## C0MP0 CONSTRUCTION COMPANY

2704 Florida Avenue Norfolk, VA 23513 757-858-2184 Fax 757-858-2187

21 December 2015 U.S. Department ofTransportation 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 of2012 (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 ofSmall Unmanned Aircraft System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe conditions outlined herein or as maybe 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 overprivate or controlled access property and will do so with the propertyowner’s consent and knowledge and that onlypeople 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 ofsUAS, and will adhere to all weather and enviromnental restrictions or limitations in reference to the operations ofsUAS. 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 forthe 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 bythis grant ofexemption are limited to the DII Phantom 3 when weighing less than 55 pounds including payload. Proposed operations ofany other aircraft will require a new petition or a petition to amend this exemption. 2. Operations forthe purpose ofclosed-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 bythe aircraft manufacturer. 4. The UA must be operated at an altitude ofno more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL. 5. The UA must be operated within visual line ofsight (VLOS) ofthe PlC at all times. This requires the PlC to be able to use human vision unaided by any device otherthan 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 ofsight (VLOS) ofthe PlC and VO at all times. The VO maybe used to satis~’ the VLOS requirement as long as the NC always maintains VLOS capability. The VO and FTC must be able to communicate verballyat all times; electronic messaging ortexting is not permitted during flight operations. The PlC must be designated before the flight and cannot transfer his or her designation forthe 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 ofexemption, 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. Ifa 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 followthe 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 amendmentto this grant ofexemption. Ifthe operator determines that any update or revision would affect thebasis upon which the FAA granted this exemption, then the operator must petition for an amendmentto its grant

ofexemption. The FAA’s UAS Integration Office (AFS—80) maybe contacted ifquestions 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 ofa flight critical component, must undergo a functional test flight prior to conducting further operations underthis 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. Priorto 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 followthe UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements forthe aircraft and aircraft components. 12. Each UAS operated underthis exemption must comply with all manufacturer safety bulletins. 13. Underthis grant ofexemption, a PlC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PlC mustalso hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe 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 herpilot 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 underthis 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 forthe purposes oftraining the operator’s PICs and VOs (training, proficiency, and experience-building) and determining the PlC’s abilityto safely operate the UAS in a manner consistent with howthe UAS will be operated underthis exemption are permitted underthe terms ofthis exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experiencebuilding flights, all persons not essential forflight 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 undervisual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 16. The UA may not operate within 5 nautical miles ofan 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 ofagreement with that airport’s management is obtained or otherwise permitted bya 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 orwhen 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 ofunpredicted obstacles or emergencies.20. The PlC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is

enough available power forthe UA to conduct the intended operation and to operate afterthat forat least five minutes orwith the reserve power recommended by the manufacturer ifgreater. 21. AirTraffic Organization (ATO) Certificate ofWaiver orAuthorization (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 part47, 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 operatorto 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 orvehicle. 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 sufficientlyprotect nonparticipating persons from the UA and/or debris in the event ofan accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa 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 ofany vessels, vehicles or structures has granted permission for operating closerto those objects and the PJC has made a safety assessment ofthe risk of operating closerto those objects arid determined that it does not present an undue hazard. The PlC, VO, operatortrainees or essential persons are not considered nonparticipating persons underthis exemption. 27. All operations shall be conducted overprivate or controlled-access propertywith permission from the property owner/controller or authorized representative. Permission from property owner/controlleror authorized representative will be obtained for each flightto be conducted. 28. Any incident, accident, or flight operation that transgresses the lateral orvertical 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 reliefpreviously requested in Grant ofExemption Nos. 11062, 11109,11112, and 11213
Public Benefit and Safety Unmanned Aircraft System sUAVs are often seen as superiorto 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 abilityto 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-flyzone 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 controllertransmitter. At that time, the sUAS will return to its point oftakeoffand land safety. If the connection is restored, the PlC can regain control offlight and land manually. These specifications meetwith the Model Aircraft Operating Standards as set below:

• The petitionerwill only operate its sUAS in line-of-sight ofa 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 orthe public.”

• When flying the sUAS within three (5) miles ofan airport, airport operators will be notified and the operatorwill give the right-of-wayto 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 ofcomputerbased flight training priorfirst flight and then perform as a pilot under training for a minimum of4 hours priorto becoming a 

### PlC. The initial company PlC is a retired Navy airman with over 40 years ofexperience fly remote controlled aircraft at AMA sanctioned airfields. All PICs will hold an FAA medical certificate orvalid drive3r’s license. All PICs will also complete an FAA certification afterthe FAA establishes a streamed lined pilot program for drone operators.

• The sUAS operated by the petitionerweighs less than 25 pounds, including all payload (i.e. camera, lens, and stabilized gimbal).

• The sUAS will operate at speeds ofno 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 itwill 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, riowind) Max FlightAltitude 600Cm Max RightTine 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-SODcm Operating Range 30 cm-300cm 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 FQV94° 2(~nrn(3&nmtoimat 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 at0.7EV 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: MP4IMOVQ’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. 53Phantom3 Profeulonal User Manual

• BIlr~dr~ Omer Flight Lima DJI P3ktapp AiruaftStatist Indicator Maxlrtun FigIt Aircraft’s altiludecniot Waniing: He~ht None Mi[ude excdthescffiedva& kj*~’eaofrnd.

- Rar~dredfIathinfl

•• , ,~, flight distance must bewithin Warning: Distance r ‘vex .,~tus

~ tiiti ~ when cosetot, 1e rex radius limit.


## on si~n~iWeilS ~itting ~Ilow

Flight Limits DJI Pttapp AiruaftStains h’~dlcator H~ght1s restricLed Lo4C10 Wantig: Height limit. Km feet. (12am) and 

### under. reached. -n 

### MaxAadlius No limits 

### .Ifyiftywtdthnk~yucAno~tdthePhabbutarnokflyitanylathor~ffthe

~ ~ianloni 3 

### Ihes out ofthe max radiis Wi 

### Ready Iaflj (non-ePS) mode, it

## ~ fl~ ba&W~ttM 

### rangeautomaticaily.

• If the 

### Ptw~om 3

### tIes outof 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-FlyZones are dMded WiIaAkpatsand Resbicted Ata Pkpocts inckidemajc airpods aid Ilykig fidde 

### ntiere ~ned alrcrnft operate at 

### low altitudes. 

### Restricted heat include border lines 

### between countries or

### sensitive insliLute. The details

### cithe 

### No-fl~tZones 

### are e~Ith~ed as Iolbw 

### PJrport (1) 

### Airport No-FlyZone arecomprised ofTake-off Reatsieted zones and Restricted Altitude Zones. Each 

### zonefeattxes cities ofvariousthes. (2) fli 

### miles (value of the 

### Ill dependson the size and 

### shape ofthe airport) around the

### ai’pctt isaTake offrestricted zone, inside

### ofwf*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 enterswithIn320feet(1wmeters) of 

### No-FlyZones. awam~~g message will

### appear on the WI Pilot app.

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

# Flight Once pa-flightpreperatin iscomp4ete~ ~le reccntendedthatyouusethefight~iuIelorinthe DJL Plot t hone sowfIght 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 severeweatherconditlDns. These in~ide wind speeds exceeding ID riva. snow. rain aid fog. 2. Ordy f~ h’i open aeaTai ari,rtwes end large theisi sln)Dtixes tiny sElect the acc.aacy of the on board compass and GPS system. 

## a Avoidobstacles~ ~owds, Ngh vcMage power lines, trees, and bodiesofwater. 4. Minlete interference byavelding areaswith high levels ofeleclromagrteiism, including base stalicns and radio Iransmissicn towera F~:7P 6. Aircraft and battery performance is subject to enyfronmental factors such as air density and

lanperatutesevenjcatefd wt’ien flying ~ ailiudee gre~erthan 19,885feet (WOO nida’s) above see ,i level, as the peifomance ofthe batteryandakcraftmay beaffected. 6. The Phantom 3 Professional cannotoperatewithin the polarareas.

All unmanned aerial vehicle (UAV) operatorsshodd abkie byall regulations Salforth bygovernmentand regulaioiy agei~es includrig the ICAO and the FAA. Forsafety reasons, fights are k~ited by dotadt, vthlch helps users operate this pi-oóict safelyand le~ll~& Flight liniitalicns include heighL~s. distance Irnas, and No-FlyZones. 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 attitudefrom exceedIng 1540 (eat (500m)

- MadrlxNnfighI 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 hiarestricted o~tder, asdiown bebM

~Amxrnjm F~htMlhude F4amePo~’t H&ghtota]rciuit ~t’ionttjriwj aft

40 §2015 DJI.flRqlti Pn~o,;,i~iPhmntom3 Profen~onat U~mrt4aaual 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. Thevalue atR‘jaiesbesedon medeffr~tbnoftherestrictedareas. (3) A ‘warning zone” has been setaround 

### the Restricted Area V~en the afrci’aft apprcechesvAtNri 0.6 ‘Nsa(1 kni) 

### of ittzone, awwnin~ messagewWappearen the Dii P~ot

### app. RestrictedArea

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



### 42 e 2olsQJtnT~ht,~ ~

# Camera and Gimbal

The on-board camera usesthe 112.3 inch CMOS sensortocapturevideo (upto4(S6x2180p at241ps cc 4Kat up to aOtpswith the PharAam 3 ProfessIonal) and 12 megaplxel at. You may choose to record the video in ether MOVcx 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 viathe DJI Pilotapp. 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 tosave high-resolution videodata.

Camera Data Port Turn on the Phantom 3 Professional and connect a USS cable to the Camera Data Pact to download photos andvideos toyourcon~utar. r~c 0 

## g 3 In



# 0 Do not remove the Micro-SD card tram the Phantom3 Prolessionalwhen it isturned on.

.t ,rz Jrn...
.~ a



## its Theafroraftmustbe lined on beforeatlempung toaccessthefileson the#hc~-SDcard

~) 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 thevideo downHnksystemand aIcralt remoteccclrcl systan. Thevideodo~*kand 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)orson thefrontpanelot thD:emoiocc*itm1I~r. 

## ~j~1 Comp~ncc ~rs~on: The rnmole ccitt Is amplbngwftl, toti CE and FCC refltbns.
•Oparallng Modo: Conlid cai be sat%oModel or Mode

## a ariaactmtom macia
• Model The rightstkkservesasthe thro~l1a
•ModG 2:The leftslickserves asthethmltlo.

Tum~gthe Remote ControllerOn and Off The Phantom 3 Professional romoto eontrol$er is powered by a 2S rechargeable batterythat has a capacityof OCXfl mAitThe ba*Ler~’ Iôvel ~s indicated viath& Batt~ty Lev~i LEDson the Ircnt panel. Ftlbw the steps belowtoWnionyes mane confrollmt When the emo~e contvolles’ s turned off, press the Power aLAton once. The BaUey Lsvel LEDs wfll displaythecurront baltery leveL 2. Pressand hdd the PowerBuLtcc~

## m bin on the remDtecontrolI~r. 3. The remote controllerwill beepwhen it Is lurnod ort The Swius LEDwill rapidlyb&d green. kdcathg thai the remo&contro~a Is linking tothe altcraft. The Status L&7swill g’owsoki green when lir*ng is complate. 4. Repeal Step2to Ian oiltha remotoconlrollo. 

## Ai To preventtra~sm~sthi in4Morenco. & no~op~ato moteth&i lhrGGakeraftsin the same

### ~‘ea 

# I

5 0 S C



# 0

Chaigingthe Remote Coniroler Cbai~e tbGranotecat1I~ tslngthe üflided dwg&. Ro(ewtothe iigtweon ned page be&~wlotmore detat C) 2~1S Cd’. AIIb~ti~i IiornMd. 23