January 11, 2015

David Rabold

113 Alpine Court

Bowling Green, KY USA 42104

Mobile: (270) 303-9741

Home: (270) 842-1893

Email: david.rabold@crye-leike.com

Federal Aviation Administration: 

I, David E. Rabold, am writing pursuant to the FAA Modernization and Reform Act of 2012 and the 

procedures contained within 14 C.F .R. 11, to request that I, David E. Rabold, owner and operator of 

small unmanned aircraft (DJI Phantom 3 Professional) and registration number FA3WCX44MH, be 

exempted from the Federal Aviation Regulations ("FARs") listed below so that I, David E Rabold, may 

operate a small ultralight unmanned aircraft system (''UAS") commercially to be used for remote sensing 

to support aerial data collection specifically photography and video capture of residential and 

commercial properties including golf courses in airspace regulated by the Federal Aviation 

Administration ("FAA") in accordance with FAA UAS Regulations & Policies. 

I would like to formally submit for an exemption from the following Section 333 regulations: 14 C.F.R. 

Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 91.119(c), 

14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(l), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 C.F.R. 

91.407(a)(l), 14 C.F.R. 91.409(a)(l) and (2), 14 C.F.R. 91.417(a) and (b) to operate a Phantom 3 

Professional. This proposed exemption would allow the operation of unmanned aircraft systems (UAS) 

for the purpose of aerial videography/ photography as a service to the public/ business interests. As 

found in exemption No. 14078, No. 14097, and No. 14099.

The Phantom 3 Professional was selected because it has proven reliable flying capabilities and upgraded 

vision positioning system VPS, GPS aided navigation, blinking LEDs, failsafe mode for returning home 

when battery reaches a predetermined low warning, and prop guards. Also, records all take offs, 

landings and flight paths. 

The following are the DJI Phantom 3 Professional unmanned aircraft (UA) specifications:

1. Take-Off Weight 1280g

2. Max Ascent Speed 5m/s

3. Max Descent Speed 3 m/s

4. Hover Accuracy Vertical: +/-0.1m (when Vision Positioning is active) Horizontal: +/-1.5m

5. Max Speed 16 m/s (ATTI mode, no wind)

6. Max Flight Time Approximately 23 minutes

7. Battery Type LiPo4S

8. Remote Controller Operating Frequency 2.400 GHz-2.483GHz
9. Remote Controller Max Distance up to 5 km or 3.1 miles (unobstructed, free of interference) 

when FCC complainant and up to 3.5 km or 2.1 miles (unobstructed, free of interference) 

when CE compliant

10. Remote Controller Operating temperature 0 degrees C-40 degrees C

11. Remote Controller Battery 6000mAh LiPo 2S

Petitioner’s Previous Credentials

FAA Commercial Pilot Certificate, ratings: Airplane Single/Multiengine Land, Instrument Airplane, Flight 

Instructor

Kentucky Driver’s License Class D License #R94-138-791 expiration 02/19/2019

Specific section or sections of 14 CFR which I seek relief and the reason I seek 

relief: 

14 C.F.R. Part 21: Airworthiness Certificates 

Given the size and limited operating area associated with the aircrafts to be utilized by David E. Rabold, 

an exemption from Part 21 meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the reform Act. In all cases, an analysis of these criteria demonstrates that the UA 

operated without an airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than conventional aircraft operating with an airworthiness 

certificate without restrictions and conditions proposed. 

14 C.F.R. 45.23: Display of marks: general The UA does not have a cabin, cockpit, pilot station, fuselage, 

boom, or tail on which to mark certain words or phrases. Further, the two inch lettering is difficult to 

place on such a small aircraft with dimensions smaller than the minimal lettering requirement.

Small markings have been affixed to aircraft (drone) regarding aircraft registration number 

FA3WCX44MH.

14 C.F.R. 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command 

The FAA has previously declared that additional manned airship experience of a commercially certified 

pilot would not correlate to the airmanship skills necessary for similarly proposed operations in 

previously issued exemptions to this regulation through Exemption Nos. 11062 and 11138. 

14 C.F.R 91. 7: Civil aircraft airworthiness 

Currently, since there is no certificate applicable to the UAs in question, this regulation is inapplicable. 

14 C.F.R. 91. 9 (b) (2): Civil aircraft flight manual, marking, and placard requirements 
Requires an aircraft flight manual in the aircraft, however there are no pilots or passengers on board this 

aircraft and given its size, this regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining a safety/flight manual with the operator. 

14 C.F.R. 91.119(c): Minimum safe altitudes 

I, David E. Rabold, will ensure that UAS do not operate any higher than 400 feet at ground level. I will 

not fly over congested areas. I will plan operations before hand, for proper flight safety, and proper 

height analysis as to avoid collisions. 

14 C.F.R. 91.121: Altimeter settings 

The UAS utilize electronic GPS and a light bridge sensor. An equivalent level of safety will be achieved by 

using this. 

14 C.F.R. 91.151(a) (l): Fuel Requirements for flight in VFR conditions 

The UAS that we will fly are powered by electricity, using LiPo 4S battery that currently have a flight limit 

of approximately no more than 23 minutes. Therefore, due to the limitations of the battery, it is 

currently impossible to comply with part 91.151. 

14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required 

Currently, there are no procedures for providing airworthiness certificates for the mentioned UAS. I, 

David E. Rabold, however will always fly safely while having the manual of the DJI Phantom 3 

Professional on hand. C.F.R. 91.405(a): Maintenance Required, 

14 C.F.R. 91.407(a) (l): Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

14 C.F.R. 91.409(a) (I) and (2): Inspections &

14 C.F.R. 91.417 (a) and (b): Maintenance records 

Maintenance inspections may be required and should be granted since they only apply to aircraft with 

an airworthiness certificate. However I, David E, Rabold, will perform preflight inspections of the UAS 

before each flight as outlined in the operating documents. I, David E. Rabold, will also follow 

manufacturer recommendations from said operating documents. 

Public Interest 

Aerial photography and videography as an available service to the public allows for a cheaper method to 

capturing imagery than its alternative. Its alternative being aircraft and helicopters. They are expensive, 

create lots of noise, and are much more threatening due to size and combustible fuel. 

I, David E. Rabold, would gladly offer my services upon request and with proper coordination to any 

official search and rescue or emergency services organization to benefit the public. 

Also as mentioned in the Trudeau exemption, exemption No.11138: 

""Manned aircraft conducting aerial filming and photography can weigh 5,000 lbs. or more, are 

operated by an onboard pilot and may carry other onboard crewmembers, as well as 100 gallons or 

more of fuel. The petitioner's [UAS] weighs less than 3 lbs. The pilot and crew will be remotely located 
from the aircraft. The limited weight reduces the potential for harm to persons or damage to property in 

the event of an incident or accident. The risk of an onboard pilot and crew during an incident or accident 

is eliminated with the use of a [UAS] for the proposed operation." 

Summary 

I, David E. Rabold, am seeking exemption from the following rules: 

14 C.F.R. Part 21, 14 C.F.R. 45.23(b), 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R. 91.9(b)(2), 14 C.F.R. 

91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(l), 14 C.F.R. 91.203(a) and (b), 14 C.F.R. 91.405(a), 14 

C.F.R. 91.407(a)(l), 14 C.F.R. 91.409(a)(l) and 

(2), 14 C.F.R. 91.417(a) and (b) 

With the exemptions of the mentioned rules I, David E. Rabold, will be seeking to make my drone 

photography/videography services available to my clients and the public. By not using combustible 

fuel, flying at safe heights and strictly following the usage recommendations from DJI Phantom 3 

Professional. 

These include but are not limited to:

 Flying the following UAS Safely

 DJI Phantom 3 Registration Number FA3WCX44MH

 Flying below 400 feet

 Proper visual inspection of UAS before flights

 Keeping mentioned UAS in visual sight at all times when in operation

 Using an observer to assist if needed

 Remain well clear of and do not interfere with manned aircraft operations, and avoid other 

aircraft and obstacles at all times

 Not intentionally fly over unprotected persons or moving vehicles

 Contact the airport or control tower before flying within 5 miles of an airport

 Not flying in adverse weather conditions such as high winds or reduced visibility

 Not flying under the influence of alcohol or drugs

 Ensure the operating environment is safe

 Not flying over sensitive infrastructure or property such as power stations, water treatment 

facilities, correctional facilities, etc.

 Check and follow all local laws and ordinances before flying over private property

 Do not conduct surveillance or photograph persons in areas where there is an expectation of 

privacy without the individual's permission.

Respectfully, 

David E. Rabold

113 Alpine Court

Bowling Green, KY 42104 USA

Mobile: (270) 303-9741

Home: (270) 842-1893

Email: david.rabold@crye-leike.com