1 

### Drone Exemption Certificate

The rule is: PUBLIC LAW 112

- 95

- FEB . 14 , 2012 126 STAT. 77 SEC 336.

Pursuant to section 33 3 of the FAA Modernization and Reform A ct t he exemption

requested is to operate a n Unmanned Aircraft System(UAS) , within the National Airspace

System (NAS), for commercial use aerial image acquisition, including but not limited to, the

following industries: motion picture and television, commercial photography and

advertising, real estate, short range inspection, mapping and sur vey and other purposes

within the scope and limitations set forth in the exemption certificate.

November 8 , 2015

To: U.S. Department of Transportation, Docket Operations

West Buil ding Ground Floor, Room Wl2

- 140

1200 New Jersey Avenue, SE Washington, DC 20590

From: Terrance Charles Hogan

DBA Gold Eagle Drones (GEdrones.com)

1020 Marshall Avenue

Saint Paul Park, Minnesota 55107

651.756.8335

sold@GoldEagleRealty.com

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation Federal Aviation Administration

Petitioner: Terrance C. Hogan dba Gold Eagle Drones (GEdrones.com)

Petition of exemption from sections of CFR 14 ;

Under the terms of this exemption, it is Terrance Charles Hogan DBA Gol d Eagle Drones

(GEdrones.com) intention to safely fly a DJI Phantom Series UAV with a gimbal and

mounted camera.

The DJI Series Unmanned Aircraft System (UA S ) is a vertical takeoff and landing (VTOL)

System with a Ground Control Station (GCS) utilizing el ectronic tablet and / or s mart phone

systems.

Terrance Charles Hogan DBA Gold Eagle Drones (GEdrones.com) will be using a DJI

Phantom Series UA S running the already FAA approved software. Testing, updating, and

programming the DJI Series firmware will be done as the program updates become

available.

Terrance C. Hogan dba Gold Eagle Drones (GEdrones.com) requests an exemption for

commercial operat ion of an unmanned aerial vehicle (UAV) that is less than 50 pounds

including payload. Granting this exemption will allow Terrance C. Hogan dba Gold Eagle

Drones (GEdrones.com) to operate a commercial enterprise in compliance with Federal

Regulations and F ederal Aviation Administration Guidelines.2 How our request would benefit the public as a whole:

1. A smaller carbon footprint because no fossil fuels are used.

2. Noise pollution is minimized and exhaust pollution is eliminated.

3. Low altitude flight c an be accomplished without the risk of explosion in the event of

an accident.

Allowing this petition for Terrance C. Hogan dba Gold Eagle Drones (GEdrones.com) will

help satisfy the growing demand for “digital data with an aerial perspective” in a most safe

and economically efficient manner.

The request for this exemption is in the Public Interest as there are many consumer

applications for the services that can be provided by UAV that are currently conducted by

manned aircraft. Using a UAV for many of these applications creates an environmentally

friendly, lower cost solution to both the operator and consumer. These aircraft can be

operated safely, and without significant financial impact or danger to the operator or any

person or property on the ground in the event of loss of an aircraft. Utilizing these UA V will

create a safe and more productive work environment, reduce environmental pollution and

have a positive impact on the local economy, w hich is in the Public Interest.

The FAA can be confident t his request is in the public interest and that operations of this

UAV/UAS will achieve a level of safety at least equal to that provided by the rule from

which the exemption is being sought. Safety will not adversely be affected since the FAA

created safet y guidelines that will be followed.

Any and all repairs will be performed pursuant to manufacturer guidelines and a test flight

following FAA Guidelines will be conducted if any maintenance is done or components are

replaced on the UAS. The operator will follow the UAS manufacturer maintenance,

overhaul, replacement, inspection, and life limit requirements for the UAS and its

components. UAS flights, maintenance, repairs and any damage will be logged in a log book.

The requests of this petition are simila r to those of Mr. Jase W. Robak, Mr. Todd Thomas

Drone Pics, Brandon Drivon, and Mr. Mike Lloyd Lloyd & Associates, all of whom have

received Section 333 exemptions for comparable aircraft for similar operations.

Terrance C. Hogan dba Gold Eagle Drones (G Edrones.com) r equests certain information

contained in Exhibits “A” and “B” remain confidential and not be made public due to the

proprietary information that the application has not and will not share with others as well

as the personal private informatio n regarding the FAA Licenses.

Terrance C. Hogan dba Gold Eagle Drones (GEdrones.com) respectfully requests th at the

exemptions set forth on pages three, four

, and five be granted by the FAA.3 

### Description of Relief Sought from **FAA Regulations:**

http://www.ecfr.gov/

Terrance C. Hogan dba Gold Eagle Drones (GEdrones.com) respectfully requests that the FAA grant

the following requested exemptions:

14 CFR 21: Exemption from flight manuals.

Reason: this part is no t applicable because no pilot is on board. An equivalent level of Public

Safety will be maintained by adhering to the manufacturer procedures.

14 CFR 43: Maintenance.

Reason: this part is not applicable because no passengers are on board and because casu alty

and property damage due to mechanical failure is very remote. Risk to the public is miniscule

and made even more manageable by FAA guidelines and limitations. An equivalent level of

Public Safety will be maintained by adhering to the manufacturer procedures and by adhering to

FAA guidelines and limitations.

14 CFR 61: Pilot Certification.

Reason: this part is not applicable because no pilot is on board. An equivalent level of Public

Safety will be maintained by adhering to the manufacturer proce dures.

14 CFR 63: Crew Certification.

Reason: this part is not applicable because no crewmembers are on board. An equivalent level

of Public Safety will be maintained by adhering to the manufacturer procedures.

14 CFR 65: Recent aircraft mechanic experie nce requirements.

Reason: this part is not applicable because UAV maintenance, unlike conventional aircraft

maintenance, is practiced safely follo wing FAA Limitations specified within this 333 exception

request and manufacturer maintenance recommendatio ns. An equivalent level of Public

Safety will be maintained by adhering to the manufacturer procedures.

14 CFR 91.9: Manuals, markings, and placards.

Reason: this part is not practical due to weight limitations and limited surface area available for

pla cards. An equivalent level of Public Safety will be maintained by ensuring the pilot in

command (PIC) complies with all safe operating and flight procedures.

14 CFR 91.103: Preflight.

Reason: this part is not pertinent because no manuals are required, no runways are needed, and

all flights are conducted under visual flight rules. An equivalent level of Public Safety will be

maintained by ensuring PIC complies with all safe operating and flight procedures.

14 CFR 91.105: Crewmembers at stations

Reason: this part is not applicable due to the UAS carrying no flight crewmembers. An

equivalent level of Public Safety will be maintained by ensuring the PIC does not change in

flight.

14 CFR 91.107: Seat belt and Shoulder harness.

Reason: No Pilot on board. No flight crewmembers on board. No need for Seat belt and

Shoulder harness. An equivalent level of Public Safety will be maintained.

14 CFR 91.109: Flight Instruction.

Reason: this part is not applicable because the Unmanned Aerial System (UAS) method of flight

training does not require dual controls. An equivalent level of Public Safety will be maintained4 by adhering to the manufacturer flight training procedures, by following FAA guidelines, and by

utilizing a competent experienced PIC to instruct in experienced remote control operators.

14 CFR 91.119: Safe Altitudes.

Reason: this part is not pertinent because no flights will be conducte d above 4 00 feet above

ground level or as authorized by the FAA flight limitations. An equivalent level of Public Safety

will be maintained by ensuring PIC complies with all safe operating and flight procedures.

14 CFR 91.121: Safe altitudes and altimeters.

Reason: this part is not pertinent because there are no altimeters on board and all flight is

conducted using line of sight and VFR. An equivalent level of Public Safety will be

maintained by ensuring PIC complies with all safe operating and flight procedures.

14 CFR 91.151: Fuel requirements.

Reason: this part applies to power plants using fossil fuels. Drone flight is powered by battery

and conducted in VFR c onditions using line of sight t herefore this part is not applicable. An

equivalent level of Public Safety will be maintained by ensuring PIC complies with all safe

operating and flight procedures.

14 CF R 91.153: Flight Plans.

Reason: this part is not applicable because of the short flying range and line of sight operations

requirements. An equivalent level of Public Safety will be maintained by adhering to the

manufacturer flight operation procedures, FAA flight limitations, and safe flying technique

specified in the flight safety and pre

- flight manual.

14 CFR 91.203: Certifications.

Reason: this part is not applicable because the UAV will not be operating in an airport

environment or carrying fuel in a tank. The Drone fuselage is too small to mount a placard and

an equivalent level of Public Safety can be achieved by operating without posting a placard.

14 CFR 91.205: Instrument and equipment requirements.

Reason: this part is not applicable becau se no pilot is on board. An equivalent level of Public

Safety will be maintained by adhering to the manufacturer procedures.

14 CFR 91.215: Transponders.

Reason: respectfully request relief from transponder requirements because drone operation

does not interfere with safe flight operations of other conventional type commercial, general,

and military, winged and rotor aircraft, in the National Airspace System. All Drone operations

will be conducted using line of sight navigation, under VFR only flight c onditions, and not in the

vicinity of an airport. Safe drone flight operations will be below the safe flying altitudes of most

other aircraft. Safe flight rules and regulations will be employed to provide an equivalent level of

Public Safety.

14 CFR 91. 405: Maintenance.

Reason: this part is not applicable because drone maintenance will be conducted in compliance

with the Drone Manufacturer Specifications and all repairs and parts replacements will be

recorded in the aircraft log book. Entries will be recorded by the owner / operator and

maintained for the life of the aircraft. An equivalent level of Public Safety will be maintained by

adhering to the manufacturer procedures.

14 CFR 91.407: Return to service.

Reason: no persons or crewmembers are car ried and the owner / operator will maintain the

logbook entries as specified in 91.405 above. An equivalent level of Public Safety will be

maintained by adhering to the manufacturer procedures and operators hand book.

14 CFR 91.409: Inspections.5 Reason: this part is not applicable because all maintenance and repair will be performed as

specified above in 91.405 and 91.407. An equivalent level of Public Safety will be maintained by

adhering to the manufacturer procedures and operators hand book.

14 CFR 91.411: Altimeter checks and inspections.

Reason: this part is not applicable because there is no altimeter on board. An equivalent level of

Public Safety will be maintained by adhering to the manufacturer procedures.

14 CFR 91.413: ATC Transponder test s and inspections.

Reason: this part is not applicable because there is no transponder on board. An equivalent level

of Public Safety will be maintained by adhering to the manufacturer procedures.

14 CFR 91.417: Maintenance Records.

Reason: this part is not applicable because there will be no scheduled maintenance. Terrance

Charles Hogan is a Federally Licensed Airframe and Power plant mechanic and commercially

licensed pilot licensed under the Old Part 61 of Federal Aviation Regula tions. Mr. Hogan has

knowledge and experience performing commercial aviation aircraft maintenance, general

aviation aircraft maintenance, and military aviation aircraft maintenance and seeks exemption

from the maintenance requirements of CFR 14. Experie nced personnel or technicians will

perform maintenance, alterations, or preventive maintenance on the UAS using the methods,

techniques, and practices prescribed in the operating documents and by the conditions specified

by the FAA. All maintenance perf ormed will be entered into the Maintenance log book and the

log book will remain with the UAV. The operator wil l follow the UAS manufacturer's

maintenance overhaul, replacement, inspection, and life limit requirements for the

UAS and its components. An equ ivalent level of Public Safety will be maintained by

adhering to the manufacturer procedures. See Exhibit “ A ”.6 

### PRE

**- FLIGHT INSPECTION** 

Terrance C. Hogan dba Gold Eagle Drones (GEdrones.com) will comply with manufacturer

guidelines and checklists for pre

- flight inspection to determine the UAS is in a condition for

safe flight. Prior to each flight/operation of the UAV/UAS, the Pilot In Command ( PIC ) will

conduct a Pre

- Flight Safety Inspection. Pre

- flight checklist will be as follows but not limited

to:

1. A briefing will be conducted before flights with participating parties.

2. All flights will be performed in areas cleared for flight using www.skyvector.com to

make sure we are in authorized airspace.

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

owner’s permission.

4. The UAV/UAS will only be operated within visual line of sight and will not be flown

near airports.

5. A visual check for power

- lines, antenn as, and other overhead objects will be performed.

6. Wind conditions will be monitored and be a factor for flying.

7. Bolts and nuts will be checked for tightness and any torque seal checked for breaks or

cracks.

8. Propellers and components will be secure and checked for tightness.

9. The UAS frame will be visually checked for any cracks or structural damage.

10. Preflight inspection will consist of chec king battery condition/level in the transmitter

, UAS, and mobile device

.7 

### SAFE OPERATING **PROCEDURES**

1. Carry the DJI Phantom Series controller and Wi

- F i connecting monitor to an open area,

2. Turn on router.

3. Turn on transmitter remote.

4. Turn on Wi

- Fi connecting monitor.

5. Toggle switches 1 and 2 to the full up position.

6. Place DJI Phantom Series onto a flat location at ground level.

7. Turn on intelligent battery.

8. Turn on video/camera attached to DJI Phantom Series.

9. Verify Wi

- Fi connection with the DJI Phantom Series.

10. Verify GPS connection with multiple satellites.

11. Take off.

**SAFETY:**

Altitude information of the DJI Phantom Series UA will be provided to the PIC via GPS

equipment and radio communications telemetry data link, which downlinks for active

monitoring of the flight path.

1. The binding/link feature will not let the UAS start if communication is not

established.

2. The DJI Phantom Series App provides a percentage read out of the battery life

remaining.

3. The DJI Phantom Series is programmed to return h ome similar to failsafe mode if

t he remaining battery percentage reaches 5% or below.21 

### Terrance Charles Hogan

**DBA**

**Gold Eagle Realty (GEdrones.com)**

**APPENDIX**

Drone Exemption Certificate Application..........

................................... .............................................1 and 2

Summary that can be published.................................................................

................................. .3, 4, and 5

Pre

- flight Inspection.........................

....................................................... ........................................... ..................6

Safe Operating Procedures.....................................................................

.............................................. . ..............7

Appendix A PIC FAA Pilot Credentials and FAA Mechanic Credentials.................

....................... ....8

Appendix B; DJI Phantom Series Operations Manual...................

.......................... ....Pages 9 thru 19

Other Technology................................................................................

........................................ .....................20