2015

Stidham Reconstruction 

& Investigation, LLC

PO Box 632

5961 Hwy 80

Wooton, KY 41776

(606) 279-6043

EXEMPTION REQUEST UNDER SECTION 333 

OF THE FAA REFORM ACT AND PART 11 OF 

THE FEDERAL AVIATION REGULATIONS

August 7, 2015
EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM 

ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS 2015

Page	1

August 7, 2015

U.S. Department of Transportation

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Regulatory Docket No.: 

Date Submitted: August 7, 2015

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 

C.F.R. Part 11, Stidham Reconstruction & Investigation LLC (SRI), seeks an exemption from the 

Federal Aviation Regulations listed below: 

 14 C.F.R. 21, subpart H 

 14 C.F.R. 61.3 

 14 C.F.R. 61.113(a)&(b) 

 14 C.F.R. 61.133(a) 

 14 C.F.R. 91.9(b)(2) 

 14 C.F.R. 91.103(b) 

 14 C.F.R. 91.105 

 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(a) & (b) 

 14 C.F.R. 91.319(a)(1) 

 14 CFR 91, Subpart E (91.405, 91.407, 91.409, 91.417) 

The requested exemption would authorize SRI to conduct commercial operations using the DJI 

Phantom for aerial data collection in support of forensic mapping and reconstruction of crime scenes 

and traffic collisions. These applications would utilize digital photography and imaging to measure areas 

through photogrammetric software processes.

In order to ensure at least an equivalent level of safety to currently authorized operations using 

manned aircraft the Phantom unmanned aircraft system (UAS) owned by SRI will be operated only 

by individuals who hold at least an FAA issued private, recreational, or sport pilot certificate and 

who have successfully logged two hours of in-air flight time with the DJI Phantom in a controlled 

setting.
EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM 

ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS 2015

Page	2

The characteristics of the UAS, detailed UAS operator requirements, and UAS operating 

parameters given below will ensure that all SRI UAS operations are carried out with an equivalent 

or higher level of safety than currently authorized manned aircraft operations. The details below 

regarding SRI’s intended UAS applications provide clear evidence that approval of this exemption is 

in the public interest.

CHARACTERISTICS OF THE UAS:

The Phantom has a diagonal motor-to-motor distance of approximately 14 inches. The Phantom is 

approximately 23 inches across, measured diagonally and including the propellers and propeller 

guards. The Phantom is constructed primarily of frangible materials (plastic) and weigh less than 3 

pounds. The Phantom is powered by a 2200 mAh LiPo battery giving it approximately 10 minutes 

of flight time. The maximum flight speed of the Phantom is 23 miles per hour and the maximum 

ascent/descent rate is 14 miles per hour. The Phantom communicates with the controlling 

receiver on a frequency of 2.4 GHz ISM on 7 channels. The maximum communicating distance for 

the Phantom is listed as 1000 meters. The Phantom operates using an on-board GPS receiver and 

flight controller for automatic attitude adjustment and flight stabilization. The Phantom also 

utilizes a GPS “home” location to automatically return to safely when communication is lost with 

the receiver. 

The Phantom operated by SRI for commercial use will be registered in accordance with 14 C.F.R 

Part 47, and will be marked in accordance with 14 C.F.R. Part 45, Subpart C, in a size as large as 

practical for the size of the UA.

The Phantom operated by SRI will be maintained in accordance with the manufacture’s 

maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and 

aircraft components and all pertinent instructions in the user manuals. Repairs, component 

changes, and software/firmware updates will be recorded in the UAS’s maintenance log. 

Maintenance log entries will include the date, UAS ID number, registration number, current UAS 

flight time, a description of work performed, and the name of the individual who completed the 

work. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight, prior to use in any commercial operations. The functional test flight must be conducted in 

such a manner so as to not pose an undue hazard to persons and property. The pilot in command 

(PIC) who conducts the functional test flight must make an entry in the aircraft records. 

A pre-flight inspection of the UAS will be completed by the PIC prior to each flight operation as 

specified in the DJI Phantom Owner’s Manual. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance 

has been performed and the UAS is found to be in a condition for safe flight. All SRI UAS will 

comply with all applicable manufacturer safety bulletins. The safety and reliability of the DJI 

Phantom that numerous FAA exemptions have previously been approved for their use in 

commercial operations.
EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM 

ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS 2015

Page	3

UAS OPERATING PARAMETERS:

In order to provide for a level of safety at least equivalent to operations conducted using manned 

aircraft, all SRI commercial UAS operations will be conducted in accordance with the following 

specific operating limitations:

 The UA may not be operated at a speed exceeding 20 knots (23 miles per hour). In no case 

will the UA be operated at airspeeds greater than the maximum UA operating airspeed 

recommended by the aircraft manufacturer.

 All operations shall be conducted in accordance with an Air Traffic Organization (ATO)-

issued COA.

 All UA operations will occur at or below 400 feet above ground level (AGL).

 No UA will be operated within 3 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA published 

aeronautical chart, unless a letter of agreement with that airport’s management is obtained 

or otherwise permitted by a COA issued to SRI. The letter of agreement with the airport 

management must be made available to the Administrator or any law enforcement official 

upon request.

 No UA will be operated within class B, C, D or E airspace unless a letter of agreement 

from the controlling Air Traffic Control (ATC) office is obtained or the flight is otherwise 

permitted by a COA issued to SRI. The letter of agreement from ATC must be made 

available to the Administrator or any law enforcement official upon request.

 The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s 

license.

 All operating documents and a grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations in the grant of exemption and the procedures 

outlined in the operating documents, the conditions and limitations in the grant of 

exemption take precedence and must be followed. Otherwise, the PIC must follow the 

procedures as outlined in the operating documents. 

 UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

 The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC.

 Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. All maintenance and alterations 

must be properly documented in the aircraft records.
EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM 

ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS 2015

Page	4

 Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry 

in the aircraft records.

 If the UAS loses communications or loses its GPS signal, the UA must return to a 

predetermined location.

 The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

 The PIC is prohibited from beginning a flight unless the UA’s battery level is at 75% or 

higher. The PIC must begin returning the UA to the designated landing area when the 

battery level drops below 25%.

 Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the aircraft is operating. These documents 

must be made available to the Administrator or any law enforcement official upon request.

 The UA must remain clear and give way to all manned aviation operations and activities at 

all times.

 The UA may not be operated below 150 feet AGL in the vicinity of any roadway while 

vehicular traffic is present.

 The UAS may not be operated by the PIC from any moving device or vehicle.

 UA will not be operated directly over nonparticipating persons unless barriers or 

structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. UA will not be operated over any open-air 

assembly of people.

 Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA will be reported to the 

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web 

site: www.ntsb.gov.

APPLICATIONS AND PUBLIC INTEREST:

The requested exemption would allow SRI to operate the DJI Phantom for the purposes of forensic 

mapping and reconstruction of crime scenes and traffic collisions. These operations are completed on 

residential, commercial and public properties including streets, roads, and highways. Use of UAS 

for these applications will offer significant advantages related to safety, time, and cost as well as 

overall improvement of quality and accuracy. SRI currently provides forensic mapping services in 

support of civil and criminal litigation. Our crime scene forensic models often demonstrate that 

certain events either could or could not have occurred as described by witnesses or affiants in the 

criminal court. This is clearly in the public interest in order to ensure justice is carried out 

according to scientifically sound evidence and methods. Furthermore, our traffic collision models 

often identify safety hazards that currently exist under various simulated conditions and 

recommend corrective modifications. This also is clearly in the public interest to improve the 

safety of motorists across the state of Kentucky. 
EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM 

ACT AND PART 11 OF THE FEDERAL AVIATION REGULATIONS 2015

Page	5

Currently these operations are conducted using traditional survey techniques utilizing a Nikon Nivo 

3.M total station and a topographic pole prism targets in order to map areas required to build 3D 

models. These methods require survey technicians to operate close to moving traffic, often where 

vehicular accidents have occurred previously due to unsafe road conditions. The ability for SRI to 

utilize a UAS in order to map crime scenes and traffic collision scenes greatly improves the safety 

for technicians by removing personnel and equipment from potential harm caused by unsafe or 

inattentive drivers. Use of manned aircraft is typically not feasible and therefore valuable 

information remains beyond the reach of the technician. In almost all cases, use of a UA is quicker 

and easier than any other alternative and often yields better information. Due to their small size and 

the fact they carry no fuel the DJI Phantom poses a very low risk of damage to persons, structures, 

or vehicles on the ground. Because these UA are electric powered, they create no harmful 

emissions and make very little noise.

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER:

SRI requests the grant of an exemption to the following specific sections of the Title 14 Code of 

federal Regulations which would allow it to operate micro UAS for commercial use:

14 CFR 21, subpart H, 14 C.F.R Sections 61.3, 61.113(a)&(b), 61.133(a), 91.9 (b)(2), 91.103(b), 

91.105, 91.109(a), 91.119, 91.121, 91.151(a), 91.203(a) &(b), 91.319(a)(1), 91.405, 91.407, 

91.409, 91.417

CONCLUSIONS:

SRI respectfully requests that the FAA grant the exemption sought in this request. SRI believes that 

considering the small size and weight of the UAS, along with the UAS PIC training and certification 

requirements stipulated above and the strict operating guidelines proposed herein, it is clearly 

demonstrated that the UAS will be operated safely in the national air space (NAS) with an equivalent or 

greater level of safety compared to manned aircraft. 

We are prepared to modify or amend any part of this request as deemed necessary by the FAA to satisfy 

the need for an equivalent level of safety. Please contact us at any time if you require additional 

information or clarification. 

Sincerely, 

Jeremy Woods

Phone: (606) 279-6043 ◦ Fax: (606) 279-6042 ◦ Address: P.O. Box 632 Wooton, KY 41776

Email: jeremywoods@stidhamreconstruction.com