PETITIONER:

Susan M. Pfeiffer, (a.k.a. Sue Pfeiffer)

4451 Coastline Ave.

Carlsbad, CA 92008

email: harleysue@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.

The 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 by batteries. The 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 photography, videography 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 abide by to ensure this exemption will provide a level of safety at least equal to existing rules:

• She will only operate in reasonably safe environments that are strictly 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 utilized 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. Further, 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 by placing the word “Experimental” on its fuselage as 

required by § 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 inspections may be required and should be granted since 

they only apply to aircraft with an airworthiness certificate. However, the petitioner states as 
a safety precaution she will perform a preflight inspection of her UAS before each flight 

as outlined in her operating documents.

UAS Pilot in Command (PIC)

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 because her UAS does not carry any pilots or passengers. Further, she states that, 

while helpful, a pilot license will not ensure remote control piloting skills. She further indicates 

that the risks of operating a UAS are far less than the risk levels inherent in the commercial 

activities outlined in 14 CFR part 61, et seq., thus she requests an exemption from § 61.113 

Private Pilot Privileges and Limitations: 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 weather 

conditions. She further 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 time to obtain a 

private pilot certificate or to allow the FAA time to establish minimum UAS airman 

certification standards.