Robert Pring

13387 High Res Way

Perris, CA 92570

robertpring@gmail.com

(714) 742 2119

August 21, 2015

Attention:

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington DC, 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization Reform Act and 

Part 11 of the Federal Aviation Regulations from: 14 CFR 21 Subpart H; 14 CFR § 91.203 (a) 

(1); 14 CFR § 45.23 (b); 14 CFR § 61.113(a); 14 CFR § 91.7(a); 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)(1); 14 CFR § 91.409(a)(2); 14 CFR § 91.417(a) and 14 CFR § 91.417(b).

Dear Administrator:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, 

Robert Pring, holder of an FAA Airplane Single-Engine Land, Instrument Airman Certificate and 

operator of an Unmanned Aircraft System (UAS) herby applies for an exemption from the listed 

Federal Aviation Regulations to allow commercial operation of its UAS so long as such operations 

are conducted within and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped with camera(s) and 

sensors would conduct the following operations:

 Aerial inspection/videography/photography of residential or commercial structures under 

contract with the owners or local authorities. Structures may include buildings, 

infrastructure, infrastructure components, construction sites and other facilities.

 Aerial videography/photography for public and/or private use including real estate, 

engineering, land surveying, agriculture or other related professional activities.

 Aerial videography/photography for public or private use including television, news events 

and broadcasts, public events and cinematography.

 Aerial inspection/video/photography/live video feeds for assistance in search and rescue

operations in cases of an emergency or natural disaster at the request of local authorities 

or government agencies whom have requested it by contract or donation

As described below, the requested exemption would permit the operation of a UAS under 

controlled conditions within the National Airspace System (NAS) that would be a) limited b) 

controlled c) predetermined and d) will provide safety enhancements to the already safe 

operations in the industry presently using conventional aircraft. Approval of this exemption would 

thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) 

responsibilities to “....establish requirements for the safe operation of such aircraft systems in the 

National Airspace System”.
U.S. Department of Transportation

August 18, 2015

Page 2

Applicant Name and Address:

Robert Pring

13387 High Res Way

Perris, CA 92570

(714) 742-2119

robertpring@gmail.com

The applicant holds an FAA issued ASEL – Instrument Certificate with a current Class 3 Medical 

Certificate. With over 400 flight hours in GA aircraft, the application is very knowledgeable of 

operations within the NAS and FAR’s governing aircraft operations. Further, the applicant is 

keenly focused on safe operations and has a clear understanding of the safety concerns involved 

with UAS technology and the potential for conflict with traditional aircraft. The applicant has over 

50 hours of flying time with UAS vehicles and all UAS operations will be conducted pursuant to 

requirements defined by the 333 exemption.

 

Exemption from the following regulations is requested:

14 CFR 21 Subpart H and 14 CFR § 91.203 (a) (1)

14 CFR § 45.23 (b)

14 CFR § 61.113 (a)

14 CFR § 91.7 (a)

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) (1) and (2)

14 CFR § 91 417 (a) and (b)

Robert Pring will operate the following UAS vehicles under this exemption:

DJI Phantom 3

The DJI Phantom 3 is a quadcopter weighing 1280 g or approximately 3 lbs. It measures 590 

mm or approximately 24” measured diagonally from propeller tip to tip. The maximum vertical 

speed is 5 meters per second (11 mph) and the maximum horizontal speed is 16 meters per 

second (36 mph). The Phantom 3 is powered by a 4480 mAh Lipo battery with a maximum flight 

time of approximately 23 minutes. It is controlled by a Remote Controller with an unobstructed 

range of 2,000 meters (6,500 feet). All radio transmission equipment complies with part 15 of the 

FCC rules. The Phantom 3 supports geofence technology that restricts flight areas, preventing 

flight within critical areas of the NAS. It also features an ‘Auto-Return Home’ feature, enabling the 

aircraft to automatically return to the point of departure upon command. An additional ‘Failsafe’ 

capability is including, causing the Phantom to automatically return to the point of departure if 

communications with the Remote Controller is lost or if the battery power is running low.

DJI Inspire

The DJI Inspire is a quadcopter weighing 2935 g or approximately 7 lbs. It measures 581 mm or 

approximately 23” diagonally. The maximum vertical speed is 5 meters per second (11 mph) and 

the maximum horizontal speed is 22 meters per second (49 mph). The Inspire 1 is powered by a 

4500 mAh Lipo battery with a maximum flight time of 18 minutes. It is controlled by a Remote 

Controller with an unobstructed range of 2 km (6,500 feet). All radio transmission equipment 
U.S. Department of Transportation

August 18, 2015

Page 3

complies with part 15 of the FCC rules. The Inspire supports geofence technology that restricts 

flight areas, preventing flight within critical areas of the NAS. It also features an ‘Auto Return 

Home’ capability, enabling the UAS to automatically return to the point of departure upon 

command. Additionally, a ‘Failsafe’ capability is built in, causing the Inspire to automatically 

return to the point of departure if communications with the Remote Controller is lost or if the 

battery power is running low.

Manuals for both UAS have been attached as hyperlinks in Exhibit ‘A’, Manufacturer Documents 

and Manuals

The applicant will conduct all UAS operations within ‘line of sight’ such as to never loose visual 

contact with the UAS and operated within a closed off and predetermined area owned and or 

operated by the property representative. Further, the applicant will use a Visual Observer during 

all UAS operations. The Visual Observer will monitor safety and potential conflicts during 

operations and be in constant voice contact with the pilot. 

Given the small size of the UAS and the controlled environment provided, the proposed 

operations adhere to the Reform Act’s safety requirements. Approval of this application presents 

no national security issues. Regarding the level of safety surrounding the proposed operations 

and the public benefit, reduction in environmental impacts, including but not limited to reduced 

emissions and noise, the grant of the requested exemption is in the public interest. Accordingly, 

the applicant requests that the FAA grant the requested exemption with minimum delay.

AIRCRAFT OPERATIONAL LIMITATIONS AND CONDITIONS PROVIDING THE 

EQUIVLAENT LEVEL OF SAFETY

To assist the FAA in its safety assessment of the applicants proposed UAS operations, below is a 

summary of the operational limitations and conditions which the applicant intends to follow to 

ensure an equivalent or higher level of safety to operations conducted under current regulatory 

guidelines:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum horizontal speed of not more than 50 mph.

 All UAS flight operations will be conducted within line of sight of the Pilot in Command 

(PIC) and/or Visual Observer (VO). The PIC shall hold a Private Pilot’s license with a 

current Bi-annual Flight Review and Medical certificate. The UAS PIC must have a 

minimum of 20 hours of UAS flight time

 All UAS flight operations will include a minimum crew of the UAS PIC and VO. The VO 

shall be able to communicate by voice with the PIC at all times.

 All UAS flight operations will take place under Visual Flight Rules Meteorological 

Conditions (VMC) only. Flight operations shall be conducted during daylight hours only.

 All UAS flight operations shall be conducted at a height of no more than 400 feet above 

ground level (AGL).

 The maximum flight time for each flight operation will be 30 minutes. Flight operations 

will cease when 30% of the battery power remains or 30 minutes of flight time has been 

achieved, whichever occurs first. 

 A briefing of the flight crew will be conducted prior to the planned UAS operations. All 

personnel involved in the operations will be present for the briefing. 

 The PIC shall have the capability to abort a flight for any reason. Flight operations will 

not be conducted without an active ‘Failsafe’ mode.

 The UAS flight operation shall remain clear of and yield right of way to all manned 

aviation operations.
U.S. Department of Transportation

August 18, 2015

Page 4

 The PIC and VO will be trained in the UAS operation and will have received up to date 

information on the individual UAS to be operated

 Without a COA issuing an exemption, UAS operations shall not occur closer than a 5 mile 

radius of the geographic center/Airport Reference Point (ARO) of an airport.

 Flight operations over private or controlled-access property require permission from the 

property owner/controller or authorized representative. All flight operations shall be 

conducted at least 500 feet from all non-participating persons, vessels, vehicles and 

structures unless barriers or structures are present to sufficiently protect nonparticipating 

persons. 

 Flight operations shall be entered into a log book with all records available for viewing by 

governing agencies.

PUBLIC INTEREST

UAS operations as described above meet or exceed existing standards of safety. Significantly 

smaller than manned aircraft, UAS vehicles are battery powered, resulting in zero flight emissions 

with no explosive fuels to ignite or explode causing public safety hazards. Use of UAS vehicles 

also significantly reduces the risks to persons caused by manned aerial photography, surveys 

and inspections. UAS vehicles may also be rapidly deployed for search and rescue and disaster 

assistance, conducting operations in areas that may otherwise be deemed too hazardous for 

manned aircraft. The public as a whole will benefit from safer and more cost-effective services 

that UAS operations provide.

REQUESTED REGULATORY EXEMPTIONS AND EQUIVLANT LEVEL OF SAFETY

14 CFR Part 21, Subpart H, and 14 CFR § 91.203 (a) (1)

Subpart H, entitled ‘Airworthiness Certificates’ defines the requirements for issuance of 

airworthiness certificates as required by 14 CFR § 91.203 (a) (1). Given the small size, weight 

and limited operating area of UAS to be used by the applicant, an exemption from Part 21, 

Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act authorize the 

FAA to exempt aircraft from the requirements for an airworthiness certificate upon consideration 

of the size, weight, speed, operational capability and proximity to airports and populated areas of 

the particular UAS. In all cases, an analysis of these criteria demonstrates that a UAS operated 

without an airworthiness certificate in the restricted environment and under the conditions 

proposed, will be at least as safe, if not safer, than conventional aircraft operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The applicant’s UASs weigh substantially less than 55 pounds, carry no pilot or passenger, carry 

no flammable liquid fuels or explosive materials and operate exclusively within secured and 

designated area. Flight operations under this exemption will be controlled and monitored by the 

PIC and VO, conducted in full compliance with the conditions of this document and any local 

public safety requirements. 

14 CFR § 45.23 (b) Marking of the Aircraft

Applicant requests an exemption from the provisions of 14 CFR 45.23 (b), which states in part, 

“...registration number is displayed on limited, restricted or light-sport category aircraft or 

experimental or provisionally certificated aircraft, the operator must also display on that aircraft 
U.S. Department of Transportation

August 18, 2015

Page 5

near each cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches 

high, the words ‘limited’, ‘restricted’, ‘light-sport’, ‘experimental’, or ‘provisional...” While the UAS 

will have no airworthiness certificate, an exemption may be required as the UAS will have no 

entrance to a cabin, cockpit or pilot station in which the word ‘Experimental’ may be placed. 

Given the size of the UAS, 2 inch lettering is impracticable. The word ‘Experimental’ will be 

placed on the fuselage in compliance with 45.29 (f). The equivalent level of safety will be provide 

by having the UAS marked on its fuselage as required by 45.29 (f) in a location where the pilot, 

observer and others associated with the UAS operations will see the identification of the UAS as 

‘Experimental’

14 CFR § 61.113 (a) Private Pilot Privileges and Limitations: Pilot in Command

Pursuant to 14 CFR § 61.113 (a), no person who holds a private pilot certificate may act as pilot 

in command of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as pilot in command of an aircraft. The applicant 

seeks an exemption to the compensation limitation as UAS operations undertaken will not be 

incidental to business or employment. The risks associated with UAS operations are far less than 

comparable commercial activities. Further, the PIC of the UAS will be a Private Pilot with a 

current BFR and valid Medical certificate.

14 CFR § 91.7 (a) Civil Aircraft Airworthiness

91.7(a) states that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificates issued for the UAS, this exemption should be granted as 

no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft 

and the applicant’s use of the manufacturer’s documentation for maintenance and safety checks, 

an equivalent level of safety will be provided.

14 CFR § 91.119 Minimum Safe Altitudes

The applicant seeks an exemption from the minimum safe altitude requirements of 14 CFR §

91.119. This section defines safe altitudes for operation of civil aircraft. Section 91.119 (d) 

allows helicopters to be operated at less than the minimums described, provided the person 

operating the helicopter complies with any route or altitudes prescribed for helicopters by the 

FAA. To perform the UAS missions contemplated by the applicant, the UAS will normally be 

operated in close proximity to the infrastructure to be inspected or photographed. Accordingly, 

due to the nature of these missions, the UAS may at times be less than 500 feet away from 

structures during the mission and an exemption is therefore requested.

The equivalent level of safety will be achieved given the size, weight and speed of the UAS as 

well as the location of operation. Proposed UAS flight operations shall require the permission of 

the property owner/controller or local official. Because of the need obtain permission from both 

the property owner and participants in the activity, all affected individuals will be aware of the 

planned flight operations. The relative size of the UAS and lack of flammable fuel presents risks 

far below those presented by conventional aircraft operating at or below 500 feet. Further, UAS 

operations shall not exceed 400 feet AGL, providing separation between UAS and conventional 

aircraft.

14 CFR § 91.121 Altimeter Settings

The applicant seeks an exemption from altimeter setting requirements prescribed by 14 CFR §

91.121 which requires a person to maintain altitude by reference to an altimeter that is set to the 
U.S. Department of Transportation

August 18, 2015

Page 6

elevation of the departure airport or barometric pressure. An exemption is required as the UAS 

does not have a barometric altimeter. Rather, the UAS utilizes GPS derived altitude. The 

applicant shall ensure the GPS system is operational and active prior to each flight operation and 

shall monitor the altitude displayed, not allowing the UAS to operate above 400 feet.

14 CFR § 91.151 (a) Fuel Requirements for Flight in VFR Conditions

The applicant seeks an exemption from the fuel requirements prescribed by 14 CFR § 91.151 (a), 

requiring enough fuel to fly to the first point of intended landing and, assuming normal cruising 

speed, during the day, to fly after that for at least 30 minutes. The UAS is battery powered and 

able to provide approximately 23 minutes of total flight time. As such, the UAS is not capable of 

meeting the 30 minute reserve requirement and a longer time frame for flight in daylight VFR 

conditions is reasonable

Operating the UAS in a tightly controlled area, where only people and property owners who have 

given permission for the operation are allowed, with less than 30 minutes of fuel does not present 

the type of risks 91.151 (a) was intended to address. With the small size of the UAS and line of 

sight operations, the applicant believes that an equivalent level of safety may be achieved by 

limiting flight operations to not less than 30% of the UAS battery power. This provides sufficient 

reserves to return the UAS to the landing zone from anywhere within the limited operating area.

14 CFR §§ 91.405 (a); 91.407 (a)(1); 91.409 (a)(1) and (2); 91.417 (a) and (b) Maintenance 

Inspections

The applicant seeks an exemption from the maintenance inspection requirements of 14 CFR §§ 

91.405 (a); 91.407 (a)(1); 91.409 (a)(1) and (2); 91.417 (a) and (b). These regulations require 

that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of 

this part and shall between required inspections, except as provide in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter...” and others shall 

inspect or maintain the aircraft in compliance with Part 43.

This section, as well as Part 43, apply only to aircraft with an airworthiness certificate and would 

not apply to the UAS. An equivalent level of safety will be achieved through maintenance and 

inspection as defined by the UAS manufacturer and conducted by the applicant. The UAS shall 

be thoroughly inspected prior to flight operations and any maintenance activities conducted will 

be in accordance to the manufacturer’s documentation and recorded in a maintenance log for that 

UAS. Given the small size of the UAS, limited flight time and restricted flight operations area, the 

safety risks posed by the UAS are significantly less than that of manned aircraft operating in a 

similar environment.
U.S. Department of Transportation

August 18, 2015

Page 7

CONCLUSION

The applicant requests that the FAA Administrator grant this exemption. Given the foregoing, the 

applicant’s proposed UAS usage does not pose a hazard to the public or NAS. The satisfaction 

of criteria provided in Section 333 of the Reform Act of 2012 provides a level of safety that should 

be satisfactory to the FAA and general public. In view of the benefits and advantageous to public 

safety, I respectively submit this Section 333 exemption request for commercial operations of the 

applicants UAS.

Submitted on August 21, 2015

/s/ Robert Pring

______________________

Robert Pring

13387 High Res Way

Perris CA, 92570

Applicant 
U.S. Department of Transportation

August 18, 2015

Page 8

Appendix ‘A’ – Manufacturer Documents and Manuals

Note: All attachments are provided by hyperlink to ensure that the most recent documentation is 

referenced and compliance with the manufacturer’s copyrighted materials.

DJI Phantom 3

Phantom 3 Standard User Manual: http://download.djiinnovations.com/downloads/phantom_3_standard/en/Phantom_3_Standard_User_Manual_v1.0_

en.zip

Phantom 3 Safety Guidelines: http://download.djiinnovations.com/downloads/phantom_3_standard/en/Phantom_3_Standard_Safety_Guidelines_

Disclaimer_en.zip

Phantom 3 Intelligent Flight Battery Safety Guidelines: http://download.djiinnovations.com/downloads/phantom_3_standard/en/Phantom_3_Intelligent_Flight_Battery_Safe

ty_Guidelines_en.zip

Inspire

Inspire User Manual: http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.zip

Inspire Safety Guidelines: http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Safety_Guidelines_en.zip

Intelligent Flight Battery Safety Guidelines: http://download.djiinnovations.com/downloads/inspire_1/en/Intelligent_Flight_Battery_Safety_Guidelines_en.zip

Inspire Maintenance Manual: http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.zip