Richard P. Gamble – Section 333 Exemption 

Petition P a g e | 1

U. S. Department of Transportation 

Docket Management System

1200 New Jersey Ave, SE 

Washington, DC 20590

January 28, 2016

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam;

In accordance with the Public Guidance for Petitions for Exemption filed under Section 333, I, Richard P. 

Gamble request exemption from the Federal Aviation Regulations to allow for commercial operations of 

a DJI Phantom 3 Standard, Unmanned Aerial System (UAS) for purposes of training other operators of a 

UAS in the National Airspace System (NAS), aerial photography and videography; but only so long as 

such operations are conducted within and under the conditions outlined herein or as may be established 

by the FAA as required by Section 333 or Section 49 USC § 44701.

Applicant:

Richard P. Gamble

121 Peterson Drive

P.O. Box 137

Sweetser, IN 46987

romeogolf70@hotmail.com

Qualifications:

FAA Issued Airline Transport Pilot Certificate No. 2928921

-Airplane Multi-Engine Land

-EMB 145 SIC Privileges

FAA Issued Commercial Pilot Certificate No.2928921

-Airplane Single Engine Land; Instrument Airplane

FAA Issued Flight Instructor Certificate No. 2928921CFI

-Airplane Single and Multi-Engine Land; Instrument Airplane

Experience:

Chautauqua Airlines (CHQ) – First Officer

Purdue University – Assistant Chief FlightInstructor Part 141 Flight School

Aircraft Owner: Cessna 150

Member Sweetser Indiana Town Council (Reelected to second term November 2015)
Richard P. Gamble – Section 333 Exemption 

Petition P a g e | 2

Attachments:

1. DJI Phantom 3 Standard User Manual

2. DJI Phantom 3 Standard Quick StartGuide

3. DJI Phantom 3 Standard Release Notes

4. DJI Phantom 3 Safety GuidelinesDisclaimer

5. DJI Phantom Pilot TrainingGuide

6. Intelligent Flight Battery SafetyGuidelines

Regulations from which the exemption isrequested:

14 CFR 21, Subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103 (b) (2)

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (l)

14 CFR 91.409 (a) (l) & (a) (2)

14 CFR 91.417 (a) & (b)

14 CFR 21, Subpart H- In consideration of the size, weight, speed, and limited operating area associated 

with this UAS and its operation, I, Richard P. Gamble request relief from 14 CFR part 21, Subpart H, and 

any associated noise certification and testing requirements of part 36. The UAS will carry neither pilot, 

passenger, explosive materials nor flammable liquids.

14 CFR 45.23 (b)- Even though the UAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which the word 

"Experimental" can be placed. Given the size of the UAS, two-inch lettering will be impossible. The word

"Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of 

safety will be provided by having the UAS marked on its fuselage as required by §45.29 (f) where the 

pilot, observer and others working with the UAS will see the identification of the UAS as "Experimental."

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the UAS will not carry a pilot or passengers I, Richard 

P. Gamble request a relief from these regulations. Any pilot in command or (PIC) operating the UAS will 

hold a Sport Pilot (or greater) certificate. A visual observer or (VO) will be utilized and required to 

communicate verbally at all times. The UAS will be limited to operations within visual distance of both 

the PIC and VO. All UAS operations will take place in a controlled area. The risks associated with the use 

of a UAS are far less than similar commercial aircraft operations.
Richard P. Gamble – Section 333 Exemption 

Petition P a g e | 3

14 CFR 91.7 (a)- Since the UAS will not carry a pilot or passengers there will be no airworthiness 

certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard exists 

for determining airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist 

prior to each flight, an equivalent level of safety will be provided. All flights will be in accordance with 

the safety and maintenance recommendations found in the DJI Phantom 3 attachments.

14 CFR 91.9 (b) (2) - Given the size and configuration, the UAS has no ability to carry a flight manual on 

the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An 

equivalent level of safety will be maintained by keeping the flight manual at the ground station where 

the UAS pilot will have immediate access to it.

14 CFR 91.103 (b) (2) - As no FAA approved flight manuals will be provided for the aircraft an exemption 

is needed. Alternate procedures including but not limited to reviewing weather conditions, checking 

flight battery requirements, checking takeoff and landing distances along with those found in the 

attached "DJI Pilot Training" will be implemented. These actions will provide an equivalent or higher 

level of safety.

14 CFR 91.109- UAS and remotely piloted aircraft do not have fully functional dual controls. Flight 

control is achieved through the use of a control box that communicates with the aircraft via radio 

communications. An equivalent level of safety will be achieved using the real time ground station data 

and given the UAS will carry neither a pilot nor passengers.

14 CFR 91.119 (c) - The UAS will never be operated at an altitude higher than 400 feet AGL. The UAS will 

operate in safe areas away from public and traffic and only with permission of the property and

structure owners. The UAS will also be restricted by the flight controller to a maximum vertical height of 

400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed of the UAS, 

an equivalent or higher level of safety will be achieved.

14 CFR 91.121- As the UAS may not have a barometric altimeter, but instead a GPS barometric sensor 

for altitude information an exemption may be required. An equivalent level of safety will be achieved 

using a ground station which links to a telemetry data link. This will provide the pilot with live flight data 

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator prior toflight.

14 CFR 91.151 (a) - The UAS has a limited range and will be limited to operations in a controlled 

environment. The battery power the UAS provides approximately 25 minutes of flight time. The UAS is 

unable to meet the 30 minute reserve requirement and therefore requires an exemption. An equivalent 

level of safety will be achieved by monitoring the battery through the ground station and landing with a 

minimum of 30 percent battery powerremaining.

14 CFR 91.203 (a) & (b) - Given the size and configuration, the UAS has no ability to carry a flight manual 

on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An 

equivalent level of safety will be maintained by keeping the flight manual at the ground station where 

the UAS pilot will have immediate access to it.
Richard P. Gamble – Section 333 Exemption 

Petition P a g e | 4

Given the following sections only apply to aircraft with an airworthiness certificate; these sections do 

not apply to this applicant. As a safety precaution, the operator will perform preflight inspections and 

ensure UAS is in working condition before initiating each flight:

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (l) & (a) (2)

14 CFR 91.417 (a) & (b)

Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS will adhere to the following additional 

guidelines:

1. The UAS will not be operated within 5 miles of an airport unless prior contact to Air Traffic Control has 

been established.

2. Flights will not exceed an airspeed of 36 mph (31.3 knots)

3. Flights will be operated at or below an altitude never exceeding 400 feetAGL.

4. The PIC and VO will communicate verbally at alltimes.

5. UAS operations will not be conducted during night.

6. All operations will be conducted under visual meteorological conditions.

7. The UAS will land with a minimum 30 percent battery reserveremaining.

8. The UAS will only be piloted within visual line ofsight.

9. The UAS will utilize an internal flight safety feature that will return to a preprogrammed position and 

land if communication with the remote control islost.

10. Preflight inspections and protocol will be followed prior to alloperations.

11. The UAS will abort flight in the event of unpredictable obstacles oremergencies.

Public Interest

I, Richard P. Gamble, believe the use of a UAS in lieu of a manned aircraft would enhance safety and 

reduce the environmental impact compared to similar operations conducted with a manned aircraft 

carrying a crew and flammable fuel.

As a professional aviator I experience the need to keep our skies safe. Therefore, my primary role will be 

to educate and train existing and future operators with their UAS in the NAS. These operators will no 

doubt be flying UAS with cameras and such the need to educate them as to their operation while 

maintaining the privacy of their neighbors.

Privacy

All flights will occur over private or controlled areas with the owner's consent. Capturing people in 

images will rarely occur. If a person is captured in a collected image they will have consented prior to 

filming or otherwise have agreed to be in the area prior to the filming takingplace.

Sincerely,

Richard P. Gamble