Supplement for previously submitted request.

Tracking number: 1jz-8j98-dzbr

Vincent A. Flanagan petitions the Federal Aviation Administration (FAA) for an exemption from part 21, 

subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 

91.121, 91.151(a), 91.203(a)and(b), 91.207(a)(2) and (b),91.319(a)(1) 91.405(a)(b), 91.407(a)(1), 

91.409(a)(1)(2), and 91.417(a) and (b), 91.9(c) of Title 14, Code of Federal Regulations (14 CFR).

The proposed exemption would allow Vincent Flanagan to operate the PHANTOM 3 quad-copter 

(drone) unmanned aircraft system (UAS) to conduct aerial videography and cinematography as part of 

existing environmental spill response for the purpose of acquiring before and after pictures/video of the 

clean-up. The Phantom 3 will also be used for gaining an aerial perspective for customers and providing 

market research, aerial surveys, mapping, inspections and general videography/cinematography.

Background:

I have over 10 years of flying remote control aircraft as a hobbyist without incident. I’ve been involved 

in the Aerospace industry for over 20 years. I was active duty Air Force, worked on the Space Shuttle 

Program with United Space Alliance for NASA and with DynCorp on The Department of State INL/A 

contract as Site and Aviation Maintenance Manager. I also have an FAA Airframe and Power plant (A&P)

certificate and will be able to maintain the airworthiness of the aircraft. I’m also keenly aware of the 

need to stay away from air traffic. 

Public Interest:

The Unmanned Aerial System (UAS) described herein is smaller, lighter and more maneuverable than 

conventional aircraft running on combustible fuel, operates at lower altitudes with no people on board 

and will thereby reduce current risk levels, enhance safety and diminish the likelihood of death or 

serious bodily injury. With a small payload and maximum flight time of only 23 minutes, this offers little 

or no risk to national security. The UAS will also be zero air pollution as it fully electric. The electric 

motors are relatively quiet and nearly silent above 100 feet.

THE UNMANNED Aerial System (UAS) 

DJI Phantom 3 Professional 

 Professional grade 

 Under 3 pounds takeoff weight 

 4 brushless motors 

 23 minute flight time 

 Smart Battery technology

 DJI - Flight Controller with GPS and GLONAS

o Provides Fail Safe features that allow the aircraft to return to the launch point and land 

automatically in the event the command and control signal is lost or the battery has 

reached a pre-determined threshold. If battery reaches a critical level, the aircraft will 

descend and land at the current location. Control of the aircraft is maintained during 

descent to allow the PIC to guide it to a safe landing. 
 Contains a database of airports and restricted airspace and automatically prevents operation in 

these areas 

 Electronically limited maximum altitude of 394 feet.

 DJI lightbridge Video Downlink Transmitter.

 DJI iOSD - On Screen Display of Telemetry. The iOSD superimposes telemetry data on the video 

downlink to provide the pilot with heading, speed, height, distance, altitude, GPS information, 

and current battery voltage as well as indicating proximity to airports and restricted airspace. 

Direction back to launch point is also indicated. 

 The aircraft is equipped with DJI vision position system that aids the aircraft in staying in a 

steady position under 3 meters altitude should GPS/GLONAS signal be lost.

OPERATIONAL PARAMETERS 

 The UAS will weigh less than 3 pounds fully loaded.

 Flights will be operated within visual line of sight of a pilot. 

 Maximum total flight time for each operational flight will be 23 minutes. Flights will be 

terminated at 20% battery power reserve should that occur prior to the 23 minute limit. 

 Flights will be operated at an altitude of no more than 400 feet (122 meters) AGL. Unless a 

specific COA is obtained, the limit will be according to the “blanket” COA of 200 feet (61 

meters). 

 PIC will comply with AMA flying fields and rules and will be used to accumulate flying time and 

practice. 

 Aircraft will be maintained by an FAA certified A&P mechanic in accordance with manufactures 

standards.

 Written and/or oral permission will be obtained from the property owner. 

 Pilot and observer will be able to communicate by voice at all times during the operation. 

Communication may be assisted by VHF or UHF radio or cellular device when necessary. Text 

communications are not allowed. 

 The UAS will only be operated during daytime hours in VFR weather conditions. 

 Operations may not be conducted aboard a moving device or vehicle. 

 Operation near airports will be conducted according to the “blanket” COA unless another COA is 

obtained. 

 5 nautical miles (NM) from an airport having an operational control tower; or 

 3 NM from an airport with a published instrument flight procedure, but not an operational 

tower; or 

 2 NM from an airport without a published instrument flight procedure or an operational tower; 

or 

 2 NM from a heliport with a published instrument flight procedure 

 Maximum speed 35 mph 

 Altitude will be electronically limited to 394 feet

 Landing will occur at or before 20% battery life is reached.
PRE-FLIGHT Checklist and Operation

1. The Phantom 3 will be inspected by A&P certificate mechanic before and after each flight.

2. Weather conditions are suitable for VFR flight and wind is 18 mph or less.

3. A map of the local area will be reviewed prior to any flight to double check for any local 

obstacles or restrictions.

4. FAA B4UFLY smartphone application will be reviewed before flight (when it becomes available)

5. The aircraft will be flown in a safe manner at all times.

6. All batteries on the aircraft and transmitter will be fully charged before takeoff.

7. GPS/GLONAS acquisition and calibration will be performed before flight.

8. The “Return Home” point will be set on the aircraft.

9. DJI No fly Zone software will be installed.

10. All Manufacturer guidelines will be followed.

11. Verify camera equipment. 

12. Turn on radio control transmitters and video equipment. 

13. Connect the UAS main battery. Check for radio connection with RC transmitters and video 

downlink. 

14. Announce your intention to take off by announcing “Take Off”.

Sincerely,

Vincent A. Flanagan, MBA

Flanagan.vincent@yahoo.com

321-652-1256

7170 Holly Ave Cocoa FL, 32927