August 28th, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

Exemption Request Pursuant To Section 333 of the FAA Modernization Reform Act of 

2012

Name and Address of Petitioner

Stephen Marshall, Owner

Quad City UAS Services, LLC

3513 N. Sharon Dr. 

Prescott Valley, AZ 86314

(928) 925-3829

Stephenmarshall2013@gmail.com

Introduction

As set forth herein, to commercially operate small Unmanned Aircraft Systems (UAS) safely and 

legally in the National Airspace System (NAS), Stephen Marshall of Quad City UAS Services, 

LLC, Prescott Valley, Arizona, seeks an exemption from Federal Aviation Regulations pursuant 

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

Section 333 states that the FAA may issue a certificate of waiver upon a finding that a type of 

UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and 

populated areas, and operations within visual line of sight do not create a hazard to users of the 

NAS or the public or pose a threat to national security. The grant of such an exemption is 

consistent with Congress’ intent, reflected in Section 333, that safe systems be permitted in the 

national airspace prior to the issuance of final regulations governing general use of these 

systems.

Being “unmanned aircraft and associated elements, including communication links and the 

components that control the unmanned aircraft that are required for the pilot in command to 

operate safely and efficiently in the national airspace system,” Quad City UAS Services’ UAS 

meet the Section 331 definition of “small unmanned aircraft.”
Section 332 provides for such integration of civil unmanned aircraft systems into our national 

airspace system as it is in the public’s interest to do so. We would like to operate our small 

UAS(s) prior to the time period by which the Reform Act requires the FAA to promulgate rules 

governing such craft, thereby providing direct experience and valuable information for formal 

regulation.

Quad City UAS Services intends to use small UAS to provide aerial photography and 

videography services to businesses, organizations and community members. See the Public 

Benefit section of this document for more details. More specifically, we intend to:

 Enable businesses to improve marketing and outreach through the use of state-of-the-art 

aerial photography and videography

 Help to inspect buildings and structures, and map landscapes in a safe, cost-effective 

manner

 Provide economic stimulus and public benefit by providing an effective means by which 

companies or individuals can use up-to-date, high-quality photos and videos to learn 

about properties, neighborhoods and communities

 Help communities realize economic benefit by encouraging public participation and 

encouraging tourism; by showcasing community buildings and landscapes; and by

documenting community events in low-cost ways not previously available to them

 Increase awareness/knowledge of the amenities of a local area by the general public and 

by visiting tourists

 Provide non-profit organizations as well as schools and universities and local 

municipalities ways to showcase facilities, document events, and educate the public

 Aid in search and rescue operations and accident investigations

We understand that we are entitled to submit a Petition for Exemption if we believe that 

following a rule will burden us, we can provide a level of safety at least equal to that provided by

the rule, and our request is in the public interest. Therefore we seek relief from the following 

sections of the current regulations:

14 CFR 21 subpart H - Certification procedures; Airworthiness Certificates

14 CFR 45.23 - Display of Marks

14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations

14 CFR 91.105 Flight crewmembers at stations

14 CFR 91.109 (a) Flight instruction

14 CFR 91.119 (c) Minimum safe altitudes

14 CFR 91.121 - Altimeter settings

14 CFR 91.151 (a) - Fuel Requirements for Flight in VFR Conditions

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

14 CFR 91.405 (a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) Maintenance required;

Operation after maintenance, preventive maintenance, rebuilding or alteration

14 CFR 91.417 (a) & (b) Maintenance Records

14 CFR 91.7 (a) - Civil Aircraft Airworthiness

14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements.
This application is similar to many which have received FAA approval. As stated in Exemption 

#11639, the FAA has found that the enhanced safety achieved using an UAS with the 

specifications described by herein, and carrying no passengers or crew, rather than a manned 

aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives 

the FAA good cause to find that such exemption is in the public interest. Since we are applying 

at a time when the FAA is using a “summary grant process” be informed that while developing 

this request we reviewed, among others, exemptions #11636, #11639, #11595, #11596, #11564, 

#11569, #11616, #12640, and #12641

Extent of Relief and Reason for Seeking Relief; Why the Exemption would not

Adversely Affect Safety, or How the Exemption would Provide a Level of Safety Equal to 

Existing Rule

Part 21 Airworthiness Certification; Subpart H Certification procedures for products and 

parts, Airworthiness Certificates

This section outlines requirements for the issue of design and production approvals, 

airworthiness certificates, and other airworthiness approvals. We seek relief from this 

rule because the size, weight and enclosed operational area of our UAS, as described 

elsewhere in this document, permit exemption from Part 21 because our UAS meet and 

exceed an equivalent level of safety pursuant to

Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the 

airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and 

Section 333 of the Reform Act. Therefore, relief from 14 CFR part 21, and any associated 

noise certification and testing requirements of part 36, is not necessary.

Instead of following this requirement, we will as outlined in this document, as per our 

Flight Operations and Procedures Manual and Training Manual (currently in 

development), Quad City UAS Services seeks to uphold the same level or exceeded level 

of safety as described in Part 21 of 14 C.F.R. Therefore this exemption will not adversely 

affect safety or will provide a level of safety equal to the existing rule.

14 CFR 45.23 Display of Marks

This section outlines regulations requiring specific location(s) and size of aircraft marks. 

We seek relief from this rule because, given the size of our UAS, and the lack of cabin, 

cockpit or pilot station, two-inch lettering is difficult to place on such small aircraft.

Instead of following this requirement, we will mark the UAS in lettering that is as large 

as practicable by placing an N number registered with the FAA on its fuselage so that the 

PIC, VO, or other observers will see the markings. This exemption will therefore not 

adversely affect safety or will provide a level of safety equal to the existing rule.
14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations

This section describes regulations concerning certification of pilots. We seek relief from 

this rule because the risks associated with the operation of a UAS are lesser than and 

often uncorrelated with the risks associated with the commercial and private aircraft 

operations contemplated by Part 61 when drafted. The skills required to fly large, manned 

aircraft are substantially different from the skills required to remotely operate a small 

UAS. Also, manned aerial vehicles weighing significantly more than small drones (such 

as ultralight vehicles) as well as small UAS legally operated by hobbyists, operate 

without the need for pilot certification. Requiring a private or commercial pilot certificate 

would provide no appreciable safety benefit and would needlessly impose an undue 

burden of time and cost on Quad City UAS Services, most particularly in light of the 

FAA’s Small UAS Notice of Proposed Rulemaking which proposes that small UAS 

pilots be considered ‘operators’ required to meet certain requirements that do not include 

pilot’s license.

Instead of following this requirement, to minimize risk and maximize safety, all UAS 

operations will be controlled and limited, and all flights will be planned and coordinated 

prior to operations:

 Prior to operations, Quad City UAS Services’ PIC(s) will go through a documented 

process of dedicated ground school and flight lessons in accordance with manufacturer 

and industry guides.

 All PIC’s will only operate the UAS as stated in this document and in our Flight 

Operations and Procedures Manual, flying at altitudes well below the permissible limits 

for other civil aircraft, and within a geographical envelope under the control of Quad City

UAS Services’ clients.

 The PIC will be designated before a flight and will not transfer control at any time during 

a flight.

 Quad City UAS Services’ PICs will comply with upcoming FAA Operator Certification 

and Responsibilities once they are finalized.

This exemption will therefore not adversely affect safety or will provide a level of safety 

equal to the existing rule. More information about pilot safety can be found in the Operation 

of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property section of this 

document.

14 FR 91.105 Flight crewmembers at stations

This section outlines regulations for flight crewmembers inside an aircraft. We seek relief 

from this rule because there is no flight crew onboard a small UAS. Instead of following 

this requirement, in keeping with the direction of the regulation, the PIC of the UAS and 

VO will be at their respective crewmember stations on the ground during takeoff and 

landing as well as the complete duration of the flight. By instituting this procedure this 

exemption will therefore not adversely affect safety or will provide a level of safety equal 

to the existing rule.
14 FR 91.109 (a) Flight Instruction

This section provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. We seek relief from this rule because UAS do not have fully functioning 

dual controls.

Instead, flight control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. The FAA has approved exemptions for flight 

training without fully functional dual controls for a number of aircraft and for flight 

instruction in experimental aircraft. This exemption will therefore not adversely affect safety

or will provide a level of safety equal to the existing rule.

14 CFR 91.119 (c) Minimum safe altitudes: General.

This section establishes minimum altitudes for operation of civil aircraft. We seek relief 

from this rule because the services we intend to provide for the public good may require 

photo or video images captured from an altitude of less than 500 feet.

Instead of following this requirement, all UAS flights will be conducted with within 

visual line of sight and with prior permission from the owner of the property or 

municipality. All persons, vessels, vehicles, not directly involved with the operation will 

be notified and cleared of the area where UAS operations will be conducted. Given our 

policies of advance notice and access restricted area, and given the size, weight, 

maneuverability and speed of our UAS, we will maintain an equivalent or higher level of 

safety of that described in this rule.

14 CFR 91.121 Altimeter settings

This section defines regulations for altimeter settings. We seek relief from this rule 

concerning altimeter settings because: our UAS has no altimeter settings. Instead, 

electronic GPS downlinks telemetry data in real time to the PIC’s ground-based onscreen display as to the altitude (AGL) of the UAS above the takeoff location.

This exemption will not adversely affect safety, as our PIC will provide a level of safety 

equal to the existing rule by confirming the altitude of the launch site shown on the GPS 

altitude indicator prior to each flight.
14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “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; or (2) At night, to fly after that for 

at least 45 minutes.” We seek relief from this rule because our UAS runs on battery

instead of fuel, most of our UAS flights last less than the 30 minute reserve requirement, 

and we do not fly at night. 

Instead of following this requirement, an equivalent level of safety will be achieved by 

following the UAS manufacturer’s operating documents with regard to battery voltage. 

To ensure safety and maintain adequate communication between radio contol and the 

UAS, our PIC will not begin a flight with a battery holding less than 75% charge; and 

will not begin a flight unless (considering wind and forecast weather conditions) there is 

enough power to fly to the intended landing point at normal cruising speed and land the 

UAS with no less than 30% of battery power. A landing sequence will be initiated at the 

30% warning and the UAS automatically initiates landing sequence at 15% charge while 

still under PIC control.

Through implementation of these procedures, this exemption will not adversely affect 

safety or will provide a level of safety equal to the existing rule.

14 CFR 91.203 Carrying Civil Aircraft Certification and Registration

This regulation pertains to display of airworthiness certification within an aircraft. We 

seek relief from this rule because our small UAS each weigh less than 10 pounds, and are 

operated without an onboard pilot. There are passengers or crew; and no cabin or cockpit 

entrance upon which to display certificates. An equivalent level of safety will be achieved 

by keeping these documents at the ground control point where the PIC will have 

immediate access to them, and be able to provide them upon request.
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) (2) 

Inspections; and 14 CFR 91.417 (a) & (b) Maintenance records

We seek relief from these 4 rules because these regulations only apply to aircraft with an

airworthiness certificate, and will not, therefore, apply to Quad City UAS Services UAS. 

We seek relief also because the FAA has not developed maintenance standards for UAS 

that would allow an UAS operator to meet the part 91 maintenance requirements. In 

particular, there are no individuals authorized by the FAA to approve a UAS for return to 

service or to conduct the initial airworthiness and annual return to service inspections as 

required.

Instead of following these requirements, we will:

 Perform preventative and required maintenance on each aircraft as per the owner’s 

manuals.

 Inspect our UAS before and after each flight as per our Flight Operations and Procedures 

Manual to ensure that the UAS is in a condition for safe flight.

 Will conduct a test flight on each aircraft following any major repairs.

 Will properly note all discrepancies, maintenance, and alterations in a Maintenance Log.

Therefore this exemption would not adversely affect safety or would provide a level of safety 

equal to the existing rule. More information about maintenance procedures can be found in the

Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and Property section 

of this document.

14 CFR 91.7 (a) Civil aircraft airworthiness

This section states that “no person may operate a civil aircraft unless it is in an airworthy 

condition.” We seek relief from this rule based on the fact that Quad City UAS Services’

UAS will not require an airworthiness certificate in accordance with 14 CFR part 21, 

Subpart H. Based on the fact that an airworthiness certificate will not be issued, 

exemption from § 91.7(a) is not necessary. An equivalent level of safety will be achieved 

through the guidance from our Flight Operations and Procedures Manual, pilot training, 

and operational risk management for each activity.

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

This section requires an aircraft flight manual in the aircraft. We seek relief from this rule 

based on the small size of our UAS and the fact that our UAS carries no onboard pilots or 

passengers. Given its size and configuration there is no room or capacity in our UAS to 

carry such an item. This regulation is therefore inapplicable. An equivalent level of 

compliance will be achieved by keeping our versions of these documents at the ground 

control point where the PIC will have immediate access to them, and be able to provide 

them upon request.
Public Benefit: how our request would benefit the public as a whole

Granting Quad City UAS Services the ability to operate small UAS safely and legally in the 

National Airspace System will have the following positive economic and societal impacts on 

local communities, businesses, organizations and community members:

 benefit local business marketing by offering state-of-the-art aerial photography and 

videography

 help to inspect buildings and structures, and map landscapes in a safe, cost-effective 

manner

 provide economic stimulus and public benefit by providing an effective means by which 

companies or individuals looking to relocate to an area can use up-to-date, high-quality 

photos and videos of real estate properties to learn about properties, neighborhoods and 

communities

 help communities realize economic benefit by encouraging public participation and

encouraging tourism by showcasing community buildings and landscapes and by

documenting community events in low-cost ways not previously available to them

 increase awareness/knowledge of the amenities of a local area by the general public and 

by visiting tourists

 provide non-profit organizations as well as schools and universities and local 

municipalities in ways to showcase facilities, document events, and educate the public

 aid in search and rescue operations and accident investigations

All of the above services:

 are otherwise unavailable to the public, given the UAS’s the ability to:

o Safely capture images from 0 to 400 feet.

o Create images that are more up-to-date and more closely defined than Google Earthtype satellite images.

o Create images at prices lower than that of traditional helicopter and airplane 

photography and videography.

 Increase safety of and reduce risk to the public and the NAS by:

o Replacing large manned helicopter and airplane flights with small UAS flights, 

thereby reducing air and noise pollution as well as the dangers inherent in flying 

aircraft loaded with crewmembers and combustible fuel close to people and property.

o Offering safer ways to inspect tall structures and remote locations, e.g. removing the 

physical risk of climbing on a roof or structure to inspect it.

 Reduce environmental pollution and reliance on fossil fuels by replacing fueled aircraft 

flights with battery-operated UAS flights.
Operation of the Unmanned Aircraft to Minimize Risk to the NAS, People and

Property

Concerning our commercial UAS flight operations, we take seriously our obligation to clearly

define operational borders, and implement operational risk management procedures to ensure the 

public safety of persons and property both in the air and on the ground. While Quad City UAS 

Services currently provides photography and videography services in Northern Arizona, we may

at times contract with clients throughout the U.S. Our area of intended operations include a range 

of population areas, from urban to rural, with some areas, especially coastal ones, experiencing 

seasonal increases and decreases in activity from both people and aircraft.

Our operations will take into account these variations in populations and activities. My rotorcraft 

experience (Commercial Pilot Rotorcraft enables me to apply operational risk management 

techniques when assessing situations where the safety of the general population and the NAS are 

concerned.

Meeting or exceeding COA requirements to perform commercial operations in low-risk, 

controlled environments, our UAS will be operated:

●During daytime Visual Flight Rules (VFR) conditions and visual meteorological 

conditions (VMC).

●Within visual line of sight (VLOS) of the Pilot in Command (PIC) or the Visual 

Observer (VO), in accordance with the statutory Section 333(b)(1) mandate.

●In such a manner that the PIC and VO are able to communicate verbally at all times; 

and that the VO can assist the PIC with seeing and avoiding other air traffic and other

ground-based obstacles/obstructions.

We will not operate our UAS:

●At altitudes exceeding 400 feet AGL

●In winds exceeding 25 knots.

●From any moving vehicle or device.

●At airspeeds greater than the maximum recommended by the manufacturer.

●Less than 500 feet below or less than 2000 feet horizontally from a cloud or when 

visibility is less than 3 statute miles from the PIC.

●Unless (considering wind and forecast weather conditions) there is enough available 

power for the UAS to conduct the intended operation and to operate after that for at least 

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

●Near areas where general public is within 200 feet; or directly over any person except 

authorized Quad City UAS Services personnel and consenting inspection personnel, 

unless operations nearer to the PIC do not present an undue hazard to those persons; or 

unless 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 near power lines, wind turbines, or elevated lights; or within areas of airspace 

restrictions such as the one imposed by the National Park Service.
●Near airports, heliports, or military bases; more specifically:

o In accordance with the statutory Section 333 mandate regarding proximity to 

airports, we will stay certain distances away from airports or heliports: 5 NM 

from an airport having an operational control tower; or 3 NM from airport w/ a 

published instrument flight procedure, but not operational tower; or 2 NM from 

an airport w/out published instrument flight procedure or an operational tower; or 

2 NM from a heliport with a published instrument flight procedure.

o We will 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 will be made available to the 

Administrator or any law enforcement official upon request.

 If we intend to conduct operations in controlled airspaces which have existing 

requirements to notify Flight Standards District Offices (FSDOs) prior to operations –

such as motion picture and television filming, or pipeline and power line patrol – we will 

contact the local FSDO and comply with their procedures, such as filing a NOTAM as 

per their request

Our Flight Operations and Procedures Manual, will include procedures for:

 Conducting a preflight safety risk assessment to determine that the UAS is in a condition 

for safe flight, i.e. completing a preflight inspection checklist to ensure the UAS’s 

airworthiness. If the inspection reveals a condition that affects the safe operation of the 

UAS and/or the Ground Control Station, the aircraft will be prohibited from operating 

until the necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight.

 Maintaining a Flight Log (noting UAS flight time, Control Unit operation time, incident 

reports, etc.); and making said Log available to the FAA if requested.

 conducting initial and ongoing training of PICs and VOs, to include classroom training, 

and training, proficiency and experience-building flights; all persons not essential for 

flight operations will be considered nonparticipants, and the PIC will operate the UAS 

with appropriate distance from nonparticipants in accordance with 14 CFR 91.119.

 Evaluating the operational abilities of PICs and VOs on a regular basis.

 maintaining and repairing the aircraft to ensure that it is in a condition for safe operation 

by:

o Following the UAS manufacturer’s maintenance, overhaul replacement inspection, 

and life limit requirements and safety bulletins for the aircraft and its components.

o Installing firmware updates provided by the manufacturer.

o Keeping a Maintenance Log noting all maintenance, inspection, alterations, and status

of replacement/overhaul component parts in the aircraft records, including total time

in service, description of work, and signature of the authorized person returning the

UAS to service; and making said Log available to the FAA if requested.

o Verifying condition of flight batteries and calibrating the Inertial Measurement Unit

(IMU) using manufacturer software.
o Conducting a functional test flight on any UAS that has undergone maintenance or

alterations that affect the UAS operation; said functional test flight will be conducted

by a PIC with a VO and so as to not pose an undue hazard to persons and property;

and recorded in the aircraft records.

● Procedures that ensure that the planned operation can be completed safely, such as:

o Checking local sectional (air) charts, notam (notice to airmen), etc. prior to the 

flight.

o Conducting a pre-flight visual survey of the area to consider characteristics of the 

area of intended operation(s) and the associated potential hazards regarding 

proximity to populated areas.

o Remaining clear and giving way to all manned aviation operations and activities 

at all times.

o Aborting a flight and landing the UAS at the nearest and safest ground point in 

the event of safety breaches, potential danger, unpredicted obstacles or 

emergencies.

o Using a fresh, fully-charged battery with each flight as a safety precaution, to 

ensure safety and maintain adequate communication between radio contol and the 

UAS; and not operating our UAS at or below manufacturer recommend minimum 

charge levels for operation.

Also:

● Flight operations will be performed only at the request of and with the authorization and 

permission of clients (property owner/controller) or their authorized representatives.

● Caution signs will be placed at the site of aerial operations to warn people that aircraft 

operations are in progress.

● Our Client Agreements will reserve us the right to decline a photo shoot if conditions of the 

location (e.g. proximity of power lines) may cause unacceptable risk; and to reschedule a photo 

shoot if weather conditions such as precipitation or wind speed become a factor.

●The operating documents for our UAS, and any revisions, will be accessible during UAS 

operations and made available to the Administrator or law enforcement official upon request.

● We will carry comprehensive general liability insurance coverage and an additional insurance 

policy specifically covering our UAS.

Summary for Federal Register

Stephen Marshall of Quad City UAS Services LLC, Prescott Valley, Arizona, seeks exemption 

from Federal Aviation Regulations pursuant to 14 C.F.R. and Section 333 of the FAA 

Modernization and Reform Act of 2012 for the purpose of commercially operating small 

Unmanned Aircraft Systems (UAS) safely and legally in the National Airspace System.

Specifically, Quad City UAS Services seeks relief from the following sections of the current 

regulations:

14 CFR 21 subpart H - Certification procedures; Airworthiness Certificates; 14 CFR 45.23 -

Display of Marks ; 14 CFR 61.113 (a) & (b) Private Pilot Privileges and Limitations ; 14 CFR 

91.105 Flight crewmembers at stations ; 14 CFR 91.109 (a) Flight instruction ; 14 CFR 91.119 

(c) Minimum safe altitudes ; 14 CFR 91.121 - Altimeter settings ; 14 CFR 91.151 (a) - Fuel 

Requirements for Flight in VFR Conditions ; 14 CFR 91.203 Carrying Civil Aircraft 

Certification and Registration ; 14 CFR 91.405(a) 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2) 
Maintenance required; Operation after maintenance, preventive maintenance, rebuilding or 

alteration; 14 CFR 91.417 (a)&(b ) Maintenance Records; 14 CFR 91.7 (a) - Civil Aircraft 

Airworthiness ; 14 CFR 91.9 (b) Civil aircraft flight manual, marking, and placard requirements.

Quad City UAS Services intends to use small UAS to provide aerial photography and 

videography services to businesses, organizations and community members. More specifically, 

we intend to:

● enable businesses to benefit through the use of state-of-the-art visual marketing 

materials

● help to inspect buildings and structures, and map landscapes in a safe, cost-effective 

manner

● provide economic stimulus and public benefit by providing an effective means by

which companies or individuals can use up-to-date, high-quality photos and videos to 

learn about properties, neighborhoods and communities

● Help communities realize economic benefit by encouraging public participation and

encouraging tourism; by showcasing community buildings and landscapes; and by

documenting community events in low-cost ways not previously available to them

● Increase awareness/knowledge of the amenities of a local area by the general public 

and by visiting tourists

● Provide non-profit organizations as well as schools and universities and local 

municipalities ways to showcase facilities, document events, and educate the public

● Aid in search and rescue operations and accident investigators.

The enhanced safety achieved using an UAS with the specifications described herein, and 

carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, 

carrying crew in addition to flammable fuel, should give the FAA good cause to find that such 

exemption is in the public interest. By granting this request for exemption, the FAA will 

facilitate the smooth integration of UAS into the NAS.

Additional Information

Design Characteristics, Aircraft Performance and Performance Limitations, and

Conditions of UAS to be Operated

UAS Described Below

● Utilize 4 counter-rotating propellers for balance, control and stability

● Are equipped with GPS to maintain geospatial orientation and position

● Use Return Home safety technology and Auto Landing feature if UAS loses transmitter signal

● are controlled primarily through FCC approved RF spectrum transmitter/controller/receivers; 

and FCC approved RF spectrum EIRP with transmitting power of 100 mW for dedicated wifi 

transmitter/receiver between sUAS, Range Extender attached to transmitter and mobile viewing 

device displaying operational telemetry and video/photography functions.

● Send real time video and telemetry information is transmitted back to a ground control station, 

allowing PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from PIC, 

camera imagery, and control camera angle.

● Have failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited 

by the onboard flight controller and maximum altitude can be preprogrammed by the PIC.

● Have audible and visual sequential low battery warnings set at 30% charge and 15% charge

remaining. The SUAS automatically initiates landing sequence at 15% charge while still under
PIC control. The onboard flight controller will warn the pilot via telemetry and external lighting 

cues before reaching a low battery state. An automatic termination of flight and landing will be 

initiated when the battery reaches a predetermined low state.

DJI Phantom 3 Professional

● Gross weight of less than 3 pounds including camera and battery

● Cruising speed of 15 knots, with a maximum speed of 31 knots and maximum altitude of

6000m

● Maximum flight time of 23 minutes

● FCC compliant Radio Frequency (RF) spectrum 2.400 GHz2.483

GHz

● Manual available at http://www.dji.com/product/phantom-3/download