Zachary Z. Truempy

14 Bunn St., Califon, NJ 07830

(908) 638-6555

Email: craftlete@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 2012 

Attachments: 

1) Phantom 3 Safety Guidelines and Disclaimer v1.0 2015.4 

April 29, 2015 

Dear Sir or Madam, 

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption 

under section 333 of the FAA Modernization and Reform Act of 2012, I Zachary Z. 

Truempy, referred to hereafter as the petitioner, request exemption from the 

following sections of Title 14, Code of Federal Regulations §§ 61.113(a); 61.113(b); 

91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 91.409(a)(2); 

91.417(a) & (b); 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial 

photography, cinematography, videography, and other flight operations that could be 

performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. national airspace system as compared to a manned aircraft. 

Operations will be performed only at the request of and with the authorization and 

permission of clients or their authorized agents in order to facilitate commerce 

and raise awareness of the beneficial uses of small unmanned air systems. 

So long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. The 

conditions identified and proposed by the petitioner are drawn from references 1-3. 

The FARs 
The petitioner seeks exemption from the above mentioned FARs for the following 

reasons; 

61.113(a) & (b); The petitioner requests relief in order to facilitate the 

utilization of an UAS operator with the addition of an observer. All pre-flight 

inspection, maintenance and flight logs will be saved and made available to the FAA 

and Secretary of Transportation (SoT) for review; with the purpose of safely 

integrating civil UAS operation in the National Airspace System. 

91.119(c) 

The petitioner will primarily operate the UAS between ground level and 200 feet. 

The UAS will be operated over designated properties with the owner’s consent and 

while maintaining a safe distance from persons. The petitioner will compile flight 

data from the logs. This data may assist the FAA in development of regulations for 

commercial operations in low-risk, controlled environments. 91.121 

91.151(a) 

The UAS provides battery power remaining in percent to the PIC. The UA batteries 

provide approximately 25 minutes of powered flight. Information provided in the 

operating documents discusses procedures regarding remaining battery power 

management. Those documents contain a condition in which the PIC will initiate a 

landing procedure when battery remaining reaches a specified level. Given the 

limitations on proposed operations and the location of those proposed operations, 

The FAA found that a reduced minimum power reserve for flight in daytime VFR 

conditions was reasonable. 91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & 

(b) 

The petitioner proposes to inspect and ensure that the UAS is in a condition for 

safe flight in accordance with the operating documents. The FAA found that 

adherence to the petitioner’s operating documents and the conditions and 

limitations specified, describing the requirements for maintenance, inspection, and 

record keeping, were sufficient to ensure that safety would not be adversely 

affected. 

The UAS 

The DJI Phantom 3 is a highly effective consumer grade small rotorcraft in the 

quadcopter configuration with an advertised weight of less than 44 Ounces (1242g) 

designed primarily to carry aloft a high definition camera. It has an advertised 

maximum speed of less than 30 knots (15m/s) and a maximum climb rate of less than 

1200 feet per minute (6 m/s). It is powered by four electric motors with a distance 

between motors of less than 14 inches (350mm). It utilizes an internal inertial 

measuring unit (IMU) with integrated barometric sensor augmented with global 

positioning system (GPS) to maintain its geospatial orientation and position. It is 

controlled primarily through an FCC certified radio control (RC) unit. Real time 

video and telemetry information is transmitted back to a ground control station 
allowing the operator and/or PIC to monitor battery level, GPS signal strength, 

altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has 

failsafe modes of operation for either loss of RC or GPS signal. Altitude can be 

limited by the onboard flight controller and maximum altitude can be preprogrammed 

by the PIC. Battery life limits flight times to approximately 25 minutes. The 

onboard flight controller will warn the pilot via telemetry and external lighting 

cues before reaching a low battery state. An automatic termination of flight and 

landing will be initiated when the battery reaches a predetermined low state. It is 

anticipated that flights will usually last less than 15 minutes. More information 

is available at http://www.dji.com/product/phantom-3/download (file too large to 

attach). 

Risk mitigation 

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and 

Limitations section and believes that the procedures specified therein are 

reasonable and will be utilized in order to manage and mitigate risk and ensure 

public safety. A preflight checklist will be developed and employed to ensure that 

the UA airworthiness will be verified before launch. Airworthiness will be 

maintained by performance of routine inspections before each flight, maintaining 

flight and maintenance logs to record time on failure prone components. These 

documents will be made available to the FAA and SoT to assist in future 

implementation of safety standards and regulations. The petitioner will only 

operate the UAS over designated properties with the owner’s consent. Flight plans 

will be predetermined to limit the UASs flight time and limit safety concerns. The 

petitioner will take into account distance from persons and potential flight 

obstacles prior to operating the UAS. UAS operation will always be within VLOS of 

the PIC and the observer. 

Public interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned 

aircraft of greater proportions, carrying a crew and flammable fuel. Additionally, 

use of the UAS in order to facilitate commerce could lead to economic growth. 

Operations for this petition will enable service for property owners or their 

designees seeking an enhanced perspective for characteristics, amenities, and 

benefits of their desired photographic subjects that cannot be displayed through 

ground level videography/photography. Aerial photography is a valuable marketing 

tool that can lead to increased commerce and enhance personal photography. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric 

estimations and reduce risks. The petitioner will provide clients with photographic 

data for these purposes on a ‘for hire’ basis acting as an independent contractor. A 

visual observer will be utilized. Flight data including UA flight time, Control 

Unit operation time, incident, accident, and details concerning any deviations from 

normal operations will be available to FAA for use in collecting data regarding the 
use of UAS as part of this application. This data may be submitted to FAA via 

traditional means or other means as required. 

Conclusion 

The petitioner is 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 the petitioner wishes 

to utilize a business strategy of horizontal integration and maximize economies of 

scope in order to capitalize on opportunities as they may arise in the future 

without the long turnaround time associated with additional exemptions. The 

petitioner's 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. The petitioner has 

refrained from engaging in commercial use of the UAS. The primary purpose of 

seeking this exemption is to obtain the capability to offer those services while 

remaining in compliance. The petitioner has 10 years of experience in the radio 

control model aircraft hobby. 

Respectfully,

Zachary Z. Truempy