May 25, 2015 

Travis Bedell

Pacific Aerial Surveyors

7619 Canberra Way 

Riverside, CA 92508

petition to the Federal Aviation Administration (FAA) for an 

exemption from part 21, subpart H; and Sections 

45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 

91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 

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

(b) of Title 14, Code of Federal Regulations (14 CFR). The 

proposed exemption would allow Pacific Aerial Surveyors 

to operate the PHANTOM 2 Vision+ quad-copter 

unmanned aircraft system (UAS) to conduct 

aerial photography and videography for construction 

surveying purposes. A grant of exemption to petitioner 

would lower carbon imprints (in comparison to jet turbine 

helicopters currently used), risk of injury/death to pilots/

passengers aboard currently used jet turbine helicopters 

and those in proximity of it’s flight path, and total costs of 

projects by reducing amount of jet turbine helicopter flight 

time (directly benefiting certain Mello-Roos and property 

tax payers in surrounding area of project).

The petitioner supports his request with the following 

information:

The petitioner has provided the following information – 

contained in his petition and supporting documentation 

including: 

 1) Supplemental Response for Petition 

Page 1 of 5

(951) 990-6859

PacificAerialSurveyors@yahoo.com

7619 Canberra Way

Riverside, CA 92508

PACIFIC AERIAL SURVEYORS
 2) PHANTOM Flying Flow Chart V1.0 (Simplified 

Version), PHANTOM Quick Start Manual v1.7, PHANTOM 

Advanced Manual v.1.4, 

 3) PHANTOM 2 Vision+ User Manual 

 4) restricted areas map 

 5) Safety/Preflight Checklist (all hereinafter referred 

to as operating documents).

The FAA has organized the petitioner’s information into 

these sections: 

 1) the unmanned aircraft system (UAS) and 

 operating parameters 

 2) the UAS Pilot In Command (PIC), 

 3) Public Interest.

Unmanned Aircraft System

The petitioner states he plans to operate a UAS, the 

PHANTOM 2 Vision+, which is comprised of an 

unmanned aircraft (UA or PHANTOM) and a transportable 

ground station.

The PHANTOM is referred to as a quad-copter with a 

maximum gross weight of about 3 pounds. It is equipped 

with four rotors that are driven by electric motors powered 

by batteries. The UA has a maximum airspeed of 30 

knots. Petitioner plans to operate the UA over various 

areas in Southern California to lower project costs, 

increase project safety, and lower the environmental 

impact.

Petitioner makes the following representations of 

operational enhancements which he proposes to abide by 

to ensure this exemption will provide a level of safety at 

least equal to existing rules:

Page 2 of 5
• He will only operate in reasonably safe environments 

that are strictly controlled, are away from airports and 

actively populated areas. All operations are conducted 

during daytime Visual Flight Rules (VFR) conditions and 

within visual line of sight (VLOS) of the pilots; and

• He will conduct extensive preflight inspections and 

protocols, during which safety carries primary importance.

The petitioner states that given the size, weight, speed, 

and limited operating area associated with the aircraft to 

be utilized by him, an exemption from 14 CFR part 21, 

Subpart H (Airworthiness Certificates) and § 91.203 (a) 

and (b) (Certifications required), subject to certain 

conditions and limitations, is warranted and meets the 

requirements for an equivalent level of safety under 14 

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

Petitioner requests an exemption from § 45.23 Marking of 

the aircraft because his UA will not have a cabin, cockpit 

or pilot station on which to mark certain words or phrases. 

Further, he states that two-inch lettering is difficult to place 

on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. Regardless of this, 

petitioner states that he will mark his UAS in the largest 

possible lettering by placing the word “Experimental” on 

its fuselage as required by § 45.29(f) so that he or anyone 

assisting him as a spotter will see the markings.

The petitioner states that an exemption from §§ 91.405(a), 

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

Maintenance inspections may be required and should be 

granted since they only apply to aircraft with an 

airworthiness certificate. However, the petitioner states as 

a safety precaution he will perform a preflight inspection of 

his UAS before each flight as outlined in his operating 

documents.

Page 3 of 5
UAS Pilot in Command (PIC)

The petitioner asserts that under § 61.113 (a) and (b) 

private pilots are limited to non commercial

operations, however he can achieve an equivalent level of 

safety as achieved by current regulations because his 

UAS does not carry any pilots or passengers. Further, 

he states that, while helpful, a pilot license will not ensure 

remote control piloting skills. He further indicates that the 

risks of operating a UAS are far less than the risk levels 

inherent in the commercial activities outlined in 14 CFR 

part 61, et seq., thus he requests an exemption from § 

61.113 Private Pilot Privileges and Limitations: Pilot in 

command.

Regarding UAS operational training, the petitioner states 

he has flown numerous practice flights in remote areas as 

a hobbyist simulating flights for future commercial use to 

gain familiarization with the characteristics of his UAS’ 

performance under different temperature and weather 

conditions. He further states that he practices 

computerized simulated flights to maintain adequate skills 

and response reflex time.

Public Interest 

Environmental;

Aircraft engine exhaust consists mainly of N2, O2 

(oxygen), NOx, CO2, H2O (water vapor), CO, UHC 

(unburnt hydrocarbons), soot, and SOx (oxides of 

sulphur). NOx are combustion by-products while CO2 and 

H2O are the final products of the combustion process.

The considered UAS produces zero of these emissions, 

directly benefiting surrounding publics air quality. 

Page 4 of 5
Surrounding public can also be affected by noise pollution 

benefits. 

Safety; 

Safety is of large concern on every construction project. 

Lowering the possibility of death/injury by utilizing the 

considered UAS in comparison to jet turbine helicopter 

directly affects publics interest. 

Costs; 

Reduction of total project costs by applying the considered 

UAS instead of jet turbine helicopter can benefit local 

property tax payers. Petitioner states that even indirectly, 

the cost savings of the UAS are in the publics interest. 

In a supplemental request to the FAA, the petitioner 

requests consideration of a "blanket" COA for flights at or 

below 200 feet, or a 120 day temporary airman certificate 

in accordance with § 63.13, to allow the FAA time to 

establish minimum UAS airman certification standards.

Page 5 of 5