Steve	D.		Tacang

107	Coppock	Ct.

Vallejo,	California	94591

P:		(707)	704-0380

E:		stacangjr7@gmail.com		

August	2,	2015

U.S.	Department	of	Transportation	Docket	Management	System1200	New	

Jersey	Avenue,	SE	Washington,	DC	20590

RE:	Request	for	Exemption Per	PL	112-95	§333	from	14	CFR	61.113(a)	and	(b),	

14	CFR	91.103,	14	CFR	91.109,	14	CFR	91.119,	14	CFR	91.121,	14	CFR	

91.151(a),	14	CFR	91.405(a),	14	CFR	91.407(a)(1),	14	CFR	91.409(a)(2),	14	

CFR	91.417(a)	and	(b)

The	following	documents	have	been	included	in	order	to	provide	supplemental	

information	for	this	petition’s	request	for	exemption:	

1. Iris	Plus	Operation	Manual.

2. Iris	Plus	Flight	Checklist.	

Dear	Sir	or	Madam,	

This	letter	will	serve	as	a	request	for	an	exemption	of	the	above	sections	of	title	14	

CFR	for	myself,	Steve	D.	Tacang,	hereafter	referred	to	as	the	petitioner,	for	the	

purpose	of	conducting	commercial	“aerial	photography,	videography and	survey	

services”	operating	a	small	Unmanned	Aircraft	System	(sUAS)	in	FAA	controlled	

airspace.	As	described	herein,	Steve	D.	Tacang,	is	an	experienced	user	of	multicopter	

sUAS	for	hobby	operations,	flying	multicopters	of	varying	sizes	under	55	pounds	

using	both	onboard	camera	controls	and	Visual	Line	Of	Sight	(VLOS).	The	following	

petition	provides	all	necessary	information	to	justify	an	exemption	from	the	above	

listed	Federal	Aviation	Regulations	(FARs).	

The	Small	Unmanned	Aircraft	System (sUAS)

The	petitioner	will	be	flying	3D	Robotics	Iris+	that	is	equipped	with	4	propellers,	

onboard	camera,	and	onboard	flight	control	systems	that	utilize both	GPS	and a

ground	control	station	to	stabilize and	navigate the	aircraft.	The	3D	Robotics	Iris+ is	

operated	via	remote	control	in	the	2.4ghz	spectrum.	
The	sUAS	has	a	built	in	functionality	that	can	limit	the	height	it	flies	above	the	

ground,	distance	between	the	aircraft	and	PIC,	and	restricts the	sUAS	from	flying	in	

class	B,	C,	and	D	airspace.	The	aircraft	also	comes	preinstalled	with	the	ability	to	

automatically	return	to	the	PIC	and	land	if	any	of	the	previous	restrictions	are	

violated,	or	if	the	connection	to	the	wireless	controller	is	lost.	

The	sUAS	weighs	less	than	5 pounds	while	carrying	all	necessary	batteries	and	

cameras.	It	also	has	a	max	speed	of	fewer	than 43	knots	that	can	be	limited	prior	to	

takeoff.	

The	aircraft	is	powered	via	a	lithium	polymer	battery,	which	supplies	electricity	to	

the	4	brushless	onboard	motors.	

(For	more	specifications,	please	refer	to	the	attached	owner’s	manual	[IRIS	–PLUSOperation-Manual-vC-web.pdf].	Pre-flight	and	post-flight inspections	will	be	

consistent	with	the	attached	Flight	Checklist	[IRIS-Plus-Flight-Checklist-vA.pdf]).	

Additional	Specifications	

Autopilot:		Pixhawk	v2.4.5

Firmware:		ArduCopter	3.2

GPS:		3DR	uBlox	GPS	with	Compass	(LEA-6H	module,	5	Hz	update)

Telemetry	radio:		3DR	Radio	Telemetry	v2	(915	mHz)

Motors:		920	kV

Frame	type:		V

Propellers:		9.5	x	4.5	T-Motor	multirotor	self-tightening	counterclockwise	(2)	

							9.5	x	4.5	T-Motor	multirotor	self-tightening	clockwise	(2)

Battery:		3S	5.1	Ah	8C	lithium	polymer

Low	battery	voltage:		10.5	V

Maximum	voltage:		12.6	V	

Battery	cell	limit:		3S

IRIS	is	compatible	with	3S	lithium	polymer	batteries	only.	Using a	4S	battery	

can	cause	permanent	damage	to	the	gimbal	electronics	and	will	void	the	

warranty.	
Payload	capacity:		400	g	(.8	lbs)

Radio	range:		up	to	1	km	(.6	miles)

Flight	time:		16-22	minutes,	depending	on	payload	

Resources	

Hardware:		3dr.com/iris/info

Firmware:		copter.ardupilot.com

Software:		planner.ardupilot.com	and	planner2.ardupilot.com

3DR	Store:		store.3dr.com

Community:		diydrones.com



The	Unmanned	Aircraft	PIC	

Steve	D.		Tacang,	the	PIC	of	the	3D	Robotics Iris+, is	an	experienced	sUAS	pilot,	

especially	piloting	multi-rotor	aircrafts.	The	petitioner	has	been	a	hobbyist	sUAS	

pilot	for	over	4 years,	and	has	piloted	this	particular	aircraft	on	numerous	occasions	

without	incident.	To	improve	safety	and	comply	with	the	FAA’s	requests,	a	trained	

observer	will	be	present	at	all	times	during	all	commercial	flights.	The	petitioner	is	

also	experienced	with	maintaining	a	controlled	area	of	operations,	ensuring	the	

safety	of	all	nearby	persons	and	property.	

sUAS	Operation	Overview	

The	sUAS	will	be	operated	to	provide	aerial	photography,	videography and	survey	

services,	particularly	for	the	purposes	of	real	estate listing	enhancement,	weddings,	

events,	and	property	surveys.	

Prior	to	the	operation,	flight	restrictions	will	be	programmed	into	to	sUAS	to	

prevent	it	from	flying	400	feet	above ground	level	or	1500	feet	away	from	the	PIC.	

Before	takeoff,	the	PIC and	Observer will	review	the	pre-flight	checklist	(found	in	

IRIS-Plus-Flight-Checklist-vA.pdf)	and	survey	the	area	to	determine	if	weather	

conditions	are	suitable	for	flight	and	what	the emergency	landing	sites	would	be.	All	

nearby	persons	in	the	operations	area	will	be	made	aware	of	the	flight	in	progress.	

Flights	will	not	take	place	over	densely	populated	areas	or	private	property	without	

the	owner‘s	permission.	Once	the	operation	is	complete,	the	sUAS	will	be	inspected	

to	determine	if	any	maintenance	will	be	needed	before	the	next	operation.	

Compared	to	traditional	flights	using	manned	aircraft,	flights	using	sUAS	are	much	

less	dangerous	and	therefor	would	not	adversely	affect	safety:	

The	nature	of	these	flights	will	restrict	the	use	of	the	sUAS	to	a	
small	area	where	all	nearby	persons	can	be	aware	of	the	ongoing	flight.	

The	sUAS	carries	no	explosive	materials	or	combustible	liquid	fuel.	



The	lightweight of	the	sUAS	would	cause	minimal	damage	in	the	

event	of	an	airborne	failure,especially	when	compared	to	traditional	

manned	aircraft	with	airworthiness	certificates.	

The	small	size	of	the	sUAS	would	allow	for	all	operations	to be	

conducted	within	a	clearlydefined	area,	including	takeoffs	and	landings.	

All	flights	by	the	PIC	will	begin	and	remain	outside	of	a	5mile (8km) radius	

of	any	airport.	The	sUAS	has	a	mandatory,	built-in	functionality	to	restrict	the	

aircraft	from	flying	within	this	radius	and	will	automatically	land	if	it	

inadvertently	violates	this	restriction.	Any	and	all	precautions	will	be	taken	

by	the	PIC	and	the	accompanying	Observer	to	prevent	midair	collisions	with	

objects	and	other	aircrafts,	even	outside	the	5mile (8km)	radius	of	airports.	

All	planned	operations	utilizing	the	sUAS	will	be	completed	safely.	With	the	

combination	of	the	preflight	safety	risk	assessments	previously	discussed	and	the	

inherently	reduced	risk	of	flying	an sUAS	compared	to	a	traditional	manned	aircraft,	

the	PIC	will	be	able	to	provide	a	level	of	safety	greater	than	the	traditional	method	of	

performing	aerial	based	photography,	videography,	and	survey	operations.	

Benefit	to	Public	Interest	

Given	the	above	stated	evidence,	attached	procedures and	precautions;	operating

the	petitioners sUAS	commercially	for	the	purposes	of	photography,	videography	

and	surveying	will	ultimately	be	in	the	public	interest.	The	services	provided	by	the	

petitioner,	when	executed	with	caution,	will	exceed	the	current	level	of	safety	as	the	

regulations	from	which	I	seek	exemption.	Granting	this	exemption	would	reduce	the	

need	for	traditional	forms	of	aerial	photography,	videography	and	surveys,	which	

relies	primarily	on	the	use	of	larger	aircrafts	running	on	combustible	fuel.	Posing	

potential	risk	to	the	public,	these	traditional	methods	are	much	more	dangerous	

than	operations	performed	by	a	sUAS.	

Granting	this	exception	will	also	allow	greater	access	to	commercial	aerial	services	

that	were	not	previously	economically	sufficient	for	many	businesses	and	

individuals.	The	cost	of	sUAS	operations	is	significantly	lower	than	traditional	aerial	

photography,	making	these	services	available	to	smaller	businesses	and/or	

individuals	that	otherwise	may	not	be	able	to	afford	them.	This	in	turn	allows	

businesses	to	better	serve	their	clients,	increasing	the	public	benefit	as	a	whole.	
Conclusion	

All	commercial	sUAS	flights	by	the	petitioner	shall	satisfy	the	criteria	provided	in	

Section	333	of	the	Reform	Act	of	2012,	including:	size,	weight,	speed,	flight	within	

VLOS,	distance	from	PIC,	distance	from	airports,	operation	capabilities,	maintaining	

safety,	and	the	benefit	to	the	public.		These	qualifications	more	than	justify	granting	

the	petitioner,	Steve	D.	Tacang,	with	an	exemption	to	the	stated	sections	of	title	14	

CFR.	

In	addition,	granting	my,	Steve	D.	Tacang,	request	for	exemption	will	reduce	current	

risk	levels	and	thus	enhance	safety.	My	sUAS	craft	do	not	contain	potentially	

explosive	fuel,	is	smaller,	lightweight	and	more	maneuverable	than	conventional	

video	and	photographic	aircrafts	with	much	less	flight	time.		I	will	operate	at	lower	

altitudes	and	in	controlled	airspace	eliminating	potential	public	risk	flying	to	and	

from	established	airfields.	

The	requests	of	this	petition	are	similar	to those	of	Marcus	D.	Melhus,	Ralph	J.	

Apel,Gerald	R	Tookes,	Kenneth	Dungey	and	Joseph	Busalacchi all	of	whom have	

received	Section	333	exemptions	for	use	of	comparable	aircraft	for	similar	

operations.	

Thank	you	for	your	time	and	consideration.	

Respectfully	Submitted,	

Steve	D.	Tacang

Petitioner