1 November 2015

David G. Iadevaia

N Avenida Silencioso

Tucson, AZ 85750

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590

Re: Petition for Exemption Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from: 14 CFR 61.57 - Recent flight experience: Pilot in command

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act ) and 14 CFR Part 

11, David G. Iadevaia (Petitioner) hereby applies for an exemption from the listed Federal Aviation 

Regulations (FAR) to allow commercial operation of a designated unmanned aerial system (UAS), provided 

such operations are conducted within the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

David G Iadevaia (PIC) seeks the requested exemptions to permit him to fly, as PIC, UAS such as the

Phantom 3 Pro.

I hold a PP airman certificate ASEL and I am a former aircraft owner with 1000 hours logged.

As described in the following pages, the requested exemption would permit the operation of the designated 

type of UAS as set forth in this document under controlled conditions in the National Airspace System (NAS) 

that would be operated safely. Approval of this exemption would provide services that would reduce the 

risk associated with manned solutions, in both flight and other methods of completion of the proposed 

services.

The name and address of the Petitioner is as follows:

David G. Iadevaia

5700 N Avenida Silencioso

Tucson, AZ 85750

520-577-3783

Airman Cert #2898117

E-mail: apiaz123@yahoo.com
Granting an Exemption Would Serve the Public Interest and Maintain Flight Safety

In the absence of a UAS, many of the proposed activities would have to be carried out by a helicopter, fixed wing 

aircraft, a bucket truck, or a lineman climbing a tower. All of these conventional methods involve a risk to 

human lives and property that is clearly higher than risks to human lives and property posed by the utilization of 

UAS.

There are many experienced pilots who could be available to safely fly UAS in the NAS if not for the inconsistent flight 

review required to fly a ASEL which is not applicable to the flight of the type of UAS described here.

The flight training part of the review is intended to be sufficient to demonstrate to the reviewer that the pilot is able to 

safely exercise the privileges of his or her certificate however the requirement for the PIC of the type of UAS is 

inconsistent with the Flight Review specified in 14 CFR 61.57 - Recent flight experience: Pilot in command because 

there is no type or rating specified in the airman certificate that describes a UAS.

 The flight experience in a UAS of the type described here has been accrued and logged at approximately 100 hours by

the petitioner with a perfect safety record.

The petitioner realizes that ground instruction is still required to maintain a body of knowledge consistent with the 

airman’s responsibilities regarding flight in the NAS and safe practices and as such the petitioner participates in the 

FAA Wings safety program.

Further the UAS does not carry passengers.

The institution of the Biennial Flight Review in 1974 was to enhance air flight safety. The exemption requested

is consistent with enhanced flight safety as it applies to the flight of UAS by a certified airman however the Fight 

Review as specified in 14 CFR 61.57 - Recent flight experience: Pilot in command does nothing to improve safety of a 

UAS PIC of the type of UA described here.

UAS utilization in accordance with the typical terms of an exemption grant does not require the interaction 

of Air Traffic Control (ATC). Where such use replaces manned aircraft, a net reduction in ATC burden is realized.
OPERATIONAL LIMITATIONS TO ACHIEVE AN EQUIVALENT LEVEL OF

SAFETY

I propose the following operational limitations to achieve an equivalent or higher level of safety than

under the current regulatory structure, particularly in comparison to the use of manned aircraft.

1. All operations will be carried out with strict adherence to the operating procedures outlined in the

Pilot s Operating Handbook (POH) contained in the manufacturer s user manual (Attachment A)

The POH includes the following:

a. General description, specifications, and warnings

b. Limitations

c. Emergency Procedures

d. Normal Procedures

e. Performance

f. Weight and Balance/Equipment List

g. Air Vehicle and Systems Description

h. Handling, Service, and Maintenance

i. Supplements

2. The UA will weigh less than 2.8lbs.

3. The UA, will operate at a true airspeed maximum (VNE) of 15 m/s (approximately 30 knots)

which is within manufacturer specifications.

4. Minimum crew for each operation will consist of the UA Designated Pilot in Command (PIC) 

and at least one Visual Observer (VO). I and the VO will be able to communicate verbally at 

all times during the flight and will not exchange roles during the flight. Electronic messaging or 

texting is not permitted during flight operations. I will ensure that the VO can perform the 

required duties of the VO.
5. I will hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate and a current FAA airman medical certificate or a valid U.S. driver s license issued by

a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

Government.

6. Flights will be operated within visual line of sight (VLOS) of the PIC and VO at all times. API

understands that definition of VLOS is human vision unaided by any device other than corrective

lenses.

7. The primary responsibility of the VO will be to enhance the safety of flight operations by verbally 

communicating potentially unsafe observations to the PIC. Such conditions may include, but are 

not limited to, conflicting aircraft, hazardous terrain, features, or weather, UA approaching VLOS 

limits or altitude limits, assisting the PIC in monitoring battery voltage, and advising the PIC if 

non-participating personnel move within a potential danger zone. VO s will be familiar with the 

UAS normal and emergency procedures and aircraft limitations in sufficient detail as to provide 

the PIC with recommended corrective actions.

8. Maximum flight time for each operational flight will be approximately 20 minutes. The actual

flight time will depend on a variety of variables including wind conditions, sensor payload,

mission requirements, and the choice of battery capacity. All flights will be conducted under a strict 

battery management regime that alerts the operator to end flight at a pre-determined battery capacity. If 

the PIC exceeds this limit, the P3Pro will autonomously return to the departure point and land upon 

reaching the first critical battery level (first alert) and will land immediately upon reading the second 

critical battery level (second alert).

9. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL).

10. All operating documents will be accessible to the PIC at the ground control station during UAS

operations. Operating documents will include the current POH and a copy of the FAA s

Exemption, if granted. If a discrepancy exists between the various operating documents, the

FAA s Exemption, the Exemption will take precedence. The POH will be updated as necessary. Such 

updates will be tracked.

11. A safety briefing will be performed prior to each day’s flights consisting of all the day’s flight 

operations. All parties involved in the flight operations will participate in the safety briefing.

12. The PIC will conduct a pre-flight inspection for the UAS. The pre-flight inspection will account 

for all systems to insure that the UAS is in a condition for a safe flight. As a minimum, the preflight inspection will follow the checklist procedures in the POH. If the pre-flight inspection

reveals a condition that may affect the safe operation of the UAS, the aircraft will not be operated until 

necessary maintenance has been completed.

13. In the event of an emergency or other unpredicted obstacle to the completion of a flight, the PIC 

will abort the flight in the safest manner possible.

14. I will follow normal and emergency procedures and maintaining appropriate

distances from persons, vessels, vehicles and structures. My flight hours and

currency will be logged in a manner consistent with 14 CFR ß61.51(b).

15. I and VO will have been trained in operation of UAS and receive current information 

regarding operation of the UA.
16. PIC and VO training and evaluation flights will only be conducted during dedicated training 

sessions. During such sessions, the PIC will operate the UA a manner consistent with 14 CFR

ß91.119 by maintaining the prescribed distance from non-participants.

17. All DJI P3Pro and types similar to aircraft utilized as a part of this request will be registered 

assigned a serial number in accordance with 14 CFR part 47 and display identification markings 

in accordance with 14 CFR part 45, subpart C. N-number markings will be as large as practicable.

18. I will conduct routine inspections of the UA to ensure that it is in condition for safe operation.

As a minimum, inspections will be conducted as per the POH and as per manufacturer

recommendations. Additional inspections will be completed as deemed necessary. API will

comply with all safety bulletins issued by the manufacturer.

19. I will conduct maintenance on the UA as necessary. Maintenance procedures will follow

manufacturer s recommendations regarding replacement, overhaul, and life limited components.

20. After maintenance or alterations that affect the operational or flight characteristics of the UA, a 

test flight will be conducted to determine that the UA is properly functioning prior to resuming 

commercial operations. Flight tests will be conducted by a PIC and a VO and will remain at least 

500 feet from other non-participants. Further, the flight test will be conducted in a manner so as 

not to pose an undue hazard to persons and property.

21. I will also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic 

Organization (ATO) prior to conducting operations within the NAS.

22. No UA flights will be conducted at night and all flights will occur under Visual Meteorological 

Conditions (VMC). The UA will not be operated less than 2,000 feet horizontally from a cloud or 

when the visibility is less than 3 statute miles from the PIC.

23. I will ensure that the UA remains clear of and gives right-of-way to all manned aviation 

operations.

24. I will not operate the UA from a moving device or vehicle.

25. The UA will not be operated within 5 nautical miles of an airport reference point (ARP) unless a 

letter of agreement with that airport s management is obtained or it is otherwise permitted by a 

COA issued to API .

26. The UA will be operated in a manner that maintains at least a 500 foot clearance from all nonparticipating persons, vessels, vehicles and structures except in the case of the following

conditions:

a. Barriers are present to protect non-participating persons in the event of an accident. API

will ensure that non-participating persons utilize these protective barriers. If a nonparticipating person leaves a barrier and is within 500 feet of the UA, flight operations will 

be terminated in a manner that ensures the safety of non-participating persons.

b. The owner or controller of any vessels, vehicles, or structures has granted permission to

operate closer than 500 feet to those obstacles and the PIC has completed a safety

assessment of the proposed operation and determined that the operation could be

completed safely.

27. Flight operations will only be conducted over property where the permission is granted by the

property owner or otherwise authorized representative.

28. The P3Pro or type UAS automatically determines its failsafe return-to-home position upon liftoff. If

the UAS loses communications with the remote controller, it will return to a liftoff location and land autonomously.
29. I will report any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA to the FAA's UAS Integration 

Office (AFS−80) within 24 hours. Accidents will be reported to the National Transportation Safety 

Board (NTSB).

CLOSING

I appreciate the opportunity to submit this petition for exemption to the 

Federal Aviation Administration. I have endeavored to provide the appropriate information required based 

on guidance from the FAA s website. If there are any questions or if I can provide further information

please contact me.

Signed

David G. Iadevaia