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PROPRIETARY	INFORMATION-NOT	FOR	PUBLIC	RELEASE

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations Docket No. FAA-2015-0975

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) 

and 14 C.F.R. Part 11, Rupestrian CyberServices, seeks an exemption from Federal Aviation 

Regulations (“FARs”) detailed below for the DJI Phantom 2 Vision+, DJI Phantom 2, and DJI 

Phantom 3. 

The requested exemption would support an application for a commercial Certificate of 

Authorization (COA) to use the system to support; photography of archaeological features, aerial 

photography, and mapping and surveying. By approving these exemptions, the FAA will create 

benefits to industries benefiting from applications of using multi-rotor UA Systems and the 

environment which are ultimately in the public interest.1

Each DJI UAS weighs less than 55 lbs. fully loaded, will be operated at a speed no more than 87 

knots, carry neither a pilot nor passenger, carry no explosive materials or flammable liquids, and 

operate exclusively within an approved COA airspace. All DJI UA Systems use a radio 

frequency spectrum for operation and control that complies with Federal Communications 

Commission (“FCC”) requirements and has integrated safety features as described within user 

manuals for each DJI UAS. The UAS are equipped with redundant safety mechanisms allowing 

them to operate safely after experiencing certain-flight failures. If a lost-link event occurs, 

including the loss of ground communications and/or the loss of a GPS signal, the UAS have the 

ability to perform a pre-coordinated, predictable, automated flight maneuver and return to a 

predetermined location within a designated security parameter for landing. The UAS further 

have the ability to abort a flight in the event of unpredicted obstacles or emergencies. 

The aircraft will be operated in the field with both a Pilot in Command (PIC) and a ground-based 

Visual Observer (VO) in accordance with FAA Order 8900.1, vol. 16 "Unmanned Aircraft 

Systems" with the following additional restrictions: 

- All operations will be conducted IAW the Air Traffic Organization (ATO) Certificate of

Waiver or Authorization (COA).

- All UAS operations will remain clear of manned aviation operations and activities at all times.

- All operations will occur at altitudes no more than 400' AGL

1 We will provide an explanation of equivalent level of safety for each exemption request, but will point back to the 

benefits to the environment to justify why the requests are in the public interest.
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- Operations will be operated over private property or public lands with the permission of the 

land owner

- The UAS will not be operated by a PIC from any moving device.

- The aircraft will not be operated within 5 NM of an airport or heliport unless prior coordination 

with ATC or airport management is made.

- Operations will be limited to day, visual meteorological conditions

- Aircraft will remain within Visual Line of Sight of the PIC and VO at all times.

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC

The PIC and VO will meet the requirements outlined in FAA Order 8900.1, volume 16, chapter 4. 

The PIC will hold at least a recreational or sport pilot certificate. Additionally, the PIC will 

perform maintenance on the system and will complete a course of maintenance instruction as 

part of their initial training. Due to the simplicity of the system, we do not anticipate the need 

for a supplemental pilot.

We submit that the combination of the aircraft's light weight, historically demonstrated flight 

performance, fully qualified flight crew and strict operation under the guidelines established in 

8900.1, the FAA can have confidence that the operation will have an equivalent or greater level 

of safety of manned aircraft performing the same mission.

The name and contact information of the applicant is:

Rupestrian CyberServices

Attn: Robert Mark

Ph: 928-526-3625

Email: rmark@infomagic.net

The regulations from which the exemption is requested are as follows: 

- 14 CFR Part 21

- 14 CFR 91.203

- 14 CFR 45.23, 45.29

- 14 CFR 91.9

- 14 CFR 61.113, 61.133

- 14 CFR 91.109, 91.119

- 14 CFR 91.121, 91.151

- 14 CFR Subpart E (91.401 - 91.417)

- 14 CFR 91.103(b)
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We are prepared to modify or amend any part of this request to satisfy the need for an equivalent 

level of safety. We look forward to working with your office. Please contact us at any time if 

you require additional information or clarification. 

Sincerely, 

Robert Mark 

Owner 

Rupestrian CyberServices 

Appendices: 

A. Exemption Request and Equivalent Level of Safety

B. Privacy Issues

C. Safety Assessment

D. Maintenance Procedures

E. User Manuals

F. Public Interest 

G. DJI Multi-rotor Training Program