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A Pulitzer Prize-Winning Newspaper Owned locally by Sonoma Media Investments, LLC

December 28, 2015 

Chad Surmick

Sonoma Media Investments LLC

The Press Democrat

427 Mendocino Ave

Santa Rosa, Ca. 95401

Cell 707-291-5486 

Email: Chad.Surmick@pressdemocrat.com

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave SE 

Washington, DC 2059 

RE: Exemption Request Section 333 of the FAA Reform Act of 2012 

Attachments: 

1) DJI Phantom 3 Professional User Manual v1.2 - Link HERE (File too large to upload) 

References: 

1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the matter of the 

petition of DOUGLAS TRUDEAU 

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of the 

petition of ADVANCED AVIATION SOLUTIONS LLC 

3) FAA Exemption No. 11080 Regulatory Docket No. FAA-2014-0355 in the matter of the 

petition of FLYING CAM INC 

Dear Sir or Madam, 

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under section 

333 of the FAA Modernization and Reform Act of 2012, Sonoma Media Investments LLC, 

referred to hereafter as the petitioner, request exemption from the following sections of Title 14, 

Code of Federal Regulations:
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61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)(1); 

91.409(a)(2); 91.417(a) & (b); 

In order to operate a small unmanned aircraft system (UAS) commercially in airspace regulated 

by the Federal Aviation Administration (FAA) for the purposes of news gathering, aerial 

photography, cinematography, videography, mapping, agricultural surveying, and inspections 

which could be performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. national airspace system as compared to a manned aircraft. Operations 

will be performed only with the authorization and permission of the public or authorized agents 

in order to facilitate news gathering, commerce and raise awareness of the beneficial uses of 

small unmanned air systems. So long as such operations are conducted within and under the 

conditions outlined herein or as may be established by the FAA as required by Section 333. The 

conditions identified and proposed by the petitioner are drawn from references 1-3. 

The FARs 

The petitioner seeks exemption from the above mentioned FARs for the following reasons; 

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of pilots, who 

hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under this exemption 

would be required to comply with any conditions as set forth and in a similar fashion to the 

previously granted exemptions. 

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted 

closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. The petitioner 

requests modification, waiver or exemption and clarification concerning the terms “congested 

areas” and “densely populated”. The petitioner requests waiver for this condition to allow 

reasonable and responsible operations in areas of subdivisions and neighborhoods if required. 

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the 

UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for 

altitude information. 

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) 

prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS-specific relief has 

been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The 

UAS provides battery power remaining in percent to the PIC. The UA batteries provide 

approximately 25 minutes of powered flight. Information provided in the operating documents 

discusses procedures regarding remaining battery power management. Those documents contain 

a condition in which the PIC will initiate a landing procedure when battery remaining reaches a 

specified level. Given the limitations on proposed operations and the location of those proposed 
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operations, the FAA found that a reduced minimum power reserve for flight in daytime VFR 

conditions was reasonable. 

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in Exemption 11138 

(DOUGLAS TRUDEAU), The petitioner proposes to inspect and ensure that the UAS is in a 

condition for safe flight in accordance with the operating documents. The FAA found that 

adherence to the petitioner’s operating documents and the conditions and limitations specified, 

describing the requirements for maintenance, inspection, and record keeping, were sufficient to 

ensure that safety would not be adversely affected. 

The UAS 

The petitioner plans on utilizing the DJI Phantom 3 Professional. This airframe is a "pro-sumer" 

grade small rotorcraft in the quadcopter configuration powered by electric motors. Individual 

Specifications for the airframe are located in the table below. 

The DJI Phantom 3 Professional airframe utilize an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) to maintain its 

geospatial orientation and position. It is controlled primarily through an FCC certified radio 

control (RC) unit. Real time video and telemetry information is transmitted back to a ground 

control station allowing the operator and/or pilot in command (PIC) to monitor battery level, 

GPS signal strength, altitude (AGL), distance from PIC, camera imagery, and control camera 

angle. 

Failsafe modes of operation for either loss of signal (RC or GPS) or battery level. Altitude is 

limited and pre-programmed to not exceed 400ft AGL. Battery life limits flight times to 

approximately 20-25 minutes. The onboard flight controller will warn the pilot via telemetry

and external lighting cues before reaching a low battery state. An automatic termination of flight 

and landing will be initiated when the battery reaches a predetermined low state. It is anticipated 

that flights will usually last less than 10 minutes. More information is available in the product 

manual which is attached as a link. 

UAS Airframe Specifications 

DJI Phantom 3 

Weight (Pounds) 2.82 

Dimensions (inches) 23.23 (Diagonal) 

Max Speed (Knots) 30 

Temp Range (°C) 0° to 40° 
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Risk Mitigation

The petitioner has reviewed FAA exemptions reference’s 1-3 Conditions and Limitations section 

and believes that the procedures specified therein are reasonable and will be utilized in order to 

manage and mitigate risk and ensure public safety. A preflight checklist has been developed and 

employed to ensure that the UA airworthiness will be verified before launch. Airworthiness will 

be maintained by performance of routine inspections before each flight, maintaining flight and 

maintenance logs to record time on failure-prone components. 

The petitioner requests that in a manner similar to reference 3, he be allowed to operate within 5 

miles of an airport provided that; 

“The UA may not operate in Class B, C, or D airspace without written approval from the FAA. 

The UA may not operate within 5 nautical miles of the geographic center of a non-towered 

airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request.” 

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner is 

requesting a mechanism to facilitate such activities without requesting a new and separate 

exemption(s) should the need arise. Operations within Class B airspace are not requested due to 

the lack of Mode C transponder. 

Public Interest 

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the environmental 

impact as compared to similar operations conducted with manned aircraft of greater proportions, 

carrying a crew and flammable fuel. An exemption allowing the use of a DJI Phantom 3 

Professional UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. Operations for this 

petition will enable news gathering journalists to serve the public good in enhancing accurate 

dissemination of newsworthy and relevant information with timely aerial visual coverage.

Aerial photography is a valuable information and marketing tool that can lead to increased 

commerce. Agricultural surveying applications could lead to decreased use of pesticides and 

fertilizer and conservation of water as well as increased crop yields and decreased costs. Aerial 

surveying and inspections can increase work site efficiency, improve volumetric estimations and 

reduce risks.
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A visual observer will be utilized. Flight data including UA flight time, Control Unit operation 

time, incident, accident, and details concerning any deviations from normal operations will be 

available to FAA for use in collecting data regarding the use of UAS as part of this application. 

This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or other 

means as required. 

Conclusion 

The petitioner seeks an exemption, pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA) and title 14 Code of Federal Regulations part 11, which will 

permit the petitioner to safely operate a DJI Phantom 3 Professional UAS in the National 

Airspace System for the purposes of “news gathering, aerial photography, cinematography, 

videography, mapping, agricultural surveying, and inspections.” The petitioner has identified 

public agencies that could benefit from the operation requested in this application to aid in 

search and rescue by contract or donation.

Chad Surmick, of Sonoma Media Investments, is the Director of Photography for the Santa 

Rosa Press Democrat, a media outlet that consists of a 60,000 circulation daily newspaper, 

25,000 circulation magazine and news website. As part of the news media we work closely with 

public agencies and first responders and take safety very seriously.

Adding to the level of safety and experience in these operations, the petitioner has 12 years of 

experience in the radio control model aircraft hobby, 15 years of experience in general aviation

and holds the following FAA Airmen licenses, certificates and endorsements:

Private Pilot License – Single Engine Land Rating

Current Third Class Medical

Current Biannual Flight Review

Thank you in advance for your time and consideration. 

Sincerely,

Chad Surmick

Director of Photography

The Press Democrat

Sonoma Media Investments LLC