Brown 

Hapa LLC 

8275 S. Eastern Ave. 

Ste 200-815 

Las Vegas, NV 89123 

(702) 716-5002 

hapalvnv@gmail.com 

Re: Petition for Exemption Pursuant to Section 333 

To Whom It May Concern: 

I, David Lee Brown, am seeking exemption from the requirements to operate an Unmanned Aircraft 

System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit David Lee Brown to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography. I, David Lee Brown, have been 

performing traditional commercial video and photography for over 4 years, and have extensive 

experience with various electronic equipment, function, capabilities, and limitations. 

Following is a brief explanation of specific sections I am seeking exemptions: 

14 CFR Part 21 — Airworthiness Certificates 

Due to the speed, weight, size, and limited operating area associated with the unmanned aircraft, on 

operation of DJI Phantom 3 Professional meets the conditions of FMRA Section 333 and therefore, will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Earl 

D. Harrison requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) & 

(b), as these sections set forth requirements for maintenance that only apply to aircraft with an 

airworthiness certificate. 

14 CFR 61.113(a) &(b) — Private pilot privileges and limitations: Pilot in command 

The FAA has previously declared that additional manned airship experience of a commercially certified 

pilot would not correlate to the airmanship skills necessary for similarly proposed operations in previously 

issued exemptions to this regulation through Exemption Nos. 11062 and 11138. 

14 CFR Section 91.7 — Civil aircraft airworthiness 

Currently, the DJI Phantom 3 Professional does not require an airworthiness certificate in accordance 

with 14 CFR Part 21, Subpart H. However, David Lee Brown will ensure that the DJI Phantom 3 Pro is in 

an airworthy condition, prior to every flight, by determining that the UA is in compliance with the operating 

documents and that the aircrafts are in a condition for safe flight. 

14 CFR 91.9 (b)(2) — Civil aircraft flight manual, marking, and placard requirements 

Due to the size of the DJI Phantom 3 Pro, there will be no pilots or passengers, as well as an aircraft flight 

manual within the UA. However, the owner's safety/flight manual will be located within reach of the 

operator. 

14 CFR 91.119(c) — Minimum safe altitudes 
The operator will not fly the UA higher than 400 feet (the DJI Phantom 3 Pro has an altitude limit of 395'). 

Additionally, the UA will be kept in eyesight at all times and the use of an observer will always assist. 

14 CFR 91.121 — Altimeter settings 

To achieve a level of safety, the DJI Phantom 3 Pro is equipped with an electronic GPS with a barometric 

sensor. 

14 CFR 91.151(a)(1) — Fuel requirements for flight in VFR conditions 

The DJI Phantom 3 Pro is powered by lithium polymer batteries that have a flight limit of no more than 20 

minutes. 

14 CFR 91.405(a) — Maintenance Required 

14 CFR 91.407(a)(1) — Operation after maintenance, preventive maintenance, rebuilding, or alteration 

14 CFR 91.409(a)(1) & (2) — Inspections 

14 CFR 91.417(a) &(b) — Maintenance records 

Regarding the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) will be met because we will use trained 

technicians to perform maintenance, alterations, and preventive maintenance on the UAS's using the 

methods, techniques, and practices prescribed in the user manual of the DJI Phantom 3 Professional. 

Additionally, David Lee Brown will document and maintain all maintenance records for the DJI Phantom 3 

Professional will be inspected as prescribed by the user manual. 

Hapa LLC is a newly formed company comprised of myself, David Lee Brown, and business partner, 

Gilbert Sales. Hapa LLC is hired, but not limited to, take video & photo of pre-construction, progress, and 

post-construction projects. If the exemption request is granted to David Lee Brown to allow the flight of 

our unmanned aircraft (UA), we would provide an effective and efficient alternative to the use of manned 

aircrafts to our clients. The company is in the process of seeking DBE (Disadvantaged Business 

Enterprise) certification from the Nevada Department of Transportation. 

Respectfully 

David Lee Brown 

Appendices: 

A— DJI Phantom 3 Pro Specifications Data Sheet