January 22, 2016

Mark Coulter

2619 Austin Court

Stillwater, OK 74074

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue, SE., 

Washington, DC 20590-0001 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 and Part 11 of the

Federal Aviation Regulations 

Dear Sir or Madam; 

In accordance with the Public Guidance for Petitions for Exemption filed under Section 

333, Mark Coulter requests exemption from the Federal Aviation Regulations to allow for 

commercial UAS operations of a DJI Phantom 3 Professional, DJI Inspire 1, and Matrice 

100 for the purpose of aerial photography, tower inspection, real estate marketing, 

surveying, agricultural mapping, search and rescue, UAS instruction and ground training, 

and other flight operations that could be performed safer, quicker, and more cost 

effectively than with traditional manned aircraft. 

Applicant: 

Mark Coulter

2619 Austin Court

Stillwater, OK 74074

markcoulter@mac.com

508-560-5444

Attachments links to documents and manuals for:

DJI phantom 3 professional

http://www.dji.com/product/phantom-3/download

DJI Inspire 1

http://www.dji.com/product/inspire-1/download

Matrice 100
https://developer.dji.com/matrice-100/downloads

Regulations from which the exemption is requested: 

14 CFR 21, Subpart H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b)(2) 

14 CFR 91.109 

14 CFR 91.119 (c) 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(l) 

14 CFR 91.409 (a)(l) & (a)(2) 

14 CFR 91.417 (a) & (b) 

14 CFR 21, Subpart H- In consideration of the size, weight, speed, and limited operating 

area associated with this UAS and its operation, Mark Coulter requests relief from 14 

CFR part 21, Subpart H, and any associated noise certification and testing requirements 

of part 36. The UAS will carry neither pilot, passenger, explosive materials or flammable 

liquids. 

14 CFR 45.23 (b)- Even though the UAS will have no airworthiness certificate, an 

exemption may be needed as the UAS will have no cabin, cockpit, or pilot station on 

which the word "Experimental" can be placed. Given the size of the UAS, two-inch 

lettering will be not be possible. The word "Experimental" will be placed on the fuselage 

in compliance with §45.29 (f). The equivalent level of safety will be provided by 

having the UAS marked on its fuselage as required by §45.29 (f) where the pilot, 

observer and others working with the UAS will see the identification of the UAS as 

"Experimental." 

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)- Since the UAS will not carry a pilot or 

passengers, Mark Coulter requests relief from these regulations. As a licensed private 

pilot (VFR and IFR SEL) I will be the PIC and sole manipulator of the controls. A visual 

observer or (VO) will be utilized and required to communicate verbally with me at all 

times. The UAS will be limited to operations within visual distance of both the PIC and 

VO. All UAS operations will take place in a controlled area. The risks associated with the 

use of a UAS are far less than similar commercial aircraft operations. 
14 CFR 91.7 (a)- Since the UAS will not carry a pilot or passengers there will be no 

airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard exists for determining airworthiness. Given the size of the aircraft, 

maintenance, and use of safety checklist prior to each flight, an equivalent level of safety

will be provided. All flights for each aircraft will be in accordance with the safety and 

maintenance recommendations found in the attached manufacturers’ manuals. 

14 CFR 91.9 (b)(2)- Given the size and configuration, the UAS has no ability to carry a 

flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately 

carry a flight manual. An equivalent level of safety will be maintained by keeping the 

flight manual at the ground station where the UAS pilot will have immediate access to it. 

14 CFR 91.103 (b)(2) -As no FAA approved flight manuals will be provided for the 

aircraft listed, an exemption is needed. Alternate procedures including but not limited to 

reviewing airspace, weather conditions, checking flight battery requirements, checking 

takeoff and landing distances, along with checklists found in the manufacturers’ manuals

will be implemented. These actions will provide an equivalent or higher level of safety. 

14 CFR 91.109- UAS and remotely piloted aircraft do not have fully functional dual 

controls. Flight control is achieved through the use of a control box that communicates 

with the aircraft via radio communications. An equivalent level of safety will be achieved 

using the real time ground station data since the UAS will carry neither a pilot or 

passengers. 

14 CFR 91.119 (c)- The UAS will never be operated at an altitude higher than 400 feet

AGL. The UAS will operate in safe areas away from public and traffic and only with 

permission of the property and structure owners. The UAS will also be restricted by the 

flight controller to a maximum vertical height of 400 feet AGL, and 1500 feet horizontal. 

Given the size, weight, maneuverability and speed of the UAS, an equivalent or higher 

level of safety will be achieved. 

14 CFR 91.121- As the UAS may not have a barometric altimeter, but instead a GPS 

barometric sensor for altitude information an exemption may be required. An equivalent 

level of safety will be achieved using a ground station which links to a telemetry data link. 

This will provide the pilot with live flight data monitoring, confirming the altitude of the 

launch site shown on the GPS altitude indicator prior to flight. 

14 CFR 91.151 (a)- The UAS has a limited range and will be limited to operations in a 

controlled environment. The battery power the UAS above provide approximately 22

minutes of flight time. The UAS is unable to meet the 30-minute reserve requirement and 

therefore requires an exemption. An equivalent level of safety will be achieved by 

monitoring the battery through the ground station and landing with a minimum of 30 

percent battery power remaining. 

14 CFR 91.203 (a) & (b)- Given the size and configuration, the UAS does not have the
ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on 

board to store a flight manual. An equivalent level of safety will be maintained by 

keeping the flight manual at the ground station where the UAS pilot will have immediate 

access to it. Given the following sections only apply to aircraft with an airworthiness 

certificate, these sections do not apply to this applicant. As a safety precaution, the 

operator will perform preflight inspections and ensure UAS is in working condition 

before initiating each flight: 

14 CFR 91.405 (a) 

14 CFR 91.407 (a)(1) 

14 CFR 91.409 (a)(l) & (a)(2) 

14 CFR 91.417 (a) & (b)

Equivalent Level of Safety 

In addition to the safety standards mentioned above the UAS will adhere to the following 

additional guidelines: 

1. The UAS will not be operated within 5 miles of an airport unless prior contact to Air 

 Traffic Control has been established. 

2. Flights will not exceed the airspeed of 87 knots (100 mph)

3. Flights will be operated at or below an altitude of 400 feet AGL. 

4. The PIC and VO will communicate verbally at all times. 

5. UAS operations will not be conducted during night, as defined in 14 CFR§1.1.

6. All operations will be conducted under VMC. 

7. The UAS will land with a minimum 30 percent battery reserve remaining. 

8. The UAS will only be piloted within visual line of sight. 

9. The UAS will utilize an internal flight safety feature that will return to a

 preprogrammed position and land if communication with the remote control is lost. 

10. Preflight inspections and protocol will be followed prior to all operations. 

11. The UAS will abort flight in the event of unpredictable obstacles or emergencies. 

12. Operated by the Applicant, a licensed private pilot.

Public Interest 

I believe the use of a UAS to supplement manned aircraft will enhance safety and help 

reduce the impact to the environment compared to similar operations conducted with a 

manned aircraft carrying a flight crew and flammable fuel. 

The inspections of cellular communication towers or similar structures will eliminate the 

risks associated with persons climbing these structures. The photographs and videos

collected can provide engineers with valuable information as to the needed maintenance

of these structures for safety.

The use of a UAS in the real estate industry helps provide a higher level of marketing and 

service for all parties involved. The UAS is able to provide a view which can capture the 
entire property in a single photo or short video clip. When compared to similar operations, 

utilizing a UAS poses much less of a safety concern for the general public with less fuel, 

time, noise and other resources. 

The use of a UAS in search and rescue make it possible to place resources where they 

need to be quicker which can help save lives and property. A UAS can be deployed and 

provide a broader picture of conditions to help the incident commander make a more 

informed decision.

Privacy 

All flights will occur over private or controlled areas with the owner's consent. Any

person captured in a collected image will have consented prior to filming or otherwise 

have agreed to be in the area prior to the filming taking place. The right to privacy will 

always be respected and considered. In the case of search and rescue, the standard 

operating procedure of the authority having jurisdiction will serve as rule in the case of 

emergencies when consent cannot be obtained from each individual. 

Sincerely,

Mark Coulter

Applicant/Operator