September 14, 2015

Trevor C. Hunter

3437 N. 900 E.

North Ogden, UT 84414 

(801) 391-9620 

Trevorchunter@gmail.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave. SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation 

Regulations from 14 C.F.R. §§ Part 21; 45.23(b); 61.113(a)&(b); 91.7(a); 91.9(b) 

(2); 91.103(b); 91.109; 91.119; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 

91.409(a) (1) (2); 91.417(a)&(b) 

Dear Sir or Madam: 

I, Trevor C. Hunter, am writing pursuant to the FAA Modernization and Reform Act of 

2012 and the procedures contained within 14 C.F.R. 11, to request that I, Trevor C. 

Hunter, an owner and operator of small unmanned aircrafts, be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that I, Trevor C. Hunter may 

operate my small light-weight unmanned aircraft system (“UAS”) commercially in 

airspace regulated by the Federal Aviation Administration (“FAA”). 

I, Trevor C. Hunter, have over 15 years of commercial aviation experience. I currently 

hold an ATP certificate #2840011 with a First class medical. Using the DJI Phantom 31, 

I, Trevor C. Hunter, intend to provide videography, cinematography and photography 

services in the areas of building inspections, real estate, site surveys, aerial mapping, 

special events to include but not limited to weddings, private or public parties/events, 

geological surveying, environmental studies, outdoor recreational facilities and 

landscapes. 

I, Trevor C. Hunter, am committed to safety with each flight. My, Trevor C. Hunter’s, 

exemption request would permit operation of a UAS(s) in areas away from the general 

public, airports, heliports and vehicular traffic for community videos, and within property 

boundaries for individual homeowner real estate listing videos/photos. 

 

1

Attachment – DJI Phantom 3 Specifications
I. Contact Information: 

Trevor C. Hunter

3437 N. 900 E.

North Ogden, UT 84414 (801) 391-9620 

Trevorchunter@gmail.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From 

Which Trevor C. Hunter Requests Exemption are: 

• 14 CFR Part 21; 

• 14 C.F.R. 45.23(b); 

• 14 CFR 61.113(a) & (b); 

• 14 C.F.R. 91.7(a); 

• 14 C.F.R. 91.9(b) (2); 

• 14 C.F.R. 91.103(b); 

• 14 C.F. R. 91.109; 

• 14 C.F.R. 91.119; 

• 14 C.F.R. 91.121; 

• 14 C.F.R. 91.203(a) & (b); 

• 14 C.F.R. 91.151(a); 

• 14 C.F.R. 91.405(a); 

• 14 CFR 407(a) (1); 

• 14 CFR 409(a) (1) & (a) (2); 

• 14 CFR 417(a) & (b) 

III. The Extent of Relief Trevor C. Hunter Seeks and the Reason He Seeks Such 

Relief: 

I, Trevor C. Hunter, am writing pursuant to the FAA Modernization and Reform Act of 

2012 and the procedures contained within 14 C.F.R. 11, to request that I, Trevor C. 

Hunter, an owner and operator of small unmanned aircraft, be exempted from the 

Federal Aviation Regulations (“FARs”) listed below so that I may operate my small light 

weight unmanned aircraft system (“UAS”) commercially in airspace regulated by the 

Federal Aviation Administration (“FAA”). The Reform Act in Section 332 provides for 

such integration of civil unmanned aircraft systems into our national airspace system as 

it is in the public’s interest to do so. My, Trevor C. Hunter’s, light-weight UAS meets the 

definition of “small unmanned aircraft” as defined in Section 331 and therefore the 

integration of my light-weight UAS is expressly contemplated by the Reform Act. The 

Reform Act guides the Secretary in determining the types of UAS's that may operate 

safely in our national airspace system. Considerations include: The weight, size, speed 

and overall capabilities of the UAS's, whether the UAS will be operated near airports or 

heavily populated areas; and, whether the UAS will be operated by line of sight 112 P.L. 

95 § 333 (a). Each of these items reflect in favor of an exemption for me, Trevor C. 

Hunter. My UAS utilizes four (4) counter-rotating propellers for balance, control and 

stability and is equipped with a GPS and auto return safety technology. Weighing less 
than five (5) pounds (far below the maximum 55 pound limit); including camera with 

gimbal. 

I, Trevor C. Hunter, will operate the Phantom 3 in a safe manner, using the following 

checklists as well as operating procedures to determine that the aircraft is physically 

and electronically ready for safe flight and that permission from the property 

owner/representative is received: 

Pre-flight Checklist: 

• Survey the property for hazards, such as trees, utility poles and other elements 

that might compromise the flight then make a judgment as to whether to proceed. 

• Check the weather for wind speed, cloud cover and any forecast changes that 

might adversely affect flight safety and performance. 

• Examine the aircraft- looking at connections and searching for cracks and loose 

parts. 

• Determine that the electronic elements are performing correctly (receiving GPS 

signals along with calibration of the magnetic compass). 

• Determine that the barometric altimeter reflects approximately 0 feet AGL. 

• Following takeoff, hover at an altitude of approximately 10 feet to assure that the 

Home Point is solid. Then exercise all controls to confirm their functionality, if one 

of the controls is not functioning, the flight will be terminated immediately. 

• Give right-of-way to any manned aircraft. 

• Stay clear of FAA controlled airspace at airports (generally a five nautical mile 

radius) as well as restricted and prohibited zones. 

• Fly no higher than 400' and no further than 1000' from the Home Point, 

recognizing that the primary responsibility is to safely keep the aircraft safely 

within VLOS. 

• Stay clear of clouds and fog (500' vertically and 2,000' horizontally). 

Post-flight Checklist: 

• Inspect the Phantom 3 to determine its physical and electronic condition. 

• Examine the aircraft- looking at connections and searching for cracks and loose 

parts. 

IV. How Trevor C. Hunter’s Request Will Benefit the Public as A Whole: 

Aerial videography and photography has been around for a long time through manned 

fixed wing aircraft and helicopters. For small budget companies and individuals, the 

expense of such aerial videography and photography is cost prohibitive. Only large 

companies and high-income individuals can afford to absorb such expense. Manned 

aircraft pose a threat to the public through potential catastrophic crashes resulting in a 

potential loss of life. My, Trevor C. Hunter’s, UAS poses no such threat since size and 

lack of combustible fuel alleviates any potential threat to the public. Congress has 
already proclaimed that it is in the public’s interest to integrate commercially flown UAS’ 

into the national airspace system, hence the passing of the Reform Act. My, Trevor C. 

Hunter, light- weight UAS is battery powered and creates no emissions that can harm 

the environment. 

V. Reasons Trevor C. Hunter’s Exemption Will Not Adversely Affect Safety Or 

How the Exemption Will Provide a Level of Safety At Least Equal To Existing 

Rule: 

My, Trevor C. Hunter’s, exemption will not adversely affect safety. 

• My UAS weighs less than 5 pounds complete with a small light- weight high 

definition (HD) camera. 

• I only operate my UAS below 400 feet (well within the 400 foot permissible 

ceiling set by the FAA Modernization and Reform Act of 2012). 

• I land my UAS prior to manufacturer recommended minimum level of battery 

power. 

• I pilot my UAS through remote control/FPV only by line of sight. 

• My UAS has GPS with a flight safety feature whereby it hovers and then slowly 

lands if communication with the remote control pilot is lost. 

• I only operate in reasonably safe environments that are strictly controlled.

• I conduct extensive pre-flight inspections and protocol, during which safety 

carries primary importance. 

• I always obtain all necessary permissions prior to operation. 

VI. A Summary the FAA May Publish in the Federal Register: 

A. 14 C.F.R. § 21, 14 C.F.R. § 91 and 91.151: Airworthiness Certificates, Manuals 

and the Like 

14 C.F.R. § 21, Subpart H, entitled Airworthiness Certificates, sets forth 

requirements for procurement of necessary airworthiness certificates in relation 

to FAR § 91.203(a) (1). The size, weight and enclosed operational area of my, 

Trevor C. Hunter’s, UAS permits exemption from Part 21 because my UAS 

meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 

333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

UAS's from the airworthiness certificate requirement in consideration of the 

weight, size, speed, maneuverability and proximity to areas such as airports and 

dense populations. My, Trevor C. Hunter’s, current and projected UAS’ meet or 

exceed each of the elements. 

14 C.F.R. § 91.7(a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by 

the FARs, this Regulation is inapplicable. 
14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there 

are no on board pilots or passengers, and given the size of the UAS, this 

Regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a safety/flight manual delineating areas of where safety can be 

defined. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS 

utilizes electronic global positioning systems with a barometric sensor. 

14 C.F.R. § 91.151(a) with the condition that the PIC does not begin a flight 

unless (considering wind and forecast weather conditions) there is enough power 

to fly to the first point of intended landing and, assuming normal cruising speed, 

land the UA with 30% battery power remaining. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft 

certifications and registrations. They are inapplicable for the same reasons 

described above. The equivalent level of safety will be achieved by maintaining 

any such required certifications and registrations by me, Trevor C. Hunter.

B. 14 C.F.R. § 91.119: Minimum Safe Altitudes

14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It 

allows helicopters to be operated at lower altitudes in certain conditions. My UAS 

will never operate at an altitude greater than 400 AGL; safely below the standard 

of 400 AGL. I, Trevor C. Hunter, will however operate my UAS in safe areas 

away from public and traffic, providing a level of safety at least equivalent to or 

below those in relation to minimum safe altitudes. Given the size, weight, 

maneuverability and speed of my UAS, an equivalent or higher level of safety will 

be achieved. 

C. 14 C.F.R. § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417 (a) & (b): Maintenance 

Inspections 

The above-cited Regulations require, amongst other things, aircraft owners and 

operators to have the aircraft inspected as prescribed in subpart E of this part 

and shall between required inspections, except as provided in paragraph (c) of 

this section, have discrepancies repaired as prescribed in part 43 of this chapter.

These Regulations only apply to aircraft with an airworthiness certificate. They 

will not, therefore, apply to my, Trevor C. Hunter’s, UAS. However, as a safety 

precaution, I, Trevor C. Hunter, inspect my UAS before and after each flight. 
A Summary the FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 

C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, 

entitled Airworthiness Certificates, sets forth requirements for procurement of necessary 

airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and 

enclosed operational area of my UAS permit exemption from Part 21 because my, 

Trevor C. Hunter’s, UAS meets an equivalent level of safety pursuant to Section 333 of 

the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness 

certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of 

the Reform Act. Both pieces of legislation permit the FAA to exempt UAS’ from the 

airworthiness certificate requirement in consideration of the weight, size, speed, 

maneuverability and proximity to areas such as airports and dense populations. My UAS 

meets or exceeds each of the elements. 14 C.F.R. § 91.7(a) prohibits the operation of 

an aircraft without an airworthiness certificate. As no such certificate will be applicable in 

the form contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) 

(2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, 

and given the size of the UAS’, this Regulation is inapplicable. An equivalent level of 

safety will be achieved by maintaining a manual. The FAA has previously issued 

exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 

9565B, 10167, maintenance program that involves regular software updates and 

curative measures for any damaged hardware. Therefore, an equivalent level of safety 

will be achieved. 

In summary, Trevor C. Hunter seeks an exemption from the following 

Regulations: 

14 C.F.R. § 21, Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 61.113 (a) & (b); 14 

C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 (b) (2); 14 C.F.R. § 91.103 (b); 14 C.F.R. § 91.119; 

14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. § 91.203 (a) and (b); 14 C.F.R. § 

91.405 (a); 14 C.F.R. § 91.407 (a) (1); 14 C.F.R. § 91.409 (a) (2); 14 C.F.R. § 91.409 

(a) (1); and, 14 C.F.R. § 91.417 (a) & (b) 

I, Trevor C. Hunter, am requesting this exemption for the purposes of aerial 

photography, cinematography, videography, inspections and other flight operations. The 

reason for such a general and broad based request is that I, Trevor C. Hunter, wish to 

utilize a business strategy that capitalizes on opportunities as they may arise in the 

future. My, Trevor C. Hunter, business model is based on the idea of offering ad hoc 

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 hobby. 

Granting my, Trevor C. Hunter’s, request for exemption will reduce current risk levels 

and thereby enhance safety. My UAS craft does not contain potentially explosive fuel, is 

smaller, lighter and more maneuverable than conventional video and photographic 

aircraft. Further, I operate at lower altitudes and in controlled airspace eliminating 

potential public risk flying to and from established air fields. There are no personnel on 

board my, Trevor C. Hunter’s, UAS and therefore the likelihood of death or serious 

bodily injury is significantly diminished. My, Trevor C. Hunter’s, operation of my UAS, 
weighing less than 5 pounds and travelling at lower speeds within limited areas will 

provide an equivalent level of safety as that achieved under current FARs. Accordingly 

I, Trevor C. Hunter, respectfully request that the FAA grant my exemption. 

Respectfully submitted, 

Trevor C. Hunter

3437 N. 900 E.

North Ogden, UT 84414 (801) 391-9620 

Trevorchunter@gmail.com

Attachment: 

DJI Phantom 3 Specifications 

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

DJI only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be 

set to limit flight to no higher than a predetermined and set altitude as well as limit flight 

to a predetermined and set distance. In addition, DJI software provides real-time altitude 

and location information to the PIC via the linked monitor (smart phone/tablet devices) 

2.1 DJI Phantom 3 

2.1.1 Aircraft 2.1.1.1 Supported Battery – DJI 6000mAh LiPo 2S 2.1.1.2 Weight (Battery 

& Propellers Included) – 1280 g 2.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: 10cm; 

Horizontal: 1m 2.1.1.4 Max Ascent Speed – 5m/s 2.1.1.5 Max Descent Speed – 3m/s 

2.1.1.6 Max Flight Speed – 16m/s (ATTI mode, no wind) 

2.1.2 Gimbal 2.1.2.1 Controllable Range – Pitch: -90 + 30 2.1.2.2 Stabilization – 3-

zxis (pitch, roll, yaw) 

2.1.3 Camera 2.1.3.1 Sensor – Sony EXMOR 2.1.3.2 Sensor Size – 1/2.3” 2.1.3.3 

Effective Pixels – 12.4M 2.1.3.4 Video Recording Mode – 4096x2160p, 3840x2160p, 

1920x1080p, 1280x720p 

2.1.4 Remote Controller 2.1.4.1 Operating Frequency – 2.400GHz – 1.483GHz 2.1.4.2 

Max Distance – 2000m 2.1.4.3 Receiver Sensitivity (1%PER) -101dBm+/-2dBm 2.1.4.4 

Transmitter Power (EIRP) – FCC: 20dBm, CE: 16dBm 2.1.4.5 Working Voltage –

12A@7.4V