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U.S.	Department	of	Transportation,	Docket	Operations

West	Building	Ground	Floor,	Room	w12B140

1200	New	Jersey	Avenue,	S.E.

Washington,	DC	20590	

Petition	for	Exemption	Under	14	CFR	§ 11.81.	to	Allow	Commercial

Use	of	Unmanned	Aircraft	Systems

Petitioner:

Maribeth	Medich

9068	New	Classic	Court

Elk	Grove,	CA	95758

916-417-3689

kinsaieireland@gmail.com

Prepared	By:	

John	Fischbeck,	Dir.	of	Training,	Aviation

Drone	Universities

4225	Executive	Square

La	Jolla,	CA	92037

858-216-4416

john.fischbeck@droneuniversities.com

http://droneuniversities.com

ATP: 231642588

CFI-I-MI: 231642588

To	Whom	It	May	Concern,		

I,	Maribeth	Medich,	hereby	submit to	the	Federal	Aviation	Administration,	pursuant	

to the	 FAA	 Modernization	 and	 Reform	 Act	 of	 2012,	 an	 exemption	 petition,	 in	

accordance	with	Section	333	of	the	Act.		

This	 application	 is	 substantially	 based	 on	 the	 FAA's	 findings	 in	 Exemption	 No.	

11351	granted	 to	Corp	on	April	17,	2015,	and	in	reliance	on	 the	analysis	provided	

therein.

1. Sections	from	which	exemptions	are	sought:	Application	is	hereby	made	for	

exemption	from:

a. FAA	Modernization	and	Reform	Act	of	2012,	PL	112-95	FEB.	14,	2012,	

Section	333

b. 14	CFR	Part	21,	subpart	H

c. 14	CFR	Part	61.113(a)	and	(b)

d. 14	CFT	Part	91

i. 91.103(b)(2)
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ii. 91.105

iii. 91.109

iv. 91.119

v. 91.121

vi. 91.151

vii. 91.405

viii. 91.407

ix. 91.409

x. 91.417

2. Relief	sought:

a. Maribeth	Medich wishes	to	operate	small	Unmanned	Aircraft	Systems	

(sUAS)	for	commercial	purposes	to include	(but	not	be	limited	to)	

aerial	photography	and	data	collection.	This	relief	is	sought	because	

law	currently	prohibits	commercial	use	of	sUAS	unless	performed	

under	an	exemption.

b. This	exemption	will	cover	use	of	the	following	airframes,	all	of	which	

will	weigh	less	than	55	pounds	including	payload	and	energy	sources:

i. DJI	Phantom	3	Professional (2015)

ii. Other	models	to	be	added	by	future	amendment	to	this	

exemption.

3. Public	benefit:

a. Use	of	sUAS	technology	to	obtain	imagery,	information	and	data	

currently	obtained	by	use	of	manned	flight	or	manual	methods:

i. Reduces	statistical	risk	to	human	life	due	to	manned	aircraft	

accidents	(e.g.,	power	line	inspections)	and	due	to	other	

dangerous	activities	that	can	be	avoided	(e.g.,	

scaffolding/rigging	failures	during	stack	or	bridge	inspections).

ii. Reduces	the	cost	of	obtaining	such	information,	which	benefits	

consumers	and	the	economy.

iii. Reduces	environmental	impact	by	eliminating	sources	of	

hydrocarbon	emissions	from	manned	aircraft.	

4. Safety	not	adversely	affected:

a. Aircraft	will	be	registered	and	marked	in	accordance	with	Section	

44711	and	Part	47	and	Part	45,	Subpart	C.

b. Aircraft	will	comply	with	maintenance	and	inspection	requirements	of	

the	manufacturer.	All	repair	and	maintenance work	will	be	conducted	

or	approved	by	qualified	personnel	such	as	those	authorized	by	

Robotic	Skies	(or	equivalent),	and	will	require	a	test	flight	after	such	

work.	Records	of	all	maintenance	and	repair	work	will	be	kept	in	a	

maintenance	log	for	each	aircraft.

c. All	flight	operations	will	be	conducted	by	at	least	two	individuals	(PIC	

and	observer)	who	will	maintain	verbal	communication	capability	

with	each	other	at	all	times	during	the	flight,	and	who	will	remain	

stationary	on	the	ground	during	the	flight	operations:
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i. A	Pilot	In	Command	(PIC)	who	possess	the	following	

credentials:

1. A	Sport	Pilot	Certificate	or	better	rating

2. A	Third	Class	medical	certificate	issued	under	14	CFR	

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3. A	bi-annual	flight	review	under	14	CFR	61.56

4. A	certificate	of	competency	for	UAS	issued	by	Drone	

Universities,	UMEX	or	equivalent	certification

5. At	least	200	cycles	and	25	hours	of	flight	experience	in	a	

UAS	rotorcraft.	Such	cycles	and	hours	may	be	gained	

during	flights	under	this	exemption	if	a	safe	distance	is	

maintained	from	persons	in	accordance	with	14	CFR	

91.119

6. At	least	5	hours	of	flight	experience	and	3	takeoffs	and	

landings	in	make	and	model	being	flown	in	the	prior	90	

days.	Such	cycles	and	hours	may	be	gained	during	

flights	under	this	exemption	if	a	safe	distance	is	

maintained	from	persons	in	accordance	with	14	CFR	

91.119

ii. A	Visual	Observer

iii. A	Sensor	Operator	(whenever	necessary)

d. All	flight	operations	will	be	conducted	in	accordance	with	valid	

Certificates	of	Authorization

e. All	flight	operations	will	comply	with	the	following:

i. The	manufacturers'	Aircraft	Flight	Manuals	and	Operation	

Guidelines

ii. Maribeth	Medich’s flight	operations	policies	including	lost	

communication	and	other	emergency	and	safety	procedures.

iii. Conducted	in	VMC	conditions	during	daylight	hours.

iv. PIC	and	VO	will	maintain	VLOS at	all	times.

v. Pre-flight	inspections	(including	ground	control	station,	if	any)	

and	safety	risk	assessments	will	be	conducted	prior	to	each	

flight.

vi. Flight	altitudes	will	remain	below	400	feet	above	ground	level.

vii. Flight	ground	speeds	will	not	exceed	50	knots.

viii. Not	intrude	into	Class	B,	C or D	airspace,	or	published	

approach,	SID	or	STAR,	or	take	place	within	5	nautical	miles	of	

an	airport.

ix. Not	be	made	near	persons	as	required	in	14	CFR	91.119	and	

not	over	persons	on	the	ground	without	their	prior	permission.

x. Each	flight	will	be	logged	in	both	the	PIC's	logbook	and	the	

aircraft	logbook.

xi. Not	exceed	75%	of	the	battery	or	fuel	capacity	of	the	aircraft,	

or	30	minutes,	whichever	occurs	first.
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xii. Any	incidents	will	be	reported	to	NTSB	within	24	hours	of	

occurrence.

xiii. Maribeth	Medich will	maintain	liability	insurance	sufficient	for	

each	flight by	a	major	aviation	insurance	underwriter.

xiv. Any	applicable	local	FSDO	requirements.

xv. All	other	applicable	regulations	concerned	with	the	operation	

of	aircraft.

f. Aircraft	will	use	2.4	GHz for	control	of	the	aircraft,	and	5.8	GHz	for	

sending	data	with	well-defined	and	tested	lost	link	procedures.

Please	advise	us	of	any	additional	information	or	changes	that	may	be	required.	

Sincerely,	

Maribeth	Medich
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Appendices

1. Appendix	1	– Current	FAA	Rules

2. Appendix	2	– DJI	Phantom	3 Professional	Specifications

3. Appendix	3	– DJI	Inspire	3 Professional	Flight	Manual

4. Appendix	4 – Monthly	Maintenance	Log

5. Appendix	5 – Flight	Log
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Appendix	1	– Current	FAA	Rules

Maribeth	Medich understands	that	the currently	proposed	FAA	rules	are	as	follows:

• A	small	UAS	operator	must	always	see	and	avoid	manned	aircraft.	If	there	is	a	

risk	of	collision,	the	UAS	operator	must	be	the	first	to	maneuver	away.

• The	operator	must	discontinue	the	flight	when	continuing	would	pose	a	

hazard	to	other	aircraft,	people	or	property.

• A	small	UAS	operator	must	assess	weather	conditions,	airspace	restrictions	

and	the	location	of	people	to	lessen	risks	if	he	or	she	loses	control	of	the	UAS.

• A	small	UAS	may	not	fly	over	people,	except	those	directly	involved	with	the	

flight.

• Flights	should	be	limited	to	500	feet	altitude	and	no	faster	than	100	mph.

• Operators	must	stay	out	of	airport	flight	paths	and	restricted	airspace	areas,	

and	obey	any	FAA	Temporary	Flight	Restrictions	(TFRs).
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Appendix	2 – DJI	Phantom	3	Professional Specifications

Aircraft

Weight	(including	battery	and	

propellers)

1280	g

Diagonal	size	(including	

propellers)

590	mm

Max	Ascent	Speed 5	m/s

Max	Descent	Speed 3	m/s

Hover	Accuracy Vertical:	+/- 0.1	m	(when	Vision	Positioning	is	

active)	or	+/- 0.5	m

Horizontal:	+/- 1.5	m

Max	Speed 16	m/s	(ATTI	mode,	no	wind)

Max	Service	Ceiling	Above	Sea	

Level

6000	m	(Default	altitude	limit:	120	m	above	

takeoff	point)

Operating	Temperature 0°C	to	40°C

GPS	Mode GPS/GLONASS

GIMBAL

Controllable	Range Pitch	-90°	to	+30°

Stabilization 3-axis	(pitch,	roll,	yaw)

REMOTE	CONTROLLER

Operating	Frequency 2.400	GHz-2.483	GHz

Max	Distance Up	to	5	km	or	3.1	miles	(unobstructed,	free	of	

interference)	when	FCC	compliant

Up	to	3.5	km	or	2.1	miles	(unobstructed,	free	of	

interference)	when	CE	compliant

Video	Output	Port USB

Operating	Temperature 0°C- 40°C

Battery 6000	mAh	LiPo	2S

Mobile	Device	Holder For	tablet	or	phone
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Receiver	Sensitivity	(1%PER) -101	dBm	±2	dBm

Transmitter	Power	(EIRP) FCC:	20	dBm

CE:	16	dBm

Working	Voltage 1.2	A	@7.4	V

Intelligent	Flight	Battery

Capacity 4480	mAh

Voltage 15.2	V

Battery	Type LiPo	4S

Energy 68	Wh

Net	Weight 365	g

Max	Flight	Time Approximately	23	minutes

Operating	Temperature -10°C	to	40°C

Max	Charging	Power 100	W

Camera

Sensor Sony	EXMOR	1/2.3”	Effective	pixels:	12.4	M	

(total	pixels:	12.76	M)

Lens FOV	94°	20	mm	(35	mm	format	equivalent)	

f/2.8,	focus	at	∞

ISO	Range 100-3200	(video)	100-1600	(photo)

Shutter	Speed 8s	-1/8000s

Image	Max	Size 4000	x	3000

Still	Photography	Modes Single	Shot

Burst	Shooting:	3/5/7	shots

Auto	Exposure	Bracketing	(AEB):	3/5

Bracketed	Frames	at	0.7EV	Bias

Time-lapse

Video	Recording	Modes Phantom	3	Professional

UHD:	4096x2160p	24/25,	3840x2160p	

24/25/30

FHD:	1920x1080p	24/25/30/48/50/60
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HD:	1280x720p	24/25/30/48/50/60

Supported	SD	Card	Types Micro	SD

Max	capacity:	64	GB.	Class	10	or	UHS-1	rating	

required

Max	Bitrate	of	Video	Storage Phantom	3	Professional

60	Mbps

Supported	File	Formats FAT32/exFAT

Photo:	JPEG,	DNG

Video:	MP4,	MOV	(MPEG-4	AVC/H.264)

Operating	Temperature 0°C	to	40°C

Vision	Positioning

Max	Velocity Less	than	8	m/s	(when	2	m	above	ground)

Altitude	Range 50	cm-300	cm

Operating	Range 50	cm-300	cm

Operating	Environment Surface	with	clear	pattern	and	adequate	

lighting	(Lux	>	15)

Battery	Charger

Voltage 17.4	V

Rated	Power Phantom	3	Professional

100	W

APP	/	Live	View

Mobile	App DJI	GO

EIRP 100mW

Power	Spectral	Density 6.9mW/MHz

Live	View	Working	Frequency 2.4GHz	ISM

Live	View	Quality 720P	@	30fps	(depending	on	conditions	and	

mobile	device)

Latency 220ms	(depending	on	conditions	and	mobile	

device)

Required	Operating	Systems iOS	8.0	or	later
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Android	4.1.2	or	later

Recommended	Devices iOS:	iPhone	5s,	iPhone	6,	iPhone	6	Plus,	iPad	

Air,	iPad	Air	Wi-Fi	+	Cellular,	iPad	mini	2,	iPad	

mini	2	Wi-Fi	+	Cellular,	iPad	Air	2,	iPad	Air	2	

Wi-Fi	+	Cellular,	iPad	mini	3,	and	iPad	mini	3	

Wi-Fi	+	Cellular.	This	app	is	optimized	for	

iPhone	5s,	iPhone	6,	and	iPhone	6	Plus.

Android:	Samsung	tabs	705c,	Samsung	S6,	

Samsung	S5,	Samsung	NOTE4,	Samsung	NOTE3,	

Google	Nexus	9,	Google	Nexus	7	II,	Ascend	

Mate7,	Huawei	P8	Max,	Nubia	Z7	mini,	Sony	

Xperia	Z3,	MI	3,	MI	PAD,	Smartisan	T1.

*Support	for	additional	Android	devices	

available	as	testing	and	development	continues.
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Appendix	3 – DJI	Phantom	3	Professional	Flight	Manual
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The	latest	DJI	Phantom	3	Professional Flight	Manual	is	available	for	download	in	

PDF	format	at	the	following	URL:

• https://dl.djicdn.com/downloads/phantom_3_standard/en/Phantom_3_Stan

dard_User_Manual__V1.4.pdf
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Appendix	4 – Monthly	Maintenance	Log

Aircraft:	 Date:

Serial	Number:	

Date	Issue	

Discovered:

Date	Issue	

Addressed:

Issue	Description	&	

Maintenance	

Conducted:

Maintenance	

Performed	By:

Signature:

Software	

Updates:

Airframe:

Engines:

Propellers:

Camera	

Gimbal:

Landing	

Gear:

Vibration	

Dampening:

Other:
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Appendix	5 – Flight	Log

Aircraft:	 Date:

Serial	Number:	 Location:

PIC: AVO:

Trained	Visual	

Observer:

Payload:

Flight	Battery	#: Weather:

Maintenance	

Required:

Notes:

1.	Pre-flight 2.	Mission	Planning

Prior	Maintenance	

Completed:

Set	Home	Point:

Wind	Direction: Create	Grid:

Video	Transmitter: Altitude:

Flight	Battery	

V/Cell:

Angle:

Connect	Flight	

Battery:

Flying	Speed:

Green	Light: Overshoot:

Connect	Datalink: Sidelap:

Verify	Compass: Area:

Radio	Link	%: Distance:

Verify	On-screen	

Display:

Distance	Between	

Images:

Verify	Satellite	

Connection:

Ground	

Resolution:

Pictures:
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Number	of	Strips:

Distance	Between	

Lines:

Flight	Time	(Est.)	

Hours:

Photo	Every	(Est.)	

Seconds:

Accept	Mission:

Save	WPs/.txt	WP	

File:

Write	WPs:

3.	Takeoff	Checklist 4.	In-flight	Checklist

Install	Camera	– All	

Parameters:

Attain	Altitude:

Antennas	Vertical: Verify	Controls:

Motor	Spins	Free: Engage	Autopilot:

Propellers	Are	

Tight:

Verify	WP1:

Verify	Home	Point;	

Start	Point:

Monitor	V	– 25%	

Minimum:

Arm	UAS: Flight	Speed	

Average:

Verify	Flight	

Controls:

Amps	Average:

Verify	Stabilizer: Altitude	Average:

Verify	Throttle:

5.	Landing	Checklist 6.	Post-flight	Checklist

Flight	Battery	V: Disarm:

Landing	Zone	

Clear:

Camera	Off:
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Land: Motor	and	Speed	

Control	

Temperatures:

Flight	Duration:

Disconnect	Flight	

Battery:

Video Transmitter	

Off:

Flight	Batter	

V/Cell:

Verify	Camera	

Operation:

.tlog	File	Name:

Total	Time	on	

Airframe: