This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

PO Box 4055, Greenville, SC 29608

864.492.1648

M3 Partners, LLC & White Top Unmanned Aircraft Systems (WT-UAS)

Petition for Exemption 

Title 14 Code of Federal Regulations (14 CFR) 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

FAA-2007-0001

March 17, 2015

Submitted by:

Mr. Michael W. Middleton Mr. Marty J. Fisher

President, M3 Partners, LLC Member, M3 Partners, LLC

FAA Commercial Pilot Certificate xxx-xx-4625 FAA Commercial Pilot Certificate xxx-xx-2972
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

PETITION EXEMPTION REQUEST FROM M3 PARTNERS LLC, DOING BUSINESS 

AS WHITE TOP UNMANNED AIRCRAFT SYSTEMS (WT-UAS)

M3 Partners LLC (herein referred to as M3 and also doing business as (DBA) White Top 

Unmanned Aircraft Systems WT-UAS) is requesting exemption from the Federal Aviation 

Administration (FAA) of the following: part 21, subpart H; and Sections 45.23(b), 61.113(a) and 

(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 

91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal 

Regulations (14 CFR).

INTRODUCTION AND INTERESTS OF THE PETITIONER

M3 Partners, LLC is a South Carolina limited liability corporation. We are a Service Disabled 

Veteran Owned Minority Small Business (SDVOMSB) formed in 2012 for the purpose of 

helicopter/helipad safety design and assessment and aviation support services. M3 is owned 

and operated by former Presidential helicopter pilots and Helicopter Emergency Management 

Services (HEMS) pilots who have seen the need for increased safety in the realm of helipad 

location, design and maintenance. The two principal members of M3, Mr. Martin Fisher and Mr. 

Michael Middleton are both Marine Corps veterans with over 40 years of aviation experience in 

the piloting, operations, and maintenance of aircraft in the United States and abroad. Mr. 

Fisher and Mr. Middleton are both FAA commercially rated airplane and rotorcraft-helicopter

pilots. Among their aviation credentials both have served as White House Helicopter Aircaft 

Commanders (WHHAC) while serving at Marine Helicopter Squadron One (HMX-1) in support

fhe President of the United States. Their responsibilities included the safe and timely 

transportation of the President and the the coordination and safety of operations for HMX-1 

missions domestically and internationally. Mr. Fisher and Mr. Middleton bring a wide array of 

knowledge and experience in the areas of operational planning, airspace coordination, and 

safety oversight that they are seeking to apply to the fledgling UAS sector. 

The increase in helicopters, specifically HEMS and police helicopters throughout the country

has translated into an increase in take-off and landings as well as patient transports to and from 

privately operated helipads. A business need for a more standardized helipad and Emergency 

Landing Zone verification system was realized. M3 Partners has been working with hospitals, 

HEMS operators and fire departments to maximize safety in and around hospital helipads. M3 

has also worked with local EMS and Fire and Rescue departments in order to establish and 

utilize predetermined (audited and safety documented) Emergency Landing Zones. M3's 

proprietary Helipad Risk Register (HRR), procedures, and tools are assisting in standardizing

and providing a quantitative non-subjective evaluation and remedy for many of the privately 

owned and operated helipads. These helipads will greatly reduce the risk associated with a pilot 

landing in an unfamiliar environment. Our requested use of UAS’s will aid in the identifying and 

safely certifying ELZ and helipads for future HEMS and Police usage. 

In the course of helipad work we have also routinely been asked to perform numerous real 

estate specific tasks. These requests have come from real estate and development 

professionals seeking someone with aviation experience that could operate a UAS in support of 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

their businesses. Upon a market analysis, we have determined that out aviation experience, 

operational planning, and flight safety knowledge positions us to provide these services if we 

are allowed to do so within the current regulations. We also feel that our experience places us 

in unique position to assist in setting the “standard” for the safe employment of UAS’s at this 

initial stage of their inception for commercial use. 

I. Helipad and Helicopter Interests of Petitioner:

Utilizing Turbine or piston helicopters to verify and land in ELZ is both costly and an ineffective 

use of assets. Operating turbine powered HEMS helicopters costs between $500 and $1500/hr. 

HEMS helicopters are also not be able to shoot video or photo’s as the crew is focused on

“eyes out”. Commercial helicopter video services costs are $500 -1000/hr and require 

helicopters to fly low and hover at altitude’s that would require the aircraft to operate inside the 

dangerous Height-Velocity curve of a helicopter. 

Unmanned Aircraft Systems (UAS) will be able to safely video the landing zones and use that 

video to orient pilots and HEMS crews on the zones for future operations. UAS’s will also be 

able to identify hazards to hospital helipads which currently have no FAA regulations for 

certifications. UAS’s are able to safely identify approach and departure routes based on safe 

obstacle avoidance. UAS’s will also be able to do this with little to no “noise pollution” to local 

residence, which is one of the chief complaints of residence who live close to hospital helipads. 

II. Real Estate Interests of Petitioner:

M3 Partners LLC has been in discussion with real estate and videography companies to 

integrate UAS operations into private real estate development, survey, assessment and filming. 

M3 will utilize UAS’s to bring a more accurate and truer picture in the development, selling and 

buying of private property. M3 can use the small size UAS’s over private property to minimize 

any chance of damage to property or personnel. M3 will remain in the confines of specified and 

contracted private property to aid in the overall assessment of property. This enhanced look into 

property will benefit both the owner and potential buyer of properties as well as to give a more 

complete picture of the properties potential. This is currently done with large commercial 

property at great expense utilizing helicopters or fixed wing aircraft with multiple crewmembers,

expensive cameras and both noise and fuel pollution. 

M3 can bring this opportunity to smaller private properties with a safe and economically 

advantageous systematic approach. Utilizing small UAS’s along with Pilot in Command and 

Visual Observer teams M3 will conduct safe, efficient, effective and revolutionary real estate 

services to companies and individuals. M3 will operate similar to an “On Demand” FAR Part 135 

carrier utilizing a General Operations Manual, as well as a Maintenance and Safety system. M3 

will function as an integrated team utilizing the safe employment of small UAS’s in its

commercial implementation. 

Business development teams will effort and seek potential projects then work directly with the 

flight department. Pilot in Command and Director of Safety will obtain, assess and plan a 

project. This integrated approach will do so in a documented, verifiable and safety conscious 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

manner. M3 PIC’s will all be FAA Commercially rated pilots working in conjunction with Visual 

Observers to operate small UAS’s. Pre-project planning will be discussed with business 

development and flight operations teams. Preflight assessment culminating in a mission briefing 

package, will be done by experienced pilots acting as PIC’s to add another layer of safety 

implementation. Final risk assessments will be signed off by a Director of Safety to verify 

compliance with company safety procedures as well as local, state and federal regulations. All 

flights will have two members in order to insure the safe outcome of each project. This 

integrated and layered approach exemplifies M3 Partners goal to only employ UAS’s in a 

responsible and safe manner. Please see the provided “M3 Partners UAS General Operations 

Manual” for further details and more in-depth implementation information.

III. Conclusion Interests of Petitioner:

We believe the ability to operate UAS’s in support of these business ideas will not only help 

economic growth in the forms of jobs but will increase the safety and awareness in the 

helicopter, HEMS, and real estate industries within the United States. The HEMS industry has 

been under scrutiny for years and this is another step that industry and government can take in 

order to affect a safer flying environment. The Real Estate industry will benefit through a more 

thorough “showing” process. Informed buyers will be more likely to target their time and 

resources to homes and real estate that is more closely to their liking. Video obtained through 

UAS flights will create a more informed buyer, one who will be able to directed their time and 

efforts. There is also the potential for environmental savings by avoiding pitfalls early on in the 

real estate development process that the use of UAS’s can aid in. The use of UAS’s can assist 

both developers and authorities having jurisdiction better understand the environmental and 

physical impacts of real estate development projects. 

As set forth in this Petition, M3 seeks to operate its Phantom 2+ UAS for the special purpose of 

aerial surveying, enhancing an established business model with increased safety and efficiency 

utilizing the highest standards of operations and safety in the states of North Carolina, South 

Carolina, Georgia, Tennessee, and Virginia. 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

UAS BACKGROUND INFORMATION

DJI Phantom 2 Vision+ V3.0DJI Phantom 2 Vision+ V3.0Unmanned information is provided for 

supplemental information. This UAS model will be our primary UAS vehicle to fulfill the 

commercial needs requested in this petition. 

General Features

• Ready to Fly, Multifunctional Quad-rotor System

• Customized H3-2D and H3-3D Gimbal Support

• Precision Flight and Stable Hovering

• 25min Flight Time & Smart Battery

• Auto Return-to-Home & Landing

• Advanced Power Management

• Intelligent Orientation Control (IOC)

• Easy Battery Replacement

• Self-tightening Propeller

• Video Downlink Support

• CAN-Bus Expansion Module

Aircraft

• Weight (Battery & Propellers Included) 1000g

• Hover Accuracy (Ready To Fly)
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

o Vertical: 0.8m;

o Horizontal: 2.5m

• Max Yaw Angular Velocity 200°/s

• Max Tilt Angle 35°

• Max Ascent / Descent Speed

• Ascent: 6m/s; Descent: 2m/s

• Max Flight Speed 15m/s(Not Recommended)

• Diagonal Length 350mm

• Flight Time 25mins

• Take-Off Weight ≤1300g

• Operating Temperature -10°C ~ 50°C

Battery

• Supported Battery DJI Smart Battery

• 3S LiPo

• Capacity 5200mAh, 11.1V

• Charging Environment Range 0°C to 40°C

• Discharging Environment Range -20°C to 50°C

Remote Control & Operating Frequency

• 2.4GHz Remote Control

• Communication Distance (Open Area) 1000m

• Receiver Sensitivity (1%Per) -97dBm

• Working Current/Voltage 120 mA@3.7V

• Built-In Lipo Battery Working Current/Capacity 3.7V, 2000mAh

BASIS FOR PETITION

Petitioner, M3 Partners, LLC pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special 

Rules for Certain Unmanned UAS Systems, hereby petitions the Administrator for an exemption 

from the requirements of 14 C.F.R. part 21, subpart H; and Sections 45.23(b), 91.7(a), 

91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 

CFR).

In the alternative, and in accordance with Federal Aviation Regulation (“FAR”) Section 21.16, 

entitled Special Conditions (14 C.F.R. § 21.16), M3 respectfully requests that the Administrator 

prescribe special conditions for the intended operation of the UAS that contain such safety 

standards as the Administrator finds necessary to establish a level of safety equivalent to that 

established by the restricted category airworthiness certification standards specified in 14 

C.F.R. § 21.185. In the alternative, M3 seeks an exemption from the requirement to have a 

certificate of airworthiness issued for its Phantom 2+ UAS, as otherwise contemplated by 14 

C.F.R. Part 21.
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

Below is an outline and description as to how M3 will responsibly and safely conduct UAS 

operations, based off the FAA Sep 2014 published guidelines.

I. Regarding UAS

1. Describe how UAS will be operated safely to minimize risk to NAS, persons and 

property on the ground.

a. M3 will implement a tiered approval process before conducting any flights. 

Flights will be approved on an operations level (they must be able to be 

completed within the prescribed company General Operations Manual and 

they must fit into the Safety Guidelines set forth by company Safety Policy)

b. M3 will operate a 2 person crew with Pilot in Command (PIC) as final 

operational control.

c. Flights will file a Risk Assessment Matrix prior to operations.

i. Weather will be obtained from an approved FAA weather forecasting 

agency

ii. Flight path and plan will be digitally filed and briefed prior to flight

iii. UAS limitations will be briefed prior to flight

iv. Line of Sight limitations will be identified, mitigated and briefed

v. Vehicle safety features (return to home) will be tested prior to flight

vi. Emergency procedures and emergency action plans will be reviewed 

prior to approval

vii. (Insert vehicle specs addendum here)

d. Two tiered Operational control will be in place. Company Policy and 

Procedures and PIC final authority.

2. Describe procedures you would implement to ensure UAS is in condition for safe 

flight.

a. M3 will comply with all manufacturers required and recommended 

maintenance procedures. 

b. M3 will implement a digital maintenance tracking system to monitor and 

record all maintenance action items.

c. M3 will inspect the device in accordance to manufacture guidelines prior to 

each flight and post flight. 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

d. The PIC will perform a company “preflight” before each flight. The PIC will 

also conduct a UAS conformity check before conducting a flight operation

e. UAS flight manual and Maintenance and Inspection Manual added here 

3. Describe the RF spectrum used for UAS control.

a. Phantom 2 is already authorized for flight not interfering with FAA RF 

spectrum usage.

II. Regarding the UAS PIC

4. Describe the qualifications required to perform as Pilot In Command (PIC) (who is 

directly responsible for the operation of the UAS. What would be the roles and 

qualifications of Visual Observers (VO).

a. All PIC’s are at a minimum FAA Commercial Instrument Rotorcraft rated PICs 

with a minimum of 1,500 flight hours.

b. VO’s will have the same qualifications as PIC or will be an experienced UAS 

operator with a minimum of 50 flight hours controlling UAS. The VO’s primary 

role will be a “Second set” of eyes and safety observer for the PIC. VO’s will 

maintain sight of UAS as well as remain watchful for and hazards to UAS or 

personnel and property. 

c. All PIC’s and VO’s will operate with standard aviation terminology regarding 

communication to flight operations. 

d. All PIC’s and VO’s will log at least 1 flight within 30 days of pervious “flight for 

hire”.

e. All PIC’s and VO’s will be required to pass an annual written and flight exam 

conducted by M3 Partners Chief Pilot.

f. All PIC’s and VO’s flights will be logged digitally.

5. Medical standards of PIC 

a. All PIC’s will hold at a minimum a class 2 medical certificate.

b. All M3 employee’s will participate in “Drug Free” work place and comply with 

all appropriate FAR’s pertaining to Drug and Alcohol use.

III. Regarding the Operations of UAS

6. Describe the intended and proposed UAS operations. How you intend to provide a 

level of safety equivalent to that provided by the rule from which exemption is sought. 

Address plans to define operations boarders and procedures to ensure public safety. 

(Describe in petition or Operations Manual)
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

a. M3 intends to utilize its UAS in the following procedures:

i. Helipad assessment

ii. Emergency Landing Zone certification

Real Estate

b. M3 will utilize approved FAA VFR sectionals and airspace classifications. In 

addition M3 will utilize GPS locations and Fore Flight software to pinpoint 

exact location in the NAS

c. M3 will operate the UAS no higher than 400’ AGL

d. M3 will operate the UAS on private property with the knowledge of said 

property owners

e. M3 will establish applicable NOTAMS with the local FSDO

f. M3 will display signage to provide warning of UAS in operation

g. M3 partners will utilize a VHF radio to monitor traffic as well as relay UAS 

specific operations during all operations

7. Provide specific UAS operations limitations regarding: Altitude, speed, minimum 

flight visibility, cloud clearances. 

a. M3 will operate only in VFR conditions as defined by the FAA

b. M3 will operate within all airspace cloud clearances for the appropriate Class 

of airspace operating in (per FAR Part 91 cloud clearances)

c. M3 will not operate above 400’ AGL

d. M3 will not operate the UAS greater than 30 knots

e. M3 will not fly UAS over any persons below 150’ AGL (with exception of PIC 

and VO)

8. Provide the characteristics of area intended for operations. 

a. M3 will operate the UAS in both “congested and non-congested” area’s as 

defined by the FAA.

b. The “Return to Home” feature of the UAS will be a safety feature utilized 

during all flight operations. 

c. The UAS will be operated on private property. M3 will ask all potential 

personnel in the area to remain at least 150’ from UAS operations. Personnel 

may also remain behind a stationary object. Due to the lightweight and small 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

size of the UAS (less than 4 lbs) persons and property injury is unlikely but 

always remains a potential danger and will be mitigated through procedures, 

maintenance, and risk mitigation steps.

d. M3 will utilize GPS locations along with “Google Earth” to annotate potential 

aerial obstructions during preplanning operations.

9. Petition should describe operations within close proximity of airports

a. M3 may receive operation request to perform aerial UAS flights in close 

proximity to airports. In these cases M3 will coordinate with the appropriate 

airport personnel to include local FSDO’s to obtain clearance to do so. 

NOTAMS will be issued. M3 will adjust flight profiles to remain well outside 

airport flight paths to include remaining outside approach and departure 

corridors as well as operating below fixed wing and rotary wing operating 

altitudes.

b. M3 partners will also operate a hand held VHF radio to monitor traffic as well 

as relay UAS specific operations, locations and altitudes. At any time

communication is lost between the PIC and airport authorities the flight will be 

terminated. 

c. M3 Partners primary business model is assessing and surveying hospital 

helipads/heliports in order to provide the safest operating environment. The 

UAS will be able to identify and capture obstructions that are not easily 

recognizable from the ground or from satellite imagery. M3 will operate UAS’s 

on and above various Helipads, Heliports and helicopter landing zones. M3 

will only operate with the permission of Helipad/Heliport managers with

proper notification and approval disseminated and received prior to flights. 

NOTAMS will be issued along with communications with appropriate 

helicopter operators that utilize those Helipads/Heliports. M3 Partners will 

also be working with local governments to establish safe and acceptable 

“Emergency Landing Zones” for both routine HEMS flights and large scale 

disaster relief efforts.

10. Provide data in how company plans on remaining VLOS with UAS.

a. M3 will operate with a minimum two person flight team, a PIC and VO. Both 

members will maintain VLOS with UAS at all times. PIC will be responsible 

for UAS and remain in sight at all times, VO will act as a “second set of eyes” 

maintaining VLOS with UAS as well as “looking out” for potential hazards to 

flight. If at any time both personnel lose sight of UAS a “Return to Base” 

command will be initialed and the UAS will proceed to its predetermined 

rendezvous location.
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

11. Provide Preflight safety risk assessment.

a. Risk Assessment Matrix (RAM) will be filled out and maintained electronically 

for all flights. RAM will be provided in Operations Manual

12. Provide local FSDO when flights require coordination with outside agencies

a. M3 will notify and work with local FSDO any time a flight will operate in any 

airspace other than “Class G” Airspace as defined by FARs.

13. Must have Certificate of Authorization from FAA Air Traffic Organization prior to 

conducting operations in NAS.

a. M3 will work on COA with local FSDO’s upon FAA approval to operate UAS.

M3 REQUESTS REFLIEF FROM THE FOLLOWING REGULATIONS

Part 21 prescribes the procedural requirements for issuing and changing design approvals, 

productions approvals, airworthiness certificates, and airworthiness approvals. 

§ Section 45.23(b) prescribes that when marks include only the Roman capital letter “N” and 

the registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that 

aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 

inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable. 

M3 Partners request relief from this regulation on the basis that the UAS is not of 

appropriate size to have 2 inch lettering on it that will enable it to be read unless UAS is 

stationary and on the ground. Marking for easy identification will be used in order to 

maintain visual contact.. M3 will mark UAS with registration number to the largest extent 

possible.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy 

condition.

§ Section 91.7(b) prescribes that the pilot in command of a civil aircraft is responsible for 

determining whether that aircraft is in condition for safe flight and that the PIC shall 

discontinue the flight when airworthy mechanical, electrical, or structural conditions occur.

M3 Partners requests relief from this regulation on the basis that there is no FAA 

regulatory standard for determining the airworthiness of a UAS. M3 Partners will conduct 

preflight mission and maintenance inspection of UAS prior to any flight. Flights will be 

terminated and maintenance action initiated to troubleshoot and repair UAS if the PIC 

decides at any time the UAS in not in an safe for flight condition. Please refer to M3 

Operations Manual for more specific policy and procedures. 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

§ Section 91.9(b)(2) prohibits operation of U.S.-registered civil aircraft unless there is available 

in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual 

material, markings, and placards, or any combination thereof.

M3 Partners requests relief from this regulation since there will be no pilots or 

passengers on board UAS and given its minimal size. M3 believes an equivalent level of 

safety will be achieved with the intent of this regulation by maintaining a safety/flight 

manual with the UAS PIC and VO. M3 will use UAS operating manuals and any updates 

to satisfy the intent of this regulation.

§ Section 91.103(b) prescribes that a pilot shall for any flight, become familiar with runway 

lengths at airports of intended use, and takeoff and landing distance information.

M3 Partners requests relief from this regulation due to the nature of operating a UAS. 

Runways will not be used. M3 will conduct preflight planning using current satellite 

imagery such as “Google Earth” and current VFR Sectionals for the area and routing to 

be flown. M3 will also do a “walk through” of the area to be flown to verify obstacles and 

hazards that may exist. Please refer to M3 Operations Manual for more specific policy 

and procedures. 

§ Section 91.119 prescribes that, except when necessary for takeoff or landing, no person 

may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without 

undue hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or settlement, or 

over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle 

within a horizontal radius of 2,000 feet of the aircraft. 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except 

over open water or sparsely populated areas. In those cases, the aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. 

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is 

conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) 

or (c) of this section, provided each person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA; and 

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the 

minimums prescribed in paragraph (c) of this section. 

M3 Partners requests relief from this regulation as it would detrimentally prohibit the 

commercial use of flying UAS’s for M3 Partners intended commercial applications. 

Currently hospital helipad and Emergency LZ’s are operated to and from “congested 

areas”. FAA Helipad circulars (A/C150.2C) give recommended guidance to helipad 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

locations and flight paths but no regulation exist to enforce this and is “advisory” only. 

Helicopters routinely overfly homes, streets, parking lots business etc. on their approach 

and departure paths to a helipad or ELZ. M3 will be flying a small UAS (less than 3 

pounds versus the 4,000 to 12,000 lb typical helicopter) on the same flight paths in order

to verify hazards and risks associated with operating in and out of such pads. In order to 

locate and map hazards that are not on VFR Sectional or identifiable from satellite 

imagery, M3 PIC’s will have VHF radio’s and “monitor” 123.025 (as this is the common 

HEMS and “Helo Traffic Frequency) within the area it is working, in order to maintain 

Situational Awareness with operating helicopters in the area.M3 will need to fly in certain 

locations that are currently considered “Congested”. M3 will not operate UAS’s over or 

near open air assemblies or large gatherings of personel. M3 will cleary display area’s 

where operations will be conducted, and will not conduct operations within 150 or 

persons not involved in flight operations.

M3 Partners intended use for real estate assessments will be done over private property. 

Prior permission and risk mitigation as outlined earlier will be coordinated and consent 

granted with the property owner and other authorities having jurisdiction. M3 will mark 

the areas to be flown over and will not fly the UAS near individuals who are not involved 

with the flight survey. M3 will operate with two personnel (PIC and VO) which will enable 

M3 to “see and avoid” personnel and property hazards. 

M3 will operate its UAS at an altitude of no more than 400 feet AGL. Please refer to M3 

Operations Manual for more specific policy and procedures. 

§ Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain 

cruising altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.”

M3 Partners requests relief from this regulation due to the UAS’s ability to use 

barometric and GPS derived altitude. AGL altitude will be used and UAS will remain 

below 400’ AGL at all times.

§ Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing and, assuming normal cruising speed, (1) during the 

day, to fly after that for at least 30 minutes

M3 Partners requests relief from this regulation due to the UAS’s ability to only fly for 20-

25 minutes with available battery life. M3 will plan flights no longer than 15 minutes 

before returning to change batteries. Along with the “Return to Home” safety feature 

(which will automatically return the UAS to a predetermined safety landing area, we 

believe this will satisfy the “intent” of the regulation. The risk of fuel starvation (or total

battery discharge) will be mitigated. The UAS also has warning displays to indicate 

battery “life”. M3 will only operate during day time hours (the hours between official 

sunrise and sunset) and only in VFR conditions as definedin FAR Part 91.
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

§ Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft 

unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an 

effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft registration Application as provided for in 47.31(c).

§ Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft 

unless the airworthiness certificate or a special flight authorization issued under 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

M3 understands that this regulation does not pertain to its UAS operations based on 

recent decisions and that relief is not necessary

§ Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have 

that aircraft inspected as prescribed in subpart E of the same part and shall, between 

required inspections, except as provided in paragraph (c) of the same section, have 

discrepancies repaired as prescribed in part 43 of the chapter.

§ Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that 

has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has 

been approved for return to service by a person authorized under § 43.7 of the same 

chapter. 

§ Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft 

unless, within the preceding 12 calendar months, it has had an inspection for the issuance 

of an airworthiness certificate in accordance with part 21 of this chapter. 

§ Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each engine, 

propeller, rotor, and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since 

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and 

safety directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.

M3 request relief from these regulations with stipulation that M3 will operate and 

maintain UAS in compliance with manufactures operating instructions and M3 General 

Operations Manual guidelines. M3 General Operations Manual outlines the company 

policy to track and verify maintenance on the UAS’s, comply with pertinent FAA 

regulations and aviation industry “best practices” in order to operate safely and 

successfully.
This petition contains proprietary information of M3 Partners, LLC and White Top Unmanned Aircraft Systems (WT-UAS). It is intended solely for the use of the FAA and its

determination of this petition. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written 

permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems (WT-UAS). 

CONCLUSION

In conclusion M3 Partners, LLC wishes to conduct UAS operations for the commercial purpose

of Helipad and Emergency Landing Zone “safety assessments” as well as private Real Estate 

assessments. 

M3 Partners, LLC is a company with extensive civilian and military aviation knowledge and over 

40 years of experience working within the NAS structure. 

All PIC’s and company mechanics currently hold FAA certifications and work on a daily basis 

within the FAR’s that govern commercial flight and maintenance. Our management team has

held numerous aviation department positions within the civilian and military aviation sectors to 

include departments of operations, maintenance, safety, standardization, and check pilot 

certifications.

We have worked extensively to bring a robust safety management system (SMS), proven 

aviation operations procedures, and risk mitigation steps into our proposed operations. 

We strive to conduct UAS operations in a safe, legal and responsible manner. 

It is our sincere belief that our extensive knowledge and experience will allow M3 Partners, LLC

to operate UAS’s safely, legally, and responsibly and serve as a model for future UAS 

commercial operations.