October 4, 2015

U.S. Dept. of Transportation, Docket Operations West Building 

Ground Floor, Room w12-140 

1200 New Jersey Avenue, SE.,

Washington, DC 20590

Gunnar Palm 

2025 Horatio Hagood Rd

Rember SC 29128

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

Re: Exemption Request under Section 333 of the FAA Reform 

Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Edford A 

Coffey, seeks an exemption from Federal Aviation Regulations 

(“FARs”) detailed below for the following described Unmanned 

Aerial System called in this application the ME System, which 

includes an Unmanned Aircraft (UA) and ground station- based 

equipment and crew:

THE UNMANNED AIRCRAFT (UA):

A lightweight (20 lb gross weight with all on-board equipment), 

manufactured by DJI, Inspire 1- t-600, that includes the following 

equipment in flight;

An on-board flight computer with GPS navigation and location 

ability that receives signals for flight controls from a groundbased transmitter/controller;
An on-board camera capable of capturing imagery in the form of 

full color, high definition still photos and video;

An on-board telemetry system that delivers flight data from the 

on-board flight computer to the on-board radio transmitter 

including altitude AGL, horizontal and vertical speed, compass 

direction of flight and direction back to its launch site;

A 2.4GHz on-board radio transmitter that transmits live video 

from the on-board camera plus all the flight data from the 

telemetry system described above;

THE GROUD STATION –BASED PART OF THE SYSTEM:

A Pilot in Command (PIC) in operational control of a flight 

operation from beginning to end and who controls the UA while 

in the air;A 2.4GHz radio transmitter/controller operated by the 

PIC to control the UA while in flight; 

A radio receiver receiving live video and flight data from the onboard camera and computer projects it all together onto a screen 

for the PIC to view during flight;

A Visual Observer (VO) is a person who provides a second pair 

of eyes to visually track the UA while in flight.

The requested exemption would support an application for a 

commercial Certificate of Authorization to use the above 

described ME System to support Production of promotional 

materials (video and/or still images) for Real Estate sales 

Production of promotional materials, (video and/or still images) 
for Travel and Tourism industries Production of promotional 

materials, (video and/or still images) for commercial businesses,

Photography and videography of social events, such as 

weddings never operating over persons not directly involved with 

the ME system.

The UA, powered by batteries, is smaller, lighter and more 

maneuverable than larger aircraft running on combustible fuel, it 

operates at lower altitudes with no people on board and will 

thereby reduce current risk levels and thereby enhance safety 

and diminish the likelihood of death or serious bodily injury. With 

a small payload and maximum flight time of only 18 minutes, this 

is offers little or no risk to national security.

Low level oblique photos and video from several angles are far 

more effective than ground- based imagery for displaying the 

characteristics of large, complex properties with several buildings 

and large trees. The alternative could be to charter a full-sized 

helicopter for this purpose, which has proven more costly than 

many potential clients are able to afford. The benefits of reduced 

cost and improved quality of presentation from the UA will be 

valuable to and benefit many buyers and sellers of real property 

and marine property.

Additionally, we request that we be allowed to use our system to 

benefit first responders nearby who might require assistance, 

including fire fighters, the police, the sheriff, et al., while 

remaining subject to all limitations cited in this application as we 

do so.

The ME System will be operated in the field with both a PIC and 

a VO in accordance with FAA Policy N 8900.227 Section 14 

"Operational Requirements for UAS" and with the following 
Restrictions:

a) No flight will be made with a UA Gross weight exceeding 55 

pounds;

b) All operations must occur in FAA Class G airspace at no more 

than 400 ft AGL, at an airspeed of no more than 50 knots and no 

further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO and 

PIC must be able to communicate by voice at all times during a 

flight operation;

d) Operations will be restricted to flights over property with the 

permission of the property owner;

e) The PIC must have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51 (b), a minimum of 100 flight 

cycles and 25 hours of total time as a UA rotorcraft pilot and at

least ten hours logged as a UA pilot with a similar UA type;

f) All required permits will be obtained from state and local 

government prior to operation;

g) The ME System will not be operated over densely populated 

areas;

h) The ME System will not be operated at air shows;

i) The ME System will not be operated over any open-air 

assembly of people;

j) The ME System will not be operated over heavily trafficked 

roads;

k) The ME System will not be operated within 5 NM of an airport 

or heliport;

l) Operations will be restricted to day only and weather 

conditions equivalent to VFR;

m) The PIC will brief the VO and property owner about the 

operation and risk before the first flight at each new location;

n) No flight may be made without a Pre-Flight Inspection by the 

PIC before each operation to ascertain that the UA is in a 

condition safe for flight (see Appendix A).

The PIC and VO will meet the requirements outlined in FAA 

Policy N 8900.227 Section 16 personnel Qualifications. 

Additionally, the PIC and VO will perform maintenance on the 
system and will complete a course of maintenance instruction as 

part of their initial training.

We submit that the combination of the UA's light weight, flight 

performance and ability, fully qualified flight crew and strict

operation under the guidelines established in 8900.227, and 

under all of the Restrictions (a) through (n) listed above, the FAA 

can have full confidence that the operation will have an 

equivalent or greater level of safety than manned aircraft 

performing the same mission.

The name and contact information of the applicant are:

dba Palm Aeorplatforms : Gunnar Palm

203-837-6814

gunnar.palm@gmail.com

The regulations from which the exemption is requested are listed 

below. Beside each regulation number is the page of the 

attached Addendum upon which each may be found together 

with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21.................................Addendum Page 1 

- 14 CFR 91.203.................................Addendum Page 1 

- 14 CFR 45.23, 45.29..........................Addendum Page 2 

- 14 CFR 91.9....................................Addendum Page 2

- 14 CFR 61.113, 61.133.......................Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121..............Addendum Page 3

- 14 CFR 91.151.................................Addendum Page 3

- 14 CFR Subpart E (91.401 - 91.417) ......Addendum Page 3

- FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 

16(e)(1) ...Addendum 1

We are prepared to modify or amend any part of this request to 

satisfy the need for an equivalent level of safety. Please contact 

us at any time if you require additional information or clarification. 

We look forward to working with your office.
Sincerely,

Gunnar Palm

Addendum containing Exemption Requests and Equivalent Level 

of Safety Appendix A – Flight Manual’s

Appendix B – Owner’s Manual for UA

ADDENDUM EXEMPTION REQUESTS AND EQUIVALENT 

LEVEL OF SAFETY

Gunnar Palm requests an exemption from the following 

regulations as well as any additional regulations that may 

technically apply to the operation of the ME System:

14 CFR Part 21, Subpart H: Airworthiness CertificatesThis part 

establishes the procedures for the issuance of an airworthiness 

certificate. While the FAA continues to work to develop 

airworthiness standards for Unmanned Aerial Systems, we 

request an experimental certificate be issued for the ME System 

under either or both of the following provisions: 21.191 

Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design 

concepts, new aircraft equipment, new aircraft installations, new 

aircraft operating techniques, or new uses for aircraft.(b) 

Showing compliance with regulations. Conducting flight tests and 

other operations to show compliance with the airworthiness 

regulations including flights to show compliance for issuance of 

type and supplemental type certificates, flights to substantiate 

major design changes, and flights to show compliance with the 

function and reliability requirements of the regulations. Since the 

experimental certificate can be used for commercial purposes 

such as market surveys, sales demonstrations, and customer 

crew training, we would expect that an experimental certificate 

would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, 

and will only fly under strict operational requirements. Combined 
with the UA’s light weight, being constructed primarily of carbon 

fiber and plastic, we propose that the UA will be at least as safe, 

if not safer, than a conventionally certificated aircraft performing 

the same mission.

If an experimental airworthiness certificate is not appropriate for 

this application, then we request an exemption of 14 CFR Part 

21, Subpart H, and the requirement for an airworthiness 

certificate in general, citing the equivalent level of safety outlined 

in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications 

required.The regulation provides that an airworthiness 

certificate, with the registration number assigned to the aircraft 

and a registration certificate must be aboard the aircraft. 

Additionally, subparagraph

(b) provides that the airworthiness certificate be "displayed at the 

cabin or cockpit entrance so that it is legible to passengers or 

crew."At a maximum gross weight of 6.5 pounds, the UA is too 

small to carry documentation, does not have an entrance, and is 

not capable of carrying passengers or crew. To obtain an 

equivalent level of safety and meet the intent of 91.203, we 

propose that documents deemed appropriate for this aircraft by 

the FAA will be co-located with the crew at the ground control 

station and available for inspection upon request. In order to 

identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed 

to the aircraft via placard containing the following information 

plus the word “EXPERIMENTAL” to satisfy the requirement of 14 

CFR 45.23, which follows immediately after the proposed 

placard description below:

Appendix A

EXPERIMENTAL

Manufacturer: DJI Innovations, Inc. 950 E Baseline Ave. Ste. 

210 Apache Junction AZ 85119 

Models: Inspire 1- t-600, Phantom3 Professions

14 CFR 45.23 Display of marks; general and 45.29 Size of 
marks. These regulations provide that each aircraft must 

display "N" and the aircraft's registration number in letters at 

least 3 inches high. Additionally, the aircraft must display the 

word "EXPERIMENTAL" in letters at least 2 inches high near the 

entrance to the cabin, cockpit, or pilot station. The UA does not 

have an entrance in which the word "EXPERIMENTAL" can be 

placed, and may not have a registration number assigned to it by 

the FAA.

We propose to achieve an equivalent level of safety by including 

the word "EXPERIMENTAL" in the placard on the top of the 

aircraft, as shown above, where the PIC, VO and others in the 

vicinity of the aircraft while it is preparing for launch will be able 

to see the designation. Additionally, we feel that the permanent 

placard discussed in the previous paragraph will provide the 

aircraft's registration information at the ground station. Finally, 

we will display at the ground station a high contrast flag or 

banner that contains the words "Unmanned Aircraft Ground 

Station" in letters 3 inches high or greater. Since the aircraft will 

operate within 3/4 NM of the ground station, the banner should 

be visible to anyone that observes the aircraft and chooses to 

investigate its point of origin.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard 

requirements. This regulation provides that no person may 

operate an aircraft unless a current, approved flight manual is in 

the aircraft. We assume that the intent of this requirement is to 

ensure that flight manual information is available to the aircrew 

while operating the aircraft. We request an exemption to this 

requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the 

crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 

91.9, we propose that a current, approved UA Flight Manual 

(Appendix A) must be available to the crew at the ground station 

anytime the aircraft is in, or preparing for, flight.
14 CFR 61.113 Private pilot privileges and limitations: Pilot in 

Command and 61.133 Commercial pilot privileges and 

limitations.The regulation provides that no person that holds a 

private pilot certificate may act as pilot in command of an aircraft 

for compensation or hire. Subparagraph (b) allows a private pilot 

to act as pilot in command of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire.

Our proposed operations require that the PIC must either

1. Hold a Sport Pilot Certificate issued by the FAA, and have 

logged 25 hours of flight experience in this type of UA, or

2. Meet the requirements of 8900.227 para 16(c)(2)(c) 

"Operations without a pilot certificate" in which the PIC is 

required to complete "FAA private pilot ground instruction" and 

pass "the FAA

Private Pilot written examination." Since there are currently no 

means available for the pilot of a UAS to gain the experience in 

an equivalent category and class in order to apply for a 

commercial pilot's license, we propose to generate an equivalent 

level of safety by requiring our pilots to complete, at a minimum, 

FAA commercial pilot ground instruction and pass the FAA 

Commercial Pilot written examination in addition

Appendix A

to completing the private pilot requirements. Since the aircraft 

cannot carry passengers or property, we feel we meet the intent 

of 61.113 Subparagraph (b) even though the intent of this 

application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and 

certain flight tests The regulation states that "No person may 

operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls.”
The ME System ground-based control station consists of a small 

hand-held radio transmitter and while it does not offer a second 

set of "controls", both the student and instructor can, and will, 

operate the single set of controls simultaneously. With both 

student and instructor having "hands-on" the controls during 

flight, we feel that this technique meets the intent 91.109 and 

provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states that over sparsely populated areas the 

aircraft cannot be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. Since the aircraft will be operating at 

a maximum of 400 feet AGL, we cannot comply with this 

requirement.

In order to provide an equivalent level of safety we will only fly 

over private property with a size of at least two acres with the 

permission of the owner of the property flown over. The aircraft 

will not be operated over congested areas or over any open air 

assembly of persons. The property owner will be briefed on the 

expected route of flight and the associated risks to persons and 

property on the ground. The aircraft will be operated at a low 

altitude allowing, if a power unit fails, an emergency landing 

without undue hazard to persons or property on the surface.

Therefore we maintain that due to the small size of the UA, the 

hazard to persons, vehicles and structures is minimal compared 

to manned aircraft, which should be considered in granting the 

exemption.

14 CFR 91.121 Altimeter settings.The regulation requires that 

aircraft shall maintain cruising altitudes by reference to an 

altimeter setting available within 100 NM of the aircraft.

The UA will always fly below 400 feet AGL and will not need to 

maintain cruising altitudes in order to prevent conflict with other 

aircraft. An Above Ground Level altimeter measurement above 
the takeoff point is transmitted via radio from the UA on-board 

computer to the display screen held by the PIC, providing a 

constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an 

airplane under day-VFR conditions unless there is enough fuel to 

fly to the first point of intended landing and to fly after that for at 

least 30 minutes. We feel the intention of this paragraph is to 

provide an energy reserve as a safety buffer for delays to 

landing. The UA is battery operated and the maximum duration 

of flight from a single battery charge is 18 minutes with a 20% 

reserve. Since the aircraft will never fly more than 3⁄4 NM from 

the point of intended landing, a full battery charge at launch will 

ensure that we meet the reserve energy requirement of this 

paragraph. We request an exemption to the word "fuel" and ask 

for an equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401 - 91.417) - Maintenance, Preventive 

Maintenance, Alterations The regulation provides that the 

operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. 

Paragraphs 91.407 and 91.409 require that the aircraft be 

"approved for return to service by a person authorized under 

43.7" after maintenance and inspection.

It is our intention that the PIC perform maintenance and 

inspection of the aircraft and "be authorized to approve the 

aircraft for return to service." As provided in the Pre-Flight 

Checklist in Appendix A, the PIC will ensure that the aircraft is in 

an airworthy condition prior to every flight and in addition conduct 

detailed inspections after every two hours of flight. Maintenance 

performed by the PIC is limited to repairing small cracks, 

replacing a propeller, checking electrical connections and 

updating software and firmware for the on-board computer. All 

other maintenance will be performed by the manufacturer or their 

designated repair facility. The PIC will document work performed 
in accordance with 91.417. We feel that due to the size, 

construction, and simplicity of the aircraft, the PIC can ensure an 

equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 

16(e)(1) Observer Medical. This policy provides that both the 

PIC and VO must have a valid FAA second-class medical 

certificate issued under part 67 in order to perform as a pilot or 

observer. The UA maximum gross weight is 6.5 pounds, it is 

constructed of carbon fiber and plastic and the PIC is not on 

board. Both the PIC and the VO are required to be in VLOS. 

Given the unlikely event that both the PIC and VO become 

medically incapacitated while the aircraft is in flight, the UA will 

return autonomously to the site of launching and land without 

crew intervention.

Therefore, requiring the PIC and VO to meet the same medical 

requirements as a commercial pilot carrying passengers in a 

large aircraft is an unnecessary burden.

We propose that the minimum medical requirements for the PIC 

and VO be vision corrected to 20/20 and a valid, state issued 

driver's license. The 20/20 vision requirement will ensure that the 

PIC and VO can see and avoid air traffic; a licensed driver is 

medically qualified to operate a much larger vehicle.

APPENDIX A – FLIGHT MANUAL

FLIGHT RESTRICTIONS

a) No flight will be made with a UA Gross weight exceeding 55 

pounds;

b) All operations must occur in FAA Class G airspace at no 

more than 400' AGL, at an airspeed of no more than 50 knots 

and no further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO 

and PIC must be able to communicate verbally at all times during 

a flight operation;

d) Operations will be restricted to flights over property with the 
permission of the property owner; 

e) The PIC must have accumulated and logged, in a manner 

consistent with 14 CFR § 61.51 (b), a minimum of 100 flight 

cycles and 25 hours of total time as a UA rotorcraft pilot and at 

least ten hours logged as a UA pilot with a similar UA type;

f) All required permits will be obtained from state and local 

government prior to operation; 

g) The ME System will not be operated over densely populated 

areas;

h) The ME System will not be operated at air shows;

i) The ME System will not be operated over any open-air 

assembly of people;

j) The ME System will not be operated over heavily trafficked 

roads;

k) The ME System will not be operated within 5 NM of an 

airport or heliport;

l) Operations will be restricted to day only and weather 

conditions equivalent to VFR;

m) The PIC will brief the VO and property owner about the 

operation and risk before the first flight at each new location;

n) No flight may be made without a successful Pre-Flight 

Inspection by the PIC before each operation to ascertain that the 

UA is in a condition safe for flight.

PREFLIGHT CHECKLIST

1. Remote controller, aircraft battery, and mobile device are fully 

charged.

2. Propellers are mounted correctly and firmly.

3. Micro-SD card has been inserted if necessary.

4. Gimbal is functioning as normal.

5. Motors can start and are functioning as normal.

6. DJI Pilot app connected to the aircraft.

TO REGAIN CONTROL AFTER LOST RADIO CONTACT

If radio contact is lost and not restored within 3 seconds, an 

automatic Return to Home feature is activated and will bring the 

UAV back to the PIC.