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FAA 333 Examiner’s Summary: 

Submitted by:

Erick F. Larsen

Consultant to:

Bryndon Romero, Owner

Pioneer Photography and Design, Inc.

262 W. Linden Ave. # C

Burbank, LA, Ca 91502

818-732-0330

ErickLarsen@Outlook.com

Pioneer Photography and Design, Inc. a NY Corp, Bryndon Romero, Owner, (Petitioner).

Pursuant to Section 333 of FAA Reform Act and Part 11 of Federal Aviation Regulations (FARs) 

petitioner seeks exemptions to conduct commercial aerial data collection (ADC) with its fleet of 

unoccupied (unmanned) aerial systems (UAS):

DJI Phantom 3 Professional

DJI Phantom 3 Advanced

DJI Inspire 1

DJI Inspire 1 Pro 

DJI S900, and

DJI S1000+

(Operations).

Petitioner’s contact information:

Bryndon Romero, Owner

Pioneer Photography and Design, Inc.

11 Todds Lane 

Newburgh, NY 12550

(845) 787-2509

info@pioneerpd.com

www.pioneerpd.com

www.facebook.com/pioneerpd

I. OPERATIONS DO NOT CREATE SIGNIFICANT HAZARDS: Each UAS is an electric multi-rotor craft, 

weighing less than 55 lbs. including ADC payload and has been previously 333 approved by FAA. 

Each operates at no more than 100 mph, can hover, and/or move in a vertical and horizontal plane 

simultaneously, will only be operated as visual line of sight (VLOS), will remain under 400 ft. AGL, 

will give way to all occupied aircraft, and will operate only over private or controlled access property 

with permission from the owner/controller of the property or authorized representative.

All operations sites will be secured, will utilize a visual observer (VO) and a PIC, and have a maximum 

total flight time of less than 45 minutes. Non-participants (NPs) will be kept at least 500 feet away 
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from UA unless barriers or structures are present that sufficiently protect NPs in event of an 

accident or loss of UAS control.

Petitioner's operating documents consist of this petition and manufacturer’s published data, 

including Flight Operations Manual, for each UAS which set forth safety considerations, training, 

general and specific operating procedures, specifications, inspection, maintenance, UAS setup, and 

other required and recommended procedures for proposed operations (operating documents). 

II. IN THE PUBLIC INTEREST: In numerous prior Grants of Exemptions for substantially similar 

operations, FAA has noted that "[t]he enhanced safety and reduced environmental impact achieved 

using a UAS with the specifications described by the petitioner and carrying no passengers or crew, 

rather than a manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption 

is in the public interest."

III. EQUIVALENT LEVEL OF SAFETY: Operations provide for at least an equivalent or even higher 

level of safety to operations under current regulatory framework.

IV. EXEMPTIONS REQUESTED: 14 C.F.R. § 61.113 (a) and (b): PIC will have at least a private, 

recreational, or sport pilot’s certificate, and a valid driver’s license issued by a FAA acceptable issuer 

and will meet 14 CFR § 61.56 flight review requirements in an aircraft in which PIC is rated on 

his/her pilot certificate. 

PIC will not operate unless the PIC demonstrates ability to safely operate UAS in a manner 

consistent with how UAS will be operated under petitioner’s exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 

CFR § 61.51(b). 

PIC and VO training operations will only be conducted in dedicated training sessions during which all 

persons not essential for flight operations will be considered NPs, and PIC will operate UA with 

appropriate distance from NPs in accordance with 14 CFR § 91.119.

Section 91.7: Operating documents set forth inspection and maintenance procedures to ensure 

airworthiness.

14 C.F.R. §91.119 (b) and (c): Facts stated herein will reduce or eliminate any potential adverse 

impacts to safety for operations in congested areas. Section 91.119 (c): Equivalent level of safety will 

be achieved under facts stated herein. 14 C.F.R. §91.121 UAS has a constant GPS altitude read out.

14 C.F.R. § 91.151(a): Only daylight operations of no more than 45 minutes will be conducted. UA 

will be safely landed when the battery falls below its nominal voltage. Each UAS has a constant 

battery voltage display and Low Voltage Warnings which alert when the battery reaches predetermined levels. Battery level will be more than adequate to safely land the UAS if Low Voltage 

Warnings alert.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Operator and PIC will ensure UAS is 

in safe working order prior to initiating each flight. Operator will perform and log required 
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maintenance and inspections. PIC will take all actions including reviewing weather, flight battery 

requirements, landing and takeoff clearance distances and aircraft performance data before 

initiation of flight to ensure flight safety.

Federal Register: “Petition for exemptions from FARs: 14 C.F.R. § 61.113 (a) and (b); 91.7 (a); 91.119 

(b) and (c); 91.121; 91.151 (a); 91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to 

conduct aerial data collection (ADC) via UAS.

V. CONCLUSION: Exemption should issue for petitioner's proposed operations.

Respectfully,

/Signed/

Erick F. Larsen

Consultant to:

Bryndon Romero, Owner

Pioneer Photography and Design, Inc.

262 W. Linden Ave. # C

Burbank, LA, Ca 91502

818-732-0330

ErickLarsen@Outlook.com