§ 43.11 of this chapter shall be retained until the defects are repaired and the 

airoraft is approved for retum to service. 

High Flight Photo provides the following supporting documentation including: 1) Supplemental 

Response for PetRion, 2) PHANTOM 

Flying Flow Chart V1.0 (Simpfrfied Version), PHANTOM Quick Start Manual v1.7, 

PHANTOM Advanoed Manual v.1.4, 3) PHANTOM 2 Vision+ User Manual 4) restricted 

areas map, 5) personal protocols and crontrols, and 6)High Flight Photo SafetylFlight Manual (all 

hereinafter 7) Radio Frequency Spectrum chart referred to as operating documents). 

Unmanned Aircraft System 

High Flight Photo plans to operate a UAS, the PHANTOM 2 Vision+, which is comprised of an 

unmanned aircraft (UA or PHANTOM) and a transportable ground statlon. The PHANTOM is 

referred to as a quad-copter with a maximum gross weight of about 3 pounds. It is equipped 

with four rotors that are driven by elecbic motors powered by battedes. The UA has a maximum 

airspeetl of 30 knots. High Flight Photo plans to attach a small uflra-lightweight GoPro 3+ 

camera to his UA and operate the UA over various areas un Westem Washington to include 

Cfallam, Jefferson, Kitsa,o oounties to enhance academic community awareness and augment 

real estate listing videos. High Flight Photo makes the following representations of operational 

enhancements which he proposes to abide by to ensure this exemplion will provide a level of 

safety at least equal to existing rules: 

• High Flight Photo will only operate in reasonably safe environments that are strictly controlled. 

are away from power lines, elevated lights, airports and actively populated areas; and 

• High Flfght Photo will conduct extensive pref9ght inspeclions and protocols, during whfch 

safety carries primary importance. 

High Flight Photo states that given the size, weight, speed, and limited operrating area 

associated with the aircraft to be utilizetl by him, an exempGon from 14 CFR part 21, Subpart H 

(Airworthiness CerYrficates) and § 91.203 (a) and (b) (Certifications required), subject to certaln 

oonditions and limitations, is warranled and meels the requirements fOr an equivalenl level of 

safety under 14 CFR part 11 and Section 333 of P.L 112 J5 (Section 333). ~

Petitioner requests an exemption from § 45.23 Marking of the aircrafl beoause his UA will not 

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he 

states that two-inch lettering is difficult to place on such a small alrcraft with dimensions smaller 

than the minimal lettering requirerpent. Regardle8s of this. High Flight Photo states that he will 

mark his UAS in the largest possible lettering by placing the vrord 'Experimental" on ils fuselage 

as required by § 45.29(t) so that he or anyone assisling him as a spotter will see the markings. 

The petitioner states that an exempian from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 

91.417(a) and (b) Maintenance inspeetions may be required and stquld be granted since they 

onty apply to airOraft with an ainaorthiness certificate. However, High Flight Photo states as a 

safety precau8on he will perform a preflight inspection of his UAS before each flight as oullined 

in his operaGng documents. 

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