Morandi Engineering and Construction, Inc.

930 SW 16 St., Boca Ratón, FL 33486

Tel (954)-461-9785; or 5824

Morandieng@Gmail.com or Hotmail.com

Date: Monday, December 07, 2015 

To: U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC 20590

Ref: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the 

Federal Aviation Regulations from: 

1. 14 CFR 45.23(b);

2. 14 C.F.R. 45.27(a),

3. 14 CFR 45.29; 

4. 14 CFR Part 21 subpart H;

5. 14 CFR 61.101 (e)(4) & (5)

6. 14 CFR 61.113(a) & (b);

7. 14 CFR 61.23(a) & (c);

8. 14 CFR 61.315 (c) (2) & (3)

9. 14 CFR 91.7(a);

10. 14 CFR 91.9(b)(2);

11. 14 CFR 91.103;

12. 14 CFR 91.109;

13. 14 CFR 91.119(c);

14. 14 CFR 91.121;

15. 14 CFR 91.151(a);

16. 14 C.F.R. 91.151(b),

17. 14 CFR 91.203 (a) & (b);

18. 14 CFR 91.405 (a);

19. 14 CFR 91.407 (a) (1)

20. 14 CFR 91.409 (a)(1) & (2);

21. 14 CFR 91.417(a) & (b)

22. 14 CFR 91.7 (a)

In accordance with 14 C.F.R. § 11.81 Morandi Engineering and Construction, Inc. provides the following

information in support of its petition for exemption:

The Petitioner, Morandi Engineering and Construction, Inc. (MEC) hereby applies for the above 

referenced exemptions in order to operate a Small Unmanned Aircraft System (sUAS), more 

specifically a DJI Phantom 3 Professional, equipped to conduct aerial imaging and surveying within 
Morandi Engineering and Construction, Inc.

930 SW 16 St., Boca Ratón, FL 33486

Tel (954)-461-9785; or 5824

Morandieng@Gmail.com or Hotmail.com

and under the conditions outlined herein or as may be established by the FAA as required by Section 

333.

Commercial operation of the sUAS, as described herein, which is equipped with cameras and sensors, 

would operate in the following manner:

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, engineering and other related professional activities.

2. Aerial video and/or photography for public and/or private use including television, public 

events, cinematography and news gathering.

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority.

4. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation.

5. The ability to offer training to persons individually or belonging to both private and/or public

organizations that have interests in the use and application of sUAS for the purpose of the safe

operation of sUAS to enhance the safety of the National Airspace System (NAS)as well as for the

protection of the persons and property. As described fully below, the requested exemption would

permit the operation of sUAS under controlled conditions in the NAS that would be a) limited b)

controlled c) predetermined and d) will provide safety enhancements to the already safe operations in

the industry presently using conventional aircraft. Approval of this exemption would thereby enhance

safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “.... 

establish requirements for the safe operation of such aircraft systems in the national airspace system.”

Petitioner:

Morandi Engineering and Construction, Inc., specializes in conducting engineering inspections 

and forensic analysis of structural failures. The company also conducts Design/Build services for 

clients and real estate services, under the DBA of Morandi Real Estate.

The company holds professional engineering licenses certificate of authorization in the state of 

Florida and Texas. The company is also a licensed as a general contractor and real estate broker 

in the state of Florida.

Equipment:

Unmanned Aircraft Systems: DJI Phantom 3 Professional

Morandi Engineering and Construction, Inc. seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 3 Professional is a vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic or smart phone systems in tandem with its own dedicated remote system. The DJI 

Phantom 3 Professional has a maximum gross weight of 2 pounds, 3 ounces with a diagonal size 

of 23.3 inches and a maximum speed of approximately 31 knots. The DJI Phantom 3 
Morandi Engineering and Construction, Inc.

930 SW 16 St., Boca Ratón, FL 33486

Tel (954)-461-9785; or 5824

Morandieng@Gmail.com or Hotmail.com

Professional is equipped with four main rotors driven by a 6000mAh LiPo 2S powered electric 

motors and a Sony EXMOR 1 /2.3” for image capture.

The DJI Phantom 3 Professional that will be operated by Morandi Engineering and Construction, 

Inc. will be registered in accordance with 49 U.S.C. 44103, as well as 14 C.F.R. Part 47, and 

marked on accordance with 14 C.F.R. Part 45.

Basis:

Petitioner, Morandi Engineering and Construction, Inc., pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R.§ 11.61) and FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, hereby petitions the Administrator to commercially operate the DJI 

Phantom 3 Professional UAS in the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 45.23(b), 45.27(a),45.29, Part 21 subpart H, 61.113(a) 

&(b), 91.7(a), 91.9(b)(2), 91.103, 91.109, 91.119(c), 91.121, 91.151(a)&(b), 91.405(a), 

91.407(a)(1), 91.407(a)(1), 91.409(a)(1)& (2), and 91.417(a)&(b).

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

unmanned aircraft and its operation, Morandi Engineering and Construction’s operation of DJI 

Phantom 3 Professional meets the conditions of FAA Modernization and Reform Act of 2012 

(FMRA) Section 333 and therefore, will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21 Subpart H. Accordingly, Morandi Engineering and Construction requests 

relief from §§ 91.405(a), 91.407(a)(1), 91.409(a)(1)&(2), and 91.417(a) & (b), as these sections 

set forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. 

Morandi Engineering and Construction submits that the requested relief is proper since an 

equivalent level of safety will be ensured. The company will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

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

Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, the 

company will document and maintain maintenance records for the DJI Phantom 3 Professional 

UAS.

Relief from certain requirements of § 61.23(a) & (c) entitled Medical certificates:

Requirement and duration, is requested by Forensic Analysis & Engineering to operate

the DJI Phantom 3 Professional without an issued medical certificate. Forensic Analysis

& Engineering will require all pilots to have an annual physical to ensure the pilot is fit to

command.
Morandi Engineering and Construction, Inc.

930 SW 16 St., Boca Ratón, FL 33486

Tel (954)-461-9785; or 5824

Morandieng@Gmail.com or Hotmail.com

Relief from § 61.101(e)(4) & (5), 61.113(a), and 61.315(c)(2) & (3) entitled Recreational pilot

privileges and limitations, Private pilot privileges and limitations: Pilot in command,

and What are the privileges and limits of my sport pilot certificate? respectively, is

requested by Morandi Engineering and Construction to the extent necessary to allow a

PIC holding a recreational, private, or sport pilot certificate, as well as a state Driver’s

license, and who has demonstrated, by meeting minimum flight-hour and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS

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

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

where necessary.

Relief from § 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3

Professional UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Morandi Engineering and Construction submits the

they will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition,

prior to every flight, by determining that the UAS is in compliance with the operating

documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction

Manual), and that the aircraft are in a condition for safe flight.

Relief from § 91.119(c), entitled Minimum safe altitudes: General, because Forensic Analysis

& Engineering intends to use the DJI Phantom 3 Professional to collect aerial video and 

photographs of buildings and structures involved in an investigation. Outside of structures

involved in an investigation, Morandi Engineering and Construction will maintain safe

distance from structures, people, vessels, and vehicles.

Relief from § 91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UA will

not have a typical barometric altimeter onboard. However, altitude information of 

the DJI Phantom 3 Professional UA will be provided to the PIC via GPS equipment

and radio communications telemetry data link, which downlinks from the UA to the

Ground Control System for active monitoring of the flight path. This altitude

information, combined with Morandi Engineering and Construction’s operation of the

DJI Phantom 3 Professional within VLS at or below 500 feet AGL, will ensure a level
Morandi Engineering and Construction, Inc.

930 SW 16 St., Boca Ratón, FL 33486

Tel (954)-461-9785; or 5824

Morandieng@Gmail.com or Hotmail.com

of safety equivalent to § 91.121.

Relief from § 91.151(b), entitled Fuel requirements for flight in VFR conditions Morandi 

Engineering and Construction submits that safety will not be affected by operation of 

the DJI Phantom 3 Professional UA during daylight visual meteorological conditions

(VMC) under VFR, with enough battery power to fly for a total duration of approximately

13 minutes to the first point of intended landing and, assuming normal cruising speed,

to fly after that for at least 5 minutes.

If you have any questions, please do not hesitate to contact the undersigned.

Enrique Morandi, P.E., G.C. 

President, Morandi Engineering and Construction, Inc.

930 SW 16 St., Boca Ratón, FL 33486

Tel (954)-461-9785; or 5824

P.E. 36129, MEC COA 4728 

Date: Monday, December 07, 2015