U.S. Department of Transportation

Docket Operations West Building Ground Floor, Room w12-140

1200 New Jersey Ave.

SE Washington, DC 20590 

Joseph Daniel Rodricks– Section 333 Exemption Petition 

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations 

from 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.109;119.121; 91.151(a); 91.405(a); 

91.407(a) (1); 91.409(a) (2); 91.417(a)&(b) 

Dear Sir or Madam: 

I, Joseph Daniel Rodricks, am writing pursuant to the FAA Modernization and Reform Act of 

2012 and the procedures contained within 14 C.F.R. 11, to request that I, an owner and operator 

of small unmanned aircraft, be exempted from the Federal Aviation Regulations (“FARs”) listed 

below so that I, may operate a small ultra light weight unmanned aircraft system (“UAS”) 

commercially in airspace regulated by the Federal Aviation Administration (“FAA”) located in 

New England (specifically in southeastern Massachusetts) in accordance with FAA UAS 

Regulations & Policies. 

This exemption request is made based on information outlined in this petition, as well as the 

accompanying DJI Phantom 3 Operators Manual. The DJI Phantom 3 UAS was selected 

because it has a proven capability for controlled flight as well as a gyro stabilized flight mode, 

GPS aided navigation, a compass, blinking lights on the bottom, a failsafe mode for returning 

home. These devices are offered for general sale around the world and have often been used 

as Model Aircraft in the USA. In addition, I, have flown UAS’s in a recreational capacity since 

2012 and have adopted safety procedures avoid public hazard, as well as manned aircraft 

hazards. 

I. Contact Information 

Joseph Daniel Rodricks

174 West St. 

PO Box 389 

East Bridgewater, MA 02333

phone: 508.801.4524 Email: jrodricks@gmail.com 

II. Information regarding the Phantom 3 UAS 

Specifically, the UAS is: 

An ultra lightweight battery operated 4-motor rotorcraft in the form of a quadcopter that takes off 

and lands vertically, manufactured by DJI, Model Phantom 3, with the following equipment: 

 •An on-board flight computer (with GPS/GLONASS, sonar altitude and station keeping 

function) that receives signals for flight controls from a ground-based transmitter/controller

 •An integrated on-board camera capable of capturing imagery in the form of full color, 

high resolution still photos and video
 •An on-board telemetry system that delivers flight data from the on-board flight computer 

to the on-board radio transmitter including altitude AGL, horizontal and vertical speed, compass 

direction of flight and direction back to its launch site 

 •A 2.4GHz on-board radio transmitter that transmits live video from the on-board camera 

plus all the flight data from the telemetry system described above to the Ground Station 

described below 

The Ground Station: 

 •A Pilot in Command (PIC) in operational control of a flight operation from beginning to 

end and who controls the UAS while in the air

 •A 2.4GHz radio transmitter/controller (transmit power of 20 dBm) operated by the PIC to 

control the UAS while in flight

 •A radio receiver receiving and recording live video and flight data from the on-board 

camera and computer visible PIC to view during flight

III. Proposed Operations 

First, I seek an exemption to perform video filming and photographing by air for public and 

private use. Second, I will employ UAS’s to inspect land, residential commercial and industrial 

structures and property. 

Specifically, I will use UASs which are equipped with cameras and sensors, in order to engage 

in the following commercial activities in southeastern Massachusetts and the greater New 

England area: 

(a) Video and/or still photo recording by air or public and private purposes, including: television, 

cinematography and advertising and support of professional operations in engineering, land 

surveying and development, agriculture, real estate, etc. Filming and photography will only be 

conducted with permission and under contract with registered owners or with any local 

government authority and only when safe to do so. 

(b) Support provided to search and rescue operations and reconnaissance in cases of need, 

emergency or natural disasters only when government authorities have requested it by contract 

or donation and only when safe to do so. 

IV. Relevant Statutory Authority 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the FAA 

Modernization and Reform Act of 2012 ("Reform Act"). Congress has directed the FAA "to safely 

accelerate the integration of civil unmanned aircraft systems into the national airspace system." 

Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft 

systems to operate in the National Air Space ("NAS") where it is safe to do so based on the 

following considerations: 

•The UAS’s size, weight, speed and operational capability 

•Operation of the UAS in close proximity to airports and populated areas

•Operation of the UAS within the visual line of sight of the operator. 
Additionally, the FAA Administrator has general authority to grant exemptions from the agency's 

safety regulations and minimum standards when the Administrator decides a requested 

exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the 

authority of the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from§§ 44701(a), 

(b) and§§ 44702-44716,et seq.). A party requesting an exemption must explain the reasons why 

the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety 

(or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 

11.81 (petitions for exemption). 

V. These Proposed UAS Operations Meet the Requirements of Section 333 of the Reform 

Act 

The proposed operations in this Petition for Exemption qualify for expedited approval pursuant 

to Section 333 of the Reform Act as each of the statutory criteria and relevant factors are 

satisfied. 

VI. Approval is Warranted Based on the UAS Size, Weight, Speed, and Operational 

Capability 

I, Joseph Daniel Rodricks, will employ the DJI Phantom 3 quadcopter for the operations 

specified in this Petition for exemption. 

•The Phantom 3 UASs have a maximum take-off weight of less than 5 pounds 

•Flight speed will not exceed 32 knots, and it will not be flown in controlled airspace or at an 

altitude that exceeds 400 feet AGL.

• All flights will be flown in such a manner that they can be safely terminated with a reserve 

battery power of no less than 20% of the battery's maximum charge. 

• The DJI Phantom 3UAS does not carry any flammable propellant or liquid fuel. 

• The Phantom 3 UAS has an integrated GPS system that calculates the UAS’s position and 

height and relays that information via a to the operator in near real-time. 

• The Phantom 3 UAS contain a failsafe mode if its connection to the remote control is lost. This 

system permits the UAS to return to a predetermined location and land without injury 

or damage. This failsafe mode can also be triggered remotely by the Ground Station.

VII. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manual. 

DJI's operators manual contain all of the procedures and limitations necessary to 

successfully perform the operations specified in this Petition for Exemption

VIII. Public Interest 
The public interest will be served by granting Joseph Daniel Rodricks a Petition for Exemption in 

New England and southeastern Massachusetts. Congress has established a national policy that 

favors early integration of UASs into the NAS in controlled, safe working environments such as 

those proposed in this Petition. In addition the public also has an interest in reducing the 

hazards associated with alternate methods of conducting similar operations. Currently 

operations are conducted manually at risk to human life, using low flying helicopters or 

conventionally crewed aircraft, are extremely cost prohibitive or are incapable by traditional 

means. By using UAS, exposure to physical hazards will be reduced by conducting the 

operation while human life remains safely on the ground. 

Additionally, the intended uses of the UAS as outlined in this document have identifiable safety 

benefits that include reducing the danger and emissions associated with full size helicopters and 

conventionally crewed aircraft. UAS have no fuel to ignite or explode, no crew, add a greater 

degree of flexibility, supplement the current capabilities offered by manned aircraft, and public 

interest for a ground impact of a small lightweight UAS is further minimized from an ecological 

and safety standpoint. Further small UAS provide less of a nuisance to the general public by 

virtue of their inherent nature to produce less noise than conventional helicopters and crewed 

aircraft. 

IX. A Summary The FAA May Publish in the Federal Register: 

A. 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 

14 C.F.R. 91.7(a) I, Joseph Daniel Rodricks will ensure the UAS is in airworthy condition based 

on compliance with the Phantom 3 operating documents prior to each flight. 

14 C.F.R. § 91.121 Relief is requested considering the limited altitude of proposed operations. 

B. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. 

Pursuant to 14 C.F.R. § 61.113 (a), The FAA has previously declared that additional manned 

airship experience of a commercially certified pilot would not correlate to the airmanship skills 

necessary for similarly proposed operations in previously issued exemptions to this regulation 

through Exemption Nos. 11062 and 11138. 

Pursuant to 14 C.F.R. § 61.113 (b), The stick and rudder controls of the typical aircraft one 

would be trained on to achieve a private pilots license are completely different than that of a 

small UAS. Additionally, the FAA does not require manned ultralight vehicle PICs to meet any 

aeronautical knowledge, age, or experience requirements or to have airman or medical 

certificates (as outlined in 14 C.F.R. § 103). 

D. 14 C.F.R. 91.119 (c): Minimum Safe Altitudes. 

14 C.F.R. § 91.119 (c) I will ensure that all persons and objects not essential to flight operations 

must remain 500 feet away from operations. 

E. 14 C.F.R. 91.151 (c): Fuel Requirements for Flight in VFR Conditions. 

14 C.F.R. 91.151 (c): I, will ensure that each individual flight will not begin unless there is 

enough power to fly to the first point of intended landing and land the UA with 30% battery 

power remaining. In addition, each individual flight will last no longer than 20 minutes, 5 minutes 

less than the manufacturer stated 25 minutes of flight time. 

F. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. 
The above-cited Regulations require, amongst other things, aircraft owners and operators to 

“have [the] aircraft inspected as prescribed in subpart E of this part and shall between required 

inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter. . . .” 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to my, Joseph Daniel Rodricks, UAS. However, as a safety precaution I inspect 

my UAS per operating documents before and after each flight. 

X. Conclusion 

This Petition for Exemption satisfies the criteria articulated in Section

333 of the Reform Act of 2012 including weight, speed, operating capabilities, proximity to 

airports and populated areas, operation within visual line of sight and national security. 

Additionally, the Petition provides more than adequate justification for the grant of the requested 

exemptions to permit Joseph Daniel Rodricks to operate a Phantom 3 UAS in New England for 

the operations specified herein. 

Granting the exemption will benefit the public interest as a whole in several ways, including (1) 

significantly improving safety and reducing risk by alleviating human exposure to danger, and 

(2) improving the quality of services and decreasing operating costs compared with 

conventional flight operations.