Warren Corder

6851 Benner Rd

Johnstown, Ohio 43031

I formally petition the Federal Aviation Administration (FAA) for an exemption from part

21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.119 (c) 91.121,

91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and

(b) of Title 14, Code of Federal Regulations (14 CFR).

Outlined below are the descriptions of the parts, subparts and sections in which I

request exemptions and my reason for requesting the exemptions.

Part 21 prescribes the procedural requirements for issuing and changing design

approvals, productions approvals, airworthiness certificates, and airworthiness

approvals.

Section 45.23(b) prescribes that when marks include only the Roman capital letter “N”

and the registration number is displayed on limited, restricted or light-sport category

aircraft or experimental or provisionally certificated aircraft, the operator must also

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters

not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,”

“light-sport,” “experimental,” or “provisional,” as applicable.

Section 61.113(a) and (b) prescribes that—

(a) no person who holds a private pilot certificate may act as a pilot in command of an

aircraft that is carrying passengers or property for compensation or hire; nor may that

person, for compensation or hire, act as pilot in command of an aircraft.

(b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in

connection with any business or employment if:

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an

airworthy condition.

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person

may operate an aircraft below the following altitudes:

(c) Over other than congested areas. An altitude of 500 feet above the surface, except

over open water or sparsely populated areas. In those cases, the aircraft may not be

operated closer than 500 feet to any person, vessel, vehicle, or structure.

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b)

or (c) of this section, provided each person operating the helicopter complies with any

routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the

minimums prescribed in paragraph (c) of this section.

Section 91.121 requires, in pertinent part, 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.”

Section 91.151(a) prescribes that no person may begin 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 [emphasis added].

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft

unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an

effective U.S. registration certificate issued to its owner or, for operation within the

United States, the second copy of the Aircraft registration Application as provided for in

§ 47.31(c).

Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil

aircraft unless the airworthiness certificate or a special flight authorization issued under

§ 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers

or crew.

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall

have that aircraft inspected as prescribed in subpart E of the same part and shall,

between required inspections, except as provided in paragraph (c) of the same section,

have discrepancies repaired as prescribed in part 43 of the chapter.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft

that has undergone maintenance, preventive maintenance, rebuilding, or alteration

unless it has been approved for return to service by a person authorized under § 43.7 of

the same chapter.

Section 91.409(a) (2) prescribes, in pertinent part, that no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had an inspection for the

issuance of an airworthiness certificate in accordance with part 21 of this chapter.

Section 91.417(a) and (b) prescribes, in pertinent part, that—

(a) Each registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of

the 100-hour, annual, progressive, and other required or approved inspections, as

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor,

and appliance of an aircraft. The records must include—

(i) A description (or reference to data acceptable to the Administrator) of the work

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return

to service. (2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and

appliance. (iii) The time since last overhaul of all items installed on the aircraft which are

required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last

inspection required by the inspection program under which the aircraft and its

appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives

including, for each, the method of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves recurring action, the time and date

when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration

to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under

§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is

approved for return to service.

I, Warren Corder’s exemption requests from all listed above are noted below:

Unmanned Aircraft System:

I, Warren Corder plans to operate the following UAS the DJI Phantom 3 Professional, 

which is comprised of an unmanned aircraft (UA or

PHANTOM’S). The DJI Phantom 3 Professional are

quad-copter’s with a gross weight of about 3 pounds each. Each UA is equipped with

four rotors that are driven by electric motors which is powered by batteries. The UA’s

have a maximum airspeed of 30 to 35 mph.

I, Warren Corder plans to use these UAS in aerial photography and cinematography on

farming sites, enhancing real-estate listings, personal and business properties, events,

movies, photographic views and other such tasks for businesses in and around the 

state of Ohio, which could benefit from an aerial view for their planning of future 

expansions and/or advertising of their products, business, or personal use. For most 

businesses, realtors, and individual people in the area, standard aerial

photography has been very cost prohibitive. The economic impact of being able to

assist these businesses using aerial photography would be substantial.

The use of this UAS in the above named applications greatly reduces risk to the public

and property as there is no fuel carried by the PHANTOMS, aircraft noise is greatly

reduced as opposed to a standard aircraft or rotorcraft both of which require numerous

passes or extended lengths of hover time to accomplish the same task as the

PHANTOMS can in only a few minutes. The PHANTOMS only weighs about 3 pounds

each and are by far a much smaller hazard to persons or property than a standard

aircraft or helicopter in the event of a catastrophic in-flight failure.

Warren Corder’s main priority is the safety of the public and it’s property.

I, Warren Corder makes the following representations of its operation in which to abide

by to ensure these exemptions if granted, will provide a level of safety at least equal to

existing rules: The PHANTOM will only be operated by, Warren Corder using the 

Phantom 3 Professional. All flying hours completed have been as a UAV

hobbyist, with the focus of:

. a) Collision avoidance

. b) Loss of C2 link procedures as outlined in the Operators manual for the

Phantom 3 Professional.

. c) Identification of inflight hazards i.e. aerial wires, birds in the area, changing

weather etc.

. d) Estimating distance from objects, persons, vehicles and vessels.

. e) Communication with the spotter(s)

. f) Completed the DJI Phantom 3 Professional pilot training guide maneuvers and skills.
. g) The ability to recognize persons or objects that are not part of the intended

and permitted part of the project that enter the 500 foot operational area unless

such persons or objects are deemed permitted by the owner or controller of the

property or area and the PIC (pilot in command) makes a safety assessment of

the risk of operating closer and it does not pose undue or significant risk.

. h) The ability to quickly and safely land the PHANTOM in the event of intrusion

into the safe zone.

. 1.) A complete pre flight systematic check by the PIC (pilot in command) of the

PHANTOM physical condition, i.e. props, landing gear, position indicator lights,

battery capacity, battery level of UAV and remote, and overall airframe condition.

If any of the above are not within the manufacturers minimum standards no flight

will take place until such time as the issue(s) is repaired to manufacturers

standards.

. 2.) Written documentation of each physical inspection and repairs if any, by the

PIC (pilot in command) will be kept with the Phantom and will be on-site and

available for review.

. 3.) Software in relation to both PHANTOM operation will be checked for proper

function. The most current DJI vision APP/DJI Pilot APP and the current firmware

will be installed to assure the most up to date safety features.

. 4.) Prior to every flight, the compass on the PHANTOMS will be calibrated as to

ensure precise location.

. 5.) I, Warren Corder will ensure the altimeter setting on the PHANTOMS is that of

AGL (above ground level) rather than GPS or barometric pressure derived

settings.

. 6.) Every safety feature offered through the DJI Pilot APP will be

enabled for every flight, every time.

Listed are the following safety features:

(6) Enable ground station

(7) Compass calibration

(8) Low battery auto go home

(9) Dynamic home point

(10) Current RTH (return to home) altitude (AGL)

(14) Low battery alarm

7.) Use of the DJI Ground Station GUI (graphical user interface)

Of particular interest are the following:

[3] Flight attitude and radar function

[4] Flight parameters-RTH (return to home) altitude, horizontal distance from

home point, altitude-vertical distance from home point, speed-horizontal flying

speed.

[6] Flight Battery Level indication

[7} There is a built in preflight checklist within the DJI vision APP/DJI Pilot APP

which is and will be completed prior to each flight.

[8] Aircraft GPS Status - I, Warren Corder,’s PHANTOMS will not fly with less than

(7) GPS Satellites available.

[14] Hide or show flight parameters- Warren Corder’s PHANTOM will ALWAYS

fly with parameters displayed in order to assist in maintaining safe distances from
persons and objects and to adhere to the flight plan.

The Documented Pre-flight, the raw pictures and/or the raw video footage as well as the

post-flight brief and written consent will be kept by Warren Corder for a period of time.

I, Warren Corder believes that given the size, weight, speed, and limited operating area

associated with the PHANTOM, requests 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).

I, Warren Corder requests exemption from § 45.23 Marking of the aircraft. The

PHANTOMS do not have a cabin, does not have a cockpit or a pilot station. Minimum

sized lettering and wording are difficult to place on the PHANTOMS. I, Warren Corder

will however affix a sticker on the unit which will contain contact information for the

company in case of aircraft loss.

I, Warren Corder requests an exemption from §§ 91.405(a), 91.407(a) (1), 91.409(a) (2)

and 91.417(a) and (b) Maintenance inspections and feel it should be granted since they

only apply to aircraft with an airworthiness certificate. I, Warren Corder has developed

maintenance inspections and documentation methods for the PHANTOM from

personal experience as well as the manufacturer’s user manuals.

UAS Pilot in Command (PIC) Under § 61.113 (a) and (b) private pilots are limited to

non-commercial operations.

I, Warren Corder requests relief from § 91.119(c) because the aircraft will be operated at

altitudes below 300 feet AGL. Section 91.119(c) states that no person may operate an

aircraft below the following altitudes: over other than congested areas, an altitude of 500

feet above the surface, except over open water or sparsely populated areas. In those

cases, the aircraft may not be operated closer than 500 feet to any person, vessel,

vehicle, or structure. I, Warren Corder will operate pursuant to the following restrictions

related to § 91.119:

-Operate in reasonably safe environments that are closely monitored by ground

assistants and signage placed in locations that would be considered reasonable

locations for pedestrians, vehicles or vessels to enter the area.

-Within 5 miles of airports and congested areas. Congested areas will be defined by

VFR charts as well as by contacting the Des Moines, IA FSDO (flight standards district

office).

- Conduct all operations under Warren Corder’s guidelines contained in the operating

documents and will analyze flight data and other sources of information such as the

manufacturer’s website to constantly update and enhance safety.

-Contact respective airports if operations will be within 5 miles to advise them of

estimated flight time, flight duration, elevation of flight and other pertinent information

deemed important by the airport.

- Always obtain all necessary permissions prior to operation. Permissions include but

are not limited to a (COA) and a request for a (NOTAM) as well as permission from the

property owner or person in control of the property and when practical, will be in writing

and kept on file. If it’s not possible to obtain written permission, the
PIC will document in writing how permission was obtained i.e. phone call with date, time

and party information.

I, Warren Corder requests relief from 14 CFR 91.121 Altimeter Settings. Warren Corder 

have a barometric altimeter and GPS derived altitude capabilities.

I, Warren Corder requests relief from § 91.151 (a) Fuel requirements for flight in VFR

conditions based on the following:

No fuel is used in the PHANTOM as they are battery operated. Batteries have, in our

experience have about 25 minutes of quality flying time. In the interest of safety,

I, Warren Corder, generally lands with 30% of battery remaining which gives about 15 -

20 minutes of flying time per battery. The PHANTOM have an audible battery state

warning system. I, Warren Corder will always follow the manufactures minimum battery

warning which is 30% remaining. There is also an on-screen warning of low battery

reading, ‘Return to Home’ and that message is announced if flight distance has

exceeded battery capacity. In this event, an emergency landing would be made as soon

as safe and practical. The PHANTOM also have an automated function which results

in immediate landing when a low battery is detected. Researching previous relief

requests, relief has been granted for manned aircraft to operate at less than prescribed

minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar 

UASspecific

relief has been granted in exemption Nos. 8811, 10808, and 10673 for daytime,

VFR conditions. I, Warren Corder will adhere to all VFR minimums as well as VMC

conditions when planning and/or executing any flights. There is little purpose for aerial

video or pictures if the weather is less than desirable. Following VFR minimum

standards will at least ensure a safe flight. Wind and forecast weather will be a key in

deciding suitable conditions. Local weather can be attained from the nearest airport by

using AWOS. No flight will take place in any condition that would potentially be outside

of the PHANTOMS capabilities in wind. I, Warren Corder will always fly within its 30%

minimum remaining battery life at its first intended landing point.

If there are any areas that have not been addressed, please contact me for

supplemental information.

Thank you for your time,

Warren Corder

6851 Benner Rd

Johnstown, Ohio 43031