January 5, 2016

Steven Wood

Hogwild Amusements

20325 County Road 3560

Ada, Oklahoma  74820

580‐399‐7183

steve@hogwildamusements.com

U.S. Department of Transportation, Docket Management System

1200 New Jersey Ave SE  

Washington, DC 20590

Filed with www.regulations.gov

Subject: Petition for Exemption Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations

Dear Sir/Madam:

This petition is being submitted on my own behalf without legal counsel or consulting services.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11.

Scope:  Enhance and edit real estate listing videos and accurately survey property lines in Oil and Gas Title

Research by using the Phantom 3 Professional Unmanned Aircraft System to conduct aerial photography,

videography and surveying of real property.  

UAV Phantom 3 Professional:  The DJI Phantom 3 is a quad‐rotor Unmanned Aircraft System (UAS) weighing 1280

Grams or 2.82192 Pounds. The Phantom 3 UAS that Steven Wood will be responsible for also utilizes a mobile

ground station. The UAS features a safety Return to Home function that in the event of a signal loss, the UAS will

return to a preset position and land. The Return to Home feature can also be triggered manually. The remote

connects to your mobile phone or tablet, and a 720p HD view of everything your camera sees as you fly is

displayed live. This high resolution view streams to you in absolute clarity, enabling safe flying. From takeoff to

landing, the Phantom 3 responds to commands while automatically handling the most complex aspects of safe,

stable flight. Each of the four legs of the Phantom 3 contains a high‐powered antenna, all constantly broadcasting

the live video feed and receiving control commands from any direction.  

Request:  An exemption from 91.7(a), 91.119, 91.121, 91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(2) and

91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).

Petition:  I request an exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and

(b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)  

The Extent of Relief that Steven Wood seeks  

1. Extent of Relief that Steven Wood seeks regarding Section 61.113 (a) and (b) Private Pilot Privileges and

Limitations Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in Command to operate Steven

Wood’s Phantom 3. The flight would be complimented by a Visual Observer who, along with the pilot, will

maintain Visual Line of Sight with the Phantom 3 at all times. All operations conducted will be incidental to Steven

Wood’s business, Hogwild Amusements. The Phantom 3 is not able to carry passengers.  

2. Extent of Relief that Steven Wood seeks in regards to Section 91.7(a) Civil Aircraft Airworthiness Relief from

Section 91.7(a) is requested to allow Steven Wood to determine airworthiness of the Phantom 3.  
As part of this determination the following will be adhered to:  

a. Prior to the Phantom 3's flight the PIC will inspect the UA to ensure it is in a condition that will be

conducive for a safe flight. The ground control station will be included in the above inspection.  

b. Steven Wood will follow the DJI Phantom 3’s aircraft/component, maintenance, overhaul, replacement,

inspection and life limit requirements.  

c. Steven Wood will comply with all DJI manufacturer Safety Bulletins.  

3. Extent of Relief that Steven Wood seeks in regards to Section 91.119 Minimum Safe Altitudes General relief

from 91.119 is requested to allow Steven Wood to operate the Phantom 3 at altitudes not to exceed 400’ AGL over

private property at a distance at or greater than 5NM from the nearest airport as depicted on current Aeronautical

Charts. Steven Wood also wishes to be granted exemption to operate at an altitude not greater than 50’ AGL

(below tree level) between 1NM and 5NM from the nearest airport as depicted on current Aeronautical Charts.  

Steven Wood will adhere to the following in order to maintain an acceptable level of safety associated with

operations over private property:  

a. Steven Wood will display signs in the immediate vicinity of operations stating: “Aerial Photography In

Progress. Use Caution.”  

b. Steven Wood will not allow the Phantom 3 to operate at a speed greater than 10kts.  

c. Steven Wood will require the UAS operator (PIC) to be fully trained on the Phantom 3 by adhering to the

recommendations contained within the Phantom 3’s operating manual.  

d. Steven Wood will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum

of 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. In addition the operator will have logged a minimum of 5 hours as a UAS pilot operating

the make and model UAS that Steven Wood operates.  

e. Steven Wood will be familiar with and able to manually institute the Phantom 3’s Return to Home (RTH)

feature. This feature aborts a flight operation and automatically returns the UAS to a predetermined GPS

safe point.  

f. Steven Wood will not operate over private property without first finding a suitable alternate landing spot

on the property.  

g. Steven Wood will abort the flight in the event of unpredicted obstacles or emergencies in accordance with

the operating documents.  

h. Steven Wood will utilize a two man flight team consisting of the Pilot in Command (PIC) and a Visual

Observer (VO). This team will maintain visual line of sight with the Phantom 3 at all times and remain

within hearing of one another.  

i. Steven Wood will not permit flight around vessels, vehicles and structures without permission from the

owner.  

4. Extent of Relief that Steven Wood seeks in regards to Section 91.121 Altimeter Settings Relief from 91.121 is

requested because the Phantom 3 utilizes electronic GPS with a barometric sensor. In order to maintain an equal

level of safety that 91.121 requires, the PIC of Steven Wood’s UAS will abort the flight in the events that the UA

loses communications with the GPS signal.  

5. Extent of Relief that Steven Wood seeks in regards to Section 91.151(b) Fuel Requirements for Flight in VFR

Conditions Relief from 91.151(b) is requested to the extent that allows Steven Wood to operate the Phantom 3 up

to a point (considering wind and forecast weather conditions) that there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 30% battery power remaining.  

6. Extent of Relief that Steven Wood seeks in regards to Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2),

91.417(a) and (b) These are all associated a with Airworthiness certificate Relief from 91.405(a), 91.407(a)(1), and

(a)(2), And 91.417(a) and (b) is requested to the extent that allows Steven Wood to operate the Phantom 3 Quad‐

Copter as necessary. These sections are all related to airworthiness certificates of aircraft. There is not currently an

airworthiness certificate for small UAS’s. Steven Wood would comply in full to any conditions and limitations that

the Administrator would place in order to receive an approved Grant of Exemption.
Public Interest:  Aerial videography and surveying for real estate marketing and/or oil and gas title research has

been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its

expense has been cost‐prohibitive. Granting this exemption to me would allow me to provide this service and

much needed information at a much lower cost. My UAS will pose no threat to the public given its small size and

lack of combustible fuel when compared to manned aircraft. The operation of my UAS will minimize ecological

damage and promote economic growth by providing information to companies and residents looking to relocate

or build in the Erie area. Conclusion: As set forth herein, Steven Wood seeks an exemption pursuant to 14 C.F.R. §

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation

of the DJI Phantom 3 UAS commercially within the Real Estate and Oil and Gas markets. The Administrator will be

assisting small business by granting this petition. In accordance with the FAA Modernization and Reform Act of

2012, Steven Wood respectfully requests that the FAA Administrator grants this petition for exemption from TITLE

14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a);

91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)