November 9, 2015

Dharmit Patel

3347 S Lituanica Ave

Unit 1F, Chicago IL 60608

Cell 814-753-2123

Email: dharmitpatel316@gmail.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments:

1)Phantom 3 Professional User Manual V1.6

2)Phantom 3 Professional Quick Start Guide V1.2

3) Phantom 3 Professional Release Notes

4) Phantom 3 Professional Intelligent Battery Safety Guidelines V1.0

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481in the matter of the 

petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the

petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355in the matter of the petition 

of FLYING CAM INC

Dear FAA, In accordance with the FAA’s Guidelines for 

Submitting a Petition for Exemption under section 333 of 

the FAA Modernization and Reform Act of 2012, I, Dharmit 

Patel, request exemption from 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, 

aerial videography and aerial cinematography and surveys and 

other flight operations that could be performed safely and more 

cost effectively with the use of small UAS at low altitude within 

the U.S. national airspace system as compared to a manned 

aircraft. Operations will be performed only at the request of and 

with the authorization and permission of clients or their 

authorized agents in order to facilitate commerce and raise 

awareness of the beneficial uses of small unmanned air systems. 

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, Dharmit Patel, are drawn from references 13. 

The FARs 

I, Dharmit Patel, request exemption from the above mentioned 

FARs for the following reasons.

61.113(a) & (b). I, Dharmit Patel, request relief in order to 

facilitate the 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 to the previously granted exemptions. A Visual 

Observer will be used at all times while under this requested 

exemption. 

91.119(c) As discussed in Exemption 11138 (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 

“congested areas” and “densely populated”. I, Dharmit Patel 

request waiver for this condition to allow reasonable and 

responsible operations with safety as my main concern in areas of 

subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) 

is inapplicable since the UAS does not have an altimeter and 

instead utilizes electronic 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 the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, 

similar UAS specific relief has been granted in Exemption Nos. 

8811, 10808, and 10673 for daytime, VFR conditions. The UAS 

provides battery power remaining in percent to the PIC. The UA 

batteries provide approximately 23 minutes of powered flight. 

Information provided in the operating documents discusses 

procedures regarding remaining battery power management. 

Those documents contain a condition in which the PIC will initiate 

a landing procedure when 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)(1). 91.409 (a)(1) & (2). 

91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS 

TRUDEAU), I, Dharmit Patel, propose to inspect and ensure that 

the UAS is in a condition for safe flight in accordance with the 

operating documents. The FAA found that adherence to the 
petitioner’s operating documents and the conditions and 

limitations specified, describing the requirements for 

maintenance, inspection, and recordkeeping, 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 45.15 ounces (1280g) designed 

primarily to carry aloft a high definition camera. It has an 

advertised maximum speed of less than 31.10 knots (16m/s) and 

a maximum climb rate of less than 984 feet per minute (5 m/s). 

It is powered by four electric motors with a distance between 

motors of less than 14 inches (350mm) It utilizes an internal 

inertial measuring unit (IMU) with integrated barometric sensor 

augmented with global positioning system (GPS) to maintain its 

geospatial orientation and position. It is controlled primarily 

through an FCC certified radio control (RC) 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 PIC, camera 

imagery, and control camera angle. It has fail safe 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 23 minutes. The onboard flight controller will warn 

the pilot via telemetry and external lighting cues before reaching 

a low battery state. An automatic termination of flight and landing 

will be initiated when the battery reaches a predetermined low 

state. It is anticipated that flights will usually last less than 10 

minutes. More information is available in attachment 1. 

Risk mitigation I, Dharmit Patel, have reviewed FAA 
exemptions reference’s 13 Conditions and Limitations section 

and believe that the procedures specified therein are reasonable 

and will be utilized in order to manage and mitigate risk and 

ensure public safety. 

A preflight checklist will be developed and employed to ensure

that the UAS’s airworthiness will be verified before launch. 

Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance 

logs to record time on failure prone components. 

I, Dharmit Patel, request that in a manner similar to reference 3, 

be allowed to operate within 5 miles of an airport provided that. 

“The UA may not operate in Class B, C, or D airspace 

without written approval from the FAA. The UA may not 

operate within 5 nautical miles of the geographic center 

of a non towered airport 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.” 

Operations within 5 miles of an airport are not anticipated to be 

routine but I am requesting a mechanism to facilitate such 

activities without requesting a new and separate exemption(s) 

should the need arise. Operations within class B airspace are not 

requested due to the lack of mode C transponder. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety

and reduce the environmental impact as compared to similar 
operations conducted with manned aircraft of greater 

proportions, carrying a crew and flammable fuel. 

In regards to performing inspections of bridges, towers, and 

natural gas pipelines the UAS will minimize the risk to persons 

attempting to climb these structures and photograph problem 

areas. It will provide a way for companies to have their engineers 

review photographs and provide additional safety to the general 

public in regards to towers failing or natural gas pipelines having 

structural issues. Many of the natural gas pipelines in our area 

travel in areas that are hard to reach by vehicle or foot and if an 

area is suspected of having problems the UAS can reach it to 

make an assessment easier and safer. 

I, Dharmit Patel, will also make the UAS and myself available to 

local volunteer organizations (for no charge) such as fire 

departments, local law enforcement, etc., to perform search and 

rescue operations, or other similar events as directed by

authorities. 

In addition, the use of the UAS in order to facilitate commerce 

could lead to 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 photography. Aerial photography is a 

valuable marketing tool that can lead to increased commerce and 

enhance my personal photography. A visual observer will be 

utilized at all times that the UAS is performing duties for 

compensation and the PIC will hold a Private Pilots license. 

Flight data including UAS flight time, Control Unit operation time, 

incident, and details will be recorded for each flight and made 

available to the FAA at any time needed. Any deviations from 
normal operations will also be recorded and made available to 

FAA. 

Conclusion 

I, Dharmit Patel am requesting this exemption for the purposes of 

aerial photography, aerial videography and aerial cinematography

and surveys, and other flight operations. The reason for such a 

general and broad based request is that I, Dharmit Patel, wish to 

utilize a business strategy in order to capitalize on opportunities 

as they may arise in the future without the long turnaround time 

associated with additional exemptions. 

My business model is based on the idea of offering small UAS 

services to individuals or companies who wish to employ these 

services as a safe, effective, and legal option to enhance their

business or prevent structural disasters that may influence the 

general public or individuals. 

My own research shows an upward demand for these services 

that currently exists in the real estate market, Wedding market 

and other markets are just beginning to realize the need for such 

services. 

I have flown 100 hours in Quadcopter. I am familiar with 

Quadcopter preflight. I have extensive experience with a UAS and 

extensive experience as a photographer.