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Robert	D	Rideout

Netjectives

PO	Box	7225

Newark,	DE	19714.

Wednesday,	March	2,	2016

US	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

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, Netjectives,	LLC. respectfully	requests	an	exception from	several	

provisions	of	Title	14	of	the	Code	of	Federal	Regulations	(C.F.R)	to	permit	the	use	of	small	

unmanned	aerial	systems	(sUAS)	to	assist	in	the	evaluation	of	operations	for	our	clients.		This	

request	is	motivated	by	the	marketing	need	for	aerial	photography	services	for	our	website	

customers.		

The	Unmanned	Aircraft	is	defined	as:

• Lightweight	(2.8lb)	DJI	Phantom	3	Professional	with	4k	Camera,	which	carries	the	

following	safety	equipment.			

o On	board	safety	computer	with GPS	navigation	and	location	ability.		

o On-board	camera	that	has	ability	to	capture	still	images	as	well	as	high	definition

video.

o Onboard	telemetry	system,	which	includes	live	alititude,	speed	and	distance	

information.		

Ground	station:

• Private	Pilot	(PIC)	in	operational	control	of	the	aircraft	controlling	with	a	2.4GHz	radio	

transmitter/controller	operated	by	the	PIC.

• Visual	Observer	(VO)	who	is	visually	tracking	the UA	while	it	is in	flight.

Requested	exemption	would	support	a	commercial	certificate	of	authorization	to	use	the	above	

UAS	to	support	aerial	photography	and	video	of	real-estate property,	specifically	individual	

properties.		Flight	controlled	by	PIC	would	not	leave	property	boundaries,	nor	would	be	greater	

than	200	feet	AGL.		
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1. The	Flight will	be	operated	in	the	field	with	both	a	PIC	and	a	VO	in	accordance	with	FAA	

Policy	N	8900.227	Section	14	"Operational	Requirements	for	UAS"	and	with	the	

following	Restrictions:	

• No	flight	will	be	made	with	a	UA	Gross	weight	exceeding	55	pounds;

• All	operations	must	occur	in	FAA	Class	G	airspace	at	no	more	than	400	ft	AGL,	

at	an	airspeed	of	no	more	than	25	knots	and	no	further	than	3/4	NM	from	

the	PIC;

• All	operations	must	utilize	a	visual	observer	(VO).	The	VO	and	PIC	must	be	

able	to	communicate	by	voice	at	all	times	during	a	flight	operation;

• Operations	will	be	restricted	to	flights	over	private	property	with	the	

permission	of	the	property	owner;	

• The	PIC	must	have	accumulated	and	logged,	in	a	manner	consistent	with	14	

CFR	§	61.51	(b),	a	minimum	of	100	flight	cycles	and	25	hours	of	total	time	as	

a	UA	rotorcraft	pilot	and	at	least	ten	hours	logged	as	a	UA	pilot	with	a	similar	

UA	type.		In	addition, pilots	will	meet	currency	requirements	of	three	

takeoffs	and	landings	within	the	preceding	90	days.		

• All	required	permits	will	be	obtained	from	state	and	local government	prior	

to	operation.

• The	flight will	not	be	operated	over	densely	populated	areas;

• The	flight	will	not	be	operated	at	air	shows;

• The	flight will	not	be	operated	over	any	openair	assembly	of	people;

• The	flight will	not	be	operated	over	heavily	trafficked	roads;

• The	flight will	not	be	operated	within	5	NM of	an	airport	or	heliport;

• Operations	will	be	restricted	to	day	only	and	weather	conditions	equivalent	

to	VFR;

• The	PIC	will	brief	the	VO	and	property	owner	about	the	operation	and	risk	

before	the	first	flight	at	each	new	location;

• No	flight	may	be	made	without	a	PreFlight	Inspection by	the	PIC	before	each	

operation	to	ascertain	that	the	UA	is	in	a	condition	safe	for	flight.

• The	PIC	and	VO	will	meet	the	requirements	outlined	in	FAA	Policy	N	

8900.227	Section	16	personnel	Qualifications.	Additionally,	the	PIC	and	VO	

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

maintenance	instruction	as	part	of	their	initial	training.	

• We	submit	that	the	combination	of	the	UA's	light	weight,	flight	performance	

and	ability,	fully	qualified	flight	crew	and	strict	operation	under	the	

guidelines	established	in	8900.227,	and	under	all	of	the	Restrictions	(a)	

through	(o)	listed	above,	the	FAA	can	have	full	confidence	that	the	operation	

will	have	an	equivalent	or	greater	level	of	safety	than	manned	aircraft	

performing	the	same	mission.	
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The	name	and	contact	information	of	the	applicant:	

Netjectives,	LLC.

Robert	D	Rideout,	PP-ASEL

Ph:	302-999-9070

Email:	dave@netjectives.com

The	regulations	from	which	the	exemption	is	requested	are	listed	below.	

14	CFR	Part	21 – Airworthiness	Certificates – The	requirements	for	issuance	of	

airworthiness	certificates	as	required	by	14	CFR	91.203

Given	the	small	size	of	the	UA	and	the	safeguards	taken,	an	exemption	from	Part	

21	Subpart	H	meets	the	requirements	of	an	equivalent	level	of	safety.	In	addition	

the	PIC	will	perform	preflight	checks	to	ensure	airworthiness	of	UA.		

14	CFR	45.23,	45.29 – Aircraft	markings	and	Identification	Requirements	–

When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration

number	is	displayed	on	limited,	restricted	or	light-sport	category	aircraft	or

experimental	or	provisionally	certificated	aircraft,	the	operator	must	also	display

on	that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in	

letters not	less	than	2	inches	nor	more	than	6	inches	high,	the	words	"limited,"

"restricted,"	"light-sport,	"experimental,"	or	"provisional,"	as	applicable

Netjectives	will	ensure	compliance	by	both	putting	the	UA	registration	number	

as	well	as	Experimental	on	its	UA	aircraft.

14	CFR	91.9 – Civil	aircraft	flight	manual,	marking	and	placard –

prohibits	operation	of	U.S.-registered	civil	aircraft	unless	there	is	available

in	the	aircraft	a	current	approved	Airplane	or	Rotorcraft	Flight	Manual,	approved

manual	material,	markings,	and placards,	or	any	combination	thereof.

All	operating	documents,	authorizations	and	exemptions	will	be	kept	in	a	flight	

binder	accessible by	the	PIC	available	for	inspection.		

14	CFR	61.113,	61.133 – Recreational,	Private	and	Commercial	Pilot	Privilege and	

Limitations –

Except	as	provided	in	paragraphs	(b)	through	(g)	of	this

section,	no	person	who	holds	a	private	pilot	certificate	may	act	as	pilot	in

command	of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation

or	hire;	nor	may	that	person,	for	compensation	or	hire,	act	as	pilot	in	command	

of an	aircraft.	(b)	A	private	pilot	may,	for	compensation	or	hire,	act	as	pilot	in

command	of	an	aircraft	in	connection	with	any	business	or	employment

Netjectives	will	employ	a	PIC	who	holds	at	minimum	a	private	pilot	certificate	of	

any	category	or	class	and	a	valid	drivers	license.
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14	CFR	91.109 – Flight	Instruction

No	person	may	operate	a	civil	aircraft	(except	a	manned	free	balloon)	that	is	

being used	for	flight	instruction	unless	that	aircraft	has	fully	functioning	dual	

controls.

The	UAS	in	the	exemption	request	do	not	have	the	ability	for	dual	controls,	

however	there	is	a	training	program	before	a	drone	pilot	is	performing	flight	

operations.		Manufacturer	does	offer	flight	simulation	mode	which	will	allow	

operators	to	build	experience	and	maintain	proficiency	in	event	conditions	are	

not	favorable	for	flight.		Training	sessions	will	be	conducted	separately from	

flights	conducted	for	hire.

14	CFR	91.119 – Minimum	Safe	Altitudes

Except	when	necessary	for	takeoff	or	landing,	no	person	may	operate	an	aircraft

below	the	following	altitudes:	(b)	Over	any	congested	area	of	a	city,	town,	or

settlement,	or	over	any	open	air	assembly	of	persons,	an	altitude	of	1,000	feet

above	the	highest	obstacle	within	a	horizontal	radius	of	2,000	feet	of	the	aircraft.

(c)	Over	other	than	congested	areas.	An	altitude	of	500	feet	above	the	surface,

except	over	open	water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft

may	not	be	operated	closer	than	500	feet	to	any	person,	vessel,	vehicle,	or

structure.	(d)	Helicopters,	powered	parachutes,	and	weight-shift-control	aircraft.	

If the	operation	is	conducted	without	hazard	to	persons	or	property	on	the	

surface—

(1)	A	helicopter	may	be	operated	at	less	than	the	minimums	prescribed	in

paragraph	(b)	or	(c)	of	this	section,	provided	each	person	operating	the	helicopter

complies	with	any	routes	or	altitudes	specifically	prescribed	for	helicopters	by	the

FAA.

Netjectives	will	operate	the	UAS	at	200	feet	AGL	or	below	for	operations	or	as	

otherwise	noted	in	the	COA.

14	CFR	91.121 – Altimeter	Settings

Each	person	operating	an	aircraft	shall	maintain	the	cruising	altitude	or	flight	

level	of	that aircraft,	as	the	case	may	be,	by	reference	to	an	altimeter	that	is	set,	

when	operating.

Phantom	UAS	are	equipped	with	Global	Positioning	System,	which	provide	real	

time	telemetry	data	to	the	pilot,	without	an	Altimeter	present	on	the	drone.			

The	visual	observer in	combination	of	the	pilot	will	provide exemplary level	of	

safety	and	fail	safe,	should	the	electronics	telemetry	systems	fail	on	UAS.		

14	CFR	91.151 – Fuel	Requirements	for	Flight	in	VFR	Conditions

No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	unless

(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly	to
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the	first	point	of	intended	landing	and,	assuming	normal	cruising	speed— (1)

During	the	day,	to	fly	after	that	for	at	least	30	minutes;

The	total	flight	time	of	the	UAS	is	limited	to	24	minutes.		The	UAS	has	built	in	

battery	management	that	will	cause	the	drone	to	auto	return	to	home	in	the	

event	the	battery	is	low.		The	PIC	will	achieve	a	level	of	safety	by	complying	with	

the	DJI	low	battery	failsafe	system.

14	CFR	Subpart	E	(91.401	 91.417) Maintenance	Inspections	–

(a)	Except	for	work	performed	in	accordance	with	

91.411	and	91.413,	each	registered	owner	or	operator	shall	keep	the	following

records	for	the	periods	specified	in	paragraph	(b)	of	this	section:	(paragraphs	1	(i

– iii),	2	(i	– vi));	(b)	The	owner	or	operator	shall	retain	the	following	records	for

the	periods	prescribed:	(paragraphs	1	– 3)

PIC	will	conduct	Pre/Post	flight	inspections	according	to	the	operations	manual	

of	the	drone	as	well	as	checking	all	available	flight	information	for	weather	and	

current	NOTAMs	in	the	area.		All	maintenance	performed	on	drone	will	be	

documented	and	maintained	in	logbook	for	specified	aircraft.	

Public	Interest

Throughout	this	document	we	have	expressed	the	safety	that	Netjectives	will	exercise	when	

operating	the	UAS	for	the	purposes	of	commercial	aerial	photography	of	real	estate	listings	and	

other	work	related	to	aerial	photography	and	how	it	will	be	in	the	best	interest	of	the	public.		

UA	operations	will	allow	for	better	access	to	properties	and	will	give	people	an	enhanced	birds	

eye	view	of	a	property.		This	will	also	provide	an	economic	benefit	to	the	area	due	to	more	

interest	in	the	real estate.		In	addition, noise	pollution	and	other	items	will	be	minimized	as	

well.				

Attachments

1. DJI	Phantom	Professional	User	Manual	v1.6

2. Phantom	3	Intelligent	Flight	Battery	Safety	Guidelines	v1.0

3. Phantom	3	Safety	Guides	and	Disclaimer

Please	contact	us	if	you	need	additional	information	or	clarification.		I am	a	private	pilot	and	

understand	the	need	for	flight	safety.

Sincerely,	

Robert	D	Rideout

CEO,	Netjectives,	LLC.