PETI TI ONER:

Susan M. Pfeiffer , (a.k.a. Sue Pfeiffer) 4451 Coastline Ave. Carlsbad, CA 92008 email: harley sue@aol.com

The petitioner states she plans to operate a UAS, the Phantom 3 Professional , which is comprised of an unmanned aircraft (UA or PHANTOM) and a transportable ground station. T he PHANTOM is referred to as a quad

- copter with a maximum gross weight of approximately 3 pounds. It is equipped with four rotors that are driven by electric motors powered b y batteries. T he UA has a maximum airspeed of 31 knots and has an attached 4K Video / 12 Megapixel Photo camera with an integrated 3

- axis stabilization gimbal

. Petitioner plans to operate the UA over various areas near San Diego, California and Los Angeles, California to use for aerial photograph y, v ideography for television production for entertainment and educational purposes , enhance academic community awareness and augment real estate listing videos. Petitioner makes the following representations of operational enhancements which she proposes to a bide by to ensure this exemption will provide a level of safety at least equal to existing rules:

• She will only

operate in reasonabl y safe environments that are strictl y controlled, are away from power lines, elevated lights, airports and actively populated areas; and

• She will conduct extensive preflight inspections and protocols, during which safety carries primary importance. The petitioner states that given the size, weight, speed, and limited operating area associated with the aircraft to be utilize d by her , an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L . 112

- 95 (Section 333). Petitioner requests an exemption from § 45.23 Marking of the aircraft because her UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Fur the r, she states that two

- inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, petitioner states that she will mark her UAS in the largest possible lettering b y placing the word “Experimental” on its fuselage as required b y § 45.29(f) so that she or anyone assisting her as a spotter will see the markings. The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance i nspections may be required and should be granted since the y onl y appl y to aircraft with an airworthiness certificate. However, the petitioner states asa safety precaution she will perform a preflight inspection of her UAS before each flight

as outlined in her operating documents. UAS Pilot in Command (PI C) The petitioner asserts that under § 61.113 (a) and (b) private pilots are limited to non

- commercial operations, however she can achieve an equivalent level of safety as achieved by current regulations be cause her UAS does not carry any pilots or passengers. Furthe r, she states that, while he lpful, a pilot license will not ensure remote control piloting skills. She furthe r indicates that the risks of operating a UAS are far less than the risk levels inhe re nt in the commercial activities outlined in 14 CFR part 61, et seq., thus she requests an exemption from § 61.113 Private Pilot Privileges and L imitations: Pilot in command. Regarding UAS operational training, the petitioner states she has flown numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of her UAS’ performance under different temperature and weathe r conditions. She furthe r states that she practices computerized simulated flights to maintain adequate skills and response reflex time. In a supplemental request to the FAA, the petitioner requests consideration of a 120 day temporary

airman certificate in accordance with § 63.13, to allow her t ime to obtain a private pilot certificate or to allow the FAA time to establish minimum UAS airman certification standards.