C0MP0

CONSTRUCTION

COMPANY

2704 Florida Avenue Norfolk, VA 23513

757-858-2184 Fax 757-858-2187

21 December 2015

U.S. Department of Transportation

Federal Aviation Administration

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir or Madam:

This petition is being submitted without legal counsel or consulting services.

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R.Part

11, Compo Construction, hereby applies for exemption from the Federal Aviation Regulations (FARs) listed below

to allow operation of Small Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal

Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined

herein or as may be established by the FAA as required by Section 333.

The requested exemption will permit Compo Construction to provide aerial photography and video recording of

constructionjobs in planning, progress and completed using a small advanced sUAV. Compo Construction states

that all sUAS flights will occur over private or controlled access property and will do so with the property owner’s

consent and knowledge and that only people who have consented or otherwise have agreed to be within the UAS’

radius during filming and photography applications.

Compo Construction has demonstrated the ability to safely and effectively fly the sUAS DJJ Phantom 3 which is

used for all commercial and private purposes. Compo Construction will comply with all local ordinances and laws

regarding the operation of sUAS, and will adhere to all weather and enviromnental restrictions or limitations in

reference to the operations of sUAS.

All flights will occur in ordinance with state or local laws regarding privacy.

Compo Construction is seeking an exemption because we are committed to complying with all rules, guidelines,

limitations, and future legislation set forth by the FAA. Compo Construction agrees to operate the sUAS in the

manner described, and for the purposes described.

The following is a list regulations from which Compo Construction is seeking exemption, and a complete list of

responsibilities Compo Construction assumes as owner/operator; it also contains information regarding the aircraft,

public benefit and safety features, and similar petitions requests granted.

Regulations from which exemption is requested:
• 14C.F.R. 21,subpartH

• 14C.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. 9.1.105

• 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. 9l.3l9(a)(1)

• 14 CFR 91, SubpartE(91.405, 91.407, 91.409, 91.417)

COMPO CONSTRUCTION, OWNER/OPERATOR, ASSUMES THE FOLLOWING RESPONSJBJLITWS:

1. Operations authorized by this grant of exemption are limited to the DII Phantom 3 when weighing less than 55

pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to

amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not pennitted.

3. The UA may not be operated at a speed exceeding 50 knots (60 miles per hour). The exemption holder may use

either groundspeed or calibrated airspeed to determine compliance with the 50 knot speed restriction. In no case

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

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be

reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) ofthe PlC at all times. This requires the PlC to be

able to use human vision unaided by any device other than corrective lenses, as specified on the PlC’s FAAissued airman medical certificate or U.S. driver’s license.

6. Ml operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight

(VLOS) ofthe PlC and VO at all times. The VO may be used to satis~’ the VLOS requirement as long as the

NC always maintains VLOS capability. The VO and FTC must be able to communicate verbally at all times;

electronic messaging or texting is not permitted during flight operations. The PlC must be designated before the

flight and cannot transfer his or her designation for the duration ofthe flight. The FiC must ensure that the VO

can perform the duties required ofthe VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the

conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating

documents. The operating documents must be accessible during UAS operations and made available to the

Administrator upon request. If a discrepancy exists between the conditions and 4 limitations in this exemption

and the procedures outlined in the operating documents, the conditions and limitations herein take precedence

and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating

documents. The operator may update or revise its operating documents. It is the operator’s responsibility to

track such revisions and present updated and revised documents to the Administrator or any law enforcement

official upon request. The operator must also present updated and revised documents ifit petitions for extension

or amendment to this grant of exemption. Ifthe operator determines that any update or revision would affect the
basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant

of exemption. The FAA’s UAS Integration Office (AFS—80) may be contacted if questions arise regarding

updates or revisions to the operating documents.

8. 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 conducting further

operations under this exemption. Functional test flights may only be conducted by a PlC with a VO and must

remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as

to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe

operation.

10. Prior to each flight, the PJC must conduct a pre-flight inspection and determine the UAS is in a condition for

safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components,

items, or equipment. Ifthe inspection reveals a condition that affects the safe operation ofthe 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life

limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PlC must hold either an airline transport, commercial, private, recreational, or

sport pilot certificate. The PlC must also hold a current FAA airman medical certificate or a valid U.S. driver’s

license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

government. The PlC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft

in which the PlC is rated on his or her pilot certificate.

14. The operator may not permit any PlC to operate unless the PlC demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PlC

qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights

for the purposes oftraining the operator’s PICs and VOs (training, proficiency, and experience-building) and

determining the PlC’s ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption are permitted under the terms ofthis exemption. However, training operations

may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential for flight operations are considered nonparticipants, and the PlC must

operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. 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.

16. The UA may not operate within 5 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 ofthe 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 the exemption holder. The letter of

agreement with the airport management must be made available to the Administrator or any law enforcement

official upon request.

17. 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 PlC

18. Ifthe UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location

within the private or controlled-access property.

19. The PlC must abort the flight in the event of unpredicted obstacles or emergencies.
20. The PlC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is

enough available power for the UA to conduct the intended operation and to operate after that for at least five

minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be

conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended

COA ifit intends to conduct operations that cannot be conducted under the terms ofthe attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in

accordance with 14 CFR part 47, and have identification (N—Number) markings in accordance with 14 CFR

part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight ofthe UAS and any documents required

under 14 CFR §~ 91.9 and 91.203 must be available to the PlC at the Ground Control Station ofthe UAS any

time the aircraft is operating. These documents must be made available to the Administrator or any law

enforcement official upon request.

24. The UA must remain clear and give way to all manned aviation operations and activities at all times.

25. The UAS may not be operated by the PlC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles,

and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from

the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain

under such protection. If a situation arises where nonparticipating persons leave such protection and are within

500 feet ofthe UA, flight operations must cease immediately in a manner ensuring the safety of

nonparticipating persons; and b. The owner/controller of any vessels, vehicles or structures has granted

permission for operating closer to those objects and the PJC has made a safety assessment ofthe risk of

operating closer to those objects arid determined that it does not present an undue hazard. The PlC, VO,

operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with permission from the property

owner/controller or authorized representative. Permission from property owner/controller or authorized

representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational

area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS—80) within

24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov.

SIMILAR EXEMPTIONS

They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062,

11109,11112, and 11213

Public Benefit and Safety

Unmanned Aircraft System sUAVs are often seen as superior to helicopters as an aerial video gathering platform

due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller

environmental impact which promotes public safety.

Compo Construction is petitioning for an exemption to operate a DII Phantom 3 with a built-in stabilized lID

camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to limit

the radius ofthe distance it flies from the operator and to exclude it from operations within designated Class B, C

and D airspace including a no-fly zone feature.
The DII Phantom 3 also has a failsafe function that is triggered in the event communication is lost between the

sUAS and the main controller transmitter. At that time, the sUAS will return to its point oftakeoff and land safety. If

the connection is restored, the PlC can regain control offlight and land manually.

These specifications meet with the Model Aircraft Operating Standards as set below:

• The petitioner will only operate its sUAS in line-of-sight of a pilot and/or observer and will operate at sites that

are ‘sufficient distance’ from populated areas within the sterile area described in the FOPM. Such operations will

ensure that the sUAS will “not create a hazard to users ofthe national airspace system or the public.”

• When flying the sUAS within three (5) miles of an airport, airport operators will be notified and the operator will

give the right-of-way to avoid flying in the proximity offull-scale aircraft. Maximum total flight time for each

operation will be 30 minutes.

• Flights will be terminated when battery levels reach 25%, allowing sufficient reserve flight time to safely land the

sUAS.

• The sUAS will be programmed so it will not be operated at an altitude that exceeds 400 feet AOL, and not more

than 200 feet above an elevated platform from which videography is planned.

• Minimum crew for each operation shall consist of: sUAS pilot (PlC) and a visual sUAS observer.

• The pilot (PlC) will complete at least 10 hours of computer based flight training prior first flight and then perform

as a pilot under training for a minimum of 4 hours prior to becoming a PlC. The initial company PlC is a retired

Navy airman with over 40 years of experience fly remote controlled aircraft at AMA sanctioned airfields. All PICs

will hold an FAA medical certificate or valid drive3r’ s license. All PICs will also complete an FAA certification

after the FAA establishes a streamed lined pilot program for drone operators.

• The sUAS operated by the petitioner weighs less than 25 pounds, including all payload (i.e. camera, lens, and

stabilized gimbal).

• The sUAS will operate at speeds of no more than 50 knots, can hover, and can simultaneously move vertically

and horizontally.

• Given the small size ofthe sUAS and the restricted sterile environment within which it will operate, Compo

Construction’s operations will adhere to the Reform Act’s safety requirements.

Very truly yours,

COMPO CONST UCTIO OMPANY

George. Compo
PHANTOM 3

PROFESSIONAL

User Manual

2a15.o6

dji

I 1
Appendix

Weight (Battery & 1280g

Propellers Included)

Max AstentSpeed 5n~s

Max Descent Speed 3 n~s

Max Speed lSnVs (ATfl mode, rio wind)

Max Flight Altitude 600Cm

Max Right Tine Apjndmalely 23 minutes

Operating Temperature 0°C to 40°C

GPS Mode GPSJGLONASS

Z~Z -

Controllable Range PucK - ~t to + 3Q0

‘nrlrrflfl - —

Velacity Range <8 mis (2 m above wound)

Altitude Range 30cm-SOD cm

Operating Range 30 cm-300 cm

Operating Environment Brigh~y lit (kin 15) pallerned swlaoes

J Z~E:JZi~.

Sensor Sony EXMOR has” Effective pixels:12A M (total pixels. 1276 M)

lens FQV 94° 2(~nrn(3&nm toimat equivalent) 1128

ISO Range 100-3200(video) 100-1~0(pho4o)

Electroric Shutter Speed Sc -h)BO(~)s

hnage Max Size 4000 x~flX)

Sngte shot

Burst shooting 3j5f7 frames

Still Photography Modes Auto Exposure Bracketing (AEB) 3/5

Max. Buirate OF Video

60Mbps Storage

Bracketed frames at 0.7EV Bias

Time-lapse

Micro SD

Max. capacity: 64GB. Class 10cr UHS-I rating reqiixed

IJHO : 4096x2l60p 24125. 3B40x2160p24/25/3O

BID: 1 920xl080p 24l25t~V48dS0dS0

HD:1280x720p 2eWSi3W4WSWGD

FAT3~exFAT

Supported File Fonnats Photo: JPEG. ONG

Video: MP4IMOV Q’APEG-4 AVCd1-1264)

Opecaling Temperature ~ 40°C

R~ge

F~l

a

Suppated SD Card Types

Video Recording Modes

4)2315011. 1.!Eifltr~i Rn~ts~id. 53
Phantom 3 Profeulonal User Manual

• BIlr~dr~ Omer

Flight Lima DJI P3kt app Airuaft Statist Indicator

Maxlrtun FigIt Aircraft’s altilude cniot Waniing: He~ht None

Mi[ude excdthescffiedva& kj*~’eaofrnd. -

Rar~dredfIathinfl

•• , ,~, flight distance must be within Warning: Distance r

‘vex .,~tus ~ tiiti ~ when cose tot, 1e

rex radius limit.

on si~n~i WeilS ~itting ~Ilow

Flight Limits DJI Ptt app Airuaft Stains h’~dlcator

H~ght1s restricLed Lo4C10 Wantig: Height limit. Km

feet. (12am) and under. reached. -n

Max Aadlius No limits

.Ifyiftywtdthnk~yucAno~tdthePhabbutarnokflyitanylathor~ffthe

~ ~ianloni 3 Ihes out of the max radiis Wi Ready Ia flj (non-ePS) mode, it ~ fl~ ba& W~ttM

range automaticaily.

• If the Ptw~om 3 tIes out of ttie max ra&iS ii Ready t Fly (non.~PS) mode, it w~ fly back

within range auion~lically.

No-FlyZones

P1 No-Fly Zones are ~:t~ ~ fl Oil otdai w&isite at lysafed~.con~o4~r. No-Fly Zones are

dMded WiIaAkpats and Resbicted Ata Pkpocts inckide majc airpods aid Ilykig fidde ntiere ~ned

alrcrnft operate at low altitudes. Restricted heat include border lines between countries or sensitive

insliLute. The details ci the No-fl~t Zones are e~Ith~ed as Iolbw

PJrport

(1) Airport No-Fly Zone are comprised of Take-off Reatsieted zones and Restricted Altitude Zones. Each

zone feattxes cities of various thes.

(2) fli miles (value of the Ill depends on the size and shape of the airport) around the ai’pctt isa Take

off restricted zone, inside of wf*h take off is prevented.

(3) FiomRl n’iiIeIoRl + I n~ieaotmdlhe po’tthe hLaitMudflItiMed ba15degreeWicfra~t

Staring at 65 bet (20 meters) from the edge of airport and radiating outward. The IRgit aUude is

thitedto l64Dfeet(5wmeters)atRl-i-l mire

(4) ~en the aircraft enters withIn 320 feet (1w meters) of No-Fly Zones. awam~~g message will appear

on the WI Pilot app.

~ 231~nJL A1i~~Ra~&r.gd. 41
Flight

Once pa-flight preperatin is comp4ete~ ~ le reccntendedthatyouuse the fight ~iuIelor in the DJL Plot

t hone sow fIght slct a-id praclice ~*g safeIy~ Fnsire lint ~ fl~i~ a-a caiiied ciA ban open

area

1. Do not use the alrci’afl In severe weather conditlDns. These in~ide wind speeds exceeding ID riva.

snow. rain aid fog.

2. Ordy f~ h’i open aea Tai ari,rtwes end large theisi sln)Dtixes tiny sElect the acc.aacy of the on

board compass and GPS system.

a Avoid obstacles~ ~owds, Ngh vcMage power lines, trees, and bodies of water.

4. Minlete interference by avelding areas with high levels of eleclromagrteiism, including base stalicns

and radio Iransmissicn towera

F~:7P 6. Aircraft and battery performance is subject to enyfronmental factors such as air density and

lanperatutese venjcatefd wt’ien flying ~ ailiudee gre~er than 19,885 feet (WOO nida’s) above see

,i level, as the peifomance of the battery and akcraft may be affected.

6. The Phantom 3 Professional cannot operate within the polar areas.

All unmanned aerial vehicle (UAV) operators shodd abkie by all regulations Sal forth by government and

regulaioiy agei~es includrig the ICAO and the FAA. For safety reasons, fights are k~ited by dotadt,

vthlch helps users operate this pi-oóict safely and le~ll~& Flight liniitalicns include heighL~s. distance

Irnas, and No-Fly Zones.

When operating in P-mode, height limits, distance limits, and No-Fly Zones function concurrently to

manage light safety. In A-mode, only height limits axe in effect, which by default prevent the aircraft

attitude from exceedIng 1540 (eat (500 m) -

MadrlxNn fighI ttude & Ra&is units

Maximum flight altitude and radius limits may be changed In the DJI Pilot app. Be aware that the

mexkmr light aflitude cant? exceed 1640 feet (5x meters). In accordance with these seltin~ yotw

Phantoms Professional Ml fly hi a restricted o~tder, as diown bebM

~Amxrnjm F~htMlhude

F4amePo~’t

H&ghtota]rciuit

~t’ionttjriwj aft

40 §2015 DJI.flRqlti Pn~o,;,i~i
Phmntom 3 Profen~onat U~mr t4aaual

Airp&rt

(1) ft ctedneascbes ~ha~’af~taI~ude resbicthns.

~ (2) R n~tes around the designated restdctlon area ~s a Take-oft Restricted area Aircraft carnaL take oil

ha ~ne. The value at R ‘jaies besed on me deffr~tbn of the restrictedareas.

(3) A ‘warning zone” has been set around the Restricted Area V~en the afrci’aft apprcechesvAtNri 0.6

‘Nsa (1 kni) of itt zone, a wwnin~ message wW appear en the Dii P~ot app.

Restricted Area

a ~

Ik~.Iy4tn. QftniiqlM* F,...n.,,

42 e 2olsQJtnT~ht,~ ~
Camera and Gimbal

The on-board camera uses the 112.3 inch CMOS sensor to capture video (up to 4(S6x2180p at 241ps cc

4K at up to aOtps with the PharAam 3 ProfessIonal) and 12 megaplxel at. You may choose to record

the video in ether MOV cx LW4 format Avalable picture shoothg modes include burst, continuous, and

time-lapse mode. A live pseview of what the camera sees can be monitored on the connected mctae

device via the DJI Pilot app.

Camera Micio-SD Card Slot

To store your photos and vIdeos. Insert the Mioo-SO card into the slot, as shown below, before

turning on the Phantom 3 Professional. The Phantoms Professional coa~es with a 16 GB Micro-SD

card ar-id supports Micro-SO cards up to 64 GB. A UHS-l Micro-SD card is secommeftded due to

their last read and write speeds allowing you to save high-resolution video data.

Camera Data Port

Turn on the Phantom 3 Professional and connect a USS cable to the Camera Data Pact to download

photos and videos to your con~utar.

r ~c

0

g

3

In

0 Do not remove the Micro-SD card tram the Phantom 3 Prolessional when it is turned on.

.t ,rz Jrn...

.~ a

its The afroraft must be lined on before atlempung to access the files on the #hc~-SD card

~) 2115 WI. MI*g!tz RnEa’~d. 3j
Remote Controller

The Phantom 3 Ptdession~ remote cortoIle~ isa mufli-lunclion wireless coatiu*alion device thai

htogrates the video downHnk system and aIcralt remote ccclrcl systan. The video do~*k and aIrctaiL

remote catol system operato at 24 GIa Tho t~mo1o con~toli~ fealures a ntxnber of camera con~ol

functions, such as taking and pre’~iawing phoTos and vidaos. as w~1I as controlling gimbal moflon.

The matte controI1a~ Is powered by a 2S rechaigoablo battery. The balteiy Ie’del ~ dsplayed via 1~D

iidica)ors on the front panel ot thD:emoio cc*itm1I~r.

~j~1 Comp~ncc ~rs~on: The rnmole ccitt Is amplbng wftl, toti CE and FCC refltbns.

• Oparallng Modo: Conlid cai be sat %o Model or Mode a aria a ctmtom macia

• Model The right stkk serves as the thro~l1a

• ModG 2: The left slick serves as the thmltlo.

Tum~g the Remote Controller On and Off

The Phantom 3 Professional romoto eontrol$er is powered by a 2S rechargeable battery that has a

capacity of OCXfl mAit The ba*Ler~’ Iôvel ~s indicated via th& Batt~ty Lev~i LEDs on the Ircnt panel. Ftlbw

the steps below to Wni on yes mane confrollmt

When the emo~e contvolles’ s turned off, press the Power aLAton once. The BaUey Lsvel LEDs wfll

display the curront baltery leveL

2. Press and hdd the Power BuLtcc~ m bin on the remDte controlI~r.

3. The remote controller will beep when it Is lurnod ort The Swius LED will rapidly b&d green. kdcathg

thai the remo&contro~a Is linking to the altcraft. The Status L&7s will g’ow soki green when lir*ng is

complate.

4. Repeal Step 2 to Ian oil tha remoto conlrollo.

Ai To prevent tra~sm~sthi in4Morenco. & no~ op~ato mote th&i lhrGG akerafts in the same ~‘ea

I

5

0

S

C

0

Chaiging the Remote Coniroler

Cbai~e tbG ranote cat1I~ tslng the üflided dwg&. Ro(ew to the iigtwe on ned page be&~w lot more

detat

C) 2~1S Cd’. AIIb~ti~i IiornMd. 23