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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

May 15, 2015

U. S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Professional Claims Services, Inc. - Exemption Request Section 333 of the FAA Reform Act and Part 11 of 

the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b); 91.7 

(a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405(a); 91.407(a) (1); 

91.409(a) (2); 91.417(a) & (b); 61.3(a); 61.23(a). 

Dear Sir or Madam: 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, 

Professional Claims Services, Inc., a California Corporation licensed by the California Department of Insurance 

as an insurance adjusting entity, hereby applies for an exemption from the listed Federal Aviation Regulations 

(FARs) to allow commercial operation of Small Unmanned Aircraft Systems (sUASs) for aerial imaging to 

perform site inspections. 

The requested exemption would permit the commercial operation of small, unmanned and relatively 

inexpensive sUAS by trained sUAS operators. The President of Professional CLaims Services, Inc. 

(ProClaims), David B. Churchill, has been a licensed pilot for 47 years and a licensed insurance adjuster for 30 

years and is the designated sUAS operator for ProClaims. 

ProClaims is involved in damage assessment for insurance companies and responds to catastrophe losses 

such as Hurricanes Katrina, Ivan, Jean, Charlie, Frances, Wilma and Sandy. The Section 333 exemption will 

allow safer documentation, and ease of assessment, of damages. 

The exemption will allow ProClaims the opportunity to invest in the sUAS and other equipment and software to 

develop inspection programs that are beneficial to not only our clients, but the safety of our inspectors and the 

public in general. 

Approval of this exemption would fulfill the Secretary of Transportations’ (the FFA Administrator’s) 

responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national 

airspace system” based on Section 333(c) of the FAA Modernization and Reform Act of 2012. Our request 

falls within the most recent set of Operational Limitations proposed by the FAA regarding commercial use of 

sUASs. 

ProClaims understands that the intent of the Act is to promptly approve such requests for the overall good of 

the public to help in determining the proper implementation of sUASs into our NAS. This will exemption will 

allow damages to be documented promptly so that those who have suffered covered losses can be 

compensated. 

Respectfully, 

David B. Churchill – dchurchill@proclaims.com

President – Professional Claims Services, Inc.
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

TABLE OF CONTENTS

 Page 

CFR EXEMPTIONS SOUGHT .......................................................................................... 3 

INTRODUCTION AND INTERESTS OF PETITIONER.................................................... 3

RELIEF SOUGHT FROM SPECIFIC REGULATIONS...................................................... 4 

EXEMPTION REQUEST....................................................................................................... 8

LIMITATIONS ON EXEMPTION & OPERATION............................................................. 8

CONCLUSION......................................................................................................................... 12

APPENDIX 1 (DIJ Phantom 2 v3.0 Specifications)................................................... 13
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED:

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

14 CFR 61.3 (a) 

14 CFR 61.23 (a) 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Professional Claims Services, Inc. (ProClaims) is an insurance claims adjusting and appraising company 

licensed by the California Department of Insurance.

An integral part of the business operations of ProClaims is damage assessment, documentation, and 

estimating the cost to repair damaged insured property. Damage to higher building elevations and roofs require 

large ladders, rope devices, and lift buckets for inspections and that dramatically increases the risk of injury to 

our adjusters and appraisers in the field. sUASs will eliminate the need to climb high and steep roofs to photo 

document any damage.

Exemption will allow ProClaims adjusters and appraisers to inspect and photo damage that may otherwise not 

be accessible or safe to access due to roof pitch or height. Currently the appraiser that climbs on the roof is not 

only is exposed to increased danger, any walking on a roof can lead to broken tiles, shingles, and leaks.

ProClaims, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to allow ProClaims to commercially operate the DJI Phantom 2 

Vision v3.0, or similar commercially manufactured sUAS, in our National Airspace System (NAS), and for an 

exemption from the requirements of 14 CFR above.

As set forth below, ProClaims meets all of the criteria for exemption. Each exemption requested is set forth with 

our rationale as to why each exemption should be granted. Also included is a checklist of limitations applicable 

to our operations and our exemption request. 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

DESCRIPTION OF RELIEF SOUGHT FOR SPECIFIC REGULATIONS

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 with the aircraft to be utilized by the Applicant, Victory Improvement Professionals, an exemption 

from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 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 proposed. The sUAS to be operated hereunder meets the definition of Section 333 

(6) being less than the 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials 

or flammable liquid fuels, and operates within an area with written or verbal approval. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by the operator, and in compliance 

with both Federal and local public safety requirements. The FAA will receive advance notice of all operations 

with the required filing of a Certificate of Waiver. These safety enhancements, which are already greater than 

currently required by hobbyist, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

Application of these criteria demonstrates that there is no 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 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated 

aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," 

"experimental," or "provisional," as applicable. Even though the sUAS will have no airworthiness certificate, an 

exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the 

word “Experimental” can be placed. Given the size of the sUAS, two-inch lettering will be impossible. The word 

“Experimental” will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will 

be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and 

others working with the sUAS will see the identification of the UAS as “Experimental.” The FAA has issued the 

following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. 

David B. Churchill, president of ProClaims, is the designated Pilot. His FAA Certificate Number is 2174907. He 

maintains a California Driver’s License. Sections 61.113 (a) & (b) limit private pilots to non-commercial 

operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to have specific 

training to the sUAS along with in house training to current FAA regulations regarding our NAS and civic 

responsibility. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely 

controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are 

planned and coordinated in advance. These types of sSUAs are currently being flown by hobbyist without any 

certifications. The level of safety provided by the requirements included in the manufacturer’s Manual exceeds 

that provided by a single individual currently operating an sUAS as a hobbyist. The risks associated with the 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

operation of the sUAS are substantially diminished from the level of risk associated with conventional manned 

operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested with 

specific training as the operator exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b) or 

what is allowed currently by hobbyists. 

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there 

will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory 

standard will exist for determining airworthiness. Given the size, speed and flight restrictions placed on the 

UAS along with the preflight and maintenance required, an airworthiness certificate is not needed since our 

practice will exceed all current FAA guidelines pertaining to airworthiness of sUASs.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is 

available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. 

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, 

not only because there is no pilot on board, but because there is no room or capacity to carry such an item on 

the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control 

point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following 

exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action 

Visual pre-flight of all physical components will be conducted prior to rotor initiation. The regulation requires 

each pilot in command to take defined actions before flight to insure the safety of the flight. As FAA approved 

rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of 

safety will be provided as set forth in the attached Operator Preflight form. The Operator will take all actions 

including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance 

data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely 

piloted aircraft, do not have fully functional dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft via radio, wi-fi, or bluetooth communications. The FAA has 

approved exemptions for flight training without fully functional dual controls for a number of aircraft and for 

flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety 

provided as neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the 

aircraft. The safety of those on the ground is protected by the fact that each structure that is the subject of the 

documented flight will have verbal or written authorization and will be conducted in a defined area where we 

can limit non-participating individuals. 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to 

be operated at less than the minimums prescribed, provided the person operating the helicopter complies with 

any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter 

and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an 

elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set 

forth herein, except for the limited conditions stated in the Manual, the UAS will never operate at higher than 

400 AGL. It will however be operated in a restricted area with security perimeter, where buildings and people

will not be exposed to operations without their pre-obtained consent.The equivalent level of safety will be 

achieved given the size, weight, speed of the UAS as well as the location where it is operated. No flight will be 

taken without the permission of the property owner or local officials. Because of the advance notice to the 

property owner and participants in the filming activity, all affected individuals will be aware of the planned flight 

operations as set forth in Section K of the Manual. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk 

associated with these operations is far less than those presently presented with conventional aircraft operating 

at or below 500 AGL in the movie industry. In addition, the low-altitude operations of the sUAS will ensure 

separation between these small-UAS operations and the operations of conventional aircraft that must comply 

with Section 91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available 

before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an 

exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to the 

Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator 

before flight. 

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

Section 91.151 (a) prohibits an individual from beginning “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 sUAS provides approximately 7-

30 minutes of powered flight. The DJI Phantom 2 v3.0 has 25 minutes of flight time. There is less than the 

minimum to meet the 30 minute reserve requirement in 14 CFR §91.151. sUAS flights would be limited to 

using 2/3 of the battery capacity. Given the limitations on the UAS’s proposed flight area and the location of its 

proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR 

conditions is reasonable. ProClaims believes that an exemption from 14 CFR §91.151(a) falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without 

compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and 

property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes 

of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the small UAS. Additionally, limiting sUAS flights to 30 minutes of fuel remaining would 

greatly reduce the utility for which the exemption will be granted. ProClaims believes that an equivalent level of 

safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This 

restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its 

limited operating area. Similar exemptions have been granted to other operations, including Exemptions 

2689F, 5745, 10673, and 10808.
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration 

The regulation provides in part: (a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: (1) An appropriate and current airworthiness certificate. . . . 

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this 

section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so 

that it is legible to passengers or crew. The UAS fully loaded weighs no more than 55 lbs and is operated 

without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or 

to display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are 

applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample 

of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections 

These regulations require that an aircraft operator or owner “shall have that 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...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43. Given that these section and Part 43 apply only to aircraft with 

an airworthiness certificate, these sections will not apply to the applicant. Maintenance will be accomplished by 

the operator pursuant to the flight manual and operating handbook attached with this exemption request. An 

equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a 

small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the 

UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, 

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. Moreover, the operator is the person most familiar with the 

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of 

safety. 

14 C.F.R. §61.3 Requirement for certificates, ratings, and authorizations. 

These regulations require that no person may serve as a required pilot of a civil aircraft unless that person 

holds a current pilot certificate in accordance §61.19; §61.77; §61.17; or §61.29(e). Given the size and nature 

of the flights that this aircraft will make along with their currently being no current certification or licensing 

process specific to sUASs, the current licensing process is for aircraft carrying at least an onboard pilot. This 

presents an undue hardship for a small business owner to proceed to develop this technology. It is apparent by 

the directive of Congress in the Modernization Act in Section 333 along with the recent FAA Comprehensive 

Plan that an exemption can be granted. By simply going through the steps of the exemption process afforded 

in Section 333 demonstrates that our commitment to a more superior level of safety in comparison to a 

hobbyist flying under the same restrictions without the requirement of 14 C.F.R. §61.3 

§61.23 Medical certificates: Requirement and duration. 

This regulation requires medical certificates for all pilots operation in the NAS, or to maintain a Drivers License 

from their home state. ProClaims meets the requirement with its designee. Given the size and nature of the 

flights that this aircraft will make along with their currently being no current certification or licensing process 

specific to sUASs, the current licensing process is for aircraft carrying at least an onboard pilot. This presents 

an undue hardship for a small business owner to proceed to use this technology. It is apparent by the directive 

of Congress in the Modernization Act in Section 333 along with the recent FAA Comprehensive Plan that an 

exemption can be granted. 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

REQUEST FOR SECTION 333 EXEMPTION 

Subject to the following limitations, the exemption request is for the commercial use of sUASs for video and still 

aerial photography to be used in documenting damage caused by insured perils and other insurable risks.

The exemption sought is to be able to operate the DJI Phantom series (2.0 v2, v3, 3.0 pro when released, 

Inspire 1) and similar commercially available sUAS and suitable to the Admininstrator: but specifically the DIJ 

Phantom 2 v3.0. The specifications are attached as appendix 1. These UAS have added safety enhancements 

that include upgraded flight controller with:

7" Field Monitor with integrated Diversity Rx (5.8 GHz 32 CH) 

 Integrate d 5200 mAh Battery – 25 minute flight time

 400 mW 5.8 GHz 32 CH Vide o Tra nsmitter – wi-fi and smartphone compatible

 Quick De ta ch Ra dio Mount 

Self-tightening rotors/props

Automated Return to launch port

GPS attitude mode - autopilot system keeps the unit stable and holds it in a fixed horizontal and vertical 

position upon release of the controls.

LED on tail that can be seen in flight showing battery charge.

(See Appendix 1 for Specifications)

The Operational Limitations to our exemptions are as follows: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in 

the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI 

Phantom or similar commercially manufactured Professional Unmanned Aircraft Systems. Proposed 

operations of any other aircraft will require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of 

aerial video and photography. 

3. The UAs will not be flown at an indicated airspeed exceeding 85 knots or the manufacturer’s

recommended indicated airspeed maximums.

4. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL), as 

indicated by the procedures specified in the operating documents unless a special request is made 

and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective lenses, as specified 

on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed 

in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other 

air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera 

or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and 

made available to the Administrator upon request. If a discrepancy exists between the conditions 

and limitations contained in the grant of exemption and the procedures outlined in the operating 

documents, the conditions and limitations contained in the grant of exemption take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator determines that any 

update or revision would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If 

the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the UAS is 

found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight 

characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. 

The PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action taken 

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification 

criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the 

UAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the 

purposes of training the operator’s PICs are permitted under the terms of the exemption. However, 

training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). If flight at night is required, a 

special request will be made at the FAA office closest to proposed area of operations. Flights under 

special visual flight rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as required 

by the operator’s COA. The letter of agreement with the airport management must be made 

available to the Administrator upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a 

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

22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location 

within the planned operating area and land or be recovered in accordance with the operating 

documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the 

UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation operations and activities 

at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures 

unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UA and/or debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons 

leave such protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not 

present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property with permission from 

the land owner/controller or authorized representative. Permission from land owner/controller or 

authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA must be reported to the FAA's UAS Integration 

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

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

CONCLUSION

The benefit of granting this exemption falls within the parameters set by Section 333(c) of the FAA 

Modernization and Reform Act of 2012. Our commitment is to the safe operation of sUASs in our NAS. 

ProClaims meets all of the criteria necessary for granting the exemption and seeks to safely operate sUASs as 

an important business tool for documenting damages to property. It will substantially lessen the risk of injury to 

adjusters and appraisers that now climb on roofs.

I hope you will process our request in a timely fashion and contact me regarding any questions you may have. 

Respectfully, 

David B. Churchill

President – Professional Claims Services, Inc.
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

Appendix 1

The version 3.0 (released late 2014) Phantom 2 Vision+ Quadcopter with Gimbal-Stabilized 14MP, 1080p Camera from DJI features a number 

of notable hardware updates over the previous Phantom 2 Vision+ model, including more efficient motors, redesigned self-tightening props, a new 

transmitter (radio controller) with built-in battery and gimbal control dial, and other improvements. 

The Phantom 2 Vision+ is based on the same air frame as the Phantom 2 and Phantom 2 Vision. Unlike its siblings, however, it features a 14MP 

camera that is stabilized and controlled with an integrated 3-axis gimbal. Gimbal stabilization makes the Phantom 2 Vision+ ideal for shooting aerial 

footage and photos. The camera can take 14MP, Adobe DNG RAW photos, and can record video in 1080p Full HD at 30 fps or 720p at 60 fps for 

creating slow motion effects.

The Phantom 2 Vision+ ships ready-to-fly, meaning that a radio controller--often referred to as a transmitter is included with it and is pre-bound to 

the aircraft and that only minimal assembly using common household tools is required. It features a 5200mAh battery that can sustain the quadcopter 

in the air for up to 25 minutes. The transmitter features a line-of-sight range of up to 2625', depending on conditions. 

The camera is controlled via 2.4 GHz Wi-Fi using an app available for iOS and Android devices. Using the supplied mount, you can attach your 

smartphone directly to the controller, giving you a "heads up" display directly from the camera's point-of-view. From the app you will also be able to 

start and stop video recording, take a snapshot and even tilt the camera up or down.

Because of the complexity associated with multi-rotor aircraft the Phantom 2 Vision+ relies on a GPS-based navigation system to maintain flight 

stability and provide other features. While fully manual operation is possible, most users, especially videographers hoping to get the smoothest 

possible shoots, will opt for GPS attitude mode. GPS attitude mode is an autopilot system that keeps the Quadcopter stable and right-side-up when 

moving, and holds it in a fixed horizontal and vertical position whenever you release the controls. This is ideal for shooting video because you can 

compensate for light or moderate wind that might otherwise cause the aircraft to drift. 

As with the other Phantom 2 models, 5200mAh battery system is simplified over the original version 1 Phantom. The battery now slots in, and 

provides LED indicators on outside, tail-end of the aircraft so they can be seen in flight. Charging is also simplified, with all of the charging circuitry 

built into the battery itself. You simply need to plug it into the wall with the supplied universal AC adapter. A DC car charger can also be used.

The Phantom 2 Vision+ includes a Wi-Fi Range extender that will increase the wireless range of the smartphone used for FPV camera operation up 

to nearly 2300' line-of-sight. The range extender mounts on the transmitter (radio controller) along with the smartphone.

Finally, there is a 4GB MicroSD card included to help get you started filming and taking photos with the 14MP camera.

What's New for Version 3.0?

Redesigned Transmitter (Radio Controller) 

The radio controller (more commonly known as a transmitter in RC lingo) has been updated with some notable additions: 

• Left Dial: Use this to operate the tilt function of the gimbal 

• Trainer Port: Connect the remote control to the computer to run a simulation application 

• Throttle Lock: Pull down the throttle stick to descend; the stick will lock into place and the aircraft will descend steadily. Push the throttle 

stick upward to release throttle lock 

• LED Battery Indicator: Foregoing AAs, the transmitter now runs on a built-in LiPo battery. Four LEDs on the front tell you how much 

charge is left 

• Micro-USB Port: Use the micro-USB port to recharge the built-in battery. The LED indicators will display charging status as the battery 

tops up 

New 2312 / 960 KV Motors 

The new motors features a stator winding structure for a neater designed and improved heat dissipation. The new motors offer: 

• Up to 200g per axis more thrust than the previous design 

• The single wire stator design improves motor efficiency and its ability to withstand a larger current 

• New bearings, with a higher durability and ability to withstand greater impacts, are used to avoid damage in the event of an accident 

• New insulation coating powder is used to improve the stator voltage capacity, helping extend the working life and stability of the motor 

• A new ESC (electronic speed controller) - ESC v2.0 - is used to ensure the efficiency improvements of the motors are maximized 

Updates Self-Tightening Props - Model 9450 

Computational fluid dynamics (CFD) have been applied to the prop redesign, providing them with increased thrust and better efficiency. 

Combined with the new motors, up to 200g per axis of thrust has been achieved - especially beneficial when flying with a heavy payload 
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Professional Claims Services, Inc. – 1235 Holmgrove Dr. San Marcos, CA 92078 (858) 748-3880

Improved Compass 

The compass is now encased in a protective shell, and features added protection against static interference 

Features

Gimbal Stabilized 14MP HD Camera 

The Phantom 2 Vision+ features a 14MP camera with a specially integrated 3-axis gimbal designed specifically for use with the 

Quadcopter. In addition to photos, the camera can record 1920 x 1080 resolution video at 30 fps and 720 video at 60 fps. The camera is 

controlled wirelessly via Wi-Fi using an app available for smartphones with Android or iOS. Internal recording is to a MicroSD memory 

card. Additionally, captured footage can be uploaded from your smartphone to social media websites such as Facebook 

Attitude and GPS Attitude Flight Modes 

The Phantom 2 Vision+ flight control system has two computer-assisted flight modes for you to choose from. Of the two, GPS attitude

mode is the most automatic. In GPS attitude mode the Quadcopter will stop as soon as you release the controls and stay hovering at a fixed 

horizontal and vertical position. This setting is the easiest to fly and is generally preferred for shooting video as the Quadcopter won't sway 

or drift because of light wind gusts

The second, attitude mode, is a more manual flying mode in which the Phantom Vision does not try and maintain a fixed spatial position. 

When you release the controls it will continue to drift unless friction slows it down or you stop it. And in this mode it will be more likely to 

be blown around if there is any wind. This not a true manual mode, however, in that the GPS navigation system is still used to maintain 

flight stability and by the "return to home" feature in the event of signal loss. 

Return to Home Failsafe 

If the Quadcopter loses the signal from the controller for any reason the "return to home" feature will initialize. The aircraft will ascend to 

60 feet then make a straight-line course back to the "home position" you will have defined during the GPS calibration process. Once there, 

it will safely descend to the ground and power itself off 

Intelligent Orientation Control (IOC) 

IOC is designed to help make flying more intuitive. Nominally, the yaw control will allow the Quadcopter to rotate continuously, which 

can quickly become confusing if you lose track of which way is "front". Suddenly your controls can get mixed up, where pressing right 

causes the craft to move left and pressing forward causes it move backward. Intelligent Orientation Control prevents this from happening, 

keeping the "tail" of the Quadcopter pointed roughly toward the pilot at all times 

DJI Vision iOS and Android App 

The DJI Vision App for iOS and Android smartphones provides many functions apart from just FPV monitoring, such as telemetry of vital 

flight stats including remaining battery and number of GPS satellites and a radar scope to help avoid collisions. It also features full camera 

control, letting you set parameters such as camera tilt, ISO, Shutter Speed, White balance as well as set video start/stop and take photos. 

Once recorded, photos and video footage can be downloaded directly to the phone allowing them to be shared on Facebook, Instagram or 

other social media networks, even while the Quadcopter is still in the air 

Assistant Software 

Windows- and OSX-based software allows you to enable Intelligent Orientation Control (IOC), update firmware, and adjust other aircraft 

and transmitter parameters. In addition, the software allows you to unlock the manual flying mode. Manual Mode will override all autopilot 

redundancy and failsafes, therefore should only be engaged by experienced pilots 

Slot-In Battery with LED Status Indicators 

A 5200mAh battery slots into the "tail" of the Phantom 2 and enables up to 25 minutes of flying time. It features and on/off switch and four 

LED charge indicators that are visible while flying so you can keep track of remaining flight time. For recharging, balance and power 

regulation is handled internally within the battery itself. You simply plug it into a wall outlet with the supplied power cord and you are 

good to go 

Included 5.8 GHz Transmitter 

The Phantom 2 Vision+ features an included 5.8 GHz RF remote transmitter, with dual toggle joystick controls similar to the kind found on 

other multi-rotor RC aircraft. The left stick controls throttle (up/down) and yaw (essentially rotation). And the right stick controls roll (sideto-side tilt) and pitch (tilting the nose up or down). A switch on the top right lets you choose between Attitude and GPS flight modes and a 

similar switch on the left lets you select between IOC modes. The control unit also features a detachable mount for holding your 

smartphone 

LED Status Indicator 

LED status light on the rear struts of the Phantom 2 Vision provides you with various feedback as well as warnings. Colors alternate 

between green, amber, and red and can either be flashing or solid. These messages give you valuable information such as whether the GPS 

system is properly calibrated, warning you the battery is getting low or telling you the remote's signal is out of range 

Self-Tightening Rotor 

The Phantom 2 features a rotor design that is new for this model. There is no longer a separate prop nut and the threading is designed to be 

self-tightening, so there is no danger of a loose prop coming off in flight