July, 24 2015 

Attn: 

U.S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: PlNPOJNT PREDICTIVE MAINTENANCE SERVICE, LLC 

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS 

SECTIONS 6l.ll3(a) & (b), 91. 7(a), 91.121 , 91.151 (b), 91.405(a), 9 I .407(a)(l), 91.409(a)(l) & 

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 

3 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW I 12-95) 

Mr. Lyndy N. Serpan 

Owner 

Pinpoint Predictive Maintenance Service, LLC 

355 1 Lecsa Ln 

Edmond OK 73013 

405-410-] 477 

1yndyserpan@pinpointpdm.corn 
TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS .................................................................................. .3 

SUMMARY ........................................................................................................................... 4 

INTRODUCTION AND INTERESTS OF PET1TIONER ................................................... .4 

BACKGROUND .................................................................................................................... 4 

BASIS FOR PE·rrriON ......................................................................................................... S 

NAME AND ADDRESS OF PETITIONER ......................................................................... 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHfCH PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC SEEKS 

EXEMPTJON ......................................................................................................................... 7 

Page 

THE EXTENT OF RELLEF PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

SEEKS AND THE REASON PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC'S 

SEEKS RELIEF ............................................................................................................... } 0 

TilE REASONS WHY GRANTING PINPOINT PREDICTIVE MAINTENANCE SERVICE, 

LLC'S REQUEST WOULD BE IN THE PUBLIC INTEREST 

............................................................................................................................................. 12 

THE REASONS WHY GRANTING THE EXEMPTION TO PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC WOULD NOT ADVERSELY AFFECT 

SAFETY ................................................................................................................................ 14 

SUMMARY TI IAT CAN BE PUBLISIIED IN THE FEDERAL REGISTER ................... 25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

REQUEST ............................................................................................................................. 25 

CONCLUSION ...................................................................................................................... 25 

APPENDICES ........... ...... .. ............ ..... ........... ... ............. .. ........... .. ............ 26 

2 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

P IC' 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofFederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Ainnan 

Pilot In Command 

FAA Moderni zation and Reform Act of2012 (PMRA) 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

3 
SUMMARY 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks exemption iiom the 

requirements of 14 C.F.R §§ 61. 11 3(a) & (b), 91.7(a), 9 1.121, 91.151(b), 91.405(a), 

91.407(a)(l ), 91.409(a)(l) & (a)(2), and 9 1.417(a) & (b), to operate Unmanned Aircraft Systems 

(DJI Phantom 3 and 3 DR X8+) pursuant to Section 333 of the FAA Modernization and Reform 

Act of2012 (FMRA). This exemption will permit PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video, photography, and infrared imaging of construction sites, residential and 

commercial real estate, electrical distribution and transmission systems, over certain areas of the 

United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

The PfNPOINT PREDICTIVE MAINTENANCE SERVICE, LLC has provided their cli ents 

(which include private sector businesses and non-profits, along with local state and federal 

agencies) with expertise and knowledge in video, public relations, and training using advanced 

technologies and solutions. The objective of The PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC and our Unmanned Aircraft Systems aerial operations is to provide a more 

affordable, high-quality production/inspection system for a variety of governmental, conunercial, 

public, and residential uses, specifically targeting 

• Construction sites before and after 

• Appraisals 

• Real-estate marketing 

• Electrical Systems 

• Private and governmental training 

PINPOINT PREDICTIVE MAINTENANCE SERVICE will be using the DJI Phantom 3 and 3DR 

X8+ Unmanned Aircraft Systems (UAS). 

1 have been safely flying radio control aircraft (fixed wing and rotorcraft) for over 26 years. 

BACKGROUND 

Pinpoint Predictive Maintenance Service, LL V Unmanned Aircraft Systems (UAS): DJI 

Phantom 3, and 3DR X8+ 

The PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks an exemption to 

operate UAS for compensation or hire within the NAS. The UAS are vertical takeoff and landing 

4 
(VTOL) Unmanned Aircraft (UA) with a Ground ContTol Station (GCS) utilizing electronic 

tablet or smart phone systems. The DJI Phantom 3 has a maximmn gross weight of 

approximately 2.8 lb. while having a diagonal dimension of 23 inches, a maximum speed of 

approximately 31 knots and a maximum flying height of 400 ft. The Dn Phantom 3 is equipped 

with four main rotors; driven by Lithium Polymer battery powered electric motors. The 3DR 

X8+ has a maximum gross weight of approximately 5.6 lb., diagonal dimension of 20 inches, a 

maximum speed of approximately 32 knots and a maximum flying height of 400 ft. The 3DR 

X8+ is equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. 

'1l1e DJI Phantom 3 and 3DR X8+ UAS that will be operated by PiNPOINT PREDICTIVE 

MAJNTENANCE SERVICE, LLC wilJ be registered in accordance with 49 U.S.C. 441 03, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraji Registration, and marked in 

accordance with 14 C.F.R. Part 45, ldent!fication and Registration Marking. 

BASIS FOR PETITION 

Petitioner, PINPOINT PREDICTNE MAINTENANCE SERVICE, LLC, pursuant to the 

provisions oftheFederal Aviation Regulations (14 C.F.R. § 11.61) and the FAJ\ Modernization 

and Refonn Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to commercially operate the DJl Phantom 3 and 30R 

X8+, UAS in the National Airspace System (NAS), and for an exemptionii·om the requirements 

of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91. I 21 , 91.15l(b), 91.405(a), 91.407(a)(l ), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, PJNPOINT PREDICTIVE MAINTENANCE SERVICE, 

UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21 , Subpart H. 

Accordingly, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC requests relief from 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections 

set forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC submits that the requested relief is 

proper since an equivalent level of safety will be ensured. PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and UAS 

Instruction Manuals). Furthermore, PiNPOINT PREDICTIVE MAINTENANCE SERVICE, 

LLC will document and maintain all maintenance records for the UAS. 

5 
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private 

pilot or higher level ce1t iticate, as well as an airman medical certificate, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able 

to safely operate the UAS in a manner consistent with this exemption, including evasive and 

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

structures. 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks relief from Section 91.7(a), 

entitled Civil aircraft aifworthiness, because the UAS do not require an airworthiness certificate 

in accordance with 14 C.P.R. Part 21, Subpart H. As such, PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC submits that they will ensure that the UAS is in an airwor1hy 

condition, prior to every flight, by determining that the UAS are in compliance with the 

operating documents (i.e., Flight/Maintenance Log, and UAS Instruction Manuals), and that the 

aircraft are in a condition for safe flight. 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Sellings, as the UAS will not have a typical 

barometric altimeter onboard. However, altitude infom1ation of the UAS will be provided to the 

PIC via Global Positioning System (GPS) equipment and radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This 

altitude information, combined with PINPOINT PREDICTIVE MAINTENANCE SERVICE, 

LLC operation of the UAS within visual line of sight, at or below 400 feet AGL, will ensure a 

level of safety equivalent to Section 91.1 21. 

Additionally, PfNPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks an exemption 

from the requirements of Section 9 1.1 51 (b), entitled Fuel requirements for flight in VFR 

conditions. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC submits that safety 

will not be affected by operation of the UAS during daylight hours in visual meteorological 

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 23 minutes. Battery power indicators are also able to show exactly 

how much battery power is left, as well as how much time is needed to return safely back to 

point of take off. 

6 
In accordance with 14 C.F.R. § ll.81, PTNPOJNT PREDICTIVE MAINTENANCE SERVICE, 

LLC provides the following information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

The name and address of the Petitioner and point of contact is: 

Mr. Lyndy N. Serpan 

Owner 

Pinpoint Predictive Maintenance Service 

3551 LeesaLn 

Edmond OK 73013 

405-410-1477 

lyndyserpan@pinpointpdm.com 

B. The Specific Sections Of 14 C.F.R. From Which PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC Seeks Exemption. 

1. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirements Of Section 61.113(a) and (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

Q>IC) of an aircraft that is carrying passengers or propet1y for compensation or hire; 

nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hiTe, act as PIC of an aircraft in 

connection with any business or employment if-

(l) The flight is only incidental to that business or employment; and 

(2) The aircraft does not cany passengers or property for compensation or hire. 

2. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirements Of Section 91.7(a). 

Section 9 1.7, entitled Civ;/ aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirements Of Section 91.121. 

Section 91.121 , entitled Altimeter settings, subsection (a), states the following, in part: 

7 
(a) Each person operating an aircraft shall maintain tbe cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(!) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within I 00 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) of 

this section, the current reported altimeter setting of an appropriate available 

station; or 

(iii) In the case of an aircrart not equipped with a radio, the elevation of the 

departure airpor1 or an appropriate altimeter setting available before 

departure. 

4. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirements Of Section 91.15l(b). 

Section 91.15 1, entitled Fuel requirements for .flight in VFR conditions, subsection 

(b), states the following: 

(b) No person may begin a flight in a rotorcraji under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

.first point of intended landing and, assuming normal cruising speed, to fly after that 

for at feast 20 minutes. 

5. PINPOJNT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirement Of Section 91.405(a). 

Section 9 1.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirements Of Section 91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding. or afleration, subsection (a)(l), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

8 
(1) [t has been approved for ret1rrn to service by a person authorized under§ 43.7 

of this chapter[.] 

7. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspecfions, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by§ 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with prut 21 of this chapter. 

8. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks Exemption From 

The Requirements Of Sections 91.417(a) And 91.417(b ). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work pe1formed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified 

in paragraph (b) of this section: 

( 1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and 

(ii) The date of completion of the work pertom1ed; ru1d 

(iii) The signature, ru1d certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information: 

(i) The total tin1e in service of the airfrrune, each engine, each propeller, and 

each rotor. 

(ii) The current status of Life-limited parts of each airframe, engine, propeller, 

rotor, and appliru1ce. 

9 
(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The cuJTent inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

(v) The cuJTent status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and applian.ccs. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(l) of this section shall be retained Lmtil 

the work is repeated or superseded by other work or for 1 year after the work is 

performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

tnis chapter shall be retained until the defects are repaired and the aircraft is 

approved for retmn to service. 

C. The Extent Of Relief PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

Seeks And The Reason The PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

Seeks The Relief. 

1. Extent Of Relief PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

And The Reason PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

10 
This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PlC of an aircraft in connection wjth any 

business or employment if: (1) TI1e flight is only incidental to that business or employment; and 

(2) The aircraft does not cany passengers or property for compensation or hire. 

As set forth more fully below, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

submits that an equivalent level of safety will be maintained because no PIC will be allowed to 

operate the UAS w1less that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the UAS in a manner consistent with 

the operations specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures. 

Further, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC submits that all flights of 

the UAS, conducted by the PIC pm-suant to the grant of this Petition: (I) will be incidental to 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC' S business; and (2) will not carry 

passengers or property for compensation or hire. 

2. Extent Of Relief PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

And The Reason PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

RcliefFrom Section 91.7(a). 

Relief from Section 9 l.7{a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC to determine 

that the UAS are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC Aerial Operations Manual, Maintenance Log, and UAS Instruction Manuals). 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks the requested relief because 

the UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 2 1, 

Subpart H. Therefore, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC will ensure 

that the UAS are in airworthy condition based upon its compliance with the operating docwnents 

(i.e., Monthly Maintenance Log, and UAS) prior to every flight, and further, determine that the 

aircraft are in condition for safe flight, as stated in the conditions and limitations below. 

3. Extent Of Relief PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

And The Reason PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

Relief From Section 91.121. 

Relief from Section 91. I 21 , entitled Altimeter settings, may be required to allow flight 

operations of the UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at 

the ground control station (GCS). Since the FAA requires that any altitude information 

II 
concerning UAS operations be reported to air traffic control (A TC) in feet above ground level 

(AGL), PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks the requested relief 

because the UAS's altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. 

Considering the limi.ted aJtitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the UAS arc 

equipped with a barometric pressure sensor and GPS equipment, which automatically ensures 

that a ground leveJ pressure setting will be established prior to each flight, and provides the PIC 

with altitude information of the UA on the heads-up display ofthe GCS. 

4. Extent Of Relief PlNI>OJNT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

And The Reason PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

Relief From Section 9l.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered UAS during daylight 

hours in visual meteorological conditions (VMC), under visual fli ght rules (VFR), for a total 

duration of23 minutes. PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks the 

requested relief because without an exemption from Section 91. 151 (b), the flight time duration 

of the battery powered UAS will severely constrain the practicality of any aerial video or still 

photo flight operations that PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the UAS operating documents, 

and PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC'S proposed operating 

limitations, ensure that PINPOINT PREDICTIVE MAINTENANCE SERVJCE, LLC will safely 

operate the battery powered UAS during daylight hours in visual meteorological conditions 

(VMC), under visual 'flight rules (VFR), with enough battery power to fl y for a total duration of 

23 minutes. 

5. Extent Of Relief PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

And The Reason PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

Relief From Sections 9l.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, PINPOINT PREDICTlVE MAINTENANCE 

SERVICE, LLC requests relief from these Sections because the VAS do not require 

airworthiness certificates. As set forth more fully below, the UAS meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, PINPOINT 

PREDICTIVE MAINTENANCE SERVICE, LLC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, technjques, 

12 
and practices prescribed in the UAS operating documents (i.e., the PINPOINT PREDICTIVE 

MAINTENANCE SERVICE. LLC Aerial Operations Manual, Monthly Maintenance Log, and 

Instruction Manuals). Furthermore, PINPOINT PREDICTIVE MAINTENANCE SERVICE, 

LLC will document and maintain all maintenance records for the UAS. 

D. The Reasons Why Granting PINPOINT PREDICTIVE MAINTENANCE SERVICE, 

LLC Request Would Be In The Public Interest; That Is, How It Would Benefit The Public 

As A Whole. 

Granting the present Petition will further the public interest by allowing PINPOINT 

PREDICTIVE MAINTENANCE SERVICE, LLC to safely, efficiently, and economically 

perfom1 aerial video and photography of construction sites, real estate, events and civic 

landscape over certain areas of the United States. 

Additionally, use of the UAS will decrease congestion of the NAS, reduce pollution. and provide 

significant benefits to the economy. Notably, the benefits of PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC'S proposed operation of the UAS will be realized without 

implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The UAS's are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of 

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a UAS 

would reduce the amount of manned aircrafi in the NAS. reduce noise and air pollution, as well 

as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airpmts caused by arriving and departing aircraft will be reduced. The UAS do not 

require an airport to takeoff or land. Likewise. a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit F.-om The Safety And Efficiency Of The DJI Phantom 3 UAS. 

Conducting aerial acquisitions with the UAS, instead of manned aircraft., will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during traditional 

aerial video and still photography flight operations. By using battery power and electric motors, 

the UAS produce no air pollution, and is the most viable environmentally conscious alternative 

to the cabin class, six cylinder internal combustion engine aircraft that arc typically utilized for 

aerial video and photography, while burning approximately 20-30 gaJlons per hour of leaded 

13 
av1at10n fuel. The UAS, while reducing the carbon footprint of aerial acqmsttlons, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather 

than an internal combustion engine. 

By using the UAS to perfom1 aerial acquisitions, the substantial risk to life and property in the 

air and on the ground, wrucb is usually associated with traditional manned aircraft flight 

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight 

crew members located onboard the ail-craft, the UAS (weighing approximately 3-5 pounds at 

their maximum gross weight with diagonal dimension of 23 inches, and with no fuel on board), 

has less physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 teet, a length of 34 feet, and a 

:fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 UAS 

Will Benefit The Economy. 

In addition to being safe and efficient, the UAS are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the UAS will allow 

United States based companies, like PINPOINT PREDICTIVE MAlNTENANCE SERVICE, 

LLC, to remain competitive and contribute to growth of the U.S. economy. Specifically, with the 

rising cost of aviation fuel and the Environmental Protection Agency ("EPA") regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered UAS is one 

such technology that not only allows companies greater operational flexibility compared to 

manned aircra11, but provides such flexibility without the high operational cost of a traditional 

manned aircraft. 

By operating the UAS, companies such as PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC, can remain competitive and profitable, and therefore, provide greater job 

stabi)jty to employees and contractors, which wiiJ ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, tlu·ougb commercial use of the 

lJAS, provides a stable workforce that increases consumer spending; improves Local, state, and 

federal tax revenues; and allows companies to invest iu research and development in order to 

remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC'S proposed operation of the wiJI 

not implicate any privacy issues. Specifically, the UAS will be operated only in compliance with 

operating documents (i.e., PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and Instruction Manuals) which requires 

prope11y owner involvement as well as local law enforcement notification, and in accordance 

14 
with the Federal Aviation Regulations, including the minimum altitude requirements of 14 

C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

Seeks Exemt>tion. 

1. Reasons Why The UAS Meet The Conditions Of The FAA Modernization and Reform 

Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the 

unmrumed aircraft and its operation, PINPOINT PREDICTIVE MAINTENANCE SERVICE, 

LLC's operation of the UAS meet the conditions of FMRA Section 333, and will not require an 

aiJworthiness certificate in accordance with 14 C. F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

(a) In General. -Notwithstanding any other requirement of this subtitle, and no/ later 

than 180 days c~fter the date of enactment of this Act, the Secretary ofTram.portation 

shall determine if certain unmanned aircraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

section 332 (~(this Act or the guidance required by section 334 ofthis Act. 

(b) Assessment of Unmanned Aircrafi Syslems.-Jn making the determination under 

subsection (a), the Secreta7y shall determine, at a minimum--

(1) which types o.lunmanned aircraft systems, ifany, as a result oft.heir size, 

weight, speed, operational capability, proximity to ail]JOrts and populated 

areas, and operation within visual line o.lsight do not create a hazard to users 

o.( the national airspace system or the public or pose a threat to national 

security; and 

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness cert(fication under section 44704 of title 49, United States 

Code, is required for the operation o.f unmanned aircrafi systems identified 

under paragraph (1). 

(c) Requirements for Safe Operation.--{(l.he Secretary determines under this section 

that certain unmanned aircrC{(t systems may operate safely in the national airspace 

system, the Secretmy shall establish requirements fiN· the safe operation o.f such 

aircrcift systems in the national airspace system. 

In seeking this exemption, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

submits that the UAS cru1 operate safely in the NAS pursuant to FMRA Section 333, as 

15 
demonstrated by: (a) the characteristics of the UAS; (b) the pilot certification requirement; and 

(c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 and 3DR X8+ UAS Demonstrate Its Safe 

Characteristics. 

The U AS does not create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security considering its size, weight; speed, and operational capability. 

i. Technical Specifications Of The UAS. 

The technical specifications of the UAS are set forth by the User Manuals, attached hereto as 

Appendix A and B. 

ii. The UAS Global Positioning Modes Enable The UAS To Remain Within A 

Defmed Operational Area. 

The UAS may be operated in. both manual and global positioning flight modes. A complete 

description of the flight and navigational modes of the UAS is provided in the User Manuals 

attached hereto as Appendix A and B. 

iii. The UAS Are Designed For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the UAS will remain stationary, in flight, for 3 seconds or more. 

li~ after 3 seconds, UAS does not reacquire control link data from the GCS, the UAS will assume 

that the Control Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, 

and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the UAS is provided in User Manuals 

attached hereto as Appendix A and B. 

iv. Tbe GCS And Its Operation. 

A complete description of the operation and specifications of the UAS GCS and flight control 

software is provided in User Manuals attached hereto as Appendix A and B. 

b. Flight Operations OfUAS Is Limited To The Line Of Sight Of A Certificated Pilot in 

Command With A Safety Observer. 

PINPOINT PREDICTIVE MAJNTENANCE SERVICE, LLC staff will be the only persons to 

act as a pilot in command (PIC) of the UAS. Additionally, a safety observer will assist him at aU 

times during flight time. 

c. Flights Of UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

proposes to conunercially operate UAS for the special purpose of conducting aerial video and 

pl10tography over certain areas of United States, pursuant to the following specific operating 

limitations. 

16 
1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating docwnents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight: Dn Phantom 3 and 3DR X8+ Unmanned Aircraft 

Systems. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for 

the purpose of aetial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedmes specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be 

in feetAGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PJC's FAA-issued airman medical 

certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the P[C always maintains VLOS capability. The SO 

and PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not pennitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perfom1 any otb.er duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other gronnd based obstacles/obstructions and is not 

permitted to operate the can1era or other instrwnents. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions and 

limitations contained in the grant of exemption take precedence and must be followed. 

Othelwise, the operator must follow the 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 tl1e Administrator upon request. The operator must also present updated 

17 
and revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the operator must petition for 

amendment to its grant of exemption. The FAA's UAS Integration Office (AFS-80) 

may be contacted if questions arise regarding updates or revisions to the operating 

doctunents. 

10. Prior to each flight the PLC must inspect the UAS to ensure that it is in a condition 

for safe night. If the inspection reveals a condition that affects the safe operation of 

the 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. The Ground 

Control Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight. The PIC who conducts the functional test flight 

must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating docwnents. 

13. The operator must follow the UAS manufacturers aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, 

and the signature ofthe authorized person retumingthe UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate or a valid U.S. driver's license issued by a state or Federal 

Government. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator's qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification fljght hours must be 

18 
logged in a manner consistent with 14 C.P.R. § 61.51(b). Flights for the purposes of 

training the operator's PICs are permitted under the terms of the exemption. 

However, training operations may only be conducted dming dedicated training 

sessions. During training, proficiency, and experience-building tlights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 

C.P.R.§ 91. 119. 

19. U AS operations may not be conducted during night, as defined in 14 C.F. R. § 1.1. 

All operations must be conducted under visual meteorological conditions (VMC). If 

flight at night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

20. The UA may not operate within 5 nautical miles of an aiip011 reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport's management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator's COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetennined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

23. The PIC must abort the flight in the event of tmpredicted obstacles or emergencies 

in accordance with the operating documents. 

24. The PIC is prohibited from beginning a fli ght wlless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising speed to 

the intended landing point and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements 

in the A TO issued COA including class of airspace, altitude level and potential 

transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable. 

19 
27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request. 

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

30. The VAS may not be operated by the PIC from any moving device or vehicle. 

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structmes where the 

owner/controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer to 

those objects and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PTC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per§ 91. 119(a). 

32. All operations shall be conducted over private or controlled-access prope1ty with 

permission from the land owner/controller or authori zed representative. Pennission 

from land owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be repo11ed 

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. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety. 

20 
PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC submits that the equivalent level 

of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be 

allowed to operate the UAS unless that PIC has demonstrated, by meeting minimum flight-hom 

and cunency requirements, that the PIC is able to safely operate the UJ\S in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Considering PINPOINT PREDICTIVE MAlNTENANCE SERVICE, LLC's proposed area of 

operations, and the operating limitations set forth-above; the parallel nature of private pilot 

aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption 

No. 11062); and the airmansbip skills necessary to safely operate the UAS, PINPOINT 

PREDICTIVE MAINTENANCE SERVICE, LLC submits that the additional manned 

airmansbip experience of a conm1ercially certificated pilot would not correlate to the airmanship 

skills necessary for PINPOINT PREDICTTVE MAINTENANCE SERVICE, LLC'S specific 

proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances simiJar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11 062, 11 063, 11064, 11065, 11066, 11 067, 11080, 11109, 11110, 111 12.11136,11138, 11150, 

111 53, ] 1156, 111 58, 11159, 11160, 11161). 

PINPOINT PREDICTIVE MAINTENANCE SERVJCE, LLC will not allow any PIC to operate 

U1e UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 

UAS training and cun·ency requirements, that the PIC is able to safely operate the UAS in a 

manner consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

6 1.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimtun of 5 hours of those 

hours as a UAS pilot operating the same make and model ofUAS to be used for operations under 

the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for cunency purposes). 

As in Exemption Nos. 11062, 11138, and 111 53, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety 

dming PINPOINT PREDICTIVE MAJNTENANCE SERVICE, LLC' S proposed operations. 

The Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion pictme filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51 (b), 25 hours of total time as a 

UAS rotorcraft pilot including at least I 0 homs logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

21 
FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 

5 how·s make and model time may be included in the 10 hours of multi-rotor time and the 

10 hours may be included in the total 25 hours ofUAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). The FAA finds that at a :minjmum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

the skills necessary to safely conduct the petitioner's proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and 

experience-building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances i:n accordance 

with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC will ensure safe 

operations by not allowing any PIC to operate the UAS unless that PIC has demonstrated, by 

meeting minimum flight-hom and Clll"fency requirements, that the PIC is able to safeJy operate 

the UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structw·es. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC will ensure that the 

UAS is in an airworthy condition based upon the UAS's compliance with its operating 

documents and as stated in the conditions and lin1itations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11 062, 11063, 11064,11065, 11066, 11 067, 11080,1 1109, 11110, 11112,11136,1 1138, 11150, 

11153, 11156, 11157, 11 158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Sectjon 91.121 will be maintained because the 

altitude information of the UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of tl1e flight path and altitude. This altitude infonnation, combined with PINPOINT 

22 
PREDTCTfVE MAINTENANCE SERVICE, LLC's operation of the UAS within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The 

altitude information wlU be generated by GPS equipment installed onboard the aircraft. Prior to 

each flight, a zero altitude initiation point is automatically established by the UAS at ground 

level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065,11066, 11067, 11080, 11109, 11112, 11136,11138, 11150,11153,11156, 11157, 

1115 8' 1115 9' 11160' 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.15l(b) Would Not 

Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of(1) the technical specifications ofthe UAS; (2) the limitations on 

the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC will ensure that it 

will safely operate the battery powered UAS during daylight hours in VFR conditions, with 

enough battery power to fly for a total duration of23 minutes. 

Here, as in Exemption No. 11109, the technical specifications ofthe UAS; the limitations on the 

proposed flight operations; and the location of the proposed operations, will ensure an equivalent 

level of safety established by 14 C.P.R. Section 91.151 (b). Furthermore, safety will be ensured as 

the UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences 

Low battery voltage, the first warning occurring at approximately 33% remaining battery power, 

and again at approximately 10% remaining battery power. At the critically low battery level, the 

UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimwns prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA bas previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811 , 10808, 10673,11042, 11062, 11063,11064, 11065, 11066, 11067,11080,11109, 11110, 

11136, 11138, 11150,11153, 11156, 11157, 11158,11 159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety. 

23 
In seeking this exemption, PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC 

submits that the equivalent level of safety with regard to the regulatory maintenance and 

alteration requirements established by Sections 91.405(a), 91.407(a)(l), 91 .409(a)(l) & (a)(2), 

and 91.417(a) & (b) will be met because PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and Instruction Manuals). Furthem1ore, 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC will document and maintain all 

maintenance records for the UAS. 

Since the VAS will be inspected as prescribed by the operating documents, PINPOINT 

PREDICTIVE MAINTENANCE SERVICE, LLC will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the UAS User 

Manuals are attached hereto as Appendix A and B; a copy of Kittyhawk Sell Sheet (Electronic 

Maintenance Log) is attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because PINPOINT 

PREDICTIVE MAINTENANCE SERVICE, LLC will use trained technicians to perfonn 

maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed by the operating documents. 

Furthennore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the UAS will be 

perfonned by trained technicians. Maintenance will be documented and maintained utilizing the 

monthly maintenance Jog. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

aflected when the technical characteristics and operating limitations of the UAS are considered. 

In consideration of PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC's proposed 

operatjng limitations, the operating documents, and the technical aspects of the UAS, PINPOINT 

PREDICTIVE MAINTENANCE SERVICE, LLC submits that safety will not be adversely 

affected by granting exemption from 14 C.P.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA bas previously granted relief specific to UAS in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066,11067, 11080, 11109, 11110, 11112, 11136,1 1138, 11150, 

11153, 11156, 11 157, 111 58, 11159, 11160, 11161). 

7. Tlie FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) 

and 14 C.P.R. § 21.16 entitled Special Conditions, PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC requests that the FAA prescribe special conditions for the intended operation of 

the UAS, which contain such safety standards that the Administrator finds necessary to establish 

24 
a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpmt H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 9l.409(a)(1) & (a)(2), and 

91.417(a) & (b). Such special conditions will permit safe operation of the UAS for the limited 

purpose of conducting aerial video and photography over certain m·eas of the United States for 

compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a 

UAS will create a hazard to users ofthe NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification in accordance with any requirements that must be established for the safe operation 

of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pmsum1t to 14 C.F. R. 

§ 21.16, for operation of the UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not 

contain adequate or appropriate safety standaJ·ds, due to the novel or unusual design features of 

the aircraft. Section 2 1. 16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standm·ds for an aiJcraft, aircraft engine, or propeller 

because of a novel or unusual desi&rn feature of the aircraft, aircraft engine or propeller, 

be prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Pm 11 of tnis chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Leading Edge's intended operation of the UAS, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) 

& (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l). 91.409(a)(l) & (a)(2), and 91.417(a) 

& (b). 

• A Summary That Can Be Published In The Federal Register, stating: The 

RuJes From Which PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC Seeks 

Exemption: 

PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC seeks exemption .from the 

requirements of 14 C.FR Sections 6l.Jl3(a)&(b), 91.7(a), 91.121, 91.15J(b), 91.405(a), 

91.407(a)(J), 91.409(a)(1) & (a)(2), and91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC Seeks: 

This exemption will permit The PINPOINT PREDICTIVE MAINTENANCE SERVICE, 

LLC to commercially operate an Unmanned Aircraft System (VAS) .for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

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• Any Additional Information, Views, Or Arguments Available To Support 

The PINPOINT PREDICTIVE MAINTENANCE SERVICE, LLC'S Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, The PINPOINT PREDICTIVE MAINTENANCE 

SERVICE, LLC's request for exemption may be granted pursuant to the authority of FMRA 

Section 333 and 14 C.F.R. Part 11 , as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national secmity; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, PINPOINT PREDICTTVE MAINTENANCE SERVICE, LLC will 

operate the UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, 

or otherwise pose a threat to national security. 

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CONCLUSION 

As set forth herein, PINPOINT PREDICTIV E MAINTENANCE SERVICE, LLC seeks an 

exemption pmsuant to 14 C.F .R. § 11.61 and Section 333 of the FAA Modemization and Reform 

Act of 2012 (FMRA), which will pem1it safe operation of the UAS commercially, without an 

airworthiness certificate, for the limited pmpose of conducting aerial video and photography 

over certain areas of the United States. By granting this Petition, the FAA Administrator wiiJ be 

fulfilling the Congressional mandate of the FAA Modernization and Reform Act of2012, whil e 

also advancing the interests of the public, by allowing PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC to safely, efficiently, and economically operate the UAS 

commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modemization and Reform Act of 2012, Section 333, PINPOINT PREDICTIVE 

MAINTENANCE SERVICE, LLC respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 61.11 3(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 9 1.409(a)(1) & (a)(2), and 91.417(a) & (b), and 

permit Leading Edge to operate the UAS commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States. 

Dated: July 24,2015 

Respectfully submitted, 

Lyndy N. Serpan 

~/,}~ 

Owner 

Pinpoint Predictive Maintenance Service, LLC 

355 I Leesa Ln 

Edmond OK 730 13 

405-410-1477 

lyndyserpan@pinpointpdm.com 

Appendices: 

A - Link to DJI Phantom 3 Manual: Click on link below 

http://download.djiinnovations.com/downloads/pbantom 3/en/Phantom 3 Professional User Manual vl.2 en.pdf 

B - Link to 3DR X8+ Manual: Click on link below 

http://3drobotics.com/wp-content/uploads/2015/04/X8-0peration-Manual-vC.pdf 

C- Electronic Flight and Maintenance Log: See following page Kittyhawk Sell Sheet: 

27 
Appendix C 

Kittyhawk.io 

The Kittyhawk.io platform makes commercial drone operations safer 

by making it easy to disseminate the freshest data to your pilots, keep 

track of maintenance events on your craft, and warn pilots about 

things like TFR's, NOTAMS, and other hazards. 

Features 

• Easily log every flight with our fully responsive web-based 

interface or handy iOS application. 

• Mark your craft into and out of service with associated 

maintenance event logging. 

• Manage your battery inventory by keeping track of the number of 

cycles and "last touch." 

• Easily work in teams to determine which pilot flew which craft --

as well as where and when they did so. 

• Kittyhawk's redundant flight logging system insures that all your 

data securely lives in the cloud so that you have one less 

potential crash to worry about. 

• Keep track of statistics like total pilot flight time, pilot's last flight 

on craft, and total airframe time to keep track of currency and 

competency. 

Kittyhawk.io - Fly Smarter. 

Link: http://kittyhawk.io/login 

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