511	E	San	Ysidro	Blvd	Suite	402,	San	Ysidro,	CA	92173

www.planehill.net					contact@planehill.net

Phone:	(619)	800-7359

February	8,	2016

U.	S.	Department	of	Transportation

Docket	Management	System	

West	Building	Ground	Floor,	Room	W12-140

1200	New	Jersey	Avenue,	SE	

Washington	DC	20590

RE:	Exemption	Request	Section	333	of	the	FAA	Reform	Act

Dear	Sir	or	Madam:

We	respectfully	request	exemption	under	Section	333	of	the	FAA	Reform	ACT	and	Part	11	of	the	

Federal	Aviation	Regulations.

Petitioner:

Plane	Hill	LLC

511	E	San	Ysidro	Blvd	Suite 402

San	Ysidro,	CA	92173

Telephone:	(619)	800-7359

Cell:	760-750-0728

Email: contact@planehill.net

PLANE	HILL	LLC intends	to	incorporate	the	use	of	Unmanned	Aircraft	Systems	(UAS)	for	a	variety	

of	 projects	 which	 may	 include	 but	 not	 be	 limited	 to	 project	 and	 construction	 management,	

inspections	 and	 monitoring;	 environmental	 review	 projects;	 aerial	 surveying;	 agricultural	

projects;	 educational	 and	 research	 projects;	 remote	 sensing	 projects;	 wildlife	 and	 forestry	

monitoring	projects;	aerial	filmmaking;	photography	and	real	estate	purposes;	search	and	rescue,	

etc.
511	E	San	Ysidro	Blvd	Suite	402,	San	Ysidro,	CA	92173

www.planehill.net					contact@planehill.net

Phone:	(619)	800-7359

Specific	Section(s)	seeking	exemption:

14	C.F.R	Part	21

14	C.F.R	45.23(b)

14	C.F.R	61.113(a)	and	(b)

14	C.F.R	91.7(a)

14	C.F.R	91.9(b)(2)

14	C.F.R	91.109

14	C.F.R	91.119

14	C.F.R	91.121

14	C.F.R	91.151(a)

14	C.F.R	91.203(a)	and	(b)

14	C.F.R	91.215

14	C.F.R	91.104	through	91.417

Extend	of	relief	requested:

To	 permit	 commercial	 operation	 of	 Small	 Unmanned	 Aircraft	 Systems	 (UAS)	 for	 operations	

conducted	within	and	under	the	conditions	outlined	herein	or	as	may	be	established	by	the	FAA	

as	required	by	Section	333.

Said	 exemption	 would	 permit	 the	 operation	 of	 (UAS)	 under	 controlled	 conditions	 in	 limited,	

predetermined	 and	 controlled	 airspace.	 Upon	 granting	 of	 this	 proposed	 exemption	 request,	

PLANE	 HILL	 LLC would	 conduct	 commercial	 operations	 of	 (UAS)	 meeting	 or	 exceeding	 all	

operational	and	safety	requirements	per	Section	333.
511	E	San	Ysidro	Blvd	Suite	402,	San	Ysidro,	CA	92173

www.planehill.net					contact@planehill.net

Phone:	(619)	800-7359

Public	Benefit:

1. Project	and	construction	management,	inspections	and	monitoring.	The	use	of	(UAS)	on	

construction	sites	may	improve	the	safety	of	workers,	local	residents	and	general	public

by	 assessing	 potential	 dangerous	 situations.	 Falls	 and	 injuries	 may	 be	 reduced	 or	

eliminated	 through	 a	 more	 thorough	 review	 of	 the	 construction	 sites.	 In	 some	 cases,	

(UAS)	may	reduce	the	reliance	of	helicopters	or	small	aircraft	to	monitor	said	sites.	This	

may	improve	safety	as	well	as	reduce	environmental	impact	by	reducing	energy	usage.

2. Environmental	Review	projects.	The	use	of	(UAS)	during	the	process	of	reviewing	projects	

as	required	by	24	C.F.R.	50.4,	58.5	and	58.6	would	provide	a	more	in-depth	Environmental	

Review	of	the	project	site	as	well	as	surrounding	areas.	Reliance	of	helicopters	or	small	

aircraft	may	be	eliminated.

3. Aerial	surveying.	The	use	of	 (UAS)	in	connection	with	aerial	surveying	of	smaller	areas	

may	eliminate	the	use	of	helicopters	or	aircraft.	This	could	provide	a	more	cost	effective,	

safer	and	more	energy	efficient	product.

4. Agricultural	projects.	Wildlife	and	Forestry	projects.	The	use	of	 (UAS)	could	assist	with	

surveying	 agricultural	 projects	 as	 well	 as	 wildlife	 and	 forestry	 projects	 by	 providing	

information	when	problems	occur,	vermin	infestation,	fire	hazards,	etc.

5. Remote	 Sensing	 projects.	 The	 use	 of	 (UAS)	 could	 provide	 views	 and	 information	 for	

remote	and	inaccessible	areas.	This	could	promote	worker	safety	as	well	as	reduce	the	

reliance	on	helicopters	and	aircraft.

6. Educational	and	Research	projects.	The	use	of	(UAS)	could	provide	information	for	said	

projects	in	a	more	cost	effective	and	efficient	manner	than	other	available	options.

7. Aerial	filmmaking,	photography	and	real	estate	purposes.	The	use	of	(UAS)	may	provide	

a	 point	 of	view	 previously	 unavailable	 through	 other	means.	This	would	 be	more	 cost	

effective,	efficient	and	safer	than	helicopters	and	aircraft.

8. Search	and	 rescue.	The	use	of	 (UAS)	may	provide	assistance	 to	local	law	organizations	

during	search	and	rescue	missions.	(UAS)	may	reach	areas	unattainable	or	viewable	with	

helicopters	and	aircraft.	 (UAS)	may	 be	 implemented	 quicker	as	 time	 is	 of	 the	essence	

during	search	and	rescue	operations.
511	E	San	Ysidro	Blvd	Suite	402,	San	Ysidro,	CA	92173

www.planehill.net					contact@planehill.net

Phone:	(619)	800-7359

Reasons	why	the	exemption	would	not	adversely	affect	safety	or	how	the	exemption	would	

provide	a	level	of	safety	at	least	equal	to	the	existing	rule.

Proposed	 operations	 using	 (UAS)	 provide	 increased	 safety	 enhancement	 especially	 when	

compared	with	helicopters	and	aircraft	for	the	following	reasons:

1. The	 (UAS)	 operated	 will	 weigh	 less	 than	 55	 pounds	 including	 payload	 (camera,	 lens,	

gimbal,	etc.).

2. Flights	will	be	operated	within	the	visual	line	of	sight	of	the	pilot.

3. Maximum	 total	 flight	 time	 for	each	operational	 flight	will	be	 thirty	 (30)	minutes.	Flight	

times	may	be	less	than	thirty	(30)	minutes	as	the	(UAS)	will	continuously	monitor	battery	

reserve	and	return	to	the	ground	station	with	at	least	20%	battery	power	reserved.

4. Flights	will	never	exceed	400	feet	AGL.

5. Minimum	crew	for	each	operation	will	consist	of	the	(UAS)	pilot	and	a	Visual	Observer.

6. A	briefing	will	be	conducted	daily	by	all	personnel	working	with	said	(UAS).

7. All	 onsite	 personnel	 and	 client	 employees	 will	 be	 required	 to	 execute	 a	 waiver.	

Verbal/written	consent	will	be	required	of	all	persons	within	100	feet	of	flight	operation.

8. Written	and/or	oral	permission	from	relative	property	owners	will	be	obtained	prior	to	

operating	the	(UAS).

9. All	permits,	permissions,	etc.	will	be	obtained	from	local	government	offices	as	required.

10. The	 (UAS)	 will	 operate	 at	 speeds	 less	 than	 50	 knots,	 hover	 and	 simultaneously	 move	

vertically	and	horizontally.

11. The	(UAS)	will	have	the	capability	to	return	and	land	at	the	pre-determined	location	with	

the	Security	 Perimeter	 should	 the	 (UAS)	lose	 communication	 or	GPS	 signal	 during	any	

operations.

12. The	 (UAS)	will	have	 the	capability	 to	abort	a	 flight	in	case	of	unpredicted	obstacles	or	

emergencies.

13. Operations	 will	 not	 be	 conducted	 over	 densely	 populated	 areas	 or	 heavily	 traffic	

highways.

14. Operations	will	not	be	conducted	within	five	(5)	NM	of	an	airport	or	heliport.
511	E	San	Ysidro	Blvd	Suite	402,	San	Ysidro,	CA	92173

www.planehill.net					contact@planehill.net

Phone:	(619)	800-7359

PLANE	HILL	LLC will	abide	by	all	regulations	including	the	following:

1. 14 C.F.R.	Part	21 - Certification	Procedures	for	Products	and	Parts.	Airworthiness	

Certificates.

2. 14 C.F.R.	45.23	- Display	of	marks;	general	and	45.29	Size	of	marks.

3. 14 C.F.R.	61.113 - Private	pilot	privileges	and	limitations:	Pilot	in	Command	and	61.133	

Commercial	pilot	privileges	and	limitations.

4. 14 C.F.R.	91.7 - Civil	aircraft	airworthiness.

5. 14 C.F.R.	91.9	- Civil	aircraft	flight	manual,	marking	and	placard	requirements,

6. 14 C.F.R.	91.109	- Flight	instruction;	Simulated	instrument	flight	and	certain	flight	tests.

7. 14 C.F.R.	91.119	- Minimum	safe	altitudes:	general.

8. 14 C.F.R.	91.121	- Altimeter	settings.

9. 14 C.F.R.	91.151	- Fuel requirements	for	flight	in	VFR	conditions.

10. 14	C.F.R.	91.203	- Civil	aircraft:	Certifications	required.

11. 14 C.F.R.	91.205	- Powered	civil	aircraft	with	standard	category	U.S.	airworthiness	

certificates:	Instrument	and	equipment	requirements.

12. 14 C.F.R.	91.215	- ATC	transponder	and	altitude	reporting	equipment	and	use.

13. 14 C.F.R.	91.401	- Applicability.

14. 14 C.F.R.	91.403	- General.

15. 14 C.F.R.	91.405	- Maintenance	required.

16. 14 C.F.R.	91.407	- Operation	after	maintenance,	preventive	maintenance,	rebuilding	or	

alteration.

17. 14 C.F.R.	91.409	- Inspections.

18. 14 C.F.R.	91.411	- Altimeter	system	and	altitude	reporting	equipment	tests	and	

inspections.

19. 14 C.F.R.	91.413	- ATC	transponder	tests	and	inspections.

20. 14 C.F.R.	91.415	- Changes	to	aircraft	inspection	programs.

21. 14 C.F.R.	91.417	- Maintenance	records.
511	E	San	Ysidro	Blvd	Suite	402,	San	Ysidro,	CA	92173

www.planehill.net					contact@planehill.net

Phone:	(619)	800-7359

Equipment	and	Specifications

DJI	Phantom	3	Professional	Quadcopter	with	4K	Camera	and	3-Axis	Gimbal	Specifications:

Up	to	23	minutes	of	flight	time

HD	video	streaming	to	mobile

Top	speed:	12	mph

Max	Altitude:	400ft,	per	FAA	rules

Weight:	2.8	lb. including	battery	and	propellers

Communication	Distance:	up	to	6500	feet

Detached	Controller	with	color	screen	and	live	flight	data	

Plug	and	play	with	3-axis	Solo	Gimbal

Please	 feel	 free	 to	contact	our	office	should	you	have any	additional	questions	or	comments.	

Thank	you	for	your	cooperation	with	this	matter.

Sincerely,

Guillermo	Osinaldi

CEO	of	Plane	Hill	LLC