Coast 2 Coast Aerial Imaging

Owner: Matthew Peterson

2207 Camryn’s Xing

Panama City, FL 32405

Ref: Exemption Request Section 333 of the FAA Reform Act 

Dear Sir or Madam:

Pursuant to section 333 of the FAA Modernization and Reform Act of 2012 (The 

Reform Act) and 14 CFR Part 11, Coast 2 Coast Aerila Imaging (Matthew 

Peterson), Owner of an Unmanned Aircraft System (UAS), Hereby applies for an 

exemption from the listed Federal Aviation Regulations (FARs) to allow Coast 2 

Coast Aerial Imaging to legally operate its DJI Phantom 3 UAS, 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 proposed exemption would allow Coast 2 Coast Aerial Imaging to operate a 

small UAS under controlled conditions in FAA regulated airspace that is 1) limited 

2) predetermined 3) controlled, for purposes of unmanned aerial photography 

and videography. If the exemption is granted, Coast 2 Coast Aerial Imaging will 

conduct commercial UAS flights following all conditions set forth by the FAA 

Section 333 with emphasis on safety and operational requirements. 

Proposed Operations of Coast 2 Coast Aerial Imaging UAS

• Real Estate Photography 

• Golf Course Photography 

• Commercial Property Construction 

• Aerial Inspection 

• Special Events

Coast 2 Coast Aerial Imaging will follow all FAA UAS Safety Operating 

Guidelines including but not limited to the following. 

● The UAS will operate no more than 200 feet above ground level and 

within a radius of 1000 feet of Pilot in Command (PIC) and will not exceed 

35mph. 

● Operations will only occur during daytime conditions abiding by Visual 

Flight Rules (VFR) within Visual line of sight (VLOS) of the UAS pilots at 

all times. 

● Obtain permission from the owner or representative of the owner to 

conduct operations 

○ If operations occur within 500 feet of any vessel, vehicle, or 

structure, a safety assessment will be conducted. 

● Flight times will be limited to 10-15 minutes per flight. Allowing 

25% of total battery battery to be used to safely land the UAS. This 

exceeds the manufacturer's recommended minimum battery level 
parameters for “return to home” function. 

● DJI Phantom 3 utilizes Global Positioning System (GPS), which 

will automatically land (return to home) the UAS in any cases where 

Communication between PIC and craft is lost or the battery levels reach a 

critical level.

● DJI Phantom 3 also has “return to home” button on controller. 

● Contact Airports if operations are within a 5 mile radius. Advise 

Airports of all pertinent information including but not limited to: time of 

flight, flight duration, elevation of flight. 

● Only operate UAS in safe weather conditions. Unsafe conditions 

include, but are not limited to high wind, poor visibility, low clouds or any 

conditions that may cause the pilot to lose VLOS or control of the 

UAS.This will be achieved by: 

○ Obtaining and reviewing weather reports prior to flight 

○ Procedures for a mid-flight abort in cases where weather 

or other factors cause conditions to become unsafe or dangerous. 

● Only operate in controlled environment 

○ Will have procedures in place to identify and avoid any hazardous 

areas such as power lines, street lights, trees, airports, densely 

populated areas (yellow areas on VFR charts) 

o Will have procedures in place to abort flights that have safety 

breaches or dangerous issues. 

○ Will always operate UAS with 2 people, with a designated “visual 

observer (VO)” who will also keep constant Visual Contact with 

UAS along with PIC. 

○ Will have policies that will clear the operational flight area of any 

non-essential personnel. 

● We will conduct extensive preflight inspections on the UAS, 

utilizing procedures that will check integrity of all operational parts 

including but not limited to: propellers, aircraft antenna, aircraft LED lights, 

remote buttons, control sticks, signal strength between craft and remote,

signal strength of GPS, battery strength. 

● We will follow guidelines of 14 CFR 61.51(b) along with our own 

safety operation procedures. 

○ The PIC will have a minimum of 6 hours logged operating 

the craft before commercial use, along with over 10 hours operating 

UAS quadcopters in various conditions and environments. 

○ With emphasis on safety, we will have training procedures 

that include emergency landing, evasive maneuvers and other 

possible dangerous scenarios such as yielding the right away to 

any airplane or helicopter that comes within 5 miles of the operating 

UAS.

REGULATIONS FROM WHICH AN EXEMPTION IS REQUESTED: 

14 CFR 21 subpart H; 14 CFR 45.23(b); 14CFR 45.29; 14 CFR 61.113(a) and 
(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14 

CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a) and (b); 

14 CFR 91.405(a); 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2); 14 CFR 

91.417(a) and (b)

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) 

(1) Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as 

required by FAR 91.203 (a) (1 ).

Given the size and limited operating area associated UAS, an exemption from 

Part 21 Subpart H meets the requirements of an equivalent level of safety under 

Part 11 and 333 of the Reform Act. Federal Aviation Act (49 U.S.C.4470 1 (f)) 

and 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated 

areas of the particular UAS.In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, 

or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions of proposed UAS 

operations. 

The UAS to be operated by Coast 2 Coast Aerial Imaging is less than 55lbs. 

Fully loaded, carries neither pilot, nor passengers, carries no explosive or 

flammable materials including combustible fuels, and operates exclusively within 

a secured area. Unlike other civil aircraft, operations under this exemption will be 

controlled and monitored by both the pilot (PIC) and “visual observer(VO)” as a 

secondary monitor for safety issues, and a technician, which assists in matters 

related to maintaining the UAS and also monitors for safety concerns. These 

enhancements to current safety practices and regulations, which already apply to 

civil aircraft, provide a greater degree of safety to the public and property owners 

than conventional aircraft operations conducted with airworthiness certificates 

issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same 

criteria demonstrates that there is no intrinsic credible threat to national security 

posed by the UAS, due to its size, speed of operation, location of operation, lack 

of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.

14 CFR 45.23(b) Display of marks; general and 45.29 Size of marks 

These regulations provide that each aircraft must display "N" and the aircraft's 

registration number in letters at least 3 inches high. Additionally, the aircraft must 

display the word "EXPERIMENTAL" in letters at least 2 inches high near the 

entrance to the cabin, cockpit, or pilot station. The UAS does not have an 

entrance in which the word "EXPERIMENTAL" can be placed. We propose an 

equivalent level of safety by including the word "EXPERIMENTAL" on the top 

and bottom of the aircraft, where the PIC (Pilot In Control), VO (Visual Observer) 

and others in the vicinity of the aircraft while it is preparing for launch will be able 

to see the designation. We will display at the ground station a high contrast flag 
or banner that contains the words "Unmanned Aircraft Ground Station" in letters 

4 inches high or greater. The banner will be visible to anyone that observes the 

aircraft and chooses to investigate its point of origin.

14 CFR 61.113(a) Private Pilot Privileges and Limitations: Pilot in Command

Coast 2 Coast Aerial Imaging requests an exemption from the private pilot 

privileges and limitations of 61.113 (a) & (b): Private Pilot Privileges and 

Limitations: The regulation provides that no person that holds a Private Pilot 

certificate may act as pilot in Command of an aircraft for compensation or hire. 

Subparagraph (b) allows a private pilot to act as pilot in command of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to 

that business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. The UAS aircraft cannot carry passengers or 

property, therefore an exemption is needed.

14 CFR 91.7(a) Civil Aircraft Worthiness 

Coast 2 Coast Aerial Imaging requests an exemption from 91.7(a) which 

prohibits the operation of an aircraft without an airworthiness certificate, since 

there is currently no certificate applicable to our operation, this regulation is 

inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements. 

Coast 2 Coast Aerial Imaging requests an exemption from 91.9(b)(2) which 

requires an aircraft flight manual in the aircraft, however since there are no pilots 

or passengers on board the aircraft and given its size, this regulation is 

inapplicable. We believe an equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the UAS ground station.

14 CFR 91.103 PIC to become familiar with specific information before each 

flight 

Coast 2 Coast Aerial Imaging requests an exemption from 91.103, which 

requires a PIC to become familiar with specific information before each flight, 

including information contained in the FAA approved Flight Manual on board the 

aircraft. As an FAA approved flight manual will not be provided for the UAS, an 

exemption will be needed. 

The equivalent Level of Safety will be achieved by following the DJI 

manufactures aircraft manual with comprehensive preflight checklist. Other 

comprehensive preflight information gathering and interpreting will be done by 

the PIC utilizing weather reports, web based mapping (Google earth) battery 

requirements, determining safe takeoff and landing areas. All pertinent 

information will be gathered and interpreted by PIC before any flights.

14 CFR 91.109 Flight Instruction 

Coast 2 Coast Aerial Imaging requests an exemption from the 14 CFR 91.109(a) 

which provides that person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully UAS 

and remotely piloted aircraft, by their design do not have fully functional dual 
controls. The control box communicates with the UAS through radio 

communications. 

Equal levels of safety will be achieved based on the size and speed of UAS an 

equal level of safe training can be achieved without the “dual controls”because 

the UAS is unmanned and all essential personnel will be a safe distance away in 

the event of difficulties during the flight.

14 CFR 91.119 Minimum safe altitudes 

Coast 2 Coast Aerial Imaging requests an exemption from the minimum safe 

altitude requirements of 14 CFR 91.119. Section 91.119 prescribes the minimum 

safe altitudes under which aircraft may not operate, including 500 feet above the 

surface and away from any person, vessel, vehicle, or structure in non-congested 

areas. See 14 CFR 91.119(c). Section 91.119(d)(1) allows for a hazard to 

persons helicopter complies with any routes or altitudes specifically prescribed 

for helicopters.

14 CFR 91.121 Maintain cruising altitude or flight level by reference to an

altimeter 

Coast 2 Coast Aerial Imaging requests an exemption from 14 CFR 91.121, which 

requires a person operating an aircraft to maintain cruising altitude or flight level 

by reference to an altimeter that is set to the elevation of the departure airport or 

barometric pressure. An exemption is required because the UAS does not have a 

barometric altimeter, but the Phantom 3 software has a GPS altitude meter 

display. PIC will use display to constantly monitor altitude during the flight.

14 CFR 91.151(a) Fuel requirements for flight in VFR conditions

Coast 2 Coast Aerial Imaging requests an exemption from 14 CFR 91.151(a) fuel 

requirements for flight in VFR conditions. Section 91.151 states: (a) No person 

may begin a flight in an airplane under VFR conditions unless (considering wind 

and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed (1) During the day, to fly 

after that for at least 30 minutes or (2) At night, to fly after that for at least 45 

minutes. The battery powering the Phantom 3 UAS provides approximately 20 

minutes of powered flight. An exemption from the 30 minute reserve requirement 

in 14 CFR 91.151 is therefore required. Equal levels of safety can be achieved by 

limiting flight times to approximately 10-15 minutes or until 25% of battery life 

remains , whichever comes first. This is more than enough battery power to 

achieve a safe landing.

14 CFR 91.405(a); 91.407(a)(1); 91.409(a)(2); 91.417(a)&(b) Maintenance and 

inspection standards in reference to 14 C.F.R. Part 43.

Coast 2 Coast Aerial Imaging requests exemptions from these regulations 

because Part 43 and these sections apply only to aircraft with an airworthiness 

certificate, which the UAS will not have. Coast 2 Coast Aerial Imaging will 

achieve an equivalent level of safety because maintenance and inspections will 

be performed in accordance with the DJI Phantom 3 Aircraft Operations Manual. 
The operator will ensure that the UAS is in working order prior to initiating flight, 

perform all required maintenance, and keep a comprehensive log of any 

maintenance performed on UAS. The UAS small size, carrying capacity, and the 

fact that flight operations will only take place in controlled areas for limited 

periods of time, create less risk than the same factors associated with 

conventional fixed-wing aircraft and rotorcraft performing the same operation.

Public Interest & Safety

The enhanced safety of small unmanned UAS eliminates the greater risk 

alternatives when using larger manned aircraft, carrying fuels at low altitudes. In 

addition this relatively new technology provides clients access to photographic 

and videography services and information that were previously not financially 

cost effective. Conducting aerial acquisitions with a UAS, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and 

noise pollution generated during traditional aerial video and still photography 

flight operations. By using battery power and electric motors, our UAS will 

produce no air pollution, and is the most viable environmentally conscious 

alternative to the internal combustion engine aircraft that are typically utilized for 

aerial video and photography, while burning approximately 20-30 gallons per 

hour of leaded aviation fuel. Our UAS, while reducing the carbon footprint during 

flights, will also eliminate noise pollution, as the UAS is propelled by a battery 

powered electric motor, rather than an internal combustion engine. 

The FAA, by granting the Coast 2 Coast Aerial Imaging’s exemption request, will 

serve to stimulate development of viable commercial UAS operations while 

guiding the public's understanding of how UAS can be legally and beneficially 

integrated into the National Air Space, NAS. 

UAS Overview Coast 2 Coast Aerial Imaging will operate the DJI 

Phantom 3 Professional 

● Dimensions

○ Size-40.36cm x 40.36cm x 19.05 x or 16inch x 16inch x 7.5inch 

○ Weight- 1280g total or 2lbs 13oz total 

● Speed 

○ Under still air maximum speed is no more than 16m/s or 35mph with a 

cruising speed of 11m/s or 25mph 

● Motors 

○ 4 motors total 

○ Motor model DJI 3510 

● Power 

○ 4480mAh 4s LiPo Lithium Polymer Battery 

● Propellers 

○ Model DJI 1345 

● Remote Controller 
○ DJI issued C3 remoter controller 

○ Operating frequency- 2.400GHz-2.483GHz 

○ Live Video frequency- 2.4GHz ISM (max range- 1.2 miles) 

● Operation Parameters 

○ Coast 2 Coast Aerial Imaging will operate the UAS with visual line of 

sight within a closed off pre-determined area; With authorization of the property 

owner or representative. 

DJI Phantom 3 GENERAL FEATURES 

● Ready to fly 

● Precision flight and stable hovering 

● GPS/GLONASS positioning and auto return home 

● FAA no-fly zones locked out via DJI installed software 

● Onscreen real-time flight parameters 

○ High Definition 4k camera 

○ 3 Axis camera stabilization 

○ Adobe lens profile support 

○ Album synchronization 

○ DJI VISION APP-System requirement of Mobile Device: 

iOS version 6.0 or above/ Android system version 4.0 or above 

● CAMERA 

○ Operating Environment Temperature- 0 degrees C to 40 

degrees C 

○ FOV- 94 degrees/85degrees 

○ Sensor Size- 1/ 2.3” 

○ Max Resolution-4096x2162p @24/25 fps 

● TRANSMITTER 

○ Communication Distance (open area) – CE: 2000m; FCC: 

2000m 

○ Transmitter Power- CE: 16dBm; FCC: 20dBm 

○ Operating Frequency- 2.400 GHz- 2.483 GHz 

○ Receiver Sensitivity (1%PER) :-101dBm +/- 2dBm 

○ Battery- 6000 mAh LiPo 2s 

○ Working Voltage- 1.2A @ 7.4V 

Conclusion 

Coast 2 Coast Aerial Imaging is confident that with the strict safety standards set 

by Coast 2 Coast Aerial Imaging, the FAA, and the physical safety properties of 

the UAS, all proposed operations will meet or exceed the Reform Act’s safety 

requirements. Granting the present Petition will further the public interest by 

allowing Coast 2 Coast Aerial Imaging to safely, efficiently, and economically 

perform aerial video and photography of client sites, events, and landscape over 

certain areas of the United States. Additionally, use of the UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of Coast 2 Coast Aerial Imaging’s proposed 
operation of the UAS will be realized without implicating any privacy issues. 

Manuals and Specifications: 

- DJI Phantom 3 Professional User Manual - http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Man 

ual_v1.2_en.pdf 

Please see attached document (Pre-Flight Safety Checklist)

I would like to thank you for your consideration in granting the exemptions 

mentioned in this document. If additional information is required or if you have 

any questions please contact Matthew Peterson, 805-204-1239 owner of Coast 2 

Coast Aerial Imaging.

Thank you, 

Matthew Peterson

Caost 2 Coast Aerial Imaging

Matt@c2caerialimaging.com