REQUEST FOR EXEMPTION UNDER SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

December 28, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Name and Address of Petitioner: 

Christyl Nagao 

2620 Hoonani Road 

Koloa, HI 96756 

(808)639-0207 (m) 

(808)977-7303 (f) 

christylnagao@gmail.com

CHRISTYL NAGAO
To Whom It May Concern: 

I am submitting on my own behalf a petition for exemption request under Section 333 of the FAA Modernization 

and Reform Act of 2012 (the “Reform Act”), and 14 CFR Part 11. I, Christyl Nagao, Realtor and photographer, 

hereby seek an exemption to operate DJI Phantom 3 Standard system for compensation/hire within the National 

Airspace System. 

The following pages outline my intent of use referencing all pertinent Federal Regulations of concern to the best of 

my knowledge. 

Please feel free to contact me with any questions or concerns at christylnagao@gmail.com or (808)639-0207. 

Thank you for your time and consideration in reviewing my petition for exemption. 

Sincerely, 

Christyl Nagao 

2620 Hoonani Road 

Koloa, HI 96756

CHRISTYL NAGAO
SUMMARY 

I, Christyl Nagao, seek an exemption from the requirements pursuant to Section 333 of the FAA Reform Act of 

2012 (the “Reform Act”) and 14 CFR Part 11. I hereby apply for an exemption from the listed Federal Aviation 

Regulations (“FARs”) to allow for commercial operation of designated Unmanned Aircraft System (“UAS”), DJI 

Phantom 3 Standard in airspace regulated by the Federal Aviation Administration (“FAA”) so long as such 

operations are conducted with and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333. 

The requested exemption shall allow myself, Christyl Nagao, to pursue my commercial interest in providing 

services to clients in the following areas: Real Estate, Marketing, Land Management and Special Events. 

I demonstrate the ability to safely and effectively fly the UAS as I use it for personal hobby as well. I shall comply 

with local ordinances and laws regarding the operations of the UAS and adhere to all weather and environmental 

restrictions or limitations in reference to the operations of the UAS. 

CHRISTYL NAGAO
EXEMPTION 

I have listed the following regulations in which I am seeking exemption, and a complete list of responsibilities I 

assume as operator: 

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. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417 

I, Christyl Nagao (“Operator”), assume the following responsibilities: 

UAS may not be operated at a speed to exceed 100 miles per hour. The exemption holder may use either 

grouped or calibrated airspeed to determent compliance with the 100 mile per hour speed restriction. In no case 

will I operate the UAS at airspeeds greater than the maximum UAS operating airspeed recommended by the 

aircraft manufacturer. 

UAS may not be operated at an altitude of no more than 400 feet above ground level. Altitude must be reported in 

feet above ground level. 

UAS must be operated within visual line of sight of the operator at all times unaided by any visual device other than 

corrective lenses. All operations must utilize a visual observer (“VO”). The VO and Operator must be able to 

communicate verbally at all times; electric messaging or texting is not permitted during flight operations. The 

Operator must be designated before the flight and cannot transfer his or her designation for the duration of the 

flight. 

Operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation. 
Prior to each flight the operator must conduct a pre-flight inspection for safe flight. 

Operations for the purpose of closed-set motion picture and television filming are not permitted. 

The Operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life 

requirements for the aircraft and aircraft components. 

UAS operated under this exemption must comply with all manufacturer safety bulletins. 

Under this grant of exemption, an Operator must hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate. The Operator must also hold a current FAA airman medical certificate or a valid U.S. 

driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession or the Federal 

government. The Operator must also meet the flight review requirements specified in 14 C.F.R. 61.56 in an aircraft 

in which the Operator is rated on his or her pilot certificate. 

The Operator may not permit any other person to operate unless the Operator demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. Operators qualification flight hours and currency must be logged in a manner consistent with 14 C.F.R. 

61.51(b). 

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

under visual meteorological conditions. Flight under special visual flight rules are not authorized. 

The UAS may not operate within 5 miles of any airport reference point as denoted in the current FAA Airport/

Facility Directory or for airports not denoted with a Airport/Facility Directory, the center of the airport symbol as 

denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airports, 

management is obtained or otherwise permitted by a COA missed to the expedition holder. The latter of 

agreement with the airport management must be made available to the Administrator or any law enforcement 

official upon request. 

If the UAS loses communications or loses its GPS signal, the UAS must return to a pre-determined location within 

the private or controlled-access property. 

Operator must abort the flight in the event of unpredicted obstacles or emergencies. 
The Operator is prohibited from beginning a flight unless (considering wind and forces weather conditions) there is 

enough available power for the UA to conduct the intended operation and to operate after that for at least five 

minutes or with the reserve power recommended by the manufacturer if greater. 

Air Traffic Organization (“ATO”) Certificate of Waiver or Authorization (“COA”). All operations shall be conducted in 

accordance with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to 

conduct operations that cannot be conducted under the terms of the attached COA. 

All UAS operated in accordance with this exemption must be identified by serial number, registered in accordance 

with 14 C.F.R. 47,and have identification markings in accordance with 14 C.F.R. 45(c). Markings must be as large 

as practicable. 

The UAS must remain clear and give way to all manned aviation operations and activities at all times. 

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

All operations shall be conducted over private or controlled access property with permission from the property 

owner/controller or authorized representative per flight. 

Any and all 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 website. 

SIMILAR EXEMPTIONS 

These are similar exemptions in most material information and use: 

11062, 11109, 11112, and 11213