04 August 2015

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, DC 20590

Subject: Petition for Exemption under Section 333 of the FAA Modernization & Reform 

Act and Title 14, Part 11 of the Code of Federal Regulations (CFR)

Dear Sir/Madam,

Pursuant to Section 333 of the FAA Modernization and Reform Act and 14 C.F.R. Part 

11, FlightGraphix LLC, a Texas based Limited Liability Company, hereby applies for 

exemption from certain Federal Aviation Regulations, utilizing the commercial operation 

of the DJi Phantom Vision 2+ UAS (N568AF). The requested exemption would support 

an application for a “blanket” commercial Certificate of Authorization (COA) to operate 

the DJi Phantom Vision 2+ UAS with the following flight restrictions: 

• Flight operations below 200 feet AGL

• UAV will less than 55 pounds

• Flight operations during daytime Visual Flight Rules (VFR) conditions and within 

visual line of sight (VLOS) of the pilots 

• And during flight, staying certain specified distances away from airports or 

heliports

FlightGraphix LLC service offerings consists of collecting aerial data for surveys,

inspections, and marketing in construction, roofing, and real estate. FlightGraphix LLC,

will serve all three types of markets in the residential, commercial, and government 

sectors. The operations will commence in the North Texas region and later expand into 

other geographical areas throughout the state and nation. The DJi Phantom Vision 2+

UAS consists of - a lightweight, battery operated aircraft (2.73 lbs including batteries and 

propellers), a computer based ground control station with video downlink support, a 

remote control with range extender, and an onboard camera with a secure gimbal mount. 

The DJi Phantom Vision 2+ is a popular and compliant UAS, having previously 

demonstrated to meet specific safety and operational requirements. Some of the Dji 

Phantom Vision 2+ features consist of: auto-return home and landing, intelligent 

orientation control, advanced power management, precision flight and stable hovering, 

and a 25 minute flight time with a smart battery (data retrieved from

http://www.dji.com/product/phantom-2-vision-plus/spec).The UAV will be carrying the 

standard-equipped Phantom Vision 2+ HD camera attached with the standard gimbal 

mount. The hardware will be downlinked to a Ground Station on the 2.4 GHz frequency 

band. The Pilot in Command (PIC) will be using the DJi Pilot mobile app, or other apps

developed specifically for the Phantom Vistion 2+, for aircraft navigation and data 

storage. The DJi Phantom Vision 2+ will be later be separately equipped with an infrared 
sensor for infrared inspections, once UAV’s are approved for night flight (pending FAA 

regulation approval).

The UAS will be observed at all times through line of sight with a Pilot in Command 

(PIC) and a Visual Observer (VO). The high-resolution aerial data collected through the 

onboard high-definition camera and infrared sensors will provide information that will be 

in high demand in the roofing, real estate, and construction industry. Also, any research 

and development will consist of a PIC and VO using the onboard camera, infrared sensor, 

and downlink to collect data benefiting the roofing and construction industry.

The aircraft will be operated in accordance with both a PIC and a VO, in accordance 

with, FAA Order 8900.1 Volume 16 “Unmanned Aircraft Systems” with the following 

rules and exemptions:

• All operations will not take place over 400 feet AGL in any airspace, but can 

operate in controlled airspace (Class C, Class D, and Class E) and uncontrolled 

airspace (Class G) in accordance with FAA Order 8900.1 Volume 16. The PIC 

will, at a minimum, hold a FAA private pilot’s license and have a current third 

class medical certificate.

• The aircraft will not exceed an airspeed of 50 knots.

• The weight of the aircraft will never exceed 20 lbs. when fully equipped. 

• FlightGraphix LLC will perform any necessary requirements to inform aircraft 

and airmen in same controlled and uncontrolled airspace of our operations.

• Operations will take place over public or private property with prior permission 

and signing of a waiver by land owner and/or homeowner and flying will be 

confined to the property.

• When necessary, applicable permits will be requested from local authorities.

• The aircraft will not be operated over densely-populated urban areas, but will take 

place in suburban and rural areas

• The aircraft will not be operated at air shows or over a large, open mass of people

• The aircraft will not operate over roads with high-density traffic

• The aircraft will not operate in high wind conditions

• The aircraft will be kept away from high voltage power lines, trees, and bodies of 

water while in flight

• FlightGraphix LLC will take notice to no-fly zones and temporary flight 

restrictions (TFR)

• The aircraft will not be operated within 5 nautical miles of an airport or helipad, 

unless prior permission is first granted through air traffic control (ATC), or the 

proper authorities

• Operations will be limited in windy conditions and operations will not commence 

if wind exceeds 15 knots

• Operations will be limited to day, visual meteorological conditions

• Aircraft will remain within 500 feet of the PIC and VO and within line of sight. 

• While the aircraft is in flight, the VO will remain within voice distance with the 

PIC
Based on a fully qualified flight crew, the UAS aircraft model, and general 

compliance with most of the regulations for UAS operations, the FAA can have the 

greatest confidence that FlightGraphix LLC will operate in safe and knowledgeable

manner at all times during their operations. Additional documents will be supported 

with this request, including a Certificate of Authorization (COA).

Sincerely,

Christopher M. Suldo

FlightGraphix LLC
Chris Suldo

FlightGraphix LLC

2807 Allen St. #379

Dallas, TX 75204

Phone Number: 817-703-2448

E-mail: csuldo@gmail.com

Website(s): 

www.flightgraphix.com

Relief Sought From Following Section(s):

FlightGraphix LLC petitions for exemptions from the following regulations listed in Title 

14 Code of Federal Regulations (CFR):

• 14 CFR Part 21, Subpart H

• 14 CFR Part 45.23 

• 14 CFR Part 45.27 

• 14 CFR Part 45.29

• 14 CFR Part 61.113 

• 14 CFR 61.133

• 14 CFR Part 91.9

• 14 CFR Part 91.103

• 14 CFR Part 91.109 (a)

• 14 CFR Part 91.119

• 14 CFR Part 91.121 

• 14 CFR 91.151

• 14 CFR 91.405 

• 14 CFR 91.407 

• 14 CFR 91.409 

• 14 CFR 91.417 

Relief Defined For Exemption 

In order to perform these commercial operations, FlightGraphix LLC will seek relief in 

the following manner:

• 14 CFR Part 21, Subpart H

These regulations state procedural requirements for the issue of airworthiness 

certificates and 21.19 (a) addresses research and development including testing 

new aircraft design concepts, new aircraft equipment, new aircraft installations, 

new aircraft operating techniques, or new uses for the aircraft. FlightGraphix LLC 

requests an exemption from this regulatory 14 CFR Part 21, Subpart H, due to the 

fact the UAS will be in compliance with safety and FAA airworthiness standards, 
without the need for an airworthiness certificate. The aircraft will not be carrying 

any passengers or fuel and will fly under strict operational requirements and 

supervision. 

• 14 CFR Part 45.23 - Display of Marks 

These regulations state that each aircraft display an “N” and the aircraft’s 

registration number and letters are at least three inches high. Drone Roofing & 

Construction LLC requests an exemption from 45.23. If the FAA requires an “N” 

number to be placed on the UAV, the aircraft N-Number will be sized and 

displayed, according to the amount of space available on the UAV. 

• 14 CFR Part 45.27 – Location of Marks

These regulations state that each operator of the rotocraft must display on that 

rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or the tail 

marks required by 45.23. FlightGraphix LLC requests exemption from 45.27 and 

will locate the marks on the UAV according to the amount of space available.

• 14 CFR Part 45.29 – Size of Marks

These regulations state that on rotorcraft the marks need to be at least 12 inches 

high and two-thirds as wide as they are high. FlightGraphix LLC requests 

exemption from 45.29 and the marks will be sized on the UAV, according to the 

amount of space available.

• 14 CFR Part 61.113 – Private Pilot Privileges and Limitations: Pilot in Command 

and 61.133 Commercial Pilot Privileges and Limitations

FlightGraphix LLC currently requests exemption from 14 CFR Part 61.113 and 

14 CFR 61.133. Drone Roofing & Construction LLC proposes if the operation 

takes place in controlled airspace (Class C, Class D, Class E) and/or uncontrolled 

airspace (Class G) the PIC will, at a minimum, hold a FAA private pilot’s license

and possess a current third class medical certificate. FlightGraphix LLC will be 

operating for commercial purposes, line of sight (500 feet) and under 400 ft AGL. 

The UAS has navigation and a control unit, comprised of a Ground Control 

Station (GCS) and auto-pilot system, and all flights will utilize precision GPS 

guidance. In the case of unplanned events, the operator can input evasive 

maneuvers from the control unit, and the control unit executes that maneuver. 

Operator interventions include - diversion to the right, initiation of holding at 

present position, suspension of mission, fly back to launch point, fly to point and 

hold, abort mission and land, and emergency power cut off and land (Flight 

Termination System). By having these control capabilities, we believe the PIC 

will be fully capable of operating the UAS in commercial operations in 

uncontrolled and controlled airspace in commercial operations.
• 14 CFR Part 91.9 – Civil Aircraft Flight Manual, Marking, and Placard 

Requirements

This regulation requires that no person may operate an aircraft unless a current, 

approved flight manual is in the aircraft. Since the aircraft is too small to carry 

documentation and the aircraft is unmanned, we would like to request exemption 

from this 91.9. However, the PIC and VO will carry a current an aircraft flight 

manual near the ground station during all operations. 

• 14 CFR Part 91.103

This regulation requires that each pilot in command takes certain actions before 

flight to ensure safety of the flight operations. FlightGraphix LLC would like to 

request an exemption from 91.103. FlightGraphix LLC will be performing their 

own quality pre-flight inspections – to include – checking weather and 

atmospheric conditions for flight permissibility, checking battery requirements, 

checking landing zones, and inspecting the equipment for any malfuctions or 

structural problems. 

• 14 CFR Part 91.109 (a)

This regulation requires dual controls for for civil aircraft involved in flight 

instruction. FlightGraphix LLC would like to request an exemption from 

91.109(a) and will be utlizing the UAS in commercial operations and flight

instruction as a remotely operated aircraft. Therefore, dual controls will not be a 

necessary requirement for commercial operations and/or flight instruction.

• 14 CFR Part 91.119 – Minimum Safe Altitudes – General

This regulation specifies that over sparsely populated areas, aircraft cannot be 

operated closer than 500 feet to any person, vehicle, vessel, or structure. Since the 

aircraft will be operating at less than 400 ft AGL, FlightGraphix LLC will request 

an exemption from 91.119.

Our safety measures include notifying the land or property owner before hand and 

receiving permission to fly within 500 ft. The land or property owner will be 

informed of all possible hazards and risks associated with the flight to people and 

property. Due the lightweight of the DJi Phantom Vision 2+, the unmanned 

aircraft does not pose such a safety threat like a manned aircraft poses to people 

and property. The DJi Phantom Vision 2+ will not be operated over any open air 

assembly of people. In case of a mechanical system failure, the DJi Phantom 

Vision 2+ will be operating at an altitude where a safe emergency landing can 

occur without any hazards to people or property. FlightGraphix LLC will be 

keeping a minimum of $1,000,000 dollars in liability insurance. 

• 14 CFR Part 91.121 
This regulation states that aircraft shall maintain cruising altitude by reference to 

an altimeter setting available within 100 nautical miles of aircraft. FlightGraphix 

LLC will request an exemption to 91.121. The DJi Phantom Vision 2+ will be 

flying below 400 ft AGL and the altitude will be determined based on the 

barometric pressure at the time of flight. Since the maximum operating time for 

the DJi Phantom Vision 2+ is approximately 25 minutes, there will not be a rapid 

change in barometric pressure affecting altimiter settings.

• 14 CFR 91.151

This regulation states that no person may begin a flight in an airplane under 

Visual Flight Rules (VFR) conditions, unless there is enough fuel to fly to the first 

point of intended landing and, assuming normal cruising speed, (1) During the 

day, to fly for at least 30 minutes; or (2) At night, to fly after that for at least 45 

minutes. FlightGraphix LLC will request an exemption to 91.151. The DJi 

Phantom Vision 2+ is a battery operated aircraft and the maximum operation of 

the flight with full payload is 25 minutes. Since the aircraft will never fly more 

than .5 miles from the point of intended landing, a full battery charge at launch 

and landing the aircrat with 20% charge (5 minutes) is more than enough time for 

performing a landing. 

• 14 CFR 91.405

This regulation requires, in pertinent part, that an aircraft operator or owner shall 

have that aircraft inspected as prescribed in Subpart E of the same part and shall, 

between required inspections, except as provided in paragraph (c) of the same 

section, have discrepancies repaired as prescribed in part 43 of the chapter.

FlightGraphix LLC will request an exemption to 91.405. FlightGraphix LLC will 

inspect the UAS prior to each flight for mechanical or structural discrepancies and 

malfunctions to ensure airworthiness. Drone Roofing Solutions will follow the 

maintenance requirements set forth by the manufacturer – DJi. Additionally, 

FlightGraphix LLC will perform maintenance dealineated by the FAA as 

pertinent for UAS operations. 

• 14 CFR 91.407 

This regulation requires that no person may operate any aircaft that has undergone 

maintenance, preventitive maintenance, rebuilding, or alteration unless it has been 

approved for return to service by a person authorized under 43.7 of the same 

chapter. FlightGraphix LLC will request an exemption from 91.407. The PIC, 

VO, and authorized personnel will ensure proper maintenance and inspection of 

the aircraft and be fully authorized to approve aircraft fit for flight. 

• 14 CFR 91.409

This regulation requires inspections of an aircraft. FlightGraphix LLC will request 

an exemption from 91.409. The PIC, VO, and authorized personnel will ensure 

proper maintenance and inspection of the aircraft and be fully authorized to 

approve aircraft fit for flight.
• 14 CFR 91.417 

This regulation requires records being maintained for maintenance and alterations 

and how long to keep the records. FlightGraphix LLC will ask for an exemption 

from 91.417. FlightGraphix LLC does not feel the maintenance and alterations 

performed to the UAS will need to be documented.

Benefit To The Public

In 2009, four of the top 10 most frequently cited OSHA violations were directly related to 

commercial roofing, including: scaffolding requirements, fall protection and training, and 

ladder requirements. Out of numerous possible violations, scaffolding was first and fall 

protection was second. In 2008, more than 1,200 scaffolding-related citations were issued 

with more than $1.1 million in penalties. Clearly it is a common safety violation, as well 

as a financially burdensome one.

Additionally, fall protection takes center stage in commercial roofing safety, as falls are 

one of the leading causes of death in commercial industries. According to the National 

Safety Council, over 6,000 people die from falls each year caused by such factors as 

falling off roofs and ladders. And to emphasize the importance of safety in the 

commercial roofing industry - more than 30,000 people are injured annually as a result of 

falls involving ladders.

FlightGraphix LLC’s operations will benefit the public by offering a safer solution for 

roofing inspections, surveys, and estimates. Roof inspections are one of the most 

dangerous jobs today, and utilizing UAVs, the roofers/adjusters would not have to walk 

around roofs for roofing inspections/surveys/estimates. Additionally, FlightGraphix LLC 

‘s will be operating unmanned aircraft that poses no flight risks to pilots. 

Through our UAS operations and research and product development undertakings, we 

will be able to more effectively troubleshoot roofing issues, save time and money for 

contractors and insurance companies, and provide better solutions for our clients in 

roofing and construction industry. 

Additional benefits include local job creation due to hiring of staff under our Company. 

Argument in Support of Application

FlightGraphix LLC understand the important and value of using UAV’s and UAV

technology in the roofing and construction industry. FlightGraphix LLC is filing for a 

petition under Section 333 of the FAA Modernization & Reform Act, in order to become 

an independent provider of inspection, monitoring, surveying, and measuring services to -

contractors, residents, businesses, governments, and any other entities. The use of a UAS

will provide time and cost savings for residential, commercial, and government clients. 

Because of this time saving solution, the UAS flying service(s) will be in high demand in 

roofing and construction. We will utilize the proven DJi Phantom Vision 2+ camera and 

aircraft sensors for our operations. 
In the roofing industry, a demand exists for this service due to safety issues that exist 

when roofers access dangerous roofs for inspections and/or measuring. It is extremely 

dangerous for roofers to walk on roofs, especially roofs with a high pitch and many steep 

angles. Our Company can completely eliminate this risky procedure by using our UAS

platform to perform the service for private and public clients. 

In the construction industry, a demand exists due to cost and time constraints. It is 

relatively cheaper and quicker to perform the surveying, inspection, and monitoring 

services utlizing an unmanned aircraft, rather than a manned aircraft.

Safety and Adherence and Benefit Thereof

FlightGraphix LLC will at all times operate UAVs within visual line of sight of the 

operator, fly less than 400 feet AGL, and only during daylight conditions. The operations 

will take place inside Class G (uncontrolled airspace) and, if flying in controlled airspace, 

FlightGraphix LLC will obtain prior approval from ATC before operations can 

commence. Before each flight, the UAVs and ground station systems will be visually and 

operationally inspected for any mechanical or structural problems as part of pre-flight 

safety measures. Any additional UAV pilots flying for FlightGraphix LLC will have to be 

approved by the FlightGraphix LLC owner to ensure they are capable of flying the UAS 

in a safe and effective manner. This may involve additional flight training outside of 

normal operations. FlightGraphix LLC will at all times follow all applicable regulations 

listed in 14 CFR Parts 60 and 91. The owner of the Company is FAA certified rotorcraft 

private pilot and acknowledges and understands the NAS and the FAA’s rules and 

regulations. We will also be attending UAV operating and educational classes to provide 

a more effective and safe flying service. The owner also possess direct experience in 

airspace regulations, aeronautics, traffic patterns, flying, pilot training, maintenance, and 

safety standards. This will provide extra safety measures beyond what a normal UAV 

operator may possess. FlightGraphix LLC will also carry liability insurance with a 

minimum of $1,000,000 in coverage. 

Summary That Can Be Published In The Federal Register

Description of Relief Sought:

The Limited Liability Company, FlightGraphix LLC, is requesting a petition for 

exemption under Section 333 of the FAA Modernization & Reform Act and Title 14, Part 

11 of the Code of Federal Regulations (CFR). The Company will operate the DJi 

Phantom Vision 2+ with an equipped HD camera on a camera mount downlinked to a 2.4 

Ghz ground station on a commercial basis. FlightGraphix LLC service offerings consists 

of collecting aerial data for surveys, inspections, and marketing in construction, roofing, 
and real estate. FlightGraphix LLC, will serve all three types of markets in the residential, 

commercial, and government sectors. FlightGraphix will be geographically expanding at 

a future date. FlightGraphix LLC will also be using the DJi Phantom Vision 2+ with a 

equipped camera for research and product development in the roofing and construction 

industry. These operations will assist clients with their real estate and construction 

product and service needs. The Company will abide by FAA laws and regulations 

governing operations of aircraft in the National Airspace System (NAS). 

Petitioning Company:

FlightGraphix LLC

FAR’s that FlightGraphix LLC Will Be Petitioning For Exemption:

FlightGraphix LLC petitions for exemptions from the following regulations listed in Title 

14 Code of Federal Regulations (CFR):

• 14 CFR Part 21, Subpart H

• 14 CFR Part 45.23 

• 14 CFR Part 45.27 

• 14 CFR Part 45.29

• 14 CFR Part 61.113 

• 14 CFR 61.133

• 14 CFR Part 91.9

• 14 CFR Part 91.103

• 14 CFR Part 91.109 (a)

• 14 CFR Part 91.119

• 14 CFR Part 91.121 

• 14 CFR 91.151

• 14 CFR 91.405 

• 14 CFR 91.407 

• 14 CFR 91.409 

• 14 CFR 91.417