Central Oregon Aerial LLC

Austin Buskohl (President)

63351 NW Britta St

Bend, OR 97703

October 27, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Amendment to Exemption No. 12137 Issued Under Section 333 of the FAA

Reform Act and Part 11, in Regulatory Docket No. FAA-2015-1625

of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”

or “Section 333”), Subsection (f) of 49 U.S.C. § 44701, and 14 C.F.R. Part 11, Central Oregon 

Aerial Surveying LLC (“Central Oregon Aerial”) seeks an amendment to Exemption No. 12137 

to operate two additional small Unmanned Aircraft Systems: the DJI Phantom 3 Professional. On 

July 24, 2015, the FAA issued Exemption No. 12137 to Central Oregon Aerial LLC to allow it to 

operate the Yuneec Typhoon Q500 sUAS for aerial surveying, inspection and data collection 

services. This requested amendment to that exemption will allow Central Oregon Aerial LLC to 

operate the DJI Phantom 3 Professional for the same reasons and under the same conditions. 

There has been no other change in conditions and reasons relative to public interest and safety 

that were the basis for granting the original exemption.

Additional sUAS Platform – DJI Phantom 3 Professional

Operations pursuant to the exemption will be subject to strict operating requirements and

conditions to ensure at least an equivalent level of safety to currently authorized operations

using manned aircraft and under the same conditions as permitted by the FAA in Exemption

No. 12137. The DJI Phantom 3 Professional weighs approximately 2.83 pounds,

including payload. Both models are powered electrically via small, lithium polymer batteries

that drive electric propellers. The DJI Phantom 3 Professional has extensive automated control

features, redundant systems, and integrated fail-safes, and they will be operated under controlled

conditions and at low altitudes in airspace that is limited in scope.

Exemptions Requested

Central Oregon Aerial LLC respectfully requests exemptions from the following regulations 

previously granted by the FAA in Exemption No. 12137:
• 14 C.F.R. Part 21

• 14 C.F.R. 45.23

• 14 C.F.R. 61.113(a) & (b)

• 14 C.F.R. 61.133(a)

• 14 C.F.R. 91.7(a)

• 14 C.F.R. 91.9

• 14 C.F.R. 91.109(a)

• 14 C.F.R. 91.119

• 14 C.F.R. 91.121

• 14 C.F.R. 91.151(a)

• 14 C.F.R. 91.203

• 14 CFR Subpart E (91.401 - 91.417)

Airworthiness of the DJI Phantom 3 Professional

The DJI Phantom 3 Professional is airworthy and compliant with a significant level of safety.

In fact, the many previous 333 Grants of Exemptions by the FAA for operations of the Phantom 

3 Professional and similarly designed DJI platforms, underscore that operations of the Phantom 3 

Professional Central Oregon Aerial LLC will not adversely affect safety when compared to 

similar operations conducted by aircraft that have been issued an airworthiness certificate under 

14 C.F.R. Part 21, Subpart H. [E.g., FAA Exemption Nos. 11357 (granting exemption for the DJI

Phantom 2 Vision +), 11325 (granting same for the DJI Phantom 2)]. To be sure, the DJI 

Phantom 3 Professional weighs a mere 2.83 pounds (approximately 1,280 grams) and is

powered electrically by small, lithium polymer batteries that drive electric propellers. It operates

at a cruising speed of no more than 16 meters per second. This platform was designed with 

extensive automated control features, redundant systems, and integrated fail-safes which enhance 

safe takeoff, flight, and landing in many conditions. Further details of these features are provided 

in the DJI Phantom 3 Professional operating manual.

To maintain airworthiness, Central Oregon Aerial LLC will follow the inspection and 

maintenance program designed specifically for the Phantom 3 Professional by their 

manufacturer. This program is enhanced by in-flight monitoring systems for the Phantom 3 

Professional that monitor current position, direction, battery charge, flight time, and altitude, 

including both above the takeoff location. If onboard sensors detect critical situation at any time 

(low battery, weak data link signal, etc.) the aircraft will automatically initiate a preprogrammed 

safety procedure. In the event of any malfunction, the Phantom 3 Professional will undergo all 

maintenance required by the manufacturer and undergo flight-testing before recommencing 

commercial operations. Good cause exists to grant Central Oregon Aerial LLC an amendment to 

Exemption No. 12137. Doing so, is in the public interest based on the clear direction in Section 

333, the Federal Aviation Act, the high and equivalent level of safety of the proposed operations, 

and in consideration of the size, weight, speed and limited operating area associated with the 

Phantom 3 Professional. Accordingly, Central Oregon Aerial LLC respectfully requests that the 

FAA grant an expedited amendment to add the DJI Phantom 3 Professional to its sUAS 

operations.

Truly yours,

Austin Buskohl

Central Oregon Aerial LLC