September 18, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE, Washington, DC 20590 

RE: A Petition for Exemption Pursuant to Section 333 ofthe FAA Modernization 

and Reform Act of 20 12 

Dear gentleperson: 

Satori Realty Advisors, Inc. 

54052 Alton Pkwy #A303 

Irvine, CA 92604 

www.satori-realty.com 

(949) 273-0966 

Satori Realty Advisors, Inc. (dba. Satori Advisors), a California corporation in good legal 

standing (hereinafter, "Petitioner"), hereby seeks exemption from the requirements of 14 C.F.R 

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), 

and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Petitioner to 

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial 

video and still photography over certain areas of the United States. 

The exemption is based upon information outlined in this petition, Petitioner's enclosed 

Unmanned Aerial Systems Guidelines, the DJI UAS manufacturers manuals and guides, and any 

other requirements established by the FAA pursuant to Section 333 of the Reform Act. 

In closing, you are invited to contact me anytime at your convenience should you have any 

questions. Thank you for your invaluable time and consideration. 

Yours very sincerely and respectfully submitted, 

Executive 

~ Managing Director 

Satori Realty Advisors, Inc. 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No: 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Gary J. Clayman and Satori Realty Advisors, Inc. (dba. Satori Advisors) 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT 

SYSTEM 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on September 18th, 2015 

Gary J Clayman 

Executive Managing Director 

Satori Realty Advisors, Inc. 

5405 Alton Pkwy #A303 

Irvine, California 92604 

(949) 273-0966 
TABLE OF CONTENTS 

INTRODUCTION AND INTERESTS OF PETITIONER ............................................................... ! 

BACKGROUND ...................................................................................................................... 2 

BASIS FOR PETITION ............................................................................................................ 3 

NAME AND ADDRESS OF THE PETITIONER ......................................................................... .4 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEK 

EXEMPTION ......................................................................................................................... 5 

THE EXTENT OF RELIEF PETITIONER SEEKS AND THE REASON PETITIONER 

SEEKS THE RELIEF .............................................................................................................. 8 

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER, STATING: 

THE RULES FROM WHICH PETITIONER SEEKS EXEMPTION ........................................... 27 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT PETITIONER'S REQUEST .................................................................................... 27 

CONCLUSION ..................................................................................................................... 27 

GLOSSARY OF ABBREVIATIONS ........................................................................................ 29 

APPENDICES ....................................................................................................................... 30 

EXHIBIT A .................................................................................................................... 31 

EXHIBIT B .................................................................................................................... 32 

ExHIBIT c .................................................................................................................... 33 

EXHIBIT D .................................................................................................................... 34 

EXHIBIT E .................................................................................................................... 35 
1 of35 

INTRODUCTION AND INTERESTS OF PETITIONER 

The contact information for Petitioner is as follows: 

Gary J. Clayman 

Executive Managing Director 

Satori Realty Advisors, Inc. 

5405 Alton Pkwy #A303 

Irvine, California 92604 

(949) 273-0966 

gary .clayman@satori-realty .com 

Petitioner possesses over 20-years in providing its clientele with complex real estate 

advisory and valuations throughout the United States; Petitioner is recognized throughout 

the United States as an expert in the areas of cost segregation, valuation, and in the 

analysis of: Highest & Best Use, site selection, competitive market, buy versus lease, 

litigation support, and financial modeling (Argus). Throughout the course of20-years, 

Petitioner has been required-pursuant to the terms of Petitioner's engagement lettersto produce complex real estate (interior and exterior) photography and video utilizing 

state of the art technology. Petitioner has over 2 years recreational/hobby experience in 

all aspects of aerial video and photography. The objective of Petitioner's aerial video and 

photography operations is to provide high quality imaging for a variety of commercial, 

residential uses, private and public, specifically targeting: 

• Aerial acquisitions used in the analysis of: 

• Site selection 

• Competitive market 

• Highest & Best Use 

• Surveys 

• Encroachments 

• Topography 

• Mapping 

• Litigation Support 

• Aerial acquisitions used for physical inspections of private and public 

structures 
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• Demonstration (and training) flights 

• Infomercial filming 

• News gathering 

• Real Estate Marketing 

• Real Estate Valuations (of commercial, residential and public real estate) 

• Litigation Support 

• Search and Rescue 

• Wildlife surveys 

• And/or any other related entities/activities that can utilize the safe and 

efficient operation of the UAS 

Petitioner's goal is to operate in an accident-free environment by: 

• Ensuring for the proper training on the latest safety procedures for the 

UASs operate as well as Petitioner's safety procedures outlined in the 

Operations Manual. 

• Being proactive when performing pre-flight operations and identifying any 

potential safety hazards. 

• Demonstrating the ability to identify and appropriately eliminate hazards 

and risks to the aircraft as well as persons involved in the flight. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 Professional UASs 

Petitioner, seeks an exemption to operate DJI systems for compensation or hire within 

the NAS. The DJI Phantom 3 Professional (hereinafter, "PHANTOM 3") UASs is a 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) utilizing an iOS (Apple) or Android handheld device. The PHANTOM 3 

has a maximum gross weight of approximately 2 pounds 12 ounces, while having a 

length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of 

approximately 29 knots. The PHANTOM 3 UAs is equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. 
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BASIS FOR PETITION 

Petitioner, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

§ 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator 

to commercially operate the PHANTOM 3 UASs in the National Airspace System 

(NAS), and for an exemption from the 6 requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) 

& (b). 

In consideration of the speed, weight, size, and limited operating area associated with 

the unmanned aircraft and its operation, Petitioner operation of PHANTOM 3 UASs 

meets the conditions ofFMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, Petitioner requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Petitioner submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Petitioner will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

methods, techniques, and practices prescribed in the operating documents (i.e., Monthly 

Maintenance Log, and PHANTOM 3 Instruction Manual). Furthermore, Petitioner will 

document and maintain all maintenance records for the PHANTOM 3 UASs. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

privileges and limitations: Pilot in command, is requested by Petitioner to the extent 

necessary to allow a Pilot in Command (PIC) not holding a certificate, or an airman 

medical certificate, and who has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the PHANTOM 3 UASs in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 
4 of 35 

Petitioner seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the PHANTOM 3 UASs do not require an airworthiness certificate in accordance 

with 14 C.P.R. Part 21, Subpart H. As such, Petitioner submits that he will ensure that the 

PHANTOM 3 UASs are in an airworthy condition, prior to every flight, by determining 

that the UASs are in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and PHANTOM 3 Instruction Manual), and that the aircraft are in a 

condition for safe flight. 

Petitioner also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the PHANTOM 3 UAs will not have a typical barometric altimeter 

onboard. However, altitude information of the PHANTOM 3 UAs will be provided to the 

PIC via Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of 

the flight path. This altitude information, combined with Petitioner's operation of the 

PHANTOM 3 UASs within visual line of sight, at or below 400 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. 

Additionally, Petitioner seeks an exemption from the requirements of Section 

91.151 (b), entitled Fuel requirements for flight in VFR conditions. Petitioner submits that 

safety will not be affected by operation of the PHANTOM 3 UAs during daylight hours 

in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough 

battery power to fly for a total duration of approximately 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. 

In accordance with 14 C.P.R. § 11.81, Petitioner provides the following information 

in support of its petition for exemption: 

NAME AND ADDRESS OF THE PETITIONER 

The name and address of the Petitioner and point of contact is: 

Gary J. Clayman 

Executive Managing Director 

Satori Realty Advisors, Inc. 

5405 Alton Pkwy #A303 
5 of 35 

Irvine, California 92604 

Email:gary.clayman@satori-realty.com 

(949) 273-0966 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEK 

EXEMPTION 

1. Petitioner Seeks Exemption From The Requirements Of 

Section 61.113(a) and (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for 

compensation or hire. 

2. Petitioner Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Petitioner Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating: 

(1) Below 18,000 feet MSL, to: 

(i) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft; 
6 of 35 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of this 

section, the current reported altimeter setting of an appropriate available 

station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 

4. Petitioner Seeks Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection (b), states the following: 

(b) No person may begin a flight in a rotorcraft 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, to fly after that for at 

least 20 minutes. 

5. Petitioner Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the 

following: 

Each owner or operator of an aircraft: 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Petitioner Seeks Exemption From The Requirements Of Section 91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l ), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless: 

(1) It has been approved for return to service by a person authorized under § 

43.7 ofthis chapter[.] 

7. Petitioner Seeks Exemption From The Requirements Of Sections 

91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 
7 of 35 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had: 

( 1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by§ 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. Petitioner Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b ). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state 

following: 

(a) Except for work performed in accordance with § § 91.411 and 91.413, 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 1 00-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: 

(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. 
8 of35 

(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) ofthis 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. 

THE EXTENT OF RELIEF PETITIONER SEEKS AND THE REASON PETITIONER 

SEEKS THE RELIEF 

1. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief 

From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC not holding any 

pilot certificate, or a current and valid airman medical certificate, but who has met certain 

flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113 (a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 
9 of 35 

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

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

compensation or hire. 

As set forth more fully below, Petitioner submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the PHANTOM 3 UAS 

unless that PIC has met certain flight-hour and currency requirements, demonstrating that 

the PIC is able to safely operate the PHANTOM 3 in a manner consistent with the 

operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Further, Petitioner submits that all flights of the PHANTOM 3 UASs, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to Petitioner's 

business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief 

From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Petitioner to determine that the PHANTOM 3 UASs are in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with 

the operating documents (i.e., the Petitioner Aerial Operations Manual, Monthly 

Maintenance Log, and DJI PHANTOM 3 Professional Instruction Manual). 

Petitioner seeks the requested relief because the PHANTOM 3 UASs do not require 

an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. Therefore, 

Petitioner will ensure that the PHANTOM 3 UASs are in airworthy condition based upon 

its compliance with operating documents (i.e., Monthly Maintenance Log, and DJI 

PHANTOM 3 Professional Instruction Manual) prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated in the conditions and 

limitations below. 

3. Extent Of Relief Petitioner, Seeks From Section 91.121. 
10 of 35 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the PHANTOM 3 UASs, which utilize a barometric pressure sensor, 

GPS equipment, and a radio communications telemetry data link to downlink altitude 

information from the UA to the PIC at the ground control station (GCS). Since the FAA 

requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Petitioner seeks the requested 

relief because PHANTOM 3 UA's altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the PHANTOM 3 UAs are equipped with a barometric pressure 

sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display ofthe GCS. 

4. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief 

From Section 91.151(b). 

Relief from Section 91.151 (b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered by 

the PHANTOM 3 UAs during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. Petitioner seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration ofthe battery powered PHANTOM 3 UAs will 

severely constrain the practicality of any aerial video or still photo flight operations that 

Petitioner proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the PHANTOM 3 

UASs, the PHANTOM 3 operating documents, and Petitioner's operating limitations, 

ensure that Petitioner will safely operate the battery powered PHANTOM 3 UAs during 
11 of 35 

daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. 

5. Extent Of Relief Petitioner Seeks And The Reason Petitioner Seeks Relief 

From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & 

(b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Petitioner requests relief from 

these Sections because the PHANTOM 3 UASs do not require airworthiness certificates. 

As set forth more fully below, the PHANTOM 3 UASs meet the conditions ofFMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, Petitioner 

will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

UAS operating documents (i.e., the Petitioner Aerial Operations Manual, Monthly 

Maintenance Log, and PHANTOM 3 Instruction Manual). Furthermore, Petitioner will 

document and maintain all maintenance records for the PHANTOM 3 UASs. 

THE REASONS WHY GRANTING PETITIONER REQUEST WOULD BE IN THE 

PUBLIC INTEREST; THAT Is, HOW IT WOULD BENEFIT THE PUBLIC AS A 

WHOLE 

Granting the present Petition will further the public interest by allowing Petitioner to 

safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the PHANTOM 3 UASs will decrease congestion ofthe NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of Petitioner's proposed operation of the PHANTOM 3 UASs will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The PHANTOM 3 UAs are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 
12 of 35 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a PHANTOM 3 UAS would reduce the 

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase 

the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

PHANTOM 3 UAs do not require an airport to takeoff or land. Likewise, a reduction of 

manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The PHANTOM 

3 UASs. 

Conducting aerial acquisitions with the PHANTOM 3 UASs, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight operations. 

By using battery power and electric motors, the PHANTOM 3 UASs produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, 

six cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. PHANTOM 3 UAs, while reducing the carbon footprint of aerial acquisitions, also 

eliminate noise pollution, as the UAs are propelled by battery powered electric motors, 

rather than an internal combustion engine. 

By using the PHANTOM 3 UASs to perform aerial acquisitions, the substantial risk 

to life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located on board the aircraft, the 

PHANTOM 3 UAs (weighing approximately 2 pounds 12 ounces, at their maximum 

gross weights with lengths and widths of 16 inches, and with no fuel on board), has less 

physical potential for collateral damage to life and property on the ground, and in the air, 
13 of 35 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The 

PHANTOM 3 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the PHANTOM 3 UASs are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the PHANTOM 3 UASs will allow United States based companies, 

like Petitioner, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection 

Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and 

operated companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered PHANTOM 3 UASs is one such technology 

that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional 

manned aircraft. 

By operating the PHANTOM 3 UASs, companies such as Petitioner, can remain 

competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved 

financial performance of U.S. companies, through commercial use ofthe PHANTOM 3 

UASs, provides a stable workforce that increases consumer spending; improves local, 

state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted 

for decades, Petitioner's proposed operation of the PHANTOM 3 UASs will not implicate 

any privacy issues. Specifically, the PHANTOM 3 UASs will be operated only in 

compliance with operating documents (i.e., the Petitioner's Aerial Operations Manual, 

Monthly Maintenance Log, and PHANTOM 3 Instruction Manual) which requires 
14 of 35 

property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119. 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY, OR HOW THE EXEMPTION WOULD PROVIDE A LEVEL OF 

SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH 

PETITIONER SEEKS EXEMPTION 

1. Reasons Why The PHANTOM 3 UAs Meet The Conditions Of The FAA 

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

In consideration of the size, weight, speed, and limited operating area associated with 

the unmanned aircraft and its operation, Petitioner operation of the PHANTOM 3 UASs 

meet the conditions ofFMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 C.F .R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan and 

rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum-

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to 

users of the national airspace system or the public or pose a threat to 

national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required 
15 of 35 

for the operation of unmanned aircraft systems identified under paragraph 

(1). 

(c) Requirements for Safe Operation.--Jfthe Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Petitioner submits that the PHANTOM 3 UASs can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the PHANTOM 3 UASs; (b) the pilot certification requirement; and (c) 

the specific operating limitations. 

(a) The Specifications Of The PHANTOM 3 UASs Demonstrate Its Safe 

Characteristics. 

The PHANTOM 3 UASs do not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and 

operational capability. 

1. Technical Specifications Of The PHANTOM 3 UASs. 

The technical specifications of the PHANTOM 3 UASs are set forth by the 

PHANTOM 3 Specifications, attached hereto as Exhibit A. 

2. The PHANTOM 3 UASs Autonomous Flight And Navigation Modes 

Enable The UASs To Remain Within A Defined Operational Area. 

The PHANTOM 3 UASs may be operated in both manual and fully autonomous 

flight modes. A complete description of the flight and navigational modes of the 

PHANTOM 3 UASs is provided at pages 39-47 of the PHANTOM 3 User Manual, 

attached hereto as Exhibit B. 

3. The PHANTOM 3 UASs Are Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation. 

When the Control Link is lost, the PHANTOM 3 UAs will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the PHANTOM 3 UAs do not reacquire 
16 of 35 

control link data from the GCS, the UAs will assume that the Control Link is lost and the 

UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to 

the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the PHANTOM 3 UAS are set 

forth at page 14 of the PHANTOM 3 User Manual, attached hereto as Exhibit B. 

4. The PHANTOM 3 GCS And Its Operation. 

A complete description of the operation and specifications ofthe PHANTOM 3 

GCS and flight control software is provided at pages 35 through 39 of the PHANTOM 3 

User Manual. 

PHANTOM 3 User Manual is attached hereto as Exhibit B. 

(b) Flight Operations Of PHANTOM 3 UASs Are Limited To The Line Of Sight 

Of A Pilot in Command With A Safety Observer. 

Petitioner will only utilize pilots who have at least 20 hours flight time to act as a 

pilot in command (PIC) of the PHANTOM 3 UASs. Additionally, a safety observer will 

assist all pilots during flight time. 

(c) Flights Of PHANTOM 3 UASs Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, Petitioner proposes to commercially operate PHANTOM 3 

UASs for the special purpose of conducting aerial video and photography over certain 

areas of United States, pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less than 

55 pounds maximum gross weight: PHANTOM 3 Unmanned Aircraft Systems. 

Proposed operations of any other aircraft will require a new petition or a petition 

to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for 

the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots. 
17 of 35 

4. The UA must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operating documents 

unless a special request is made and approved by A TC. All altitudes reported to 

ATC must be in feet AGL. 

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PIC's FAA-issued airman medical 

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The 

SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the functions 

prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator's responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The 

operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that 

any update or revision would affect the basis upon which the FAA granted the 

exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA's UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition 

for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station must be included in the preflight 
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inspection. All maintenance and alterations must be properly documented in the 

aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight. The PIC who conducts the functional test 

flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must 

be noted in the aircraft records, including total time in service, description of 

work accomplished, and the signature of the authorized person returning the UAS 

to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must have completed at least 25 hours of flight time. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator's qualification criteria and demonstrates the ability to safely operate the 

U AS in a manner consistent with how the U AS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F .R. 

§61.51(b ). Flights for the purposes of training the operator's PICs are permitted 

under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations must be conducted under visual meteorological conditions (VMC). 

If flight at night is required, a special request will be made at the FAA office 
19 of 35 

closest to proposed area of operations. Flights under special visual flight rules 

(SVFR) are not authorized. 

20. The UA may not operate within 2 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport's management is obtained, and the operation is 

conducted in accordance with a NOT AM as required by the operator's COA. The 

letter of agreement with the airport management must be made available to the 

Administrator upon request. 

21. The UA may not be operated less than 400 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

23. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies 

in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed 

to the intended landing point and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice to 

Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours 

prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.P.R. part 47, and have identification 

(N-Number) markings in accordance with 14 C.P.R. part 45, Subpart C. Markings 

must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

28. The documents required fewer than 14 C.F .R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is 

operating. These documents must be made available to the Administrator or any 

law enforcement official upon request. 
20 of 35 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission 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, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per§ 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be 

reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety. 

Petitioner submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the PHANTOM 3 

UASs unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the PHANTOM 3 UAS in a manner 
21 of 35 

consistent with the exemption, including evasive and emergen((y maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Petitioner's proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11 062); and the airmanship skills 

necessary to safely operate the PHANTOM 3, Petitioner submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate to 

the airmanship skills necessary for Petitioner's specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Petitioner will not allow any PIC to operate the PHANTOM 3 UAS unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements or the PHANTOM 3 

UAS training and currency requirements, that the PIC is able to safely operate the 

PHANTOM 3 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 

14 C.F .R. § 61.51 (b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 

5 hours of those hours as a UAS pilot operating the same make and model ofUAS to be 

used for operations under the exemption). In addition to the hour requirements, the PIC 

must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience 

that was obtained in compliance with applicable regulations will ensure an equivalent 

level of safety during Petitioner's proposed operations. The Administrator has held that 
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prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot 

with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC 

must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements to 

be inclusive rather than additive; i.e. 5 hours make and model time may be included 

in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 

hours ofUAS rotorcraft time. In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). 

The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 

11062 are appropriate to practice and build proficiency in the skills necessary to 

safely conduct the petitioner's proposed operations. The FAA also finds that prior 

documented flight experience that was obtained in compliance with applicable 

regulations would satisfY this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under the grant of exemption to accomplish the 

required flight time. During training, proficiency, and experience-building flights the 

PIC is required to operate the UA with appropriate distances in accordance with 14 

C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Petitioner will ensure safe operations by not allowing any PIC to 

operate the PHANTOM 3 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the 

PHANTOM 3 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Petitioner will ensure that the PHANTOM 3 UAS is in an 

airworthy condition based upon the UAS's compliance with its operating documents and 

as stated in the conditions and limitations herein. Additionally, the FAA has previously 
23 of 35 

granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065,11066,11067,11080,11109,11110,11112,11136,11138,11150,11153,11156, 

11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the PHANTOM 3 UAs will be provided to the PIC 

via GPS equipment and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Petitioner's operation of the PHANTOM 3 UAs within visual 

line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121. The altitude information will be generated by GPS equipment installed onboard 

the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the 

PHANTOM 3 UASs; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, Petitioner will ensure that it will 

safely operate the battery powered PHANTOM 3 UAs during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes. 
24 of 35 

Here, as in Exemption No. Ill 09, the technical specifications of the PHANTOM 3 

UASs; the limitations on the proposed flight operations; and the location of the proposed 

operations, will ensure an equivalent level of safety established by 14 C.F .R. Section 

91.151 (b). Furthermore, safety will be ensured as the PHANTOM 3 UASs provide 

audible and visual warnings to the PIC at the GCS when the UAs experiences low battery 

voltage, the first warning occurring at approximately 33% remaining battery power, and 

again at approximately 10% remaining battery power. At the critically low battery level, 

the PHANTOM 3 UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

11062,11063,11064,11065,11066,11067,11080,11109,11110,11136,11138,11150, 

11153,11156,11157,11158,11159,11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) &(b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, Petitioner submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because 

Petitioner will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., the Petitioner Aerial Operations Manual, Monthly 

Maintenance Log, and PHANTOM 3 Instruction Manual). Furthermore, Petitioner will 

document and maintain all maintenance records for the PHANTOM 3 UASs. 

Since the PHANTOM 3 UASs will be inspected as prescribed by the operating 

documents, Petitioner will maintain the equivalent level of safety established by Sections 
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91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of the PHANTOM 3 User Manual is 

attached hereto as Exhibit B; a copy of the PHANTOM 3 UAS Maintenance LOG is 

attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Petitioner 

will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b ), because all maintenance of the 

PHANTOM 3 UASs will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety 

is not adversely affected when the technical characteristics and operating limitations of 

the UAS are considered. 

In consideration of Petitioner's proposed operating limitations, the operating 

documents, and the technical aspects of the PHANTOM 3 UASs, Petitioner submits that 

safety will not be adversely affected by granting exemption from 14 C.F .R. Sections 

91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

previously granted relief specific to UAS in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066,11067,11080,11109,11110,11112,11136,11138,11150,11153,11156,11157, 

11158,11159,11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 

(FMRA) and 14 C.F .R. § 21.16 entitled Special Conditions, Petitioner requests that the 

FAA prescribe special conditions for the intended operation of the PHANTOM 3 UASs, 

which contain such safety standards that the Administrator finds necessary to establish a 
26 of 35 

level of safety equivalent to that established by 14 C.F .R. Part 21, Subpart H, and 14 

C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides 

the authority for such UAS to operate without airworthiness certification in accordance 

with any requirements that must be established for the safe operation of the UAS in the 

NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R.§21.16, for operation of the PHANTOM 3 UASs, since the airworthiness 

regulations of 14 C.F .R. Part 21 do not contain adequate or appropriate safety standards, 

due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the FAA 

finds necessary to establish a level of safety equivalent to that established in the 

regulations. 

See 14 C.P.R.§ 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.P.R.§ 21.16, the FAA 

may prescribe special conditions for Petitioner's intended operation of the PHANTOM 3 

UASs, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F .R. Part 21, Subpart H, 

and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 
27 of 35 

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER, 

STATING: THE RULES FROM WHICH PETITIONER SEEKS EXEMPTION 

Petitioner seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Petitioner Seeks: 

This exemption will permit Petitioner to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT PETITIONER'S REQUEST 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, Petitioner's request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F .R. Part 11, as 

set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without 

airworthiness certification. 

As discussed in detail above, Petitioner will operate the PHANTOM 3 UASs safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose 

a threat to national security. 

CONCLUSION 

As set forth herein, Petitioner seeks an exemption pursuant to 14 C.F .R. § 11.61 and 

Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will 

permit safe operation of the PHANTOM 3 UASs commercially, without an airworthiness 
28 of 35 

certificate, for the limited purpose of conducting aerial video and photography over 

certain areas of the United States. By granting this Petition, the FAA Administrator will 

be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing Petitioner to safely, 

efficiently, and economically operate the PHANTOM 3 UASs commercially within the 

NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of2012, Section 333, Petitioner respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F .R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Petitioner to operate the 

PHANTOM 3 UASs commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States. 

Dated: September 18, 2015 

Respectfully submitted, 

Gary J Clayman 

Satori Realty Advisors, Inc. (dba. Satori Advisors) 

5405 Alton Pkwy #A303 

Irvine, California 92604 

(949) 273-0966 

gary .clayman@satori-realty .com 
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GLOSSARY OF ABBREVIATIONS 

AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PHANTOM3 

PIC 

Section 333 

so 

SOP 

VA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofFederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss ofLink 

National Airspace System 

Notice to Airman 

Dn Phantom 3 Professional 

Pilot In Command 

FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 
30 of35 

APPENDICES 

Exhibit A- DJI PHANTOM 3 Professional Specifications Data Sheet 

Exhibit B- DJI PHANTOM 3 Professional Manufacturer's User Manual 

Exhibit C- Petitioner's Monthly Maintenance Log 

Exhibit D- Petitioner's Unmanned Aerial Systems Guidelines 

Exhibit E- Petitioner's Certificate of Liability Insurance 

The above Appendices are submitted as Confidential Documents under 14 C.F .R. § 

11.35(b) and exempt from disclosure under the Freedom oflnformation Act, 5 

U.S.C. § 552 et seq., and any other requirements established by the FAA 

pursuant to Section 333 of the Reform Act 
31 of 35 

EXHIBIT A 

DJI PHANTOM 3 Professional TECHNICAL SPECIFICATIONS 

Petitioner only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set 

to limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices): 

1.1 DJI PHANTOM 3 Professional 

1.1.1 Aircraft 

1.1.1.1 Supported Battery - DJI 4480mAH LiPo Battery 

1.1.1.2 Weight (Battery & Propellers Included) - 2lbs 12oz 1280g 

1.1.1.3 Hover Accuracy (Ready to Fly)- Vertical: 0.1m; Horizontal: 1m 

1.1.1.4 Max Flight time - Approximately 23 minutes 

1.1.1.5 Max Tilt Angel - 35° 

1.1.1.6 Max Ascent Speed - 5m/s 

1.1.1. 7 Max Descent Speed - 3m/s 

1.1.1.8 Max Flight Speed-16m/s {NOT RECOMMENDED) 

1.1.1.9 Operating Temperature - ooc -40°C 

1.1.1.1 0 Max Flight Altitude - 6000m 

1.1.1.11 GPS Mode - GPS/GLONASS 

1.1.2 Gimbal 

1.1.2.1 Controllable Range - Pitch: -90° + 30° 

1.1.3 Camera 

1.1.3.1 Sensor- Sony EXMOR 112.3" 

1.1.3.2 Lens- FOV 94° 20mm (35mm format equivalent) f/2.8 

1.1.3.3 Effective Pixels- 12.4M 

1.1.3.4 Resolution- 4384x3288 

1.1.3.5 HD Video Recording- 4K, 1080p & 720p 

1.1.3.6 Image Max Size- 4000 x 3000 

1.1.4 Remote Controller 

1.1.4.1 Operating Frequency - 2.400GHz - 2.483GHz 

1.1.4.2 Communication Distance (unobstructed) - 2000m 

1.1.4.3 Battery- 6000 mAh LiPo 2s 

1.1.4.4 Transmitter Power- FCC: 20dbm CE: 16 dbm 

1.1.4.5 Working Voltage -1.2 A @7.4 V 
32 of 35 

EXHIBITB 

DJI PHANTOM 3 Professional Manufacturer's User Manual 

can be found at 

http:/ /www.dji.com/product/phantom-3/download 
EXHIBITC 

Petitioner's Monthly Maintenance Log 

MONTHLY MAINTENANCE LOG 

(Month: September Year: 2015) 

Date Date 

Discovered Addressed Issue: Description and Maintenance Performed Maintenance Performed by: 

Firmware Updates 9/7/2015 9/7/2015 Phantom 3 Professional Firmware vl.4.0010 Gary J. Clayman 

Airframe 

Engines 

Propellers 

Camera/Gimbal 

Landing Gear 

Vibration/Dampening 

Other: 

33 of 35 
34 of 35 

EXHIBITD 

Petitioner's Unmanned Aerial Systems Guidelines 

Submitted as Confidential Documents under 14 C.P.R.§ 11.35(b) and 

exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 

552 et seq., and any other requirements established by the FAA pursuant to 

Section 333 of the Reform Act 

Page 1 of9 

Preface 

An upsurge in commercial unmanned aerial vehicle (UAV) activity and an ever increasing 

number of manufacturers and operators has led to the establishment ofthese guidelines for 

Unmanned Aerial Systems (UAS). Since the terms Unmanned Aerial Vehicle, Unmanned 

Aircraft System and Remotely Piloted Aircraft (RP A) are often used synonymously, this 

document will use the term UAS to standardize and describe all unmanned aircraft systems. 

The intent of these guidelines is to consider the entire system, not just the vehicle when 

operating UAS. The UAS has four subsystems: aircraft, data links (control and return), 

ground control equipment, and the pilot/operator. In general, UAS operations can occur 

within visual line of sight (VLOS), extended visual line of sight (EVLOS) (within electronic 

line of sight of the ground control station), or beyond visual line of sight (BVLOS). 

UAS may be controlled manually by a pilot or autonomously through use of programming 

and autopilot and can vary in size from those weighing less than a pound to some the size of 

a commercial jet. Regardless of the size, the basic guidelines outlined below should be 

considered. They are not an exhaustive list nor should they be considered the only source to 

reference. All UAS operators should ensure their UAS operations meet all applicable legal 

requirements and are consistent with industry guidance. Although many of the elements in 

these UAS guidelines can be incorporated directly into a Safety Management System, they 

do not constitute a complete SMS. The UAS operator should maintain a comprehensive SMS 

that seamlessly integrates UAS operations. 

These guidelines are intended to provide information for personnel seeking UAS services or 

those desiring information to help manage service providers operating a UAS. They will be 

kept under review and updated and changed as necessary. 

General Operating Rules 

1. UAS should be operated in accordance with all applicable local, state and federal 

regulatory requirements, including Section 333 of the FAA Modernization and Reform 

Act of2012 "Special Rules for Certain Unmanned Systems". 

a. Operating documents: Operators should maintain documentation of system 

operating certification, flight operations manual for each operation at the point of 

control of the UAS operation. 

b. All UAS operations should avoid overflight of personnel not involved in the 

operation. 

c. In situations where manned aircraft pose a potential conflict with UAS operations, 

manned aircraft have the right-of way and UAS operations should be terminated 

until the potential conflict has passed. 

2. All UAS should be in airworthy condition and have a continuing airworthiness program 

to conduct flight operations in the National Airspace System (NAS). All UAS should be 
Page 2 of9 

accepted as airworthy by the FAA. In cases where there are no applicable regulatory 

standard available to determine airworthiness, the operator should assert an equivalent 

level of safety to manned aircraft will be provided through adherence to maintenance and 

safety checklist usage standards prescribed in this document in addition to compliance 

with manufacturer guidance. 

3. Essential elements of a continuing airworthiness program include a maintenance training 

program, unique skills or maintenance practices relating to their aircraft and a process to 

report applicable data relating to the maintenance of an operation. 

Operations 

1. All UAS operations should be controlled by a Pilot in Command (PIC). Completely 

autonomous UAS operations should not be conducted. A PIC may control more than one 

UA V, depending on the level of autonomy. 

2. Supplemental Pilots. Supplemental pilots are those pilots assigned UAS flight duty to 

augment the PIC. It is common for operators to have both an internal and an external 

UAS pilot. The supplemental pilot can assume either of these positions. 

3. Recent Pilot Experience. The operator should provide a process that ensures that pilots 

maintain an appropriate level of recent pilot experience for the position they are assigned 

in the UAS being operated. 

4. Visual Line of Sight (VLOS). 

a. Operating within Visual Line of Sight means that the PIC or visual observer is 

able to maintain direct, unaided (other than corrective lenses) visual contact with 

the unmanned aircraft, which is sufficient to monitor its flight path in relation to 

other aircraft, persons, vessels, vehicles and structures for the purpose of avoiding 

collisions. VLOS operations are normally accepted out to a maximum distance of 

one-half nautical mile horizontally and 400 ft. vertically from the UAS pilot. 

5. Extended Visual Line of Sight (EVLOS). 

a. EVLOS operations are operations where the PIC is still able to comply with his 

collision avoidance responsibilities, but the need for the remote pilot to maintain 

direct visual contact with the unmanned aircraft is addressed via other methods or 

procedures. It is important to note, however, that collision avoidance is still 

achieved through 'visual observation' (by the PIC and/or UAS Observers.) All 

UAS operations should occur within VLOS, or EVLOS range. Operations beyond 

visual line of sight are not recommended unless an approved method of aerial 

separation and collision avoidance exists and the operations are in accordance 

with the FAA's requirements. 

b. The operator should submit a safety case including a risk assessment for the 

EVLOS operation. Factors taken into consideration should include: 
Page 3 of9 

1. The procedures for avoiding collisions. 

ii. Aircraft size and configuration. 

iii. Aircraft color and markings. 

iv. Aircraft aids to observation. 

v. Meteorological conditions and visibility, including background conditions 

(cloud/blue sky). 

c. The use of deployed observers. 

d. Operating range limits - suitable radio equipment should be fitted in order to be 

able to effect positive control over the unmanned aircraft at all times. 

e. Contingency plans for loss of link event. 

6. UAS operations (including night operations) should utilize one or more trained visual 

observers to assist the PIC with see-and-avoid responsibilities by scanning the area 

around the aircraft for intruder traffic and assisting the PIC with navigational awareness. 

The visual observer(s) should have a reliable method of instantaneous communications 

with the PIC such as two-way radios. Cellular phones are not considered reliable for this 

purpose, but may be utilized on a case-by-case basis. The PIC and visual observer(s) 

together should have a view of the area that is sufficient to allow enough time for the PIC 

to de-conflict as required. 

7. Spacing multiple visual observers and/or antennae's in a linear manner ("daisy chaining") 

to increase operational distance beyond should generally be avoided; however, operations 

involving "daisy chaining" observers/antennae may be permitted if an acceptable safety 

case is presented by the operator demonstrating the risks are sufficiently managed. These 

operations would normally fall under Extended Visual Line of Sight (EVLOS) or Beyond 

Visual Line of Sight (BVLOS) regulations. EVLOS operations are normally beyond a 

distance of 500 meters horizontally and 400 ft. vertically from the Remote Pilot. 

a. When multiple visual observers are being used, it is important for the PIC to 

know which visual observer(s) have direct visual contact on the aircraft. 

8. Visual observers should: 

a. Be in communication with PIC either within speaking distance or with a portable 

radio. 

b. Be trained in areas such as aviation terminology, Visual Flight Rules (VFR), 

airspace requirements and applicable aviation regulatory requirements. 

c. Keep the pilot informed of possible hazards (power lines, crane/venting booms, 

birds, other aircraft, approaching workboats (when working underneath facility), 

and weather conditions. 

d. Meet any medical or physical requirements mandated by the appropriate civilian 

regulatory authority. 

e. Be designated as such and not share in any other duties associated with the flight. 

f. Be briefed on lost communications procedures prior to the flight. 

9. Weather Observation 
Page 4 of9 

a. A reliable method of determining wind speed, ceiling and visibility should be 

used. 

b. Weather observations should be taken near enough to the operation that it is 

certain that they are valid; for example, an airport's observations can be used if 

the airport is within several miles and the conditions appear to be uniform. 

c. Ceiling may be determined by the temperature/dew point spread. 

10. Night Operations 

a. Night operations may be considered if the operator provides a safety case and 

sufficient mitigation to avoid collision hazards at night. External pilots and 

observers should be in place 15 minutes prior to night operations to ensure dark 

adaptation. 

11. Experience/currency: The UAS operators should provide documentation showing the 

pilots maintain an appropriate level of recent pilot experience in the UAS being operated 

or in a flight simulation training device (FSTD). At a minimum, the PIC should conduct 

three takeoffs (launch) and three landings (recovery) in the specific UAS within the 

previous 30 days, or as prescribed by the operator/applicant's recurrent training and 

currency program. This does not apply when the PIC is not required to be involved in the 

launch and recovery of the UAS operation. 

12. All operators should have a flight operations manual approved by a competent authority: 

at a minimum, the manual should include procedures and checklist information for preflight, in flight, post flight, emergency procedures, and limitations. The operations 

manual should also include information on aircraft systems and performance. 

13. Notification to other potential users of the airspace and appropriate regulatory authorities 

should be issued with ample time for those operators/regulators to plan appropriately. 

Ensure no simultaneous operations between UAS and manned aircraft are planned in 

same area. The following should take place prior to operations. 

a. Notify local airspace users. Include at least: 

i. Date and time range. 

ii. Precise location. 

m. Altitude range. 

IV. Aircraft type and description (what to look for). 

v. Contact information to coordinate, de-conflict and exchange other 

information. 

b. All UAS operations should include a pre-flight brief. The briefing should include 

at a minimum: 

I. Mission overview 

n. Hazards unique to the mission (including potential sources of interference) 

m. A TC notifications 

IV. Identify any special airspace and restrictions. (i.e. VFR corridors, TFRs, 

etc.) 
Page 5 of9 

v. De-confliction plans for intruding aircraft. 

VI. Weather (current and forecast ceiling, visibility and winds). 

VII. Mission altitude. 

vm. Lost Link, divert and flight termination procedures. 

ix. Identification of any public or residential areas near flight path and 

pnvacy concerns. 

x. Flight time and battery requirements. 

XI. Minimum voltage requirements. 

XII. Frequencies to be used. 

14. Immediately prior to each launch, the PIC should: 

a. Perform a pre-flight inspection/checklist. 

b. Visual inspection of airframe condition. 

c. Run system diagnostics. 

d. Conduct engine run test. 

e. Check battery, sensors, etc. 

f. Verify communications with the visual observer(s) and confirm that there is no 

conflicting air traffic. 

15. The use of cell phones and other electronic devices during flight operations should be 

restricted to communications pertinent to the operational control of the UA and any 

required communications with Air Traffic Control. Cell phones should not be used as the 

primary means of communications between visual observers and pilots. 

16. All UAS operations should be conducted with "sterile cockpit procedures" during critical 

phases of flight. These include: taxi and ground operations involving aircraft movement, 

take-off and landing, as well as all other flight operations in which safety or mission 

accomplishment might be compromised by distractions. 

1 7. Lost Link Procedures 

a. There are many acceptable approaches to satisfy lost link requirements. The intent 

of any lost link procedure is to ensure airborne operations remain predictable. 

b. Lost link procedures should comply with any regulatory requirements and the lost 

link solution will need to comply with the last Air Traffic Control (A TC) 

clearance if applicable. 

c. The appropriate A TC facility should be notified immediately if applicable 

d. Lost link procedures should avoid flight over any populated areas and hazards, as 

well as any frequently travelled flight paths. 

e. The time and duration of each lost link event should be recorded by the operator 

and reported through the incident reporting process. 

f. The designated return site should be clear of any personnel and hazards in the 

event of an immediate lost link return to base and landing. 
Page 6 of9 

Maintenance 

1. A maintenance program should be in place to ensure the airworthiness of any UAS being 

utilized. Maintenance be performed in accordance with manufacturer recommendations. 

The program should, at a minimum: 

a. Have a maintenance policy and a procedures manual. 

b. Include a pre-flight and post flight inspection of the vehicle and have an 

associated logbook to track inspections. 

c. Include a pre-flight and post flight inspection of the ground control station. 

d. Incorporate a logbook to track flight hours and any inspection replacement times 

and life limited items. (i.e. batteries, rotors). 

e. Software and hardware changes should be documented as a part of the 

maintenance procedures. 

f. Maintain a record of malfunctions (i.e. loss of link), anomalies and damaged 

parts. 

g. Maintenance training and evaluation program for each operated system. 

h. A quality assurance (QA) program should be utilized as a part of the overall 

safety management system (SMS). 

i. Include both field and depot level maintenance intervals. 

2. It is highly recommended that all UAS operators provide the following information: 

a. A Continuing Airworthiness Program. 

b. A maintenance training program. 

c. Any unique skill sets or maintenance practices relating to the UAS. 

d. A process to report any applicable data relating to the operation and maintenance 

of the UAS. 

Training 

1. All training programs should comply, or be consistent with manufacturer's recommended 

training programs. 

2. UA V pilots should meet applicable training and testing requirements for each class or 

type ofUAS they will operate. 

3. The training program should be appropriate for each aircrew role, the environment and 

mission the operator is expected to perform. 

4. The training program at a minimum should cover currency, evaluation, emergency 

procedure proficiency, systems knowledge and specialized tasks. 

Communications 

1. The communications control links are essential with all UAS operations. UAS should be 

operated in a reliable radio frequency environment that minimizes the probability of lost 
Page 7 of9 

link and Radio Frequency (RF) interference with nearby systems. UAS operators should 

have a valid communications plan that considers: 

a. Every effort is made to ensure positive control of the UAS at all times. 

b. At a minimum, sources of possible radio frequency (RF) interference such as 

microwave antennas and high voltage lines should be identified and assessed prior 

to commencing operations. 

c. Safe recovery of the vehicle in the event of loss of link. 

Hazard Identification and Safety 

1. The UAS operators should have an incident reporting system that tracks and reports all 

mishaps, potential mishaps, control link events, and near misses. This system should 

provide for analysis and improvements made as a part of the operator's Safety 

Management System (SMS). All mishaps, incidents and anomalies should be tracked 

internally and reported to the civilian aviation authorities when necessary. 

2. Appropriate air traffic control should be immediately notified in the event of any 

emergency, loss of command link, loss of visual contact, or any other malfunction that 

would impact safety or operations. 

3. Consideration should be given towards using UAS with redundant controls, automatic 

flight termination and/or flight recovery systems when operating near populated areas or 

sensitive infrastructure. 

Emergency Response Planning 

1. A formal emergency response plan should be in place for all flight operations. An 

incident response checklist, approved as part of the flight operations manual, should be 

followed in the event of an incident or accident. 

Battery Handling 

1. All UAS operators should have a battery safety program that includes: 

a. Documentation with appropriate Safety Data Sheets included in the aircraft flight 

manual, battery tracking systems and battery log books. 

b. Battery storage and charging plans. 

c. Battery inspection procedures and requirements. 

d. Procedures for thermal runaway, determination of battery pack capacity. 

e. Recommended procedures for safe transportation of the batteries that are 

compliant with applicable regulations and work site requirements. 

Additional Consideration 
Page 8 of9 

The following are used by the FAA's Unmanned Aircraft Systems (UAS) Integration Office and 

many UAS organizations to describe relevant differences between UAS operations and those of 

manned aircraft. Other organizations, such as the International Civil Aviation Organization 

(ICAO) and RTCA, Inc., have also developed acronyms and definitions which may differ from 

those used by the Federal Aviation Administration (FAA). Aviation safety inspectors (ASI) may 

wish to refer to the current version ofiCAO Circular 328, Unmanned Aircraft Systems (UAS) 

and RTCA Guidance D0-304, Guidance Material and Considerations for Unmanned Aircraft 

Systems, until harmonization of terminology is achieved. 

I. Aircraft. A device used or intended to be used for flight in the air, including unmanned 

aircraft (UAS). 

2. Airworthiness. A condition in which the UAS (including the aircraft, airframe, engine, 

propeller, accessories, appliances, and control station (CS)) conforms to its type 

certificate (TC), if applicable, and is in condition for safe operation. 

3. Congested Area. A congested area is determined on a case-by-case basis. The 

determination should take into consideration all circumstances, not only the size of an 

area and the number of homes or structures (e.g., whether the buildings are occupied or 

people are otherwise present, such as on roads). 

4. Daisy-Chaining. The use of multiple, successive observers to extend the flight of a UAS 

beyond the direct visual line-of-sight of any other pilot in command (PIC) or VO. 

5. Due Regard. A phase of flight wherein an aircraft commander of a State-operated 

aircraft assumes responsibility to separate his or her aircraft from all other aircraft. 

6. External Pilot. A VAS pilot who flies from outside a control station with direct visual 

contact with the aircraft. 

7. Flight Termination. The intentional and deliberate process of performing controlled 

flight into terrain (CFIT). Flight termination should be executed in the event that all other 

contingencies have been exhausted, and further flight of the aircraft cannot be safely 

achieved, or other potential hazards exist that require immediate discontinuation of flight. 

8. Flyaway. An interruption or loss of the control link, or when the pilot is unable to effect 

control of the aircraft and, as a result, the UA is not operating in a predicable or planned 

manner. 

9. Internal Pilot. A VAS pilot who flies from inside a control station without direct visual 

contact with the aircraft. 

I 0. Lost Link. The loss of command-and-control link contact with the remotely piloted 

aircraft such that the remote pilot can no longer manage the aircraft's flight. 

11. Non-Cooperative Aircraft. Aircraft that do not have an electronic means of identification 

(i.e .. , a transponder) aboard or that have inoperative equipment because of malfunction or 

deliberate action. 

12. Observer. A trained person who assists a UAS pilot in the duties associated with collision 

avoidance and navigational awareness through electronic or visual means. Collision 

avoidance includes, but is not limited to, avoidance of other traffic, clouds, obstructions, 

terrain and navigational awareness. A visual observer (VO) is a trained person who 

assists the UAS pilot by visual means in the duties associated with collision avoidance. A 

VO includes the OPA pilot when the OPA is being operated as a UAS. 

13. Off-Airport. Any location used to launch or recover aircraft that is not considered an 

airport (e.g., an open field). 
Page 9 of 9 

14. Pilot in Command (PIC). The person who has final authority and responsibility for the 

operation and safety of flight, has been designated as PIC before or during the flight, and 

holds the appropriate category, class, and type rating, if applicable, for the conduct of the 

flight. The responsibility and authority ofthe PIC as described by§ 91.3 apply to the UA 

PIC. The PIC position may rotate duties as necessary with equally qualified pilots. The 

individual designated as PIC may change during flight. (NOTE: The PIC can only be the 

PIC for one aircraft at a time. For an OPA, the PIC should meet UAS guidance 

requirements for training, pilot licensing, and medical requirements when operating an 

OPA as a UAS.) 

15. Safety Risk Management (SRM). A formalized, proactive approach to system safety. 

SRM is a methodology that ensures hazards are identified; risks are analyzed, assessed, 

and prioritized; and results are documented for decision-makers to transfer, eliminate, 

accept, or mitigate risk. 

16. Scheduled Maintenance (Routine). The performance of maintenance tasks at prescribed 

intervals. 

17. Supplemental Pilot. Pilots assigned UAS flight duties to augment the PIC. It is common 

for operators to have both an internal and an external UAS pilot. The supplemental pilot 

can assume either of these positions. The supplemental pilot may also assume duties of 

the PIC ifthe specified qualifications are met. 

18. Unmanned Aircraft (UA). A device used or intended to be used for flight in the air that 

has no onboard pilot. This device excludes missiles, weapons, or exploding warheads, but 

includes all classes of airplanes, helicopters, airships, and powered-lift aircraft without an 

on board pilot. U As do not include traditional balloons (refer to 14 CFR part 101 ), 

rockets, and unpowered gliders. 

19. Unmanned Aircraft System (UAS). An UA and its associated elements related to safe 

operations, which may include control stations (ground-, ship-, or air-based), control 

links, support equipment, payloads, Flight Termination Systems (FTS), and 

launch/recovery equipment. 

20. Unscheduled Maintenance (Non-routine). The performance of maintenance tasks when 

mechanical irregularities occur. 

21. Visual Line of Sight (VLOS). Unaided (corrective lenses and/or sunglasses exempted) 

visual contact between a PIC or a VO and a UA sufficient to maintain safe operational 

control of the aircraft, know its location, and be able to scan the airspace in which it is 

operating to see and avoid other air traffic or objects aloft or on the ground. 
35 of 35 

EXHIBITE 

Petitioner's Certificate of Liability Insurance 

Submitted as Confidential Documents under 14 C.P.R.§ 11.35(b) and 

exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 

552 et seq., and any other requirements established by the FAA pursuant to 

Section 333 of the Reform Act 
-~ CERTIFICATE OF LIABILITY INSURANCE I 

DATE (MM/DDIYYYY) 

ACORD8 

~ 02/26/2015 

PRODUCER THIS CERTIFICATE IS ISSUED AS MATTER OF INFORMATION 

AGENT CRAIG MAUK ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE 

8801 CENTRAL AVE. STE D MONTCLAIR, CA 91763 HOLDER. THIS CERTIFICATE DOES NOT AMEND, EXTEND OR 

PHONE: 909-626-7275/FAX: 909-626-7807 ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. 

I~ \ INSURERS AFFORDING COVERAGE NAIC# 

INSURED INSURER A: State Farm General Insurance Company 25151 25151 

Sa tori Realty Advisors, Inc. dba Satori 

Advisors INSURER 8: 

5405 ALTON PKWY #A303 INSURER C: 

IRVINE, CA 92604 INSURER D 

INSURER E: 

COVERAGES 

THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING 

ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR 

MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH 

POLICIES. AGGREGATE LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. 

INSR ADD'L POLICY EFFECTIVE POLICY EXPI~~N 

LTR INSRD TYPE OF INSURANCE POLICY NUMBER DATE IMM/DDIYYl DATE IMM/DD/ LIMITS 

A X ~ERAL LIABILITY 92-C7-H194-5 02/18/2015 02/18/2016 EACH OCCURRENCE $ 1,000,000 

X PMMERCIAL GENERAL LIABILITY ~~~~~iJ9E~~~~?encel $ 300,000 - CLAIMS MADE D OCCUR - MED EXP IAnv one oersonl $ 5,000 

PERSONAL & ADV INJURY $ 1,000,000 

- GENERAL AGGREGATE $ 2,000,000 

-GENt AGGREGATE UMfT APPUES PER: PRODUCTS- COMP/OP AGG $ 2,000,000 

~ .nPRO- POLICY JECT nLOC 

A X A!!IOMOBILE LIABILITY 262 0593-A03-75B 02/18/2015 02/18/2016 COMBINED SINGLE LIMIT 

(Ea accident) $ 

X ANY AUTO '---

- ALL OWNED AUTOS BODILY INJURY $ 100,000 (Per person) 

SCHEDULED AUTOS -

HIRED AUTOS BODILY INJURY $ 300,000 f-- (Per accident) 

f-- NON-OWNED AUTOS 

PROPERTY DAMAGE $ 100,000 f-- (Per accident) 

GARAGE LIABILITY AUTO ONLY- EA ACCIDENT $ 

R-ANYAUTO OTHER THAN EAACC $ 

AUTO ONLY: AGG $ 

DSS/UMBRELLA LIABILITY EACH OCCURRENCE $ 

OCCUR D CLAIMS MADE AGGREGATE $ 

$ R DEDUCTIBLE $ 

RETENTION $ $ 

WORKERS COMPENSATION AND IWCSTATUJ lOTH- TORY LIMITS ER EMPLOYERS' LIABILITY 

ANY PROPRIETOR/PARTNER/EXECUTIVE E.L. EACH ACCIDENT $ 

OFFICER/MEMBER EXCLUDED? E.L. DISEASE- EA EMPLOYEE $ 

If yes, describe under SPECIAL PROVISIONS below E.L. DISEASE- POLICY LIMIT $ 

OTHER 

DESCRIPTION OF OPERATIONS I LOCATIONS I VEHICLES I EXCLUSIONS ADDED BY ENDORSEMENT I SPECIAL PROVISIONS 

CERTIFICATE HOLDER 

132849 03-13-2007 

CANCELLATION 

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION 

DATE THEREOF, THE ISSUING INSURER WILL ENDEAVOR TO MAIL ...1Q_ DAYS WRITTEN 

NOTICE TO THE CERTIFICATE HOLDER NAMED TO THE LEFT, BUT FAILURE TO DO SO SHALL 

IMPOSE NO OBLIGATION OR LIABILITY OF ANY KIND UPON THE INSURER, ITS AGENTS OR 

REPRESENTATIVES. 

AUTHORIZED REPRESENTATIVE 

Craig Mauk: 

All rights reserved 
IMPORTANT 

If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. A statement 

on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s). 

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may 

require an endorsement. A statement on this certificate does not confer rights to the certificate 

holder in lieu of such endorsement(s). 

DISCLAIMER 

The Certificate of Insurance on the reverse side of this form does not constitute a contract between 

the issuing insurer(s}, authorized representative or producer, and the certificate holder, nor does it 

affirmatively or negatively amend, extend or alter the coverage afforded by the policies listed thereon. 

ACORD 25 (2001/08)