Ethan Narber

1/26/16

205 13th St SW

Altoona, IA 50009

ethannarber@gmail.com

Required Additional Information for Section 333 Exemption

SEEKING RELIEF FROM

Regulations in which Exemption is requested:

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b)

14 CFR Part 21, Subpart H: Airworthiness certificates 

Seeking exemption from Part 21, Subpart H in that the FAA establishes requirements for 

airworthiness certificates. Given the small size and nature of the UAS and the limited 

areas in which it may operate (no higher than 400 feet AGL and not out of visual line of 

sight of pilot-in-command), exemption from this Part is needed and is still in compliance 

with the safety under Part 11 and Section 333 of the Reform Act.

14 C.F.R. 45.23(b) – Display of Marks; general (b) 

Exemption from Part 45.23 (b) is needed because there is no entrance to cabin, cockpit, 

or pilot station on the UAS itself, nor room to display required font & words.

14 CFR 61.113 (a) - Private Pilot Privileges and Limitations: Pilot in Command

Seeking relief from Part 61.113 (a) in that the UAS cannot carry passengers or property, 

but will be used for compensation in business purposes. 

14 C.F.R. 91.7 (a) – Civil Aircraft Airworthiness
Seeking relief from Part 91.7 (a) in that there is no airworthiness regulation set for the 

UAS and there will be no certificate issued for the UAS to have.

14 CFR 91.9 (b) (2) – Civil aircraft flight manual, marking, and placard requirements

Exemption from Part 91.9 (b) (2) is needed because the UAS does not have the 

configuration or capacity to carry the required flight manuals, markings, placards, or any 

combination thereof. 

14 C.F.R. 91.103 – Preflight Action 

Seeking relief Part 91.103 due to the inability to perform a preflight of information in 

this part. Preflight actions required for the UAS are checking for safety and reliability of 

the UAS, weather in the area, GPS connectivity, surrounding areas, and referencing 

location and flight minimums for the UAS.

14 C.F.R. 91.109 – Flight instruction; Simulated instrument flight and certain flight tests

The UAS mentioned does not have fully functional dual controls; but is controlled by a 

remote control via radio communication for flight and operations. Safety in regards to 

pilot and passengers is of equal value in that the UAS cannot carry a pilot or passenger. 

14 C.F.R. 91.119 – Minimum Safe Altitudes 

Exemption from Part 91.119 is needed in that the 4-blade UAS acts primarily as a 

helicopter would, with vertical takeoffs and vertical landings with a typical flight altitude 

of ~200 feet and up to but 400 feet AGL; but never exceeding 400 feet AGL. All 

operations with are in civil daylight hours as prescribed by the FAA and in VMC (visual 

meteorological conditions) only. 

Careful planning to maintain 500ft from the nearest person, vessel, or structure will be 

conducted prior to each flight of the UAS. All person(s), vessels, and properties shall be 

notified if UAS operations should take place within the 500ft distance; and operations 

will be canceled and/or ceased if permission from one or more participants is not 

granted. 

All operations will remain within visual line of sight (VLOS) in VMC conditions. 

Exemption is requested so that the UAS may be operated at an altitude lower than the 

prescribed minimum safe altitudes under Part 91.119. Lower altitudes flown by the UAS 

will also prevent collisions from fixed-wing aircraft or helicopters in mid-air; assuming 

distance minimums that a UAS must remain from the civil airport and assuming that 

conventional aircraft are adhering to their prescribed Minimum Safe Altitudes according 

to their route of flight and/or approach to an airport. 

14 CFR 91.121 – Altimeter Settings

An exemption from Part 91.151 (a) is needed in that the UAS does not have an 

altimeter/pitot static system to have an operating adjustable barometric altimeter for 
use of reading altitude. Safety can be maintained by use of an internal GPS altitude 

readout from the technology onboard the UAS in addition to the pilot-in-command 

checking the exact altitude of the launch site before takeoff. 

14 CFR 91.151 (a) – Fuel Requirements for flight in VFR conditions

Exemption from Part 91.203 (a) & (b) is needed in that the UAS does not have fuel on 

board for flight. The UAS is equipped with an operating battery pack with only 25 

minutes of flight time, and not the required 30 minutes of reserve fuel in daylight VFR 

conditions prescribed by this part. Safety measures to prevent battery run out in flight 

are to limit flights on one battery pack to 20 minutes and no more, and carrying an extra 

battery pack for every flight that flight operations over 25 minutes are needed. 

14 CFR 91.203 (a) & (b) – Carrying civil aircraft certification and registration

Exemption from Part 91.203 (a) & (b) is needed in that the UAS does not have a cabin, 

cockpit, or pilot station and is not operated with a pilot on board; therefore there is no 

option to have certification and registration on board the UAS. Safety measures to 

comply with this are to have any certification or registration documents on the pilot-incommand at all times during flight operations from the ground control point where the 

pilot will be standing. 

14 CFR 91.405 (a) - 14 CFR 407 (a) (1) - 14 CFR 409 (a) (2) - 14 CFR 417 (a) & (b) –

Maintenance Inspections

Due to the fact that these sections as well as FAR Part 43 only pertain to aircraft with an 

airworthiness certificate, these sections need not apply to myself, Ethan Narber, or the 

UAS used during operations. Safety measures will be taken by proper education of parts 

and assembly of the UAS so that technical issues and safety hazards can be recognized 

early before issues can arise. The UAS has the ability to sense abnormalities and can 

notify the pilot that return to the starting position of takeoff is needed immediately. The 

UAS also has the ability to fly itself back to the starting point if the pilot does not or 

cannot respond. All maintenance will be made by the operator of the UAS prior to and 

after each flight operation on a needed basis. 

PUBLIC INTEREST OF GRANTING AUTHORIZATION

Granting this authorization to me, Ethan Narber, will benefit a broad customer base for 

which the business seeks to market and operate for. The UAS (DJI Phantom 3 

Professional) has a wide selection of technological features to keep the operator, and 

person(s) included in operations safe; as well as surrounding person(s), vessels, and 

property. All additional safety measures to be taken for the interest of safety in public 

are listed in each individual section for which exemption is requested. Using this specific 

UAS for various real estate, commercial, and private business practices also leaves a 

green outlook on business practices. The UAS does not require fuel, and is very 

environmentally friendly during flight operations. Many operations that are going to be 
conducted with these business practices are currently being done by manned fixed-wing 

or rotorcraft vehicles in the National Airspace System; and by granting this 

authorization, it will be contributing to less traffic congested in the NAS around large, 

urban areas with high densities of population. This equates to higher levels of safety in 

that the small size of the UAS does not pose such a threat as a fixed-wing aircraft does 

when maneuvering close to the ground in congested areas of operation. Using this UAS 

for business purposes also creates public interest in aviation sector and provides 

economic benefits to those involved in business transactions. 

ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

I am a licensed Private Pilot with an instrument rating through the Federal Aviation 

Administration. I have had my Private Pilot’s License since October of 2013. I am well 

educated and knowledgeable on the Federal Aviation Regulations and National Airspace

System. With that knowledge and understanding, I understand what additional safety 

measures must be taken to safely operate the UAS during operations. All additional 

safety measures are in original document for petition of exemption as well as located 

in this document under each specific regulation listed above for which exemption is 

requested. Information regarding the UAS (DJI Phantom 3 Professional) is located in the 

original petition for exemption (Docket No. FAA-2015-4618).