**Submitted by:** Donald R. Fritz 13342 Partridge Hill San Antonio, Texas 78247 (210) 831

-3436 donnyfritz@satx.rr.com **Scope:** Donald R. Fritz is petitioning to use the Phantom 3 Unmanned Aircraft System for multiple services, to include :

- Aerial surveying of local land and possible commercial building sites for the community

- Event Photography/Videography

- Agriculture and Livestock monitoring

- Real Estate Photography and presentation

- Aerial filmmaking and photography

- Construction site inspections an d monitoring **UAV Phantom 3:** The DJI Phantom 3 is a quad

- rotor Unmanned Aircraft System (UAS) The DJI Phantom 3 has:

 A maximum gross weight of approximately 2 pounds 11 ounces
 A length of 16 inches width of 16 inches
 Height of 8 inches
 Maximum speed of a pproximately 29 knots.
 Equipped with four main rotors; driven by Lithium Polymer battery powered electric motors  Return Home Feature (Built in Safety) The DJI Phantom 3 that will be operated by Donald R. Fritz will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Markings. The Phantom 3 UAS that Donald R. Fritz will be responsible for also util izes a mobile ground station. The UAS features a safety Return to Home function that in the event of a signal loss, the UAS will return to a preset position and land. The Return to Home feature can also be triggered manually. The remote connects to your phone or tablet, and a 1080 p HD view of everything your camera sees as you fly is displayed live. This immersive view streams to you in absolute clarity, enabling safe flying. From takeoff to landing, the Phantom 3 responds to commands while automatical ly handling the most complex aspects of a safe and stable flight.The DJI Phantom 3 transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation. The DJI Phantom 3 radio transmitter used for controlling the sUAS is wireless technology which has been tested and foun d to be compliant with the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz frequency range. **Request:** Donald R. Fritz seeks an exemption to operate DJI systems for compensation or hire within the US . The DJI Phantom 3 quad

- rotors are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA). These UAS’s use a Ground Control Station (GCS), displayed on an electronic tablet or smartphone. **Petition:** Donald R. Fritz requests an exemption from: 14 CFR 61.23(a) and(c) 14 CFR 61.101(e)(4) and (5) 14 CFR 61.113(a) 14 CFR 61.315(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 91.151(a)(1) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2) 14 CFR 91.417 (a) an d (b) to the extent necessary to allow the petitioner to operate the DJI Phantom 3 Professional UAS to perform aerial video and photographic collection. **The Extent**  **of Relief that**  **Donald R. Fritz seeks**  **:** 1. Extent of Relief that Donald R. Fritz seeks regarding Section 61.113 (a) and (b) Private Pilot Privileges and Limitations Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in Command holding a current Private Pilots Certificate to operate the Donald R. Fritz’s Phantom 3. The flight wou ld be complimented by a Visual Observer who, along with the pilot, will maintain Visual Line of Sight with the Phantom 3 at all times. All operations conducted will be incidental to Donald Fritz’s business. The Phantom 3 is not able to carry passengers. 2 . Extent of Relief that Donald R. Fritz seeks in regards to Section 91.7(a) Civil Aircraft Airworthiness Relief from Section 91.7(a) is requested to allow Donald R. Fritz to determine airworthiness of the Phantom 3. As part of this determination the following will be adhered to: **a** . Prior to the Phantom 3's flight the PIC will inspect the UA to ensure it is in a condition that will be conducive for a safe flight. The ground control station will be included in the above inspection. **b**

. Donald R. Fritz wi ll follow the DJI Phantom 3’s aircraft/component, maintenance, overhaul, replacement, inspection and life limit requirements. **c** . Donald R. Fritz will comply with all DJI manufacturer Safety Bulletins. 3. Extent of Relief that Donald R. Fritz seeks in regards to Section 91.119 Minimum Safe Altitudes General relief from 91.119 is requested to allow Donald R. Fritz to operate the Phantom 3 at altitudes not to exceed 400’ AGL over private property at a distance at or greater than 5NM from the nearest airpo rt as depicted on current Aeronautical Charts. Donald R. Fritzalso wishes to be granted exemption to operate at an altitude not greater than 50’ AGL (below tree level) between 1NM and 5NM from the nearest airport as depicted on current Aeronautical Charts. Donald R. Fritz will adhere to the following in order to maintain an acceptable level of safety associated with operations over private property: **(a)** Donald R. Fritz will display signs in the immediate vicinity of operations stating: “Aerial Photogra phy In Progress. Use Caution.” **(b)** Donald R. Fritz will not allow the Phantom 3 to operate at a speed greater than 20kts. **(c)** Donald R. Fritz will require the UAS operator (PIC) to be fully trained on the Phantom 3 by adhering to the recommendations contained within the Phantom 3’s operating manual. **(d)** Donald R. Fritz will have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), a minimum of 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. In addition the operator will have logged a minimum of 5 hours as a UAS pilot operating the make and model UAS that Flying Donald R. Fritz operates. **(e)** Donald R. Fritz will be familiar with and able to manually institute the Phantom 3’s Return to Home (RTH) feature. This feature aborts a flight operation and automatically returns the UAS to a predetermined GPS safe point. **(f)** Donald R. Fritz will not operate over private property without first finding a suitable alternate land ing spot on the property. (g) Donald R. Fritz will abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. **(h)** Donald R. Fritz will utilize a two man flight team consisting of the Pilot in Command ( PIC) and a Visual Observer (VO). This team will maintain visual line of sight with the Phantom 3 at all times and remain within hearing of one another. **(i)** Donald R. Fritz will not permit flight around vessels, vehicles and structures without permission from the owner. 4. Extent of Relief that Donald R. Fritz seeks in regards to Section 91.121 Altimeter Settings Relief from 91.121 is requested because the Phantom 3 utilizes electronic GPS with a barometric sensor. In order to maintain an equal level of safety that 91.121 requires, the PIC of the Donald R. Fritz UAS will abort the flight in the events that the UA loses communications with the GPS signal. 5. Extent of Relief that Donald R. Fritz seeks in regards to Section 91.151(b) Fuel Requirements for Flight in VFR Conditions Relief from 91.151(b) is requested to the extent that allows Donald R. Fritz to operate the Phantom 3 up to a point (considering wind and forecast weather conditions) that there is enough powe r to fly at normal cruising speed to the intended landing point and land the UA with 30% battery power remaining. 6. Extent of Relief that Donald R. Fritz seeks in regards to Sections 91.405(a), 91.407(a)(1), 91.409(a)(1), and (a)(2), 91.417(a) and (b) Th ese are all associated a with Airworthiness certificate Relief from 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and (b) is requested tothe extent that allows Donald R. Fritz to operate the Phantom 3 Quad

-Copter as necessary. These sections are all related to airworthiness certificates of aircraft. There is not currently an airworthiness certificate for small UAS’s. Donald R. Fritz would comply in full to any conditions and limitations that the Administrator would place in order to receive an approved Grant of Exemption. **Public Interest:** Aerial videography and photography has been around for a long time through manned fixed wing aircraft and helicopters, but for small business owners, its expense has been cost

prohibitive. Granting this exemption to me would allow me to provide this service at a much lower cost. My UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to manned aircraft. The operation of my UAS will minimize ecological damage and promote economic growth by providing information to companies looking to relocate or build in the San Antonio, Texas area. **Conclusion:** As set forth herein, Donald R. Fritz seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernizatio n and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 UAS commercially. The Administrator will be assisting small business by granting this petition. In accordance with the FAA Modernization and Reform Act of 2012, Donald R. Fritz respectfully requests that the FAA Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b) Thank you in advanced for your consideration, Donald R. Fritz donnyfritz@satx.rr.com (210) 831

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