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October 5, 2015

Rentenbach Constructors Incorporated 

2400 Sutherland Avenue

Knoxville, TN 37919-2354 

Phone: (865) 546-2440 Fax: (865) 546-3414 

www.rentenbach.com

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE, 

West Building Ground Floor, Room W12-140, 

Washington, DC 20590 

Request for Exemption under Section 333 of the FAA Modernization and Reform Act and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 

91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b). 

PETITION FOR SUMMARY EXEMPTION 

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, Rentenbach Constructors, Inc., an operator of Small Unmanned Aircraft (UA) hereby 

applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial 

operation of its UA, the DJI Phantom 3 Professional. 

TABLE OF CONTENTS

I. GLOSSARY OF ABBREVIATIONS..................................................................................................................3

II. QUICK REFERENCE SUMMARY.............................................................................................................................4

III. BACKGROUND..........................................................................................................................................4

IV. RENTENBACH CONSTRUCTORS, INC. REQUESTS THAT THE PUBLICATION AND COMMENT 

PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87. 

......................................................................................................................................................................4

V. FEDERAL REGISTER SUMMARY ................................................................................................................5

VI. PETITIONER’S CONTACT INFO .................................................................................................................6

VII. LIST OF REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED ................................................6
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VIII. OPERATING DOCUMENTS .....................................................................................................................6

IX. STATUTORY AUTHORITY TO GRANT THIS PETITION...............................................................................6

X. EQUIVALENT LEVEL OF SAFETY.................................................................................................................7

XI. REGULATIONS FROM WHICH EXEMPTION IS NEEDED..................................................................................12

A. 14 C.F.R. § 61.23(a) & (c): Medical Certificates.........................................................................................12

B. 14 C.F.R. § 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations & 14 C.F.R. § 61.315(a): 

Sport Pilot Limitations...................................................................................................................................12

C. 14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot In Command. .................................12

D. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness........................................................................................12

E. 14 C.F.R. § 91.119: Minimum Safe Altitudes.............................................................................................12

F. 14 C.F.R. § 91.121: Altimeter Settings.......................................................................................................12

G. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions....................................................13

H. 14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): Maintenance 

Inspections....................................................................................................................................................13

XII. CONCLUSION......................................................................................................................................................13

XIII. APPENDICIES........................................................................................................................................14
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I. GLOSSARY OFABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate Of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

GLONASS Global Navigation Satellite System

LOL Loss Of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line Of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Take-Off and Landing
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II. QUICK REFERENCE SUMMARY 

 Types of aircraft to be flown: 

 DJI Phantom 3 Professional

 The operations will be for: 

 Aerial data collection via video and photography 

 The petitioner will operate under the restrictions listed below.

 We already agree to all the restrictions listed in Exemption # 11284 which are listed below.

III. BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional

Rentenbach Constructors, Inc. seeks an exemption to operate the DJI system for compensation or hire 

within the (NAS). The DJI Phantom 3 Professional is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with Global Navigation Satellite System (GLONASS) and Ground Control Station (GCS) 

utilizing a 2.400 GHz Remote Control system with a computer tablet. The DJI Phantom 3 Professional has 

a maximum gross weight of approximately 2 pounds 13.2 ounces, while having a width of 24 inches and 

a height of 9 inches, and a maximum speed of approximately 31 knots. The DJI Phantom 3 Professional 

(UA) is equipped with four main rotors; utilizing Lithium Polymer batteries to power the electric motors. 

The DJI Phantom 3 professional (UA) that will be operated by Rentenbach Constructors, Inc. will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, 

Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.

IV. RENTENBACH CONSTRUCTORS, INC. REQUESTS THAT THE PUBLICATION AND COMMENT 

PROCEDURES BE WAIVED IN ACCORDANCE WITH 14 C.F.R. § 11.87. 

§ 11.87 Are there circumstances in which FAA may decide not to publish a summary of my petition for 

exemption? 

The FAA may not publish a summary of your petition for exemption and request comments if you 

present or we find good cause why we should not delay action on your petition. The factors we consider 

in deciding not to request comment include: 

(a) Whether granting your petition would set a precedent. 

(b) Whether the relief requested is identical to exemptions granted previously. 

(c) Whether our delaying action on your petition would affect you adversely. 

(d) Whether you filed your petition in a timely manner.

Corresponding to the above sub-sections, Rentenbach Constructors, Inc. has good cause to request the 

FAA to waive the comment period and not delay action on the petition because: 
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(a) Rentenbach Constructors, Inc. would not set any precedent. Rentenbach Constructors, Inc. 

agrees to the SAME exact limitations as Exemption # 11284. The aircraft, the Phantom 3, has 

already been evaluated under previous petitions and are deemed to have the equivalent level of 

safety if operated under the restrictions hereto already agreed upon. 

(b) Rentenbach Constructors, Inc. agrees to the SAME exact limitations as Exemptions # 11284

and #12749. 

(c) Delaying the granting of this petition would adversely affect the public, the FAA, and 

Rentenbach Constructors, Inc. The public, as well as the FAA, would be better served by the FAA 

quickly granting this petition and thereby freeing up limited FAA resources and allowing FAA 

inspectors to dedicate their time and attention to much higher priorities. Moreover, Rentenbach 

Constructors, Inc. is adversely affected by the below listed regulations. 

(d) The petition has been filed in a timely manner. 

V. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed. 

Applicant seeks an exemption from the following rules: 

14 C.F.R. 61.23(a) and (c); 61.101(e)(4) and (5); 61.113(a); 61.315(a); 91.119(c); 91.121; 

91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) & (b) to operate commercially a 

small unmanned vehicle (55 lbs. or less) for aerial data collection. 

This exemption will allow commercial operations of UAS which will enhance safety by reducing 

risk. The alternative to using a UAS is to use a jet or piston power aircraft carrying large amounts of jet A 

or other fuel. Not only is the operation dangerous at the location, the aircraft must fly to the location 

and back to the home airport. Our UAS will weigh less than 55 lbs. and powered by batteries which 

eliminates most of the risk because no highly flammable fuel will be involved. The UAS will carry no 

passengers or crew; thus, eliminating most of the risk to the pilot and personnel. The operations of the 

UAS listed under the restrictions proposed herein will provide an equivalent level of safety as the 

Federal Aviation Regulations. 
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VI. PETITIONER’S CONTACT INFO

In accordance with 14 CFR § 11.81, Rentenbach Constructors, Inc. provides the following information in 

support of its petition for exemption:

Rentenbach Constructors, Inc. 

Attn: Elizabeth Erin Walker

Email: liz.walker@rentenbach.com

651 East 4th Street, Suite 403

Chattanooga, Tennessee 37403-1930

Phone: 423-826-1640

Fax: 423-826-1644

VII. LIST OF REGULATIONS FROM WHICH THE EXEMPTION IS REQUESTED 

 14 C.F.R. § 61.23(a) and (c) 

 14 C.F.R. § 61.101(e)(4) and (5)

 14 C.F.R. § 61.113(a) 

 14 C.F.R. § 61.315(a) 

 14 C.F.R. § 91.7(a) 

 14 C.F.R. § 91.119(c) 

 14 C.F.R. § 91.121

 14 C.F.R. § 91.151(a)(1) 

 14 C.F.R. § 91.405(a)

 14 C.F.R. § 91.407(a)(1) 

 14 C.F.R. § 91.409(a)(1) & (2) 

 14 C.F.R. § 91.417(a) & (b) 

VIII. OPERATING DOCUMENTS 

Rentenbach Constructors, Inc. will operate only within the limitations below. The limitations below, 

from the previously granted exemptions, will be followed if there is a conflict with the UAS’s user 

manual, Appendix A. 

IX. STATUTORY AUTHORITY TO GRANT THIS PETITION 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under § 40101 of the Act 

that includes UAS’s, from the requirement that all civil aircraft must have a current airworthiness 

certificate. “The Administrator may grant an exemption from a requirement of a regulation prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator 

finds the exemption in the public interest.” 49 U.S.C. § 44701(f). See also 49 U.S.C. § 44711(b). 

This exemption petition is expressly submitted to fulfill Congress' goal in passing Section 333(a) through 

(c) of the FAA Modernization and Reform Act of 2012. This law directs the Secretary of Transportation to 
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consider whether certain unmanned aircraft systems may operate safely in the national airspace system 

(NAS) before completion of the rulemaking required under Section 332 of the FAA Modernization and 

Reform Act. In making this determination, the Secretary is required to determine which types of UA do 

not create a hazard to users of the NAS or the public or pose a threat to national security in light of the 

following: 

 The UA’s size, weight, speed, and operational capability

 Operation of the UA in close proximity to airports and populated areas 

 Operation of the UA within visual line of sight of the operator (VLOS)

If the Secretary determines that such vehicles "may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft in the national airspace 

system." The FAA has already established requirements for summary grants which will be further 

discussed below.

X. EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein applies to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. 

These limitations provide for at least an equivalent or even higher level of safety to operations under 

the current regulatory structure. These limitations and conditions are identical to Exemption # 11284 

except for the difference in aircraft. Rentenbach Constructors, Inc. agrees to be bound when conducting 

commercial UA operations. The list of limitations and conditions include the following: 

1. Operations authorized by this grant of exemption are limited to the Phantom 3 Professional 

when weighing less than 55 pounds including payload. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance 

with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than 

the maximum UA operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as 

specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

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

to communicate verbally at all times; electronic messaging or texting is not permitted during
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flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the VO can perform the 

duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during 

UAS operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in this exemption and the procedures outlined in the 

operating documents, the conditions and limitations herein take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator or any law enforcement official upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to this grant of 

exemption. If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an amendment to its 

grant of exemption. The FAA’s UAS Integration Office (AFS- 80) may be contacted if questions 

arise regarding updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional 

test flight prior to conducting further operations under this exemption. Functional test flights 

may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. 

The functional test flight must be conducted in such a manner so as to not pose an undue 

hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, 

e.g. inoperable components, items, or equipment. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a condition for safe 

flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

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

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman 

medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the 
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flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on 

his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC 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. PIC qualification flight hours and currency must 

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the 

operator’s PICs and VOs (training, proficiency, and experience-building) and determining the 

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA published aeronautical 

chart, unless a letter of agreement with that airport’s management is obtained or otherwise 

permitted by a COA issued to the exemption holder. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official upon 

request. 

17. The UA may not be operated 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 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. 

21. 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. 
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22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at all 

times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made a safety assessment of the risk 

of operating closer to those objects and determined that it does not present an undue 

hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating 

persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. Any 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 Web site: 

www.ntsb.gov . For the purpose of closed-set motion picture and television filming and 

production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with 

jurisdiction over the area of proposed filming. The 3-day notification may be waived with the 
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concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and 

times for all flights; b. Name and phone number of the operator for the UAS aerial filming 

conducted under this grant of exemption; c. Name and phone number of the person responsible 

for the on-scene operation of the UAS; d. Make, model, and serial or N-Number of UAS to be 

used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement 

that the operator has obtained permission from property owners and/or local officials to 

conduct the filming production event; the list of those who gave permission must be made 

available to the inspector upon request; 13 g. Signature of exemption holder or representative; 

and h. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to 

accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Rentenbach Constructor, Inc.’s UA are rotorcraft, weighing 55 lbs. or less including payload. 

They operate, under normal conditions at a speed of no more than 50 knots and they have the capability 

to hover, and move in the vertical and horizontal plane simultaneously. They will operate only within 

VLOS and only within the restrictions above. Such operations will insure that the UA will "not create a 

hazard to users of the national airspace system or the public."

Given the small size of the UA involved and the restricted sterile environment within which they 

will operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in 

which Congress envisioned that the FAA must, by exemption, allow commercial operations of UA to 

commence immediately. Also, due to the size of the UA and the restricted areas in which the relevant 

UA will operate, approval of the application presents no national security issue. 

Since the UA fully loaded weighs no more than 55 lbs. and is operated without an onboard pilot, 

there is no ability or place to carry certification and registration documents or to display them on the 

unmanned aircraft. An equivalent level of safety will be achieved by keeping these documents at the 

ground control point where the pilot flying the UA will have immediate access to them. Also, given the 

size of the unmanned aircraft, the FAA registration number will be displayed on the airframe in as large 

a font as possible. 
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XI. REGULATIONS FROM WHICH EXEMPTION IS NEEDED 

A. 14 C.F.R. § 61.23(a) & (c): Medical Certificates

Exemption # 11221, # 11284, and many others have provided that a U.S. driver’s license could be used in 

lieu of the medical certificate provides an equivalent level of safety. 

B. 14 C.F.R. § 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations & 14 C.F.R. § 61.315(a): 

Sport Pilot Limitations

Exemption # 11221, # 11284, and many others have declared that there is an equivalent level of safety 

as the FAR’s by requiring the PIC to “hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate.” Likewise, Rentenbach Constructors, Inc. is also performing commercial UAS 

work and is asking for the same restrictions which have been previously deemed to provide an 

equivalent level of safety as the burdensome regulations. 

C. 14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot In Command

Sub-sections 61.113(a) limit private pilots to non-commercial operations. Because the UAS will not carry 

a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a sport pilot license rather than a 

commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot 

and passengers, the UAS is remotely controlled with no living thing on board. 

D. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

As there will be no airworthiness certificate issued for the unmanned aircraft, and no FAA regulatory 

standard will exist for determining airworthiness of the UA, the requirements contained in the UAS’s 

user manual and the restrictions already agreed to will provide an equivalent level of safety. 

Furthermore, all of the aircraft in the exemptions above have been previously evaluated and deemed to 

have the equivalent level of safety of the regulations if operated under the restrictions above. 

Therefore, this aircraft should not be required to have an airworthiness certificate based upon the FAA’s 

previous determinations. 

E. 14 C.F.R. § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows 

helicopters to be operated at less than the minimums prescribed, provided the person operating the 

helicopter complies with any route or altitudes prescribed for helicopters by the FAA. Because of the 

lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude 

operations of the UAS will ensure separation between these small UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. 

F. 14 C.F.R. § 91.121: Altimeter Settings

This regulation requires 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." As the UAS may not have a barometric altimeter, but instead a GPS altitude 
13

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to following the confidentially submitted manual. Furthermore, many other petitions have 

been granted allowing GPS to be used in lieu of an altimeter setting. 

G. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "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." Applicant believes that an 

equivalent level of safety can be achieved by restricting operations to “the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater.” Exemption # 11284, at page 5.

H. 14 C.F.R. § 91.405 (a); § 91.407 (a) (1); § 91.409 (a) (2); § 91.417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter" and 

others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and 

Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the 

applicant. An equivalent level of safety will be achieved because these small UAS’s are very limited in 

size and will carry a small payload and operate only in restricted areas for limited periods of time. 

Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the 

aircraft in an airworthy condition to provide the equivalent level of safety. Lastly, the petitioner will 

operate in accordance with the UAS’s user manual which will provide an equivalent level of safety as the 

burdensome regulations. 

XII. CONCLUSION 

The operation of Rentenbach Constructors, Inc. using a small UAS, weighing less than 55 lbs., conducted 

under the proposed restrictions outlined above as well as the user manual, will provide an equivalent 

level of safety supporting the grant of the exemptions requested herein. If I can be of any assistance to 

further expedite this petition, please do not hesitate to contact me at (423) 826-1640 or via email at 

liz.walker@rentenbach.com. 
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XIII. APPENDICIES 

Appendix A:

Link to DJI Phantom 3 Professional User Manual: 

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_en.pdf