Sport Aviation Center LLC Exemption Request Section 333 Page 1

January 21, 2016

To:

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

Operators Name and address:

Paul Hamilton

Sport Aviation Center LLC 

711 S. Carson Street

Carson City, NV 89701

Phone 775.772.8232

Paul@SportAviationCenter.com

PIC Operators background and experience

Paul Hamilton (FAA pilot # 3051445) holds the FAA ratings of Private Pilot, Flight Instructor 

with a Sport Rating (CFIS), Light Sport Repairman Maintenance (LSRM) and is a Designated 

Pilot Examiner (DPE). He owns and operates an FBO at the Carson City Airport CXP 

specializing in light-sport aircraft (LSA) instruction. He supervises other CFI's teaching Sport 

and Private pilot certificates in LSA. http://sportaviationcenter.com/ 

Additionally, Paul owns and operates a production company specializing in light sport 

instruction training materials including DVD's, book's, CD's and on line training.

http://pilot-stores.com/

This extensive experience with aircraft operations, training and accident free operations will 

enhance the UAS operations in this region and be a great step for overall UAS safety and 

operations in the public interest. 

Paul Hamilton will be directly responsible for all operations of the UAS. 

Any training will be done similar to dual aircraft training where Paul Hamilton CFIS will be 

operating the UAS directly or supervising the student if the control box is handed over to the 

student. The "release and return" command will be used to: 

1. allow the UAS to automatically hover when the controls are released and 

2. hand the controls box back to Paul Hamilton 

This is a "similar" standardized procedure to the manned aircraft controls exchange.
Sport Aviation Center LLC Exemption Request Section 333 Page 2

Proposed Operations

Sport Aviation Center requests a broad range of services including but not limited to UAS 

flight training, GA/UAS education, photography, videography, surveys, inspections, 

search/rescue and/or demonstration flights.

• All operations will comply with current local, state and federal requirements and 

regulations.

• All operations will follow the current UAS manufacturer's checklists, maintenance 

procedures, operating limitations and operational procedures (provided below).

• All operations will be similar to manned aircraft with TFR, NOTAMS. Currently use 

Foreflight and the new FAA service B4UFLY will be used additionally for UAS 

operations.

• All operations will comply with Title 14 CFR Part 91 same as manned operations for 

compliance and safety.

• All operations will exercise common sense with safety as number one priority. 

• All operations will comply with operating limitations as specified in the FAA 333 

Exemption and a COA.

• All operations would comply and stay up to date with the FAA

requirements/regulations at http://www.faa.gov/uas/

Make, Model and Description of UAS

Make - DJI, Model - Phantom 3 Advanced. Weigh with battery, camera and propellers 2.8 

pounds. Diagonal size including propellers 23.2 inches. Max speed approx 33MPH.

This is a modern state of the art UAS with GPS and optical assisted hover with "hands off the 

controls" and one button return to home. The intelligent battery and integrated software 

automatically returns to the UAV home when the battery gets to 25% capacity. Control panel 

has a visual display of what the camera sees plus a map of where the UAS is compared to 

the controller and overall position.

This UAS has a built- in capability to limit the height it flies above the ground, to limit the 

radius of the distance it flies from the operator and to exclude it from Class B, C and D 

airspace including a no fly zone feature. The Phantom 3 Advanced has the failsafe function of 

the autopilot system, which means when the communication between the Main Controller and 

the transmitter is disconnected, the outputs of all command sticks from controller will go to 

the center position. If the GPS signal is good enough, the system will automatically trigger 

Return to Home and will land safely. Overall, this UAS has numerous safety features which 

add UAS safety and operations in the public interest.

To not duplicate current information that can change and update over time, see

http://www.dji.com/product/phantom-3-adv for basic information on the UAS and 

http://www.dji.com/product/phantom-3-adv/info#downloads for the current flight manual 

which will be used for the up dated manufacturer's checklists, maintenance procedures, 

operating limitations, operational procedures and specific UAS specifications.
Sport Aviation Center LLC Exemption Request Section 333 Page 3

Specific applicable regulations from which relief is required (CFRs);

The petitioner requests relief from the following regulations from which the exemption is 

requested: 

14 C.F.R. § 91.109 (a) Flight Instruction

For UAS flight instruction, dual controls is not needed because the default hands off is the 

hover mode or the return to home can be used while the single control box is exchanged 

between the instructor and the UAS student similar to the controls exchange process for flight 

instruction in manned aircraft which provides an equivalent level of safety for dual controls 

during instruction.

14 C.F.R. § 91.119 Minimum safe altitudes

Since the typical maximum altitude is 400 feet AGL for UAS, the UAS will operate at lower 

altitudes and therefore relief from minimum safe altitudes is requested. Any flight will be 

conducted without undue hazard to persons or property on the surface providing an 

equivalent level of safety.

14 C.F.R. § 91.121 Altimeter Settings

UAS does not have a barometric altimeter, but rather GPS altitude and an optical AGL 

sensor. Therefore, and equivalent level of safety will be provided with the calculated GPS 

MSL/AGL with the GPS and optical sensors.

14 C.F.R. § 91.151 Fuel Requirements for flights in VFR conditions

The batteries powering Sport Aviation Center LLC’s Phantom 3 UAS’s provide approximately 

23 minutes of powered flight. Therefore, it cannot meet 30 minutes reserve fuel requirement. 

However, the limitations of the UAS's flight area to line of site plus a built in 25% battery 

capacity "return to home" safety feature in the software provide equivalent safety margin 

based on a reserve amount of battery life. This safety feature is more than adequate to return 

the UAS safely to its planned landing zone even in the event of a headwind or an unexpected 

occurrence. 

14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b) Maintenance, Inspection 

and Record Keeping

These regulations refer to Part 43 which only apply to aircraft with an airworthiness 

certificate, which the UAS does not have. An equivalent level of safety will be achieved 

because maintenance and inspections will be performed in accordance with FAA, NTSB, and 

AFS-80 best practices. The operator will ensure that the UAS is in working order prior to 

initiating flight, perform required maintenance, and keep a log of any maintenance performed. 

If mechanical issues arise, the UAS's simplicity for maintenance, and the fact that flight 

operations will only take place close proximity areas for limited periods of time during daylight 

hours, creates less risk than that associated with conventional manned aircraft.
Sport Aviation Center LLC Exemption Request Section 333 Page 4

Summary

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft 

running on combustible fuel, it operates at lower altitudes with no people on board and will 

thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of 

death or serious bodily injury. With a small payload and maximum flight time of only 23

minutes, this offers little or no risk to national security and provides safety and operations in 

the public interest. 

Sport Aviation Center LLC’s singular vision is to enhance safety of UAS operations in the NAS 

while reducing risk to the general public and property owners.

The DJI UAS, weighing less than 25 pounds and powered by batteries, eliminates virtually all 

of that risk given the reduced mass and lack of combustible fuel carried on bard. The UAS is 

transported to the designated mission area and set up there. The UAS will carry no 

passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights.

The operation of this small UAS will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including exempting the applicant from the requirements

of several regulations and allowing commercial operations. These lightweight UAS’s operate

at slow speeds, close to the ground, and in a sterile environment. As a result, they are far 

safer than conventional operations conducted with fixed wing aircraft or helicopters.

If additional information is required, or if you have any questions regarding this Petition for 

Exemption, please contact the undersigned at:

With Best Regards, 

Paul Hamilton CFI, DPE, LSRM

Sport Aviation Center LLC

Phone (775) 772-8232

Paul@SportAviationCenter.com