January 11, 2016 

••• 

Robert Voigt 

The Voigt Group, LLC 

11414-C Kingston Pike 

Knoxville, TN 37934 

u.s. Department of Transportation, Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

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, Robert Voigt, Member of The Voigt 

Group, LLC, referred to as the Petitioner, kindly request exemption from the following sections 

of Title 14, Code of Federal Regulations §§ 

14 CFR21 

14 CFR 45.23(b) 

14 CFR 61.113 (a) and (b) 

14 CFR 91.7 (a) 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151.151 (a) 

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) 

The LLC will be operating a DJI Phantom 3 Professional Quadcopter. This exemption will allow 

The Voigt Group, LLC to operate an unmanned aerial vehicle commercially for the purposes of 

conducting aerial video and still photography in the Tourism, Real Estate, and Hospitality 

markets of East Tennessee. These still images and videos will provide both commercial and 

ROB@THEVOIGTGROUP,COM • (865) 560-6088 • WWW.THEVOIGTGROUP.COM 

1 141 4-C KINGSTON PIKE. KNOXVILLE, TN • 37934 
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community awareness and understanding of aerial imaging systems. The Voigt Group, LLC is a 

real estate brokerage operating out of Knoxville, TN; we additionally provide photography and 

videography for other real estate clients (both residential and commercial) and for peer 

businesses in our area. The Voigt Group, LLC will be using a DJI Phantom 3 Professional 

Quadcopter (Model #W323) to commercially capture video stills and film while working on 

private and public properties for the purpose of aerial photography and videography. The Voigt 

Group, LLC will employ both an experienced operator and utilize a visual observer to maintain 

a visualline-of-sight between the quadcopter and the SUAV operator. 

THE DJI PHANTOM 3 PROFESSIONAL QUADCOPTER 

The DJI Phantom 3 Professional Quadcopter is an electric powered quadcopter weighing less 

than three pounds; it is operated via a handheld remote that features "Return to Home" and 

"Follow Me" commands. The Return to Home feature can be triggered manually and the UA V 

unit works off of a 2.4 GHz downlink for remote control. The video function works on 5.8 GHz 

frequency video. The default altitude setting for the DJI Phantom 3 Professional Quadcopter is 

400 feet AGL. The camera system is also operated from the handheld remote control. Both units 

are powered by a single battery, allowing for approximately 20 minutes of flight time. 

BASIS FOR PETITION 

The Voigt Group, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. SS 11.61) and the F.A.A. Modernization and Reformed Act of 2012, Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to operate the 

DJI Phantom 3 Professional Quadcopter within the National Airspace System. We request 

exemption from the requirements of 14 CFR SS 61.113 (a) and (b), 91.7 (a), 91.119, 91.121, 91.151 

(a), 91.405 (a), 91.407 (a) (1),91.409 (a) (1) and (2),91.417 (a) and (b). 

NAME AND ADDRESS OF THE PETITIONER 

The Voigt Group, LLC 

Attn: Robert Voigt or Brittany Voigt 

11414-C Kingston Pike 

Knoxville, TN 37934 

THE VOIGT GROUP, LLC REQUESTS RELIEF FROM 

Section 21 

That 

As 

Section 21, subpart H, Airworthiness Certification 

This section details need for airworthiness certificate. 

Given the size, weight, speed, and limited operating area associated with 

the aircraft to be utilized, an exemption from this section is warranted and 

Robert Voigt • 2 
Section 45.23 

That 

As 

Section 61.113 

That 

As 

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meets the requirements for an equivalent level of safety under 14 CFR part 

11 and Section 333 of P.L. 112-95 (Section 333). 

Marking of the Aircraft 

Applicable Codes of Federal Regulation require aircraft to be marked 

according to certain specifications. 

The SVA is, by definition, unmanned. It does not have a cabin, cockpit, or 

pilot station on which to mark words or phrases. Two-inch lettering is 

difficult to place on such a small aircraft. Regardless, it will be marked in as 

large a lettering as possible as "EXPERIMENTAL" on its fuselage as 

required by 14 CFR 45.29(f) so that the operator or any other member of the 

team may see the markings. The FAA has previously issued exemptions to 

this regulation through Exemption Nos. 8738, 10167, 10167 A and 10700. 

Entitled Private pilot privileges and limitations: Pilot in Command, 

Subsections (a) and (b). 

Regarding section 61.113 (a) and (b) Private pilot privileges and limitations: 

Pilot in Command, Subsections (a) and (b) prescribed the following, in part: 

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as 

PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as 

PIC 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 SVA will be operated by a trained operator that is versed in proper 

flight procedure and safety. The vehicle will be flown under favorable 

conditions and will not be flown near an airport or anywhere near any 

other aircrafts. We request a 120 day temporary airman certificate to allow 

the FAA time to establish minimum VAS airman certification standards for 

these unmanned aircraft. The aircraft will carry no persons and will in fact 

carry nothing but a camera. The Petitioner will abide by VAS Operating 

Parameters, including 

• VAS will be operated below 300 feet and within a radius distance 

of 1000 feet from the controller to both aid in direct line of sight 

visual observation 

• VAS will be operated for 3-7 minutes per flight 

• VAS will be landed prior to the manufacturer's recommended 

minimum level of battery power 

Robert Voigt • 3 
Section 91.7 

That 

As 

Section 91.119 

That 

As 

Section 91.121 

That 

As 

Section 91.151 

That 

As 

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• VAS will be operated only within visual line of sight (VLOS) 

• VAS's global positioning system (GPS) flight safety feature will 

be utilized, whereby it hovers and then slowly lands if 

communication with the remote control pilot is lost 

• VAS operations will be conducted under flight safety protocols 

(including posting a warning sign reading: /I Attention Aerial 

Photography in Progress - Remain Back 150 feet"). Petitioner will 

actively analyze flight data and other sources of information to 

constantly update and enhance safety protocols 

• Respective airports will be contacted if operations will be within 

5 miles to advise of estimated flight time, flight duration, 

elevation of flight and other pertinent information 

• Necessary permissions will always be obtained prior to operation 

• Procedures will be set in place to abort flights in the event of 

safety breaches or potential danger. 

Entitled Civil airworthiness subsection (a). 

Regarding prohibition of operating an aircraft without an airworthiness 

certificate 

This regulation is inapplicable to our operations, being no current 

certificate is applicable to this situation. I request the FAA allow me to 

deem my aircraft as airworthy, as additionally evidenced by the 

manufacturer's testament. 

Entitled Minimum Safe Altitudes, General. 

The FAA prescribes safe altitudes for the operation of civil aircraft, but that 

helicopters are allowed to be operated at lower altitudes in certain 

conditions. 

The aircraft will be operated at altitudes not to exceed 400 feet AGL, over 

private property without permission, or at a distance at or greater than five 

nautical miles from the nearest airport as depicted on current aeronautical 

charts. 

Entitled Altimeter Settings. 

The FAA prescribes guidelines for altimeter settings 

This section is inapplicable, as the SUA does not have an altimeter and 

instead utilizes electronic GPS with a barometric sensor. 

Entitled Fuel requirements for flight in VFR conditions. 

The FAA sets rules for fuel in VFR conditions. 

The aircraft will only be operated up to a point that there is enough power 

Robert Voigt • 4 
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to fly at normal cruising speed to the landing point and land the vehicle 

with 25% battery power remaining. Note: a low battery alarm on the 

operating consoles for the aircraft is equipped with a shaker mechanism to 

warn the operator of a low battery condition. 

Section 91.405 Entitled Maintenance required. 

Section 91.407(a)(1) Entitled Operation after maintenance, preventative maintenance,. 

rebuilding, or alteration. 

Section 91.409 Entitled Inspections. 

AND 

Section 91.417 

That 

As 

Entitled Maintenance Records. 

These sections are all associated with an airworthiness certificate. 

There are currently no airworthiness certificates for small UAVs. 

BENEFITS GAINED VIA RELIEF 

The Voigt Group, LLC will derive numerous benefits from exemption from the above stated 

Federal Regulations. 

• The use of the small UA V will allow for quicker and timelier aerial video and aerial 

photography of properties as contracted for. 

• The use of the small UA V will allow for more cost effective aerial video and aerial 

photography as the cost to operate a small UAV is fractional compared to the cost of 

operating a full size aircraft for aerial photography. 

• Use of the small UAV will lessen the use of full size aircraft for some aerial photography 

missions and therefore give a somewhat greater safety ratio for the use of aerial 

photography. 

• The public will benefit both in economic and safety terms. The use of the SUS will allow 

our group to capture images that will drive both business and residents to our county. 

The UAV is safer, less costly, and easier to use than flying a regular aircraft to capture 

these images. We additionally perform some work pro bono, as it relates to economic 

growth and business development in our area. 

REASONS WHY SAFETY WILL NOT BE AFFECTED BY GRANTING THESE REQUESTED 

EXEMPTIONS: 

• Standard operating procedures prior to launch will include a preflight checklist of the 

vehicle and a visual inspection of area to be surveyed at ground level will be performed. 

• Flight operations will be conducted by a two man crew consisting of the Operator and 

the Visual Observer. All operations will be conducted with a clear line of sight between 

the UA V and the team. 

Robert Voigt • 5 
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• The Voigt Group, LLC will only operate the UAV over private or public property with 

the permission of the property owner or the governing body and will maintain a safe 

distance from any structures, people or vehicles. This petition is being made pursuant to 

the FAA Modernization and Reform Act of 2012, Section 333, which directs the Secretary 

of Transportation to determine if any UAS may safely operate in the National Airspace. 

The Voigt Group, LLC will operate the aircraft granted for use by the exemption as 

directed by the operating manual provided by the manufacturer. 

IN CONCLUSION 

As set forth previously, The Voigt Group, LLC seeks exemption pursuant to 14 CFR: 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe operation 

of DJI Phantom 3 Professional Quadcopter commercially within the tourism, real estate and 

hospitality markets. The Administrator will be assisting small business and local tourism 

organizations by granting this petition. In accordance with the FAA Modernization and Reform 

Act of 2012, The Voigt Group, LLC respectfully requests that the FAA Administrator grants this 

petition for exemption from TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 21 subpart H, 45.23(b), 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). 

Regards, 

~~ 

Robert Voigt 

President 

The Voigt Group, LLC 

Robert Voigt • 6