Docket #: 2014-FAA-0481

Exempt #: 11138

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Amendment 3

September 14, 2015

Docket #: 2014-FAA-0481

Exempt #: 11138

Considering that the FAA has been nonresponsive to Amendment 1 within one hundred ninety five (195) 

days and Amendment 2 within one hundred eighty (180) days I am submitting Amendment 3 to 

encapsulate key aspects of each of the prior amendments. I request that considerations be broken into 

sections to avoid further delay for areas that can be determined immediately. Sections 1 and 3 are 

reiteration of already submitted amendments. Section 2 is an easy consideration for craft already 

approved by the FAA for other exemptions already approved. 

Section I

First and foremost, as addressed in Amendment 2, I, Douglas Trudeau, hereby submit petition for 

amendment to Exemption 11138 concerning 5 nautical mile condition. Exemption 11138 is more 

restrictive in the area than hundreds of approve exemptions that have followed.

Reference: In my Exemption 11138, page 24, "19) The UA may not operate within 5 nautical miles 

of an airport reference point as denoted on a current FAA-published aeronautical chart."

I request reconsideration equal and consistent conditions concerning the 5 nautical miles from an 

airport as in like Exemption No. 11153 - Regulatory Docket No. FAA–2014–0519, page 25, "20. The 

UA 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 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."

As well as in Exemption No. 11195 - Regulatory Docket No. FAA−2014−0884, page 12, "19. The UA 

may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a Notice to Airmen (NOTAM), as 

required by the operator’s Certificate of Waiver or Authorization (COA). The letter of agreement 

with the airport management must be made available to the Administrator upon request."

I request the same flexibility as exemptions 11153 and 11195 for acquiring agreement with the 

airports' management should operations fall within 5 nautical miles of an airport. 
Docket #: 2014-FAA-0481

Exempt #: 11138

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There have been over one thousand (1,000) exemptions since exemption 11138 with less restriction

concerning the five (5) nautical mile radius around towered airports. Some of which are 

September 9, 2015

Star City SkyCams

Exemption No. 12798

Regulatory Docket No. FAA−2015−2615

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 

September 3, 2015

Mr. Keith A. Redlin

Exemption No. 12737

Regulatory Docket No. FAA–2015–1448

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request.

August 26, 2015

Mr. Gregory B. Mays

Exemption No. 12617

Regulatory Docket No. FAA−2015−2468

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 
Docket #: 2014-FAA-0481

Exempt #: 11138

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May 11, 2015

Stephenson Construction Management, LLC

Exemption No. 11536

Regulatory Docket No. FAA–2015–0401

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request.

April 8, 2015

Extreme Media Productions

Exemption No. 11300

Regulatory Docket No. FAA−2014−1034

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the 

current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the 

airport symbol as denoted on the current FAA published aeronautical chart, unless a letter of agreement 

with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 

Section 2

I, Douglas Trudeau, request approval for additional multi-rotor craft to include

 DJI Phantom 3

 DJI Inspire

 DJI S 900

 DJI S 1000

 DJI S 1000+

all of which are craft already approved by the FAA for other Section 333 exemptions.

Section 3

Finally, I, Douglas Trudeau, hereby submit petition for amendment to Exemption 11138 concerning high 

density areas where homes are not closely situated. Especially considering there are communities 
Docket #: 2014-FAA-0481

Exempt #: 11138

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outside the high density area where homes are in closer proximity to each other than within the high 

density defined areas on the VFR map.

Reference: Exemption 11138, Page 25, 30) "The UAS may not be operated over congested or densely 

populated areas." 

The requirement prohibiting operation in densely populated areas has dramatically reduced the area of 

marketing for the petitioner. Operations outside the five (5) mile radius of Tucson International and 

Davis Monthan Air Force Base is a reasonable expectation. However the VFR map depicting high density 

areas for the Tucson area prohibits areas along the north, northwest, northeast, east and west that have 

properties on sizable lots over an acre that can benefit from marketing through aerial 

video/photography. The FAA's sUAS NPRM Docket No: FAA-2015-0150; Notice No. 15-01 "Proposes a 

micro UAS category that would allow operations in Class G airspace, over people noninvolved in the 

operation..." All operations with the sUAS in exemption 11138 are operated in Class G airspace. 

Petitioner has additionally added to safety by using a VHF transceiver that allows direct communication 

with ATC as well as any aircraft in the vicinity. Most flights in higher density area would only require AGL 

of approximately 50-100 feet above roof line of the structure being videoed/photographed. Posing no 

risk to manned aircraft. Average roof line of a single story residence is 14 feet, while a 2 story home is 24 

feet. Thereby, placing operations between 64-124 AGL in high density areas. FAA sUAS NPRM Docket 

No: FAA-2015-0150; Notice No. 15-01 defines the sUAS used in exemption 1138 as a "micro UAS" that is

according to the FAA "...highly maneuverable and much easier to land than a manned aircraft. Thus, in 

an emergency, an operator should be able to promptly land the small unmanned aircraft.." Since the 

FAA through its NPRM is proposing operation "...over people not involved..." and "...highly 

maneuverable..." in operations, the burden of restricting operation in densely populated areas in 

exemption 11138 is an unreasonable burden that prohibits the use of this technology for an inordinate 

number of homeowners wishing to have their homes marketed with aerial video/photography. 

Petitioner submits that use of sensible and safe consideration during operation that does not place any 

person, structure or NAS at risk is a more reasonable requirement. Therefore, Petitioner requests 

reconsideration concerning densely populated areas to allow sensible and safe consideration during 

operation as determined by the PIC on site. 

Please see map as sample of an area along the Catalina Foothills designated on the VFR map as high 

density, when many homes are on 1+ acre lots. Many with significant distance between homes. Some 

built on a mountain slopes where sUAS aerial video/photography would provide a perspective 

unavailable otherwise.
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