December 21, 2015 P a g e | 1 of 3 

## 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 C orp, 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 aeria l 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+ (O perations).

Petitioner ’ s c ontact 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: Eac h 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 horizo ntal 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 aut horized representative.

All operations sites will be secured, will utilize a visual observer (VO) and a PIC, and have a m aximum
total flight tim e of less than 45 minutes. Non

- participants (NPs) will be kept at least 500 feet awayDecember 21, 2015 P a g e | 2 of 3 from UA unless barriers or stru ctures 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,

includin g Flight Operations Manual , for each U AS which set forth safety considerations, training, general and specific operating procedures, specifications, inspection, maintenance, UAS set up , and other required and recommended procedures for proposed operations (operating documents).

II. I N 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 carr ying 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. E QUIVALENT LEVEL OF SAFETY: O perations 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,

rec reational, or sport pilot’s certificate, and a valid driver’s license is sued 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

struc tures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b).

PIC and VO training operation s will only be c onducted 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: O perating documents set forth inspection and maintenance procedures to ensure
airworthi ness.

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 daylig ht 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
batte ry voltage display and Low Voltage Warning s which alert when the battery reaches pre

determined levels. Battery level will be more than adequate to safely land the UAS if Low Voltage Warning s 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 requiredDecember 21, 2015 P a g e | 3 of 3 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