September 27, 2015

Potomac Aerials

Steven Monell

9703 Thornville Drive

Fort Washington, MD 20744

Cell (703) 981-9547

Fax (240) 390-2386

Email paerials60@yahoo.com

US Department of Transportation

Docket Management System

1200 New Jersey Ave. SE

Washington DC 20590

RE: Exemption Request Section 333 the FAA Reform Act of 2012

Attachments:

1) Copy of Private Pilot Certificate and current Third Class Medical Certificate

2) DJI Phantom 3 Pro Specifications

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0418 in the matter of

the petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA-2014-0S08 in the matter of

the petition of ADVANCED AVIATION SOLUTIONS, LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-03SS in the matter of

the petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA's Guidelines for Submitting Petition for Exemption under Section 333 of 

the FAA Modernization and Reform act of 2012, I Steven Monell, owner and operator of Potomac 

Aerials referred to hereafter as the petitioner, request exemption to the following sections of Title

14, Code of Federal Regulations:

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a) 91.407(a){1); 91.409(a)(1); 91.409(a)(2);

91.417(a)&(b)

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the

Federal Aviation Administration (FAA) for the purposes of Aerial Photography, Cinematography,

Videography, Inspections, Surveying and other flight operations that could be performed safely and 

more cost effectively with the use of small UAS at low altitude within the US National Airspace 
System as compared to a manned aircraft. Operations will only be performed at the request of and with 

the authorization and consent of clients and their authorized agents in order to facilitate commerce and

raise awareness of beneficial uses of small UAS. 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.

The conditions identified and proposed by the petitioner are drawn from references 1-3.

The FARs The petitioner seeks the exemption from the above mentioned FARs for the following 

reasons:

61.113(a) & (b):

The petitioner requests relief in order to facilitate utilization of pilots who hold a

PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required 

to comply with any conditions as set forth and in a similar fashion as the previously granted 

exemptions.

91.119(c)

As discussed in Exemption 11139 (Douglas Trudeau), operations conducted closer than

500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons or

objects that would not be possible without additional relief. The petitioner requests modification,

waiver or exemption and clarification concerning the terms of "congested areas" and "densely

populated." The petitioner requests waiver for this condition to allow reasonable and responsible

operations in areas of subdivisions and neighborhoods.91.121

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), this is inapplicable since the

UAS does not have an altimeter and instead utilizes GPS with a barometric sensor for altitude

information.

91.151(a)

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has

been granted for manned aircraft to operate at less than prescribed minimums including Exemption

NO.s 2689, 5745, and 10650. In addition similar UAS specific relief has been granted an Exemption 

No.s 8811, 1080, and 10673 for daytime, VFR operations. The UAS provides battery power remaining 

in percent to the PIC. The UA batteries provide approximately 25 minutes of powered flight. 

Information provided in the operating documents discusses procedures regarding remaining battery

power management. The documents contain a condition in which the PIC will initiate a landing 

procedure when the battery remaining reaches a specified level. Given the limitations on proposed 

operations and the location of those proposed operations, the FAA found that a reduced minimum 

power reserve for flight in daytime VFR conditions was reasonable.

91.405(a); 91.407(a); 91.409(a) (1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 

(DOUGLAS TRUDEAU), the petitioner proposes to inspect and ensure the UAS is in a condition for 

safe flight in accordance with the operating documents. The FAA found that adherence to the 

petitioners operating documents and the conditions and limitations specified, describing the 

requirements for maintenance, inspection and record keeping, were sufficient to ensure that safety

would not be adversely affected.
The UAS

The DJI Phantom 3 Professional is a highly successful consumer grade small rotorcraft in the 

quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) designed

primarily to carry a high definition camera aloft. They have an advertised maximum speed of less than

30 kts (15 m/s) and a maximum climb rate of less than 1200 fpm (6 m/s), They are powered by 4 

electric motors with a distance between the motors of less than 14 inches (350 mm). It utilizes an 

internal inertial measuring unit (IMU) with integrated barometric sensor to augmented with Global 

Positioning System (GPS) to maintain its geospatial orientation and position. It is controlled primarily

through an FCC certified radio control (Re) unit. Real time video and telemetry information is 

transmitted back to a ground control station allowing the operator and/or PIC to monitor battery level, 

GPS signal strength, altitude (AGL), distance from the PIC, camera imagery, and control camera angle. 

It has failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the 

onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life limits 

flight times to approximately 25 minutes. The onboard flight controller will warn the pilot via telemetry

data and external lighting cues before reaching a low battery state. An automatic termination of flight 

and landing will be initiated when battery reaches a predetermined low state. It is anticipated that 

flights will usually last less than 15 minutes. 

More information is available in attachment 2.

Risk Mitigation

The petitioner has reviewed FAA exemptions references 1-3 Conditions and Limitations section and

believes that the procedures specified therein are reasonable and will be utilized in order to manage

and mitigate risk and ensure public safety. A preflight and post flight checklist will be developed and

employed to ensure that UA airworthiness will be maintained for flight operations. Flight time and

maintenance logs will be maintained to ensure tracking on failure prone components.

The petitioner requests that in a manner similar to reference 2, he be allowed to operate within 5 miles 

of an airport provided that:

"The UAS may not operate in Class 8, Class D airspace without written approval of the FAA The

UAS may not operate within five nautical miles of the geographic center of a non-towered airport

as denoted on or current FAA-published aeronautical chart unless a letter of agreement with that

airport's management is obtained, and the operation is conducted in accordance with a NOTAM

as required by the operator's GOA The letter of agreement with the airport management must

be made available to the Administrator upon request. "

Operations within 5 miles of an airport are not anticipated to be routine, but the petitioner is requesting

a mechanism to facilitate such activities without requesting a new and separate exemption should the

need arise. Operations within class B airspace are not requested due to the lack of a mode C

transponder.

Public Interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce environmental impact

compared to similar operations conducted with much larger fuel laden manned aircraft Additionally,

the use of UAS to facilitate commerce can help to encourage economic growth. Operations for this

petition will enable service for property owners or their designees seeking an enhanced perspective for

characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed
through ground level videography/photography.

Aerial photography is a valuable marketing tool that can facilitate increased commerce and enhance 

personal photography. Crop surveying and inspections could lead to decreased use of pesticides and 

fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric estimations and reduce 

risk. The petitioner will provide clients with the photographic data for these purposes in a for hire basis 

acting as an independent contractor. 

A visualobserver will be utilized. Flight data including UA flight time, Control unit operation time, 

incident,accident, and details concerning any deviations from normal operations will be available to the 

FAA for use in collecting data regarding the use of UAS as a part of this application. This data can be 

submitted to the FAA via reports as required by the FAA.

Conclusion

The petitioner is requesting this exemption for the purposes of "aerial photography, cinematography,

videography, mapping, inspections and other flight operations." The reason for such a general and

broad based request is that the petitioner wishes to utilize a strategy that allows maximum flexibility to

utilize the UA to its fullest potential within the constraints of this request, without the long turnaround

time associated with additional exemptions. 

The petitioner plans to offer services to individuals or companies seeking to enhance their business in a 

safe and lawful way. The petitioner knows from applied experience since 2006 flying manned aircraft 

in and outside of the Washington DC FRZ and ADIZ that there is extensive demand for lawful aerial 

photography and videography.

The petitioner has 430 hours flying experience (Private Pilot Single Engine Land), 362 hours as pilot in 

command.The petitioner holds a private pilot pilot certificate (single engine land) and a current third 

class medical certificate.

 The petitioner owns UAS, DJI Phantom 3 Professional which he has flown on various locations 

outside the Washington DC 15NM to develop flight and photography experience. He has executed 

many takeoffs and landings, and has demonstrated continuous proficiency . He has experience with the 

fail safe modes of the aircraft, having practiced emergency procedures as described in the DJI operating 

manual.

The petitioner plans to utilize the UA below 400' AGL, within visual line of sight (VLOS), within 500'

laterally of the PIC, and with a visual observer at all times.

Restpectully

Steven Monell

Potomac Aerials