Docket ID: FAA-2014-0481

Douglas Trudeau, Associate Broker

Tierra Antiguea Realty

1650 E River Road, Suite 202

Tucson, AZ 85718

Office: (520) 544-2335

Mobile: (520) 954-2209

Email: Doug@TheTrudeauGroup.com

Supplemental Information for FAA-2014-0481

UAV/UAS/UA Clarification

The UAV/UAS/UA which Douglas Trudeau, Petitioner, will be operating is the DJI Phantom 2 Vision +, 

referred hereafter as Phantom. The inherent safety features, sophistication, programmability, GPS 

navigation, return home capability, airport vicinity no-fly feature and restricted altitude feature, as well 

as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this a 

much safer UAV for the purposes of this petition. This is a hobby grade radio controlled UAV that has 

the capacity for software upgrades. It is light, less than 3 pounds including battery and camera. 

Incorporated into the programming of the Phantom is an automatic return home feature that 

automatically directs the craft back to point of take off should communication with the transmitter be 

lost. The Phantom has a cruising speed of 15 knots, with a maximum speed of 29 knots. Maximum flight 

time is 25 minutes. Gross weight is 2.86 pounds.

The Phantom has an additional communication link between the camera and craft on a different rf for a 

smart phone connection. Allowing the operator or Pilot In Command (PIC) to monitor battery level, 

altitude (AGL), distance from PIC, camera imagery, and control camera angle. 

The software for the Phantom allows the operator or PIC to set maximum altitude AGL for each flight, 

allowing customization of flights to no higher than 100 feet, 150 feet, or 250 feet AGL as an examples. 

The 400 foot maximum AGL can be programmed into the UAV's software pre-flight to insure compliance 

with FAA standards. Adding to the safety capabilities of this UAV. This UAV is programmed to remain in 

position when controls are released. Maintaining altitude and GPS location.

The Phantom has an altitude and radar monitoring function that allows the operator more precise 

determination of height, direction of flight and distance from the operator PIC. The operator or PIC can 

monitor GPS lock status while UAV is in flight, with the ability to anticipate loss of GPS locking so the 

operator or PIC can land the UAV as a precaution. 

Best explanation of the Phantom's sophistication and capabilities can be observed through a video 

explanation of an earlier model that was predecessor to the Phantom 2 Vision + through link 

http://youtu.be/3mqj-WBRKmE. The Phantom 2 Vision + maintains all capabilities defined in the video. 
Having flown the Blade 350 QX UAV while encountering rf interference, even with the blue tooth turned 

off to the GoPro Black 3+ with both utilizing the same 2.4 ghz rf has lead the petitioner to abort aerial 

video/photography use of this craft. Reducing it to strictly hobby use for enjoyment and additional flight 

experience. The DJI Phantom 2 Vision +'s 2.4 ghz transmitter/controller/receiver rf for managing flight

with a 5.8 ghz rf transmitter/receiver for video/photography functions eliminates the rf conflict 

experienced with the Blade 350 QX, and is by far the safer of the two when considering public and NAS 

safety. Considering the programmability and safety features of this UAV (Phantom 2 Vision +), it serves 

as the best option to protect the Public and NAS for the purposes of this petition. 

Similarities, Distinctions and Differences

Though the petition of Astraeus Aerial (FAA-2014-0352), referred hereafter as the Astraeus Petition and 

or Petitioner Astraeus, has numerous similarities to that of Douglas Trudeau (FAA-2014-0481), referred 

hereafter as the Trudeau Petition and or Petitioner Trudeau, there are some distinct and substantial 

differences. Like the Astraeus Petition, the Trudeau Petition is for UAV operation without pilot, 

passengers nor property on board. Considering that the Phantom UAV is a sophisticated hobby grade 

quad-copter with gross weight less than 3 pounds Petitioner Trudeau requests waiver or exemption for

a private pilot certificate. Aerial video/photography operations for this petition provide service for those 

businesses, transferees, retirees and others considering relocating to Tucson, Oro Valley, Marana, 

Sahuarita, or Vail who are not familiar with geographical characteristic, communities, services and other 

benefits of the area. Aerial video/photography operations for private property owners aide with an 

enhanced perspective for characteristics, amenities, and benefits a private property has that cannot be 

displayed through ground level video/photography. Petitioner Trudeau charges no additional fees for 

ground level video/photography. Therefore, there is no compensation for these services. Aerial 

video/photography represent a small portion of videos and photos currently offered at ground level for 

the community as well as private properties marketed for sale. Aerial video/photography is an

enhancement to videos/photography already offered homeowners and the public. In most cases aerial 

video will represent 4-20 seconds of a 2-3 minute video. 

Petitioner Trudeau is using a UAV that has the capability for taking off and landing at a single point, 

identical to a helicopter. There are no runways, aided take off apparatuses, nor routes that need to be 

flown to areas being aerial video recorded or photographed. Allowing a reduced and more confined area 

of flight. 

The Astraeus Petition is for movie sets involving a significant number of people, non-aerial equipment, 

moving or action sequences, and a potentially broad geographical area where individuals and 

equipment may be in motion. Requiring extensive observation, awareness, coordination and safety 

precautions. The Trudeau Petition is for video/photography of stationary objects requiring briefer 

periods for recording in a tightly confined area. The stationary setting of objects poses a significantly 

lower risks for safety, allowing the operator or Pilot In Command (PIC) to focus primarily on stationary

objects for a shorter periods of time. With the movie action scenes, numerous takes may require 

repeated flights, whereas a stationary object would in most cases require a single flight.
Home owner written consent for aerial video/photography shall be obtained prior to flight. Signs will be 

posted cautioning anyone within vicinity to remain back a minimum of 200 feet. Observer(s) to assist 

and warn/advise the PIC will be utilized in situations where spectators may be within 500 feet of the 

flight area.

The single UAV utilized in this petition is a hobby grade quad-copter that does not require an airman 

certificate for non-commercial flight involving less restrictive less regulated flight. Petitioner requests 

waiver or exemption from an airman certificate since this is a sophisticated hobby grade UAV weighing 

less than three pounds flown in confined and restricted areas. Additional waiver or exemption for formal 

health requirements placed on the Operator or PIC is requested. Petitioner is an AMA member. UAV 

flight competency can be verified/obtained through AMA standards and procedures.

The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized in this petition are 

not complicated. Engineering and design allows layman maintenance. Recording part replacement for 

this UAV may prove redundant due to the simplicity of the craft. Therefore Petitioner requests waiver or 

exemption for maintenance records. However, pre-flight inspection for cracks, damage or other physical 

conditions that could hamper safe flight is a reasonable expectation. As well as post flight inspection

that may aid in identifying flight conditions that may cause stress to propellers, landing gear, etc. 

Thorough inspection of UAV shall be conducted and flight response tested should a hard landing or 

crash occur. Insuring that the UAV can operate in a safe manner before conducting any further 

video/photography.

Like the Astraeus Petition Petitioner Trudeau requests waiver or exemption for markings due to the 

small size of the fuselage for the Phantom 2 Vision +. 

Petitioner Trudeau requests modification, waiver or exemption and clarification (within reason) 

concerning section 91.119 prohibition of flight in congested areas. Such restriction puts home owners in

subdivisions at a disadvantage by limiting enhanced marketing of their homes; thereby discriminating 

against them. Vertical takeoff and landing while video recording or photographing a home can allow an 

enhanced perspective for view or proximity of mountains, golf course, manmade lake or other 

attractions not possible through ground level video recording or photography. Petitioner Trudeau 

requests waiver for this condition to allow reasonable and responsible aerial video/photography in

congested areas of subdivisions and neighborhoods.

In compliance with Section 90.151 (a) the Phantom is a battery operated UAV/UAS with battery level 

monitoring capability. Fully charged battery flight time is rated at 25 minutes, with videos/photos taking 

much less time to record. Operator or PIC is warned when battery level is low.

Petitioner Trudeau requests waiver/exemption from Section 91.203 (a) since the Phantom is a hobby 

grade UAV/UAS that should not require an airworthiness certificate nor a registration certificate. Posting 

of special flight authorization would not be possible since the Phantom has no cabin and is not large 

enough to carry a certificate. However, a special flight authorization can be maintained by the operator 

to make available upon request.