Ambrose 333 petition

Recognizing the demand to expedite integration of UAS into the NAS, the FAA is developing a regulatory 

framework for safely integrating UAS into routine NAS operations. The first stage in this process will be 

accomplished by the small UAS rule. 

The FAA’s authority to issue exemptions from operating rules, and the Secretary’s authority granted by Section 333 

of P.L. 112-95, Special Rules for Certain Unmanned Aircraft Systems, provide an opportunity to authorize certain 

UAS operations in the NAS prior to implementation of the small UAS rule. This incremental step provides a 

pathway for civil operators who desire safe and legal entry into the NAS. 3 Rev. 9/25/2014 

 A PETITION FOR EXEMPTION IS

TO CONDUCT FLIGHTS IN A UAS UNDER 55 LBS FOR OTHER 

THAN HOBBY OR RECREATION: FOR BUSINESS PURPOSES. 

Regarding the Unmanned Aircraft System 

1. Petitioners should describe how the proposed UAS operation will be safely conducted to minimize risk to the NAS or to persons and 

property on the ground. Specifically, petitioners should describe the design and operational characteristics for the type(s) of UAS they 

intend to operate, e.g. aircraft performance and performance limitations, operating procedures, and aircraft loading information in as 

much detail as possible. This could be provided in the petition or in an Aircraft Flight Manual or similar document. 

MY RESPONSE

The under 55 lbs UAV is a Phantom 2 as manufactured by DJI. The unit has a built in sensor 

and barometric altimeter that measures both attitude and altitude, and the compass reads 

geomagnetic information which assists the Global Positioning System to accurately calculate the 

aircraft position and height in order to lock the aircraft in a stable hover, when the controls are 

released..this is be lost, the Phantom 2 has a FAILSAFE function which will maneuver the UAV 

to return to the home point and land. In the event the Phantom is unable to asses enough GPS 

satellites to determine home position it will descend in a controlled manner and land. 

Risk to the NAS is eliminated in two areas, one, the under 55 lbs. UAV will maintain position in a 

hover should control inputs be ineffective and two, the petitioner, ( James Ambrose) who will be 

the operator, is an FAA Commercial Pilot ASEL MEL, and a Certified Flight InstructorInstrument, ASEL. I am very aware of the NAS, it’s various classes, there will be NO operations 

in controlled airspace, and I understand 91.119 still applies as far as minimum safe altitude.

The Phantom 2 ( mfctr by DJI) has a loading portal to mount a ZENMUSE gimbal that is 

designed to attach a H3D3 Go Pro Camera. With the ZENMUSE gimbal and GO PRO H3D3 

camera mounted on the Phantom 2, the total weight is still significantly below the 55 lbs. ( approx. 

3 lbs). The Phantom 2 was designed and manufactured to be operated in a safe manner fully 

loaded with the camera and gimbal or without. The petitioner has operated the UAV with and 

without the camera and gimbal mounted and noted minimal performance variance.

Additional safety features include LED indicators on the unit and visible to the operator. They 

include an indication of the self test feature of the UAV. During this self test, the unit is acquiring 

sateliites, testing on board mechanical links and digital system readiness. In addition it is 

providing power level indication and confirms there is a strong signal from the controller. The on 

board self test system also evaluates compass accuracy and effectiveness and will not allow flight if 
Ambrose 333 petition

there is a ferro-magnetic interference or the compass needs calibration. The unit will not respond 

to operator control to initiate flight until all system tests pass. 

An additional safety feature added to this unit is propeller guards. The petitioner has no 

intention to operate the UAV in close proximity to people or persons where a potential prop strike 

could occur, but it does provide that higher level of safety in the completely unlikely event that 

situation could exist.

Performance data

Max ascent speed 18 feet/sec descent speed 6 feet /sec

Max flight speed approx. 25 MPH

2. Petitioners should describe any procedures they would implement, such as pre-flight inspections, maintenance, 

and repair, to ensure that the UAS is in a condition for safe flight. This could be provided in the petition, an Aircraft 

Flight Manual, a Maintenance and Inspection Manual, or similar document. 

6 Rev. 9/25/2014 

I ( the petitioner) as a FAA certificated pilot and Certified Flight Instructor have developed 

habits for thorough pre-flight inspections, pre-flight planning, to insure safe flight. I will apply 

these habits to the safe operation of my under 55lbs UAV.

I intend to use the following pre-flight planning, pre flight aircraft check and create and follow a 

flight plan when operating the Phantom 2.

Pre-flight planning:

Weather check and evaluate if conditions are conducive for safe flight.

Location for flight to occur is not in controlled airspace, is clear of any people or obstacles 

that can impair the purpose and safe operation of the flight, and has no potential to 

contribute to any safety concerns of any other activity being conducted in the area of the 

flight.

I will discuss with the intended customer if the flight is to be used for business purposes 

what the objective of the aerial operation is to be; insure it could be conducted under all 

the safe and appropriate guidelines and inform the client he or she cannot interfere in any 

way with my operation of the UAV. An agreement on the intended flight will be reached, 

as to the manner and space the UAV will operate. The flight will only occur once this 

understanding is reached and will terminate immediately if the client interferes in any way 

with the space I will require away from any and all people during the operation of the 

UAV.

Pre-Flight Aircraft check:
Ambrose 333 petition

Physical inspection of the entire unit for all mechanical connections tight and secure and 

cabling tight and secure. Feel prop edges for nicks or dents and replace with spare prop 

prior to flight. Confirm ZENMUSE gymbal secure and all fasteners have plastic detent 

rings on posts. Visually inspect camera mount and check bracket screws as tight with 

device wrench. Install battery unit and confirm firmly inserted and secure. Inspect LED 

indicator covers and confirm tight, secure and unobstructed. Inspect by gently applying 

force to insure landing gear is not cracked and stressed and is firm and secure. Visually 

inspect each electric motor from the top to insure no debris has entered into the cooling 

windings and each motor turns freely. Inspect and apply gentle force to insure each prop 

guard is not cracked or stressed and is tight and secure. 

Pre-Flight Flight Plan.

Determine a flight plan prior to flight that includes duration of flight, purpose of flight, 

intended heights and maneuvers in order to accomplish the mission for the flight as well as 

the ability to maintain AT ALL TIME VLOS

Rehearse the flight plan prior to launch by verbally explaining what the flight plan will be. 

Determine the flight time, with noted times to finish each critical leg of the mission and a 

turn the flight time back to the launch site. 

Make a final review of the airspace and surroundings to insure the flight can be conducted 

in a safe and legal manner.

Launch Check List

Launch site clear and space adequate for safe launch and recovery of the 

UAV.

A Timer with the operator is set to 0 and ready for start

UAV battery on; confirm LED indicators showing pre-flight 

self-test.

LED solid green, start timer, launch UAV and hold at a 8 to 10 foot 

vertical ascent above launch site, allow to hover for 15 seconds to insure 

aircraft is in a proper flight mode and is capable of hovering.

Apply all the control inputs one at a time to insure the aircraft is 

responding to the appropriate control inputs. Once successful self hover 

and control inputs are tested and confirmed accurate, continue flight.

Conduct flight, read timer follow flight plan. Return to launch site when 

return to launch site time is reached
Ambrose 333 petition

Landing Check List

Visually inspect landing site, instruct all people to clear the site. Hover briefly above 

landing site to visually inspect aircraft and note any abnormalities to check before next 

flight.

Land the aircraft, shut down the motors, secure aircraft.
Ambrose 333 petition

. The petitioner should describe the Radio Frequency (RF) spectrum used for control of the UAS and associated 

equipment that is part of the UAS (i.e., sensors, cameras, etc.), and whether it complies with Federal 

Communications Commission (FCC) or other appropriate government oversight agency requirements. 

The unit operates in the 2.4HGz ISM and meets FCC requirements.

Regarding the Unmanned Aircraft PIC 

4. Petitioners should describe the qualifications required of any PIC(s) who will be directly responsible for the operation of the UAS, including 

information such as: the level of airman certificate held; any applicable training related to the operation; and any minimum hours of flight experience 

required by the PIC(s), both total flight time and the time with the particular UAS. If the operation would use visual observers, petitioners should 

describe their roles and qualifications. 

5. Petitioners should describe the medical standards and certification of the PIC(s) directly responsible for the operation of the UAS. 

I am the operator and petitioner and I currently hold an FAA 3rd class 

medical certificate, commercial ASEL, MEL certificate CFI-I and I am 

current and active as a CFI. I intend to maintain my currency and medical 

according to the FAA guidelines, and I intend to apply the same rules and 

vigilance as it relates to medical and physical condition necessary for flight in 

manned aircraft to the PIC of this UAV.

Regarding the Operation of the Unmanned Aircraft 

6. Petitioners should fully describe their intended UAS operation(s). Petitioners should describe how the proposed operation(s) would 

not adversely affect safety, or how they would provide a level of safety at least equivalent to that provided by the rule from which 

exemption is sought. Petitioners should address any plans to implement clearly defined operational borders and procedures to ensure 

public safety, which includes persons and property both in the air and on the ground. This can be described in the petition, in an 

Operations Manual, or similar document. 

My intended use is to use the camera feature to provide a service to individuals 

and business where a low altitude aerial view would be helpful in what they 

were trying to evaluate or accomplish. 

I intend to assess the mission as to what is expected to be accomplished,...then 

review all of the safety parameters. Airspace, proximity to other property and 

people, any potential violation of a person or persons privacy, flight time to 

accomplish the mission, weather affecting the mission, and condition and

performance capabilities of the UAV to accomplish the mission. Each will be 

reviewed and evaluated as part of the pre flight plan explained above.
Ambrose 333 petition

7. Petitioners should specify the proposed maximum operating speed and altitude, and describe minimum flight 

visibility and distance from clouds for their intended operation(s). Petitioners should describe potential hazards and 

safety mitigations associated with these proposed conditions. These issues can be addressed in the petition, an 

Operations Manual, or similar document. 

The intended speed will be less than 5 MPH as the UAV is positioned for still 

photography or video. It will operate below 400 feet and in relatively calm 

winds and high overcast to clear skies. I see no hazards apparent in these 

operating ranges.

8. Petitioners should describe the characteristics of the area of intended operation(s) and the associated potential 

hazards, in accordance with the statutory mandate under Section 333 

7 Rev. 9/25/2014 

The characteristics of the operation will be based on the mission. In almost all 

cases it will be a very slow, very low altitude photo mission. The mission will 

be carefully reviewed to determine any and all potential hazards are identified 

and the risk mitigated before the flight takes place. This would include 

proximity to other property, people or persons, potential privacy issues and 

potential controlled airspace penetration.

9. Petitioners should describe if they intend to operate in the proximity of any airports, in accordance with the 

statutory mandate under Section 333 regarding proximity to airports. 

I am a FAA pilot ASEL MEL CFI-I and totally familiar with the Sectional 

Chart and NAS. I am also very familiar with all the local airports. I will 

adhere to the statutory mandate regarding proximity to airports.

10. The UAS must be operated within visual line-of-sight (VLOS), in accordance with the statutory mandate under 

Section 333(b)(1). Petitioners should describe how they intend to comply with his mandate. 

THE VLOS requirement will be a critical part of the pre-flight planning and the final flight plan. The flight 

will be scrubbed or altered to prevent a loss of VLOS.

 

11. Petitioners should describe any procedures they would implement for conducting a preflight safety risk 

assessment to determine that the UAS is in a condition for safe flight (14 CFR § 91.7(b)) and that the planned 
Ambrose 333 petition

operation can be completed safely. These procedures can be addressed in the petition, an Aircraft Flight Manual, 

Operations Manual, or similar document. 

I answered this in section 2 in but will repeat it here:

I ( the petitioner) as a FAA certificated pilot and Certified Flight Instructor have developed 

habits for thorough pre-flight inspections, pre-flight planning, to insure safe flight. I will apply 

these habits to the safe operation of my under 55lbs UAV.

I intend to use the following pre-flight planning, pre flight aircraft check and create a follow a 

flight plan when operating the Phantom 2.

Pre-flight planning:

Weather check and evaluate if conditions are conducive for safe flight.

Location for flight to occur is not in controlled airspace, is clear of any people or obstacles 

that can impair the purpose and safe operation of the flight, and has no potential to 

contribute to any safety concerns of any other activity being conducted in the area of the 

flight.

I will discuss with the intended customer if the flight is to be used for business purposes 

what the objective of the aerial operation is to be; insure it could be conducted under all 

the safe and appropriate guidelines and inform the client he or she cannot interfere in any 

way with my operation of the UAV. An agreement on the intended flight will be reached, 

as to the manner and space the UAV will operate. The flight will only occur once this 

understanding is reached and will terminate immediately if the client interferes in any way 

with the space I will require away from any and all people during the operation of the 

UAV.

Pre-Flight Aircraft check:

Physical inspection of the entire unit for all mechanical connections tight and secure and 

cabling tight and secure. Feel prop edges for nicks or dents and replace with spare prop 

prior to flight. Confirm ZENMUSE gymbal secure and all fasteners have plastic detent 

rings on posts. Visually inspect camera mount and check bracket screws as tight with 

device wrench. Install battery unit and confirm firmly inserted and secure. Inspect LED 

indicator covers and confirm tight, secure and unobstructed. Inspect by gently applying 

force to insure landing gear is not cracked and stressed and is firm and secure. Visually 

inspect each electric motor from the top to insure no debris has entered into the cooling 

windings and each motor turns freely. Inspect and apply gentle force to insure each prop 

guard is not cracked or stressed and is tight and secure. 

Pre-Flight Flight Plan.

Determine a flight plan prior to flight that includes duration of flight, purpose of flight, 

intended heights and maneuvers in order to accomplish the mission for the flight as well as 

the ability to maintain AT ALL TIME VLOS
Ambrose 333 petition

Rehearse the flight plan prior to launch by verbally explaining what the flight plan will be. 

Determine the flight time, with noted times to finish each critical leg of the mission and a 

turn the flight time back to the launch site. 

Make a final review of the airspace and surroundings to insure the flight can be conducted 

in a safe and legal manner.

Launch Check List

Launch site clear and space adequate for safe launch and recovery of the 

UAV.

A Timer with the operator is set to 0 and ready for start

UAV battery on; confirm LED indicators showing pre-flight 

self-test.

LED solid green, start timer, launch UAV and hold at a 8 to 10 foot 

vertical ascent above launch site, allow to hove for 15 seconds to insure 

aircraft is in a proper flight mode and is capable of hovering.

Apply all the control inputs one at a time to insure the aircraft is 

responding to the appropriate control inputs. Once successful self hover 

and control inputs are tested and confirmed accurate, continue flight.

Conduct flight, read timer follow flight plan. Return to launch site when 

return to launch site time is reached

12. If petitioners intend to conduct operations which have existing requirements to notify Flight Standards District 

Offices (FSDOs) prior to operations – such as motion picture and television filming, or pipeline and powerline patrol 

– petitioners should describe their intended coordination in this regard for their proposed operation(s). 

NO NOT APPLICABLE TO MY OPERATION AND UAV