Dear Sir or Madam,

In accordance with the FAA's Guidelines for Submitting Petition for Exemption under Section 333 of the 

FAA Modernization and Reform act of 2015, I Tae Hwan An, owner and operator of Turtle ship system, 

LLC referred to hereafter as the petitioner, request exemption to the following sections of Title 14, Code 

of Federal Regulations: 

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a) 91.407(a)(1); 91.409(a)(1); 91.409(a)(2); 

91.417(a)&(b) 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated by the 

Federal Aviation Administration (FAA) for the purposes of Aerial Photography, cinematography, 

videography, inspections and other flight operations that could be performed safely and more cost 

effectively with the use of small UAS at low altitude within the US National Airspace System as 

compared to a manned aircraft. Operations will only be performed at the request of and with the 

authorization and consent of clients and their authorized agents in order to facilitate commerce and 

raise awareness of beneficial uses of small UAS. So long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by section 333. 

The conditions identified and proposed by the petitioner are drawn from references 1-3. 

The FARs 

The petitioner seeks the exemption from the above mentioned FARs for the following reasons: 

61.113(a) & (b): The petitioner requests relief in order to facilitate utilization of pilots who hold a 

PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption would be required to 

comply with any conditions as set forth and in a similar fashion as the previously granted exemptions. 

91.119(c) As discussed in Exemption 11139 (Douglas Trudeau), operations conducted closer than 500 

feet to the ground may require that the UA be operated closer than 500 feet to essential persons or 

objects that would not be possible without additional relief. The petitioner requests modification, 

waiver or exemption and clarification concerning the terms of "congested areas" and "densely 

populated." The petitioner requests waiver for this condition to allow reasonable and responsible 

operations in areas of subdivisions and neighborhoods. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU), this is inapplicable since the UAS does 

not have an altimeter and instead utilizes GPS with a barometric sensor for altitude information. 
91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been 

granted for manned aircraft to operate at less than prescribed minimums including Exemption NO.s 

2689, 5745, and 10650. In addition similar UAS specific relief has been granted in Exemption No.s 8811, 

1080, and 10673 for daytime, VFR operations. The UAS provides battery power remaining in percent to 

the PIC. The UA batteries provide approximately 20 minutes of powered flight. Information provided in 

the operating documents discusses procedures regarding remaining battery power management. The 

documents contain a condition in which the PIC will initiate a landing procedure when the battery 

remaining reaches a specified level. Given the limitations on proposed operations and the location of 

those proposed operations, the FAA found that a reduced minimum power reserve for flight in daytime 

VFR conditions was reasonable. 

91.405(a); 91.407(a); 91.409(a) (1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 (DOUGLAS 

TRUDEAU), the petitioner proposes to inspect and ensure the UAS is in a condition for safe flight in 

accordance with the operating documents. The FAA found that adherence to the petitioners operating 

documents and the conditions and limitations specified, describing the requirements for maintenance, 

inspection and record keeping, we sufficient to ensure that safety would not be adversely affected. 

The UASs 

The DJI Phantom 3 Professional is highly successful consumer grade small rotorcraft in the quad copter 

configuration with an advertised weight of less than 44 Ounces (1242g) designed primarily to carry a 

high definition camera aloft. They have an advertised maximum speed of less than 30 kts (15 m/s) and a 

maximum climb rate of less than 1200 fpm (6 m/s). They are powered by 4 electric motors with a 

distance between the motors of less than 14 inches (350 mm). It utilizes an internal inertial measuring 

unit (IMU) with integrated barometric sensor to augment with Global Positioning System (GPS) to 

maintain its geospatial orientation and position. It is controlled primarily through an FCC certified radio 

control (RC) unit. Real time video and telemetry information is transmitted back to a ground control 

station allowing the operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), 

distance from the PIC, camera imagery, and control camera angle. It has failsafe modes of operation for 

either loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 25 minutes. 

The onboard flight controller will warn the pilot via telemetry data and external lighting cues before 

reaching a low battery state. An automatic termination of flight and landing will be initiated when 

battery reaches a predetermined low state. It is anticipated that flights will usually last less than 15 

minutes. More information is available at https://www.dji.com/product/phantom-3 . 

Risk Mitigation
The petitioner has reviewed FAA exemptions references 1-3 Conditions and Limitations section and 

believes that the procedures specified therein are reasonable and will be utilized in order to manage 

and mitigate risk and ensure public safety. A preflight and post flight checklist will be developed and 

employed to ensure that UA airworthiness will be maintained for flight operations. Flight time and 

maintenance logs will be maintained to ensure tracking on failure prone components. 

The petitioner requests that in a manner similar to reference 3, he be allow operating within 5 miles of 

an airport provided that: 

"The UA may not operate in Class 8, C, or D airspace without written approval of the FAA. The UA may 

not operate within five nautical miles of the geographic center of a non towered airport as denoted on a 

current FAA-published aeronautical chart unless a letter of agreement with that airport's management is 

obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's 

COA. The letter of agreement with the airport management must be made available to the 

Administrator upon request." 

Operations within 5 miles of an airport are not anticipated to be routine, but the petitioner is requesting 

a mechanism to facilitate such activities without requesting a new and separate exemption should the 

need arise. Operations within class B airspace are not requested due to the lack of a mode C 

transponder. 

Public Interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce environmental impact 

compared to similar operations conducted with much larger fuel laden manned aircraft. Additionally, 

the use of UAS to facilitate commerce can help to encourage economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced perspective for 

characteristics, amenities, and benefits of their desired photographic subjects that cannot be displayed 

through ground level videography/photography. Aerial photography is a valuable marketing tool that 

can facilitate increased commerce and enhance personal photography. Crop surveying and inspections 

could lead to decreased use of pesticides and fertilizer and conservation of water as well as increased 

crop yields and decreased costs. Aerial surveying and inspections can increase work site efficiency, 

improve volumetric estimations and reduce risk. The petitioner will provide clients with the 

photographic data for these purposes in a for hire basis acting as an independent contractor. A visual 

observer will be utilized. Flight data including UA flight time, Control unit operation time, incident, 

accident, and details concerning any deviations from normal operations will be available to the FAA for 

use in collecting data regarding the use of UAS as a part of this application. This data can be submitted 

to the FAA via reports as required by the FAA. 
Conclusion 

The petitioner is requesting this exemption for the purposes of "aerial photography, cinematography, 

videography, mapping, inspections and other flight operations." The reason for such a general and broad 

based request is that the petitioner wishes to utilize a strategy that allows maximum flexibility to utilize 

the UA to its fullest potential within the constraints of this request, without the long turnaround time 

associated with additional exemptions. The petitioner plans to offer services to individuals or companies 

seeking to enhance their business in a safe and lawful way. The petitioner’s family member is a licensed 

realtor and knows that there is extensive demand for lawful aerial photography and videography. 

The petitioner has owned two UAS, the DJI Phantom 3 Professional which he has flown for over 80 hours 

from his own property and various other locations with owner consent to develop flight and 

Photography experience. He has executed hundreds of takeoffs and landings, and has demonstrated 

continuous proficiency over the last year. He has experience with the fail safe modes of the aircraft, 

having run himself through non-normal procedures as described in the DJI operating manual. The 

petitioner plans to utilize the UA below 400' AGL, within visual line of sight {VLOS), within 400' laterally 

of the PIC, and with a visual observer at all times. 

Respectfully submitted, 

Turtle ship system, LLC