November 10, 2015 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

DOUGLAS THRON’S PETITION FOR EXEMPTION TO 

OPERATE UNMANNED AIRCRAFT SYSTEMS PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

Proposed Use: Closed-Set Filming In The Motion Picture 

And Televisions Industries 

Proposed Aircraft: DJI Phantom 3 and DJI Phantom 1 

Petitioner’s Name Douglas Thron 

and Address: 2850 Theresa Lane 

San Jose, California 95124 

Phone: 408-444-5000 

Email: dougthron@hotmail.com
Petition of Douglas Thron Page 2 

I. Summary. 

Pursuant to Section 333(a) through (c) (“Section 333”) of the FAA Modernization and 

Reform Act of 2012 ("Reform Act")1 and the Federal Aviation Administrations’ (“FAA”) 

general exemption authority under 49 U.S.C. §44701(f), Flight Guardian, LLC (“Petitioner”) 

petitions for exemption from 14 Code of Federal Regulations (“CFR”) sections: 61.113(a) & 

(b), 61.133(a), 91.7(a), 91.9 (b)(2), 91.103(b)(1), 91.119 (c), 91.121, 91.151, 91.203(a) & (b), 

91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) & (b). The proposed exemptions, if granted, 

would allow Petitioner to operate small unmanned aircraft systems ("UAS") weighing 55 

pounds or less for the purpose of closed-set filming of motion pictures, music videos, web 

videos, corporate videos, television programs and commercials, and still photography. 

Additionally the collection of agriculture and conservation supporting scientific data in FAA 

approved COE’s. 

Based on the small size of Petitioner’s UAS, the qualifications and experience of 

Petitioner’s UAS operators, and the restricted, sterile environment within which Petitioner 

will operate, the requested exemptions fall squarely within the zone of safety envisioned by 

Congress and set forth in Section 333. Additionally, the enhanced safety achieved by 

replacing significantly larger manned aircraft carrying crew and flammable fuel with small 

UAS carrying no passengers or crew and operated under the specific guidelines and 

procedures proposed by Petitioner gives the FAA good cause to find that the UAS 

operations enabled by this petition are in the public interest. Moreover, the requested 

exemptions are similar in all material aspects to the requests for which exemptions have 

been previously granted, e.g., Exemption Nos. 11289, 11062, 11109, 11112, and 11213. 

Thus, the requested exemptions should be granted. 

II. Identity of Petitioner. 

Douglas Thron is a FAA licensed amphibious sport pilot and has been a professional photographer 

 and cinematographer since 1991. His clients include the Discovery Channel, CBS News, TIME 

Magazine, Good Morning America and many others. He has hundreds of hours of flight time logged 

with small UAS such as the Phantom 3 and Inspire 1 and is familiar with all current FAA regulations 

regarding these aircraft. 

III. Statutory Authority For Exemptions. 

The Administrator of the Federal Aviation Administration (“FAA”) possesses both 

general and specific authority to grant the requested exemption. 

First, the FAA Administrator may exempt an operator from FAA safety regulations 

and minimum standards when the Administrator concludes that the exemption is in the 

public interest. See 49 U.S.C. §§ 106(f), 40113, 44701(±) (permitting exemptions from§§ 

44701(a), (b) and§§ 44702-44716, et seq.). A party requesting an exemption must explain 

1 Pub. L. 112-95 (2012), 126 Stat. 11 (2012). 
Petition of Douglas Thron Page 3 

why the exemption: (1) would benefit the public as a whole, and (2) would not adversely 

affect safety (or how it would provide a level of safety at least equal to the existing rules). 

See 14 C.F.R. § 11.81 (petitions for exemption). 

Second, Section 333 of the Reform Act specifically authorizes the FAA Administrator 

to grant exemptions for operation of UAS. Indeed, the Reform Act directs the Administrator 

to (1) undertake formal rulemaking to speed up the integration of UAS into the national 

airspace (“NAS”) but in the meanwhile, (2) to permit unmanned aircraft systems to operate 

in the NAS if doing is in the public interest, does not pose a threat to national security, and 

does not create a hazard to users of the NAS, taking into consideration the following: 

The UAS's size, weight, speed, and operational capability; 

How close the UAS would operate to airports and populated areas; 

That the operator would keep the UAS in his direct, visual line of sight. 

Thus, the FAA has full authority to grant the requested exemptions. 

IV. Specific Regulations For Which an Exemption is Sought. 

Petitioner requests exemptions from the following regulations: 

Section 61.113 prescribes that “no person who holds a private pilot certificate may 

act as a pilot in command of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft,” (see Section 61.113(a)), and that “a private pilot may, for 

compensation or hire, 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,” (see 

Section 61.113(b)). 

Section 61.133(a) sets forth privileges for persons holding commercial pilot 

certificates, including a provision impliedly limiting to persons holding a commercial pilot 

certificate the ability to act as pilot in command of an aircraft “[f]or compensation or hire.” 

Section 91.103(b)(1) prescribes, in pertinent part, that each pilot in command shall, 

before beginning a flight, become familiar with all available information concerning that 

flight, to include, “For any flight, runway lengths at airports of intended October 1, 2014 

use, and the following takeoff and landing distance information:... For civil aircraft for 

which an approved Airplane or 5 Rotorcraft Flight Manual containing takeoff and landing 

distance data is required, the takeoff and landing distance data contained therein.” 

Section 91.119(c) prescribes that, except when necessary for takeoff or landing, no 

person may operate an aircraft below the following altitudes: “Over other than congested 

areas. An altitude of 500 feet above the surface, except over open water or sparsely 
Petition of Douglas Thron Page 4 

populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure.” 

Section 91.121 requires, in pertinent part, each person operating an aircraft to 

maintain cruising altitude by reference to an altimeter that is set “to the elevation of the 

departure airport or an appropriate altimeter setting available before departure.” 

Section 91.151(a) prescribes that no person may begin a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough 

fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) 

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

least 45 minutes. 

Section 91.203 prohibits, in subpart (a), any person from operating a civil aircraft 

unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an 

effective U.S. registration certificate issued to its owner or, for operation within the United 

States, the second copy of the Aircraft Registration Application as provided for in October 1, 

§ 47.31(c). Section 91.203 prescribes, in subpart (b), that no person may operate a civil 

aircraft unless the airworthiness certificate or a special flight authorization issued under 

§91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or 

crew. 

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner 

shall have the 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. 

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an 

aircraft that has undergone maintenance, preventative maintenance, rebuilding, or 

alteration unless it has been approved for return to service by a person authoriZed under § 

43.7 of the same chapter. 

Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had an inspection for the 

issuance of an airworthiness certificate in accordance with part 21 of this chapter. 

Sections 91.417(a) and (b) prescribe, in pertinent part, that- 

(a) Each registered owner or operator shall keep the following records 

for the periods specified in paragraph (b) of this section: 

	 	(1) Records of the maintenance, preventative maintenance, and alteration and 

			records of the 100-hour, annual, progressive, and other required or approved 

			inspections, as appropriate, for each aircraft (including the airframe) and 

			each engine, propeller, rotor, and appliance of an aircraft. The records must 

			include- 
Petition of Douglas Thron Page 5 

V. 

	 	(i) A description (or reference to data acceptable to the Administrator) of the 

	 	 work performed; and 

	 	(ii) The date of completion of the work performed; and 

	 	(iii) The signature, and certificate number of the person approving the 

	 	 aircraft for 

	 	return to service. 

(2) Records containing the following information: 

	 	 (i) The total time in service of the airframe, each engine, each propeller, 

	 	 and each rotor. 

	 	 (ii) The current status of life-limited parts of each airframe, engine, 

	 	 propeller, rotor, and appliance. 

	 	 (iii) The time since last overhaul of all items installed on the aircraft 

	 	 which are required to be overhauled on a specified time basis. 

	 	 (iv) The current inspection status of the aircraft, including the time since 

	 	 the last inspection required by the inspection program under which 

	 	 the aircraft and its appliances are maintained. 

	 	 (v) The current status of applicable airworthiness directives (AD) and 

	 	 safety directives including, for each, the method of compliance, the AD 

	 	 or safety directive number and revisions date. If the AD or safety 

	 	 directive involves recurring action, the time and date when the next 

	 	 action is required. 

	 	 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

	 	 major alteration to the airframe and currently installed engines, 

	 	 rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until 

	 	the work is repeated or superseded by other work or for 1 year after the work 

	 	is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

	 	transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

	 	this chapter shall be retained until the defects are repaired and the aircraft is 

	 	approved for return to service. 

Petitioner’s Proposed Operations Satisfy Section 333. 

A. Unmanned Aircraft System 

The UAS to be operated under this request are less than 55 lbs. fully loaded, will be 

operated at a speed of no more than 87 knots (See, e.g., Exemption No. 11289 (Bird’s Eye 

Solutions), p. 3, Condition (“C.”) 3), carry neither a pilot nor passenger, carry no explosive 

materials or flammable liquids, and operate exclusively within a secured area. Petitioner’s 
Petition of Douglas Thron Page 6 

UAS use a radio frequency spectrum for operation and control that complies with Federal 

Communications Commission (“FCC”) requirements, and Petitioner has integrated safety 

features into the UAS, as described in the Film and Motion Picture Flight Operations 

Manual (“FMPFOM”) and Appendix A. Petitioner is tendering the FMPFOM under 

separate cover as a Confidential document as defined in 14 C.F.R. § 11.35(b). The entire 

FMPFOM contains confidential commercial and proprietary information that the Petitioner 

has not and shall not share. The operating conditions and procedures contained in the 

Operations Manual are not available to the public and are protected from release under the 

Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other requirements established 

by the FAA pursuant to Section 333 of the FAA Reform Act. 

Petitioner’s UAS are equipped with redundant safety mechanisms allowing them to 

operate safely after experiencing certain in-flight failures. If a lost-link event occurs, 

including the loss of ground communications and/or the loss of a GPS signal, Petitioner’s 

UAS have the ability to perform a pre-coordinated, predictable, automated flight maneuver 

and return to a predetermined location within a designated security perimeter for landing. 

The UAS further have the ability to abort a flight in the event of unpredicted obstacles or 

emergencies. All flights will be terminated after a maximum of 30 minutes or with 25% 

remaining battery power, whichever occurs first. Thus, good cause exists for granting 

Petitioner’s requested relief from 14 C.F.R. § 91.151(a) (setting forth fuel requirements for 

flight in VFR conditions). 

Petitioner’s UAS will be identified by serial number, registered in accordance with 

14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 

C.F.R. Part 45, Subpart C. Markings will be as large as practicable. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.121 (Altimeter Settings), 

Petitioner seeks such relief because Petitioner will not have a typical barometric altimeter 

onboard the UAS. Instead, altitude information will be provided to the UAS PIC via a 

digitally encoded telemetric data feed, which downlinks from the aircraft to a ground-based 

on-screen display. The altitude information will be generated by equipment installed 

onboard the UAS, using GPS triangulation, digitally encoded barometric altimeter, radio 

altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point 

will be established and confirmed for accuracy by the UAS PIC. Thus, good cause exists for 

granting the requested relief from 14 C.F.R. § 91.121. 

Given the size, weight, speed, and limited operating area associated with the aircraft 

to be utilized by the applicant, an exemption from 14 C.F.R. Part 21, Subpart H 

(Airworthiness Certificates), subject to certain conditions and limitations, is warranted (if 

necessary) and meets the requirements for an equivalent level of safety under 14 C.F.R. 

Part 11 and Section 333. The UAS operated without an airworthiness certificate in the 

restricted environment and under the conditions and limitations proposed by Petitioner will 
Petition of Douglas Thron Page 7 

be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating 

with an airworthiness certificate issued under 14 C.F.R. Part 21, Subpart H, and not 

subject to the proposed limitations and conditions. 

Petitioner will strictly comply with safety and maintenance procedures included in 

all applicable UAS manufacturer’s instructions and operating manuals. To the extent such 

information is not included in the guidelines developed by the manufacturers, Petitioners 

will develop and document maintenance, overhaul, replacement, and inspection 

requirements, procedures to document and maintain maintenance records with regard to 

Petitioner’s UAS, and UAS technician qualification criteria. Petitioner’s operations 

manuals will include maintenance requirements for Petitioner’s UAS, including “oncondition” maintenance and modifications. In light of these mitigating factors, exemptions 

from 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) are 

warranted. 

B. UAS Pilot in Command 

Petitioner’s UAS pilot in command (PIC) shall hold a recreational or sport pilot 

certificate, and valid driver’s license to satisfy the medical requirement. According to the 

FAA, “the FAA considers the overriding safety factor for the limited operations proposed by 

the petitioner to be the airmanship skills acquired through UAS-specific flight cycles, flight 

time, and specific make and model experience, culminating in verification through testing.” 

See Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 18. With those 

factors in mind, Petitioner’s UAS PIC shall be required to meet several conditions and 

limitations as outlined in the FMPFOM, including the following: 

The UAS PIC will have accumulated and logged a minimum of 200 flight cycles 

and 25 hours of total time as a UAS pilot and at least 10 hours logged as a UAS 

pilot with a similar UAS type (single blade or multirotor). 

The UAS PIC will have accumulated and logged a minimum of five hours of 

flight time with the specific make and model of the UAS to be utiliZed for 

operations under the exemption and three take-offs and landings in the 

preceding 90 days. 

The UAS PIC will have successfully completed the qualification process as 

specified in the operations manuals, to include a knowledge and skill test. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.7(a), it is Petitioner’s 

understanding that Petitioner’s UAS will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H, and that exemption from 14 C.F.R. § 91.7(a) 

is therefore unnecessary. To the extent such an exemption is deemed necessary, Petitioner 

asserts that it should be granted in light of the safety procedures proposed herein. In 

accordance with the pertinent part of 14 C.F.R. § 91.7(b), the operator in command of 
Petition of Douglas Thron Page 8 

Petitioner’s UAS shall be responsible for determining whether the aircraft is in a safe 

condition for flight. Petitioner’s manuals for maintenance and operations shall include 

safety checklists to be used by the operator in command prior to each flight. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.9(b)(2) (Civil aircraft 

flight manual, marking, and placard requirements and § 91.203(a) and (b), (Civil aircraft: 

certifications required), it is Petitioner’s understanding that relief from these regulations is 

no longer necessary in light of the FAA Memorandum “Interpretation regarding whether 

certain required documents may be kept at an unmanned aircraft’s control station,” dated 

August 8, 2014. To the extent the FAA deems an exemption from this section necessary for 

Petitioner’s proposed operations, such exemption should be granted in light of the 

mitigating fact that Petitioner will maintain the documents required under 14 C.F.R. §§ 

91.9 and 91.203 at the UAS ground control station during flights. Additionally, 100% of 

Petitioner’s operations will utiliZe a visual observer (“VO”). The VO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and 

the PIC will be able to communicate verbally at all times during operational flights. 

Regarding Petitioner’s requested relief from 14 C.F.R. § 91.103(b)(1), Petitioner will 

comply with the other applicable procedures and requirements stated in § 91.103(a) and (b). 

Specifically, the PIC will take all actions including reviewing weather, flight battery 

requirements, aircraft performance data, and landing and takeoff distances before 

initiation of a flight. The PIC will also account for all relevant site-specific conditions in 

their preflight procedures. Risks presented by sun glare will be mitigated by the PIC’s and 

VO’s ability to see other air traffic and initiate a return-to-home sequence if needed. 

C. Operating Parameters of Petitioner’s UAS 

Petitioner’s UAS operations will be conducted within a sterile environment of closedset filming. In this controlled environment, Petitioner’s operations will remain within 

VLOS of the PIC and VO, below 400 feet AGL, and at speeds below 87 knots. See 

Exemption No. 11289, p. 3, C. 3, 4) Only participating persons will be permitted within the 

operating area. Consistent with the relief typically provided to manned operations under 

FAA Order 8900.1, Volume 3, Chapter 8, Section 1, Petitioner requests relief from 14 C.F.R. 

§ 91.119(c) with respect to those participating persons, vehicles, and structures directly 

involved in the performance of the actual filming. Regarding distance from participating 

persons, the operations manuals set forth safety factors for authoriZed and consenting 

production personnel. Because those procedures are specific to participating persons, no 

further FSDO or aviation safety inspector approval is necessary for reductions to the 

distances specified in Petitioner’s manuals. 

Regarding the distance from nonparticipating persons, Petitioner will ensure that no 

persons are allowed within 500 feet of the operating area except those consenting to be 
Petition of Douglas Thron Page 9 

involved and necessary for the filming production, with the possibility of reducing this 

distance to no less than 200 feet if it would not adversely affect safety and the 

Administrator has approved it. This is consistent with FAA Order 8900.1, V3, C8, S1. 

Petitioner will not conduct UAS operations within 5 nautical miles of the geographic 

center of a non-towered airport unless a letter of agreement with that airport’s 

management is obtained and the operation is conducted in accordance with a Notice to 

Airmen (“NOTAM”). Additionally, Petitioner will not operate in Class B, C, or D 13 airspace 

without written approval from the FAA. Nor will Petitioner operate the UAS less than 500 

feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 

statute miles from the PIC. 

Petitioner’s UAS will remain clear and yield the right of way to all manned 

operations and activities at all times (including, but not limited to, ultralight vehicles, 

parachute activities, parasailing activities, and hangliders). 

Although Petitioner seeks to comply with the waiver process as described in FAA 

Order 8900.1, Volume 3, Chapter 8, Section 1 (Issue a Certificate of Waiver for Motion 

Picture and Television Filming), the current section of Order 8900.1 has specific processes 

that preclude a jurisdictional FAA FSDO from issuing the required Certificate of Waiver, 

because the section did not originally provide for UAS operations. Thus, Petitioner seeks 

exemption from the applicable regulations normally waived during that process. Petitioner 

proposes that the FAA include the required notifications and coordination with 

jurisdictional FSDOs through the conditions and limitations accompanying the requested 

exemption, and that the exemption sought herein will take the place of the Certificate of 

Waiver normally issued by a jurisdictional FSDO under 8900.1. Under this rubric, 

Petitioner will notify every FSDO with jurisdiction over the area that Petitioner plans to 

operate, just as with manned filming operations, and those FSDOs will have the ability to 

coordinate further conditions and limitations with the UAS Integration Office to address 

any local concerns. 

Petitioner will obtain an Air Traffic Organization (“ATO”) issued Certificate of 

Waiver or Authorization (“COA”) prior to conducting any operations under this grant of 

exemption. In fulfilling its requirements under the COA, Petitioner will be required to 

request a NOTAM not more than 72 hours in advance, but not less than 48 hours prior to 

the operation. 

D. The Requested Exemption Promotes the Public Interest 

The enhanced safety achieved by replacing significantly larger manned aircraft 

carrying crew and flammable fuel with small UAS carrying no passengers or crew and 

operated under the specific guidelines and procedures proposed by Petitioner gives the FAA 
Petition of Douglas Thron Page 10 

good cause to find that the UAS operations enabled by the instant Petition are in the public 

interest. Moreover, as the FAA has already recognized, “UAS provide an additional tool for 

the filmmaking industry, Agriculture and Conservation adding a greater degree of 

flexibility, which supplements the current capabilities offered by manned aircraft.” See 

Exemption No. 11062, Regulatory Docket No. FAA-2014-0352, at p. 22. 

VI. Privacy 

All flights will occur over private or controlled access property with the 

property owner’s prior consent and knowledge. Filming will be of people who have 

also consented to being filmed or otherwise have agreed to be in the area where 

filming will take place. 

VII. Conclusion 

For the reasons explained above, the regulatory exemptions requests should be 

granted, and Petitioner should be permitted to conduct small UAS operations for the 

purpose of closed-set filming using the DJI Phantom 3 and DJI Inspire 1. 

Respectfully submitted, 

Douglas Thron
Appendix A – Flight Manual 

Flight Restrictions 

(1) No flight will be made with a UA Gross weight exceeding 55 pounds; 

(2) All operations must occur in FAA approved airspace at no more than 400' AGL, at an airspeed of 

no more than 87 knots and no further than 3/4 NM from the PIC; 

(3) 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; 

(4) Operations will be restricted to flights over private property with the permission of the property 

owner; 

(5) 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; 

(6) All required permits will be obtained from state and local government prior to operation; 

(7) The UA will not be operated over densely populated areas; 

(8) The UA will not be operated at air shows; 

(9) The UA will not be operated over any open-air assembly of people; 

(10) The UA will not be operated over heavily trafficked roads; 

(11) The UA will not be operated within 5 NM of an airport or heliport without written permission 

Airport Manager. 

(12) Operations will be restricted to day only and weather conditions equivalent to VFR; 

(13) The PIC will brief the VO and property owner about the operation and risk before the first flight at 

each new location; 

(14) 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. 

Pic Should Verify The Following Items Before Starting The Pre-Flight Process 

(1) Verify COA Approved 

(2) Verify NOTAM Filed (if applicable) 

(3) Verify FSDO coordination completed 

(4) Verify closest Unicom/Tower Frequency for Monitoring. 

Pre-Flight Checklist 

(1) Check UA battery health (press self check button) verify 4 green bars illuminate 

(2) Check all wiring connections are tight; 

(3) Check all propellers are undamaged and no cracks exist in any structural members of the UA; 

(5) Turn on radio controller, move all control switches to forward or UP position and throttle control 

stick neutral position; 

(6) Turn On UA power 

(7) Await Aft Lights to flash green 

(8) Turn on transmitter and camera. 

Pre-Takeoff Checklist 

(1) Confirm Green Lights on aircraft 

(2) Confirm Observer is ready 

(3) Confirm area cleared of all non-essential personnel 

Petition of Douglas Thron Page 11