Christopher M. Revnew Aug. 25, 2015 

805 Sun Ridge Lane

Chagrin Falls, Ohio 44022

Cell (440) 523-8677

Email: crevnew@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: These attachments are too large for submission via the submission portal. 

They are available at this website for viewing or download. 

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

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

1) Phantom 3 Professional User Manual 

2) Phantom 3 Professional Quick Start Guide 

3) Phantom 3 Safety Guidelines and Disclaimer

 4) Inspire 1 Disclaimer and Warning 

 5) Inspire 1 Quick Start Guide 

 6) Inspire 1 User Manual 

 7) Inspire 1 Safety Guidelines 

References: 

 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481in 

the matter of the petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in 

the matter of the petition of ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355in 

 the matter of the petition of FLYING CAM INC

To whom it may concern,

 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, Christopher M. 

Revnew, 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);
 The Petitioner requests permission 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, mapping, 

inspections and other flight operations. Such Operations 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, including but not limited to, Piston 

and Turbine Helicopters, Piston Single and Double 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 13.

Public interest

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

environmental impact, in addition to added cost effectiveness 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 thoroughly from 

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

tool that can lead to increased commerce and enhance personal photography in a vast 

array of markets including real estate. 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, e.g. COA Monthly Reports, or other means as 

required.

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 pilots for compensation or hire. Any pilots operating under this exemption would be 

required to comply with any conditions as set forth and in a similar fashion to the 

previously granted exemptions.
91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated 

closer than 500 feet to essential persons, or objects that would not be possible without 

additional relief. The petitioner requests modification, waiver or exemption and 

clarification concerning the terms “congested areas” and “densely populated”. The 

petitioner requests waiver for this condition to allow reasonable and responsible 

operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable 

since the UAS does not have an altimeter and instead utilizes electronic GPS with a 

barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION 

SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less 

than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In 

addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808, 

and 10673 for daytime, VFR conditions. 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 (20%). 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) As discussed in 

Exemption 11138 (DOUGLAS TRUDEAU), 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 Professional plus is a recently released successor to the DJI 

Phantom 2 series, a consumer grade small rotorcraft in the quadcopter configuration 

with an advertised weight of less than 46 Ounces (1280g) designed primarily to carry 

aloft a high definition camera. It has an advertised maximum speed of less than 32 

knots (16m/s) and a maximum climb rate of less than 1000 feet per minute (5 m/s). It is 

powered by four electric motors with a distance between motors of less than 12 inches 

(289.5mm) 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. The PIC has control over 

camera angle to provide appropriate visual guidelines. It has failsafe modes of operation 

for either loss of RC or GPS signal. The onboard flight controller can limit altitude and 

maximum altitude can be preprogrammed by the PIC. Battery life limits flight times to 

approximately 23 minutes. The onboard flight controller will warn the PIC 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 

of 20% battery life. It is anticipated that flights will usually last less than 10 minutes. 

More information is available at http://www.dji.com/product/phantom3

 The DJI Inspire 1 is a consumer grade small rotorcraft in the quadcopter 

configuration. With an advertised weight of 2935g designed to carry a primary payload 

of a high definition camera. It is advertised as a maximum speed of 22m/s and a 

maximum climb rate of 5m/s. It is powered by four electric motors with a distance 

between motors of less than 581mm. It utilized an internal measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to 

maintain is 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 station allowing the operator and/or PIC to monitor battery level, GPS 

signal strength, altitude (AGL), distance from PIC, camera imagery. The PIC has control 

over camera angle to provide appropriate visual guidelines. It Has failsafe modes of 

operation for either loss of RC or GPS signal. The onboard flight controller can limit 

altitude and maximum altitude can be preprogrammed by the PIC. Battery Life limits 

flight times to approximately 18 minutes. The onboard flight controller will warn the PIC 

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 of 20% battery life. It is anticipated that flights will usually last 

less than 10 minutes. More information is available at http://www.dji.com/product/

inspire-1

Risk mitigation

 The petitioner has reviewed FAA exemptions reference’s 13 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.

 

The petitioner request that in a manner similar to reference 3, he be allowed to 

operate within 5 miles of an airport provided that;

“The UA may not operate in Class B, C, or D airspace without written approval 

from the FAA. The UA may not operate within 5 nautical miles of the geographic 

center of a non towered airport as denoted on a current FAA published 
aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport 

 management must be made available to the Administrator upon request.”

Operations within 5 miles of an airport are not anticipated to be routine but the 

petitioner is requesting a mechanism to facilitate such activities without requesting a 

new and separate exemption(s) should the need arise. Operations within class B 

airspace are not requested due to the lack of mode C transponder. 

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial 

photography, cinematography, videography, mapping, 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’s own 

market research shows pent up demand for these services currently exists in the real 

estate market and other markets are just beginning to emerge. 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.

 

Respectfully submitted, 

 

 Christopher M. Revnew