Cameron T. Goetzel Aug 01, 2015

324 Heritage Oaks Dr.

Eugene OR, 97405

707-596-0062 (Cell)

cameron95492@gmail.com

US Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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

References: 1) FAA Exemption No. 11138, Regulatory Docket No. FAA-2014-0481 in the 

matter of the petition of DOUGLAS TRUDEAU

In accordance with the FAA Guidelines for Submitting a Petition for Exemption under Section 

333 of the FAA Modernization and Reform Act of 2012, I, Cameron T. Goetzel, referred to 

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

Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.103(b)(1), (b)(2)

In order to operate small unmanned aircraft systems (sUAS) commercially in airspace regulated 

by the Federal Aviation Administration (FAA) for the purposes of aerial photography, crop 

surveying, mapping, inspections and other flight operations that could be performed safely and 

more cost effective than manned aircraft, the petitioner would like to apply for an exemption 

from the above mentioned Code of Federal Regulations (CFR). Operations would only be 

conducted under the request and permission of clients or their authorized agents. Conditions 

outlined herein or as may be established by the FAA would be followed during all operations. 

The Petitioner seeks exemption from the above mentioned Federal Aviation Regulations for the 

following reasons;

61.113 (a) & (b); While helpful, a Private Pilots License will not ensure remote control piloting 

skills. An equivalent level of safety can be achieved by any pilots (PIC) operating under this 

exemption because the petitioner’s UAS does not carry pilots or passengers. The risks of 

operating a sUAV, which weighs less than 3 lbs. and utilizes fuel that is not combustible, are far 

less than those associated with commercial activities outlined in 14 CFR part61. The petitioner 

has already explored earning a Recreational Pilots Certificate, and would begin education and 

eventual certification at the direction of the FAA. 

91.119 (c); As discussed in Exemption 11138 (DOUGLAS TREDEAU) operations conducted 

closer than 500 feet to the ground may require the UA to be closer than 500 feet to essential 

persons or objects. The petitioner requests exemption or modification and clarification to the 
terms “congested areas” and “densely populated”. The petitioner requests this exemption to 

allow responsible operations within subdivisions and neighborhoods. 

91.121 As discussed in exemption 11138 (DOUGLAS TRUDEAU) is not applicable since UAS 

does not use an altimeter. Instead the UAS will utilize on electronic Global Positioning System 

(GPS) for altitude information.

91.103 (b)(1), (b)(2) If granted the petitioner agrees to additional safety procedures, but not 

limited to:

 1. Operating the UAS within a radius of 1000 feet from the ground station.

 2. Maximum flight times of 9 minutes. 

 3. Operate only within visual line of sight (VLOS)

 4. Use the UAS GPS safety feature to maintain controlled, and stable flight in the case 

 of a RC communication interruption.

 5. Post waring signs reading: “Attention Aerial Photography in Progress” 

 6. Constantly monitor telemetry feeds.

 7. Contact respective airports within 5 miles of operation and inform them of flight 

 time, flight duration, flight plan elevations, and any other pertinent information. 

 8. Have procedures in place to abort flight plans in the interest of safety. 

 9. Follow pre-flight check, maintenance, and overhaul procedures recommended

 by the manufacturer. 

 10. Logs containing UA flight time, incident, accident, and parts replaced will be

 recorded, and made available to the FAA. 

 

The DJI Phantom 3 Advanced

The DJI Phantom 3 Advanced is among the highest quality of small battery powered hobby 

grade quadcopters. It is equipped with four rotors which are driven by electric motors that utilize 

self-tightening propellers. It has a flying weight of 1280 grams and is primarily designed to carry

1080p HD camera. Its maximum horizontal flying speed is 35MPH, its maximum ascending 

speed is 13MPH, and its maximum descending speed is 8MPH. It utilizes an internal inertial 

measuring unit (IMU) augmented with GPS to maintain its position and geospatial orientation. It 

is controlled primarily with a FCC approved radio control (RC) system. Real time video, 

telemetry information can be transmitted down to the ground control and PIC to allow 

monitoring of battery level, altitude, distance from PIC, and GPS signal strength. It has failsafe 

modes for either RC signal loss or GPS signal loss. It has a maximum flight time of 

approximately 23 minutes with expected flight times of less than 10 minutes. 

Public Interest

Use of UAS instead of manned aircraft would enhance safety and reduce the environmental 

human footprint compared to similar activities conducted with manned aircraft. Aerial 

photography is a valuable marketing and inspection tool and can help ensure our economy’s 

growth through efficiency, and accurate representation. Crop surveying with UAS can help 
reduce the use of pesticides, help conserve water, as well as increased crop yields. Liability

insurance with obtained after exemption request is granted.