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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

KAREN B FERRANTE (“APPLICANT”)

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, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION 

OF DJI Phantom 3, and Yuneec Typhoon Q500 (“AIRCRAFT”)

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on October 21, 2015

Karen B. Ferrante 

7B Sunflower Court 

Ayer, MA 01432 

(978) 314-4032 

karen@pointerpals.com
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TABLE OF CONTENTS

Page 

GLOSSARY OF ABBREVIATIONS 3 

SUMMARY AND INTRODUCTION AND INTERESTS OF APPLICANT 4 

BACKGROUND 5

BASIS FOR PETITION 6

NAME AND ADDRESS OF PETITIONER 7 

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

APPLICANT SEEKS EXEMPTION 8 

EXTENT OF RELIEF APPLICANT SEEKS AND THE REASON 

APPLICANT SEEKS SAID RELIEF 12

REASONS WHY GRANTING APPLICANT’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST 15 

REASONS WHY THE AIRCRAFT MEET THE CONDITIONS OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (FMRA) Section 333 17

REASONS WHY EXEMPTIONS FROM THE STATED REQUIREMENTS 

WOULD NOT ADVERSELY AFFECT SAFETY 24

THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR 

SAFE OPERATION 26

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 27

ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT APPLICANT’S REQUEST 27

CONCLUSION AND LINKS 28
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations 

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Mod and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer 

SOP Standard Operating Procedures 

UAV Unmanned Aircraft Vehicle 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing
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SUMMARY

Karen B. Ferrante (“APPLICANT”) seeks exemption from the requirements of 14 C.F.R §§ 

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

APPLICANT to operate an Unmanned Aircraft System (UAS) for the commercial purpose 

of conducting aerial video and photography of construction sites, real estate, and 

landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

APPLICANT intends to provide clients with a service they otherwise do not have easy 

access to in their daily business practices. In addition to APPLICANT’S flight expertise 

and knowledge in advanced technologies, APPLICANT is a Private Pilot with 286 flight 

hours in a single engine plane, which includes 191 High Performance hours. APPLICANT 

holds a valid U.S. driver’s license issued by the state of Massachusetts. APPLICANT is 

an active amateur photographer and videographer (including underwater photography) for 

both recreational and hobby. APPLICANT desires to move her skills and knowledge of 

flying into a new direction, to provide high quality imaging for a variety of commercial, 

public, and residential uses, specifically targeting:

• Real-estate marketing

• Construction sites before and after

• Appraisals

• Motion Picture Filming

• Aerial acquisitions for inspections of public and private structures.

• Building Inspection operations
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BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, and Yuneec Typhoon Q500 (“AIRCRAFT”)

APPLICANT seeks an exemption to operate AIRCRAFT for compensation or hire within 

the NAS. The AIRCRAFT are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) 

with a Ground Control Station (GCS) utilizing electronic visual screens. 

The DJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 30 knots. 

The Yuneec Typhoon Q500 has a maximum gross weight of 7 pounds, a length of 17

inches, width of 17 inches, height of 10 inches, and a maximum speed of approximately 

30 knots. 

The AIRCRAFT are equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. 

The AIRCRAFT will be operated by APPLICANT and will be registered in accordance with 

49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and 

Registration Marking.
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BASIS FOR PETITION

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

11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

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

commercially operate the AIRCRAFT UASs in the National Airspace System (NAS), and 

for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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

UAV and its operation, APPLICANT meets the conditions of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

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

will be ensured. APPLICANT 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 of the AIRCRAFT. 

Furthermore, APPLICANT will document and maintain all maintenance records for the 

AIRCRAFT. 

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

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

necessary to allow a Pilot in Command (PIC) with significant experience in the field of 

UAV’s holding FAA ground school certificate, as well as 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 AIRCRAFT in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

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

because the AIRCRAFT do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, APPLICANT submits that she will ensure the 

AIRCRAFT are in an airworthy condition, prior to every flight, by determining that the 

UASs are in compliance with the AIRCRAFT’S operating documents and that the 

AIRCRAFT are in a condition for safe flight. 

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

Altimeter Settings, as the AIRCRAFT will not have a typical barometric altimeter onboard. 

However, altitude information of the AIRCRAFT 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 
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altitude information, combined with APPLICANT operation of the AIRCRAFT within visual 

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

91.121. 

Additionally, APPLICANT seeks an exemption from the requirements of Section 

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

that safety will not be affected by operation of the AIRCRAFT 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 15 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5

minutes. 

In accordance with 14 C.F.R. § 11.81, APPLICANT provides the following information in 

support of its petition for exemption:

NAME AND ADDRESS OF PETITIONER

The name and address of the APPLICANT is:

Karen B. Ferrante

7B Sunflower Court

Ayer, MA 01432

karen@pointerpals.com

(978) 314-4032
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SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH

APPLICANT SEEKS AN EXEMPTION

1. APPLICANT 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. APPLICANT 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. APPLICANT 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; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i)

of this section, the current reported altimeter setting of an appropriate 

available station; or 
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(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. APPLICANT 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. APPLICANT 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. APPLICANT Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), 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 of this chapter[.] 

7. APPLICANT Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

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

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

accordance with part 21 of this chapter. 

8. APPLICANT 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 the 

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 100-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. 

(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. 
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(vi) Copies of the forms prescribed by § 43.9(d) of this 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. 
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EXTENT OF RELIEF APPLICANT SEEKS 

AND THE REASON APPLICANT SEEKS SAID RELIEF

1. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT 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 holding a private pilot or 

higher level certificate, as well as a current and valid airman medical certificate, and 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 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, APPLICANT submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the AIRCRAFT unless that PIC 

has met certain flight-hour and currency requirements, demonstrating that the PIC is able 

to safely operate either the AIRCRAFT 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, APPLICANT submits that all flights of AIRCRAFT conducted by the PIC pursuant 

to the grant of this Petition: (1) will be incidental to APPLICANT’S business; and (2) will 

not carry passengers or property for compensation or hire. 

2. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT 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 APPLICANT to determine that the AIRCRAFT are in airworthy condition 

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

documents (i.e., the Operations Manuals, Maintenance Logs, and Instruction Manuals). 

APPLICANT seeks the requested relief because the AIRCRAFT do not require an 

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

APPLICANT will ensure that the AIRCRAFT are in airworthy condition based upon its 

compliance with the operating documents (i.e., the Operations Manuals and Instruction 

Manuals) prior to every flight, and further, determine that the AIRCRAFT are in condition 

for safe flight, as stated in the conditions and limitations below.
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3. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT Seeks 

Relief From Section 91.121. 

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

operations of the AIRCRAFT, 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), APPLICANT seeks the requested relief because the 

AIRCRAFT ‘S altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field 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 AIRCRAFT 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 of the GCS. 

4. Extent Of Relief APPLICANT Seeks And The Reason APPLICANT 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 AIRCRAFT during 

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

for a total duration of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. APPLICANT seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered AIRCRAFT will severely constrain the practicality of any 

aerial video or still photo flight operations that APPLICANT proposes to conduct pursuant 

to this Petition. 

Significantly, as set forth below, the technical specifications of the AIRCRAFT operating 

documents, and APPLICANT proposed operating limitations, ensure that APPLICANT will 

safely operate the battery powered AIRCRAFT during daylight hours in visual 

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

power to fly for a total duration of 15 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 5 minutes.

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

Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b). 
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Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, APPLICANT requests relief from these 

Sections because the AIRCRAFT do not require airworthiness certificates. As set forth 

more fully below, the AIRCRAFT meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, APPLICANT will use trained technicians 

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

methods, techniques, and practices prescribed in the AIRCRAFT operating documents 

(i.e., Operations Manuals, and Instruction Manuals). Furthermore, APPLICANT will 

document and maintain all maintenance records for the AIRCRAFT. 
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REASONS WHY GRANTING APPLICANT’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST.

Granting the present Petition will further the public interest by allowing APPLICANT 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 AIRCRAFT will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of APPLICANT

proposed operation of the AIRCRAFT will be realized without implicating any privacy 

issues. 

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

The AIRCRAFT are battery powered and serve as a safe, efficient, and economical 

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing 

the amount of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of a AIRCRAFT 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 AIRCRAFT 

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 AIRCRAFT.

Conducting aerial acquisitions with the AIRCRAFT, 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 AIRCRAFT 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. The AIRCRAFT, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

UAs are propelled by battery powered electric motors, rather than an internal combustion 

engine. 

By using the AIRCRAFT 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 onboard the aircraft, the AIRCRAFT (weighing 

approximately less than 8 pounds respectively, at their maximum gross weights with 

lengths of less than 18 inches respectively, widths of less than 18 inches respectively, 
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and with no fuel on board), has less physical potential for collateral damage to life and 

property on the ground, and in the air, 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 AIRCRAFT will 

Benefit The Economy. 

In addition to being safe and efficient, the AIRCRAFT are also an economical alternative 

to using manned aircraft to conduct similar aerial operations. As such, operation of the 

AIRCRAFT will allow United States based companies, like APPLICANT, 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 

AIRCRAFT 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 AIRCRAFT, APPLICANT’S business can remain competitive and 

profitable, and therefore, provide greater job stability, which will ultimately contribute to 

growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the AIRCRAFT 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, APPLICANT’S proposed operation of the AIRCRAFT will not implicate any 

privacy issues. Specifically, the AIRCRAFT will be operated only in compliance with 

operating documents (i.e., Operations Manuals and Instruction Manual) which requires 

property owner involvement, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119. 
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REASONS WHY THE AIRCRAFT 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, APPLICANT operation of the AIRCRAFT meet the 

conditions of FMRA 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 for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the 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, APPLICANT submits that the AIRCRAFT can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

AIRCRAFT; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. Specifications Of The AIRCRAFT Demonstrate Its Safe Characteristics.
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The AIRCRAFT 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. 

i. Technical Specifications of AIRCRAFT.

The technical specifications of the AIRCRAFT are set forth in the AIRCRAFT User 

Manuals, whose latest Links are documented at the end of this Petition. 

ii. The AIRCRAFT Flight And Navigation Modes Enable The AIRCRAFT To 

Remain Within A Defined Operational Area.

The AIRCRAFT may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the AIRCRAFT are provided 

in the User Manuals, whose latest Links are documented at the end of this Petition.

iii. The AIRCRAFT 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 AIRCRAFT will remain stationary, in flight, for 3 seconds 

or more. If, after 3 seconds, the AIRCRAFT do not reacquire control link data from the 

GCS, the AIRCRAFT will presume that the Control Link is lost and the AIRCRAFT 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 AIRCRAFT are set forth in the 

User Manuals, whose latest Links are documented at the end of this Petition.

b. Flight Operations Of DJI 3, and Yuneec Typhoon Q500 UAS are 

Limited To The Line Of Sight Of A Certificated Pilot in Command With A 

Safety Observer. 

APPLICANT will be the only person to act as a pilot in command (PIC) of AIRCRAFT. 

Additionally, a safety observer will assist him during flight time. 

c. Flights Of AIRCRAFT will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, APPLICANT proposes to commercially operate AIRCRAFT 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 
19

pounds maximum gross weight. Proposed operations of any other aircraft will require a 

petition to amend this grant. 

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

the purpose of aerial video and photography. 

3. The AIRCRAFT may not be flown at an indicated airspeed exceeding 45 knots.

4. The AIRCRAFT 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 ATC. All altitudes reported to ATC must be in 

feet AGL. 

5. The AIRCRAFT 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.

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 

AIRCRAFT 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 AIRCRAFT to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects safe operation, the 
20

AIRCRAFT is prohibited from operating until the necessary maintenance has been 

performed and the AIRCRAFT is found to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.

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

AIRCRAFT 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 AIRCRAFT 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. 

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

Safety Bulletins. 

16. 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 AIRCRAFT in a 

manner consistent with how the AIRCRAFT 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. 

17. AIRCRAFT 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 closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

18. The AIRCRAFT may not operate within 5 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 
21

with a NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

19. The UAV may not be operated less than 500 feet below or less than 2,000 feet 

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

20. If the UAV 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. 

21. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

22. 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 UAV with 25% battery power remaining. 

23. 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 

(NOTAM) 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. 

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 

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

control of the UAV must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

26. 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 AIRCRAFT any time the AIRCRAFT is 

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

enforcement official upon request. 

27. The AIRCRAFT must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

28. 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 UAV and/or debris in the event of an accident. The operator must 
22

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). 

29. 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.

30. 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. 
23

REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF 

SECTION 61.113(a) AND (b) WOULD NOT ADVERSELY AFFECT SAFETY

APPLICANT 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 AIRCRAFT 

unless that PIC has demonstrated that the PIC is able to safely operate the AIRCRAFT in 

a manner consistent with the exemption, including evasive and emergency maneuvers 

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

Considering APPLICANT proposed area of operations, and the operating limitations set 

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

those of commercial pilot requirements (See Exemption No. 11062); and the airmanship 

skills necessary to safely operate the AIRCRAFT, APPLICANT submits that the additional 

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

the airmanship skills necessary for AIRCRAFT 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). 

APPLICANT will not allow any PIC to operate the AIRCRAFT unless the PIC has 

demonstrated that the PIC is able to safely operate the AIRCRAFT 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 of UAS 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 APPLICANT proposed operations. The Administrator has held that 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 
24

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 of UAS 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 experience-building 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 UAS with appropriate 

distances in accordance with 14 C.F.R 91.119. 

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

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

currency requirements, that the PIC is able to safely operate the AIRCRAFT, in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

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

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, APPLICANT will ensure that AIRCRAFT 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 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). 

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 AIRCRAFT 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 
25

with APPLICANT operation of the AIRCRAFT 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). 

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 AIRCRAFT; 

(2) the limitations on the proposed flight operations; and (3) the location of the proposed 

flight operations. Accordingly, APPLICANT will ensure that it will safely operate the battery 

powered AIRCRAFT during daylight hours in VFR conditions, with enough battery power 

to fly for a total duration of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 

Furthermore, safety will be ensured as the AIRCRAFT 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 

AIRCRAFT will descend and land automatically. 

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). 

REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF 

SECTIONS 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

WOULD NOT ADVERSELY AFFECT SAFETY

In seeking this exemption, APPLICANT 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because 
26

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

preventive maintenance on the UASs using the methods, techniques, and practices 

prescribed in the AIRCRAFT operating documents. Furthermore, APPLICANT will 

document and maintain all maintenance records for the AIRCRAFT.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (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 APPLICANT proposed operating limitations, the operating documents, 

and the technical aspects of the AIRCRAFT safety will not be adversely affected by 

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) 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). 

THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR SAFE OPERATION

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

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

FAA prescribe special conditions for the intended operation of the AIRCRAFT, 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 §§ 

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

(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 AIRCRAFT, 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 
27

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.F.R. § 21.16.

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

prescribe special conditions for operation of the AIRCRAFT 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b).

A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which APPLICANT Seeks Exemption: 

Karen B. Ferrante 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)(1), 91.409(a)(1) & 

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

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

This exemption will permit Karen B. Ferrante to commercially operate an 

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

photography over certain areas of the United States.

Additional Information, Views, Or Arguments Available To Support APPLICANT’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, APPLICANT 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. 
28

CONCLUSION

As set forth herein, APPLICANT 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 AIRCRAFT commercially, without an airworthiness 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 APPLICANT to safely, efficiently, and 

economically operate the AIRCRAFT commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, APPLICANT 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)(1) & (a)(2), and 91.417(a) & (b), and permit APPLICANT to operate the 

AIRCRAFT commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

APPLICANT only utilizes safe and reliable UASs. AIRCRAFT are industry leaders in small 

UAS production. These AIRCRAFT contain 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, AIRCRAFT software provides real-time altitude and location 

information to the PIC via the linked monitoring.

Respectfully,

Karen B. Ferrante

7B Sunflower Court

Ayer, MA 01432

karen@pointerpals.com

(978) 314-4032

Links to AIRCRAFT Operator’s Manuals:

DJI Phantom 3 Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_

en.pdf

Yuneec Typhoon Q500 Manual 

http://www.yuneec.com/download/manuals/q500_4k_user_manual.pdf