20-B Ensanche Ramirez St., San German, PR 00683 Tel. 939-630-9556 email: richard@segurosenpr.com

July 24, 2015

TO: U.S. DEPARTMENT OF TRANSPORTATION 

DOCKET MANAGEMENT SYSTEM

1200 New Jersey Avenue SE

Washington, DC 20590

FROM: RICHARD L. DUNNAM

FAA PRIVATE PILOT CERTIFICATE 3328805

20-B Ensanche Ramirez St.

San German, PR 00683

Tel. 939-630-9556

richard@segurosenpr.com

RE: Request for Exemption Per PL 112-95 §333 from 14 CFR 61.113(a) and (b), 14 CFR 91.103, 

14 CFR 91.109, 14 CFR 91.119, 14 CFR 91.121, 14 CFR 91.151(a), 14 CFR 91.405(a), 14 CFR 

91.407(a)(1), 14 CFR 91.409(a)(2), 14 CFR 91.417(a) and (b)

These documents have been enclosed as attachments to provide additional reference of safety, 

maintenance and use of sUAV under consideration for this petition’s request for exemption of above:

 DJI Phantom 3 Safety Guidelines

 DJI Phantom 3 User Manual

Dear Sir or Madam:

This document serves as a petition and request for exemption of the above cited section of Title 14 CFR 

for myself, Richard L. Dunnam, hereinafter referred to as “the petitioner”, for sole purposes of conducting 

commercial aerial photography, videography, and survey operations using a small Unmanned Aircraft 

System (sUAS) in areas that could possibly fall under FAA controlled airspace.

This petition provides necessary information to justify an exemption from the above referenced Federal 

Aviation Regulations.

THE sUAS

The petitioner is the sole owner and sole pilot in command (PIC) of a DJI Phantom 3 Professional 

multi-rotor / quadcopter with 4 carbon fiber propellers, onboard camera, gimbal and on-board 

flight control systems that uses GPS and ground movement for stabilization purposes, as well as 

manual input control systems, such as those found in remote control (RC) units. The Phantom 3 

is operated by way of RC in the 2.4 gigahertz spectrum.
20-B Ensanche Ramirez St., San German, PR 00683 Tel. 939-630-9556 email: richard@segurosenpr.com

U.S. DOT DOCKET SYSTEM

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JULY 24, 2015

The Phantom 3 has a built-in functionality that can limit the height above ground level (AGL),

limit the distance between said aircraft and PIC, therefore restricting its operation under Class B, 

C, and D airspace. The aircraft also provides the ability to “return to home” (RTH) toward the PIC 

and land if connection to the RC is lost for more than 3 seconds.

The aircraft weighs in at 1,280 grams (2.82 lbs.) while carrying battery and camera gimbal. It has 

a maximum speed of 16 meters per second at 0 wind (just under 30 knots). It is powered by 

Lithium Polymer battery which supplies electric power to the 4 on-board brushless motors.

You may refer to the enclosed attached documents pertaining the DJI Phantom 3 User Manual, 

for more specific details.

It is warranted by petitioner that no changes to the aircraft will be made to such manufacturer’s 

specifications.

THE UAV PILOT IN COMMAND (PIC)

The petitioner will be acting as sole PIC of the DJI Phantom 3 Professional aircraft referenced 

herein. The petitioner is an experienced sUAS pilot since 2012 and has been PIC for the Phantom 

3 without incident. For practical, safety and operational compliance, a visual observer (VO) will 

be present at all times during flight. Also, the petitioner holds an FAA Private Pilot Certificate with 

3

rd Class Medical (Richard Dunnam - Certificate number 3328805) and was previous owner of 

Cessna 172M N-9397H, with experience in light maintenance and safety features of said aircraft 

type. U.S. Passport Card Number: C07533578

The petitioner is experienced in risk management, loss prevention surveys, insurance claims 

investigator, surveyor, educator, speaker, and photography for more than 30 years, which 

provides and extra level of safety and preventive attitudes to ensure the safety of people and 

property. 

THE OPERATIONS REVIEW

The sUAS operations scope will be to provide aerial photos, videos, and surveying services to the 

general public sectors, governmental, residential or commercial, and particularly pertaining to

real estate properties, general events, activities and surveys.

Operations under this exemption request is accepted by the petitioner to program or operate 

aircraft to prevent it from flying 400 feet or more AGL or 1,500 feet away from PIC. 
20-B Ensanche Ramirez St., San German, PR 00683 Tel. 939-630-9556 email: richard@segurosenpr.com

U.S. DOT DOCKET SYSTEM

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JULY 24, 2015

Before every operation and therefore takeoff, PIC and VO will review the aircraft’s checklists (as 

found under manufacturer provided documentations, as well as contained herein the attached 

documents) and survey area to determine if weather / wind / cloud conditions are suitable for 

flight and to determine emergency landing sites. All nearby persons will be dully notified and 

made aware of any flight operations. Flights will not take place over densely populated areas nor 

private property without owner’s or occupant’s permission. After landing, flight operations will 

not be considered complete, unless a thorough physical inspection of all aircraft parts, batteries 

and camera is finalized to determine if any maintenance is needed.

In comparison with manned flights, sUAS are less dangerous, hence would not affect safety 

adversely. We take into account the following, which justifies our need for exemption of the 

referenced FAR’s sections and rulings:

 The aircraft carries and uses no explosive materials or combustible liquid fuels of any kind.

 The sUAV, less than 3 lbs. of total aircraft weight with battery and camera gimbal, would 

cause minimal damage in the event of flight failure.

 The sUAV operational properties will allow to operate the same under a defined and 

controlled area for takeoff, flight and landing. 

 Takeoffs, flights and landings will be restricted to small area where all nearby people may 

and can be aware of flight operations in progress.

 All flights by PIC will begin and remain more than 5 mile radius of any airport, unless 

approved by Flight Standards Services, Ground / Tower Controls.

 All flights will be maintained with visual line of sight (VLOS) of both, PIC and VO

 Visual and verbal contact will be maintained at all times of flight operations between PIC 

and VO to detect and avoid possible midair hazards, such as trees, foliage, overhead 

transmission lines, towers, birds, animals or other objects.

All aspects of operations will be conducted with the utmost consideration for safety. Preflight, 

flight, and post flight safety assessment continuity and the inherently reduced risk of flying a 

sUAS (when compared to traditional manned aircraft for video, photo and surveys) the petitioner 

will be able to provide a greater level of safety.
20-B Ensanche Ramirez St., San German, PR 00683 Tel. 939-630-9556 email: richard@segurosenpr.com

U.S. DOT DOCKET SYSTEM

PAGE 4

JULY 24, 2015

THE BENEFIT TO PUBLIC INTEREST

By the FAA granting this exemption, it will provide a practical and economical benefit to 

consumers in general, in the petitioner’s territory of operation within the Commonwealth of 

Puerto Rico, USA. By providing other alternatives to traditional forms of aerial videography, 

photography, and surveys, we all can benefit economically and risk wise.

These key aerial sUAV characteristics make these services more accessible to smaller businesses, 

small and family owned agricultural operations, surveying homeowners and condo associations, 

just to name a few as examples. All this, in turn increases public benefit as a whole.

IN CONCLUSION

The petitioner shall satisfy all criteria as established in Section 333 of the Reform Act of 2012, 

including: size, weight, speed, flight within VLOS, distance from PIC, distance from airports, 

operational capabilities, preventive and safety maintenance, and benefit to the public in general.

Also, in accordance with FAA’s announcement of March 23rd, 2015, the petitioner will apply for 

a Certificate of Waiver or Authorization for any and all flights above 200 feet AGL.

These qualifications justify granting the petitioner, Richard L. Dunnam, with an exemption to the 

stated sections of Title 14 CFR. In addition, the requests of this petition are very similar and no 

different to numerous other businesses (corporations, LLC’s or individuals), all of whom have 

received Section 333 exemptions for use of comparable aircraft for similar operations.

I appreciate all your efforts and should you require contacting me, the petitioner, you may do so 

at e-mail: richard@segurosenpr.com or phone number 939-630-9556. Thank you very much for 

your consideration.

Best Regards,

Richard L. Dunnam

The petitioner