JULY 12 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington DC 20590 

Petition of Greg Nelson's for Exemption Pursuant to Section 333 of the FAA 

Modernization and Reform Act 2012 

Dear Sir and or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 and 14 

CFR Part 11, Greg Nelson hereafter refer to as petitioner hereby applies for an 

exemption from Federal Aviation Regulations (FARs) details below for the Phantom 

3 Professional here after referred to as UAS. 

Attachments; References 

1.Phantom 3 User Manual 

2.Phantom Pilot Training 

The Petitioner requests exemption from the following sections of Title 14 Code of 

Federal Regulations: 814 CFR 61.103, 61.113a, 61.113b, 91.119c, 91.121, 91.151a,b 

91.405a, 91407a1, 91.409a1, 91.409a2, 91.417 a+b, 

This exemption would provide commercial operation of UAS craft by the petitioner 

in airspace regulated by FAA to provide aerial surveying, aerial photography, real 

estate surveying, crew member training, news gathering, fire, rescue, scientific air 

quality evaluation in hazardous conditions, and mapping services. The FAA's 

approval of this application will support various industries, benefit the 

environment, and build a new business model, all of which are in the public interest. 

Operations are to be completed only at the request of clients with their full 

permission to facilitate commerce and awareness of the benefits ofUAS craft. The 

petitioner's operation under the exemption is subject to strict operating 

requirements and procedures to ensure the highest safety standards at all times. 

Following outlined procedures of attachments 1-2.0perations are within and under 

the control outlined herein or as maybe established by the FAA under section 333. 

(I) 
Exemption from the the following FARs is requested for the following reasons: 

814 CFR 91.103 PREFLIGHT 

Petitioner requests relief do to the fact that DJI's UAS craft do not have published 

approved Airplane or Rotorcraft Manual containing takeoff and landing distances. It 

can be said they operate below 400 feet. They follow preflight actions outlined in 

attachments 1,2. 

814 61.113a; 61.113b 

The Petitioner requests exemption to benefit the utilization of pilots who hold a 

sports certificate or greater. Any pilots operating under this exemption are required 

to comply with any all conditions as set forth in previously granted exemptions. 

814 91.119c 

The Petitioner requests an exemption to operations closer than 500 feet as UAS craft 

are supposed to fly below 400 feet. They need this exemption to allow for 

reasonable and responsible operations in areas of subdivisions and neighborhoods 

and other areas if required. As set forth in the Operations Manual, the UAS craft will 

be operated in a safe and uncongested area, where buildings and people will not be 

flown near without their pre-obtained consent. This allows for property owners, 

participants, and all affected individuals to be aware of planned flight operations. 

The DJI UAS demonstrates that they can be safely used at these lower altitudes and 

closer environments to do the job they are intended for. 

814.121 

Petitioner seeks exemption due to fact that UAS craft uses a GPS for altitude 

indication. Barometric pressures are not used in a UAS craft. 

814 CFR 91.151a,b 

Petitioner requests exemption as UAS craft uses batteries for fuel and has a total 

flight limitation of about 20 minutes due to this fact. Therefore they cannot meet the 

reserve requirement for this section. Given the UAS craft flight duration proposed 

flight plans for these UAS craft must conform to a flight area and safety margin 

within their limitations. A battery alarm is in place, which indicates when the UAS 

craft must land to stay within its safety limitation for flight duration. 

('J.) 
814 CFR 91.405a, 91.407al, 91.409al, 91.409a2, 91417a, 91417b 

Petitioner seeks exemption as the UAS craft inspections to insure safe operations 

are included in the attachments 1,2. These operating documents provided by 

petitioner describe the conditions, limitations and requirements for maintenance, 

inspection, and proper record keeping. These are adequate to ensure that safety is 

foremost and maintained 100 percent. 

UAS Craft DJI Phantom 3 Professional 

The requested exemption would allow precise commercial operation of the 

petitioners UAS Craft. These craft weight between 5 and 20 lbs. with a top speed of 

under 80mph with preset ceiling of 400 feet allow for precision services to 

perspective clients. Preforming invaluable services that larger conventional fix wing 

and rotational craft simply cannot preform as efficiently. These UAS Craft can 

preform precision aerial surveying, aerial photography, real estate surveying, 

crewmember training, newsgathering, fire, rescue, scientific air quality evaluation in 

hazardous conditions, and mapping services. They also reduce fuel emissions 

providing environmental benefits. Flight operations under the 333 exemptions are 

subject to strict requirements and rules to insure an equal level of safety to current 

authorized operations using manned aircraft. These conditions maybe modified by 

the FAA as required by the 333 Exemption. 

The UAS Crafts will at low altitude under 400 feet, 5 miles away from any airport, 

and in accordance with procedures and rules laid down in attachments 1,2. The UAS 

Craft will utilize control features conforming to prescribed limitations. The UAS 

Craft will operate in air space approved by the FAA. 

The UAS Crafts will be operated by a pilot in control known as PIC. PIC will hold a 

minimum Sports Certificate and a valid drivers license. PIC will operate UAS Craft 

with a clear line of sight of the UAS Craft with no visual aids other then prescription 

eyeglasses. In addition to the PIC flying the craft a visual observer known as the VO 

must be present while the UAS is flying to insure safety looking out for where the 

PIC is flying. The PIC and VO must be within speaking distance at all times during 

the flight. 

Enhanced safety and the fulfillment of the FAA Administrator's responsibilities 

under Section 333c of the reform Act to" established requirements for the safe 

operation of such aircraft systems in the national airspace system" will be moved 

forward with approval of these exemptions. 

(?) 
FAA exemptions references 1-2. Conditions and Limitations Section will be used in 

order limit risk and enhance public safety. Preflight checklist will be used to ensure 

that the UAS Craft's airworthiness will be maintained prior to each launch. 

Public Operation 

The use ofUAS Craft compared to manned aircraft for these operations (aerial 

surveying, aerial photography, real estate surveying, crew member training, news 

gathering, fire, rescue, scientific air quality evaluation in hazardous conditions, and 

mapping services) will enhance safety and lead to economic growth. The UAS Craft 

can simply do work that manned aircraft cannot do in many specific circumstances. 

The Petitioner will provide these services acting as an independent contractor. 

Providing jobs for certified Pilots and visual observes as both will be used to 

complete services. Liability insurance has been applied for and will be in effect 

when this Exemption is granted. Information can be submitted to FAA COA monthly 

reports or by any other means required or requested. The Petitioner wants to be a 

responsible participant in this new industry and sees a tremendous need for these 

services. The petitioner prays that this 333 Exemption be granted so that the 

Petitioner may go to work under the rules and regulations of the FAA. 

Conclusion 

The Petitioner is requesting 333 Exemption for the following services: aerial 

surveying, aerial photography, real estate surveying, crew member training, news 

gathering, fire, rescue, scientific air quality evaluation in hazardous conditions, and 

agricultural spraying they can be rendered safely saving money and may even save 

life. The objective of Petitioner is to provide these services safely, efficiently, and 

legally to enhance the clients needs. 

The Petitioner has over 30 years of experience in robotics. Petitioner also has 

certified Pilots within our group. I will be enrolled in flying lessons September 2015. 

Sincerely and respectfully 

Greg 

-~~ Nelson 

843 3648900 

4466 Hope Plantation Dr. 

Johns Island SC 29455 
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