August 31, 2015

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References: 

1. FAA Exemption No. 11138, Regulatory Docket No. FAA­2014­0481 in the matter 

of the petition of DOUGLAS TRUDEAU

2. FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter 

of the petition of ADVANCED AVIATION SOLUTIONS LLC

3. FAA Exemption No. 11080 Regulatory Docket No. FAA­2014­0355 in the matter 

of the petition of FLYING CAM INC

4. FAA Exemption No. 12626 Regulatory Docket No. FAA­2015­2481 in the matter 

of the petition of Mr. Matthew Robert Pearce

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption under 

section 333 of the FAA Modernization and Reform Act of 2012 , I John Corona, referred 

to hereafter as the petitioner, request exemption from the following sections of Title 14, 

Code of Federal Regulations §§

61.113(a); 

61.113(b); 

91.119(c); 

91.121; 

91.151(a); 

91.405(a); 

91.407(a)(1); 

91.409 (a)(1); 

91.409(a)(2); 

91.417(a) & (b)

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial data 

collection and other flight operations that could be performed safely and more cost 

effectively with the use of small UAS at low altitude within the U.S. national airspace 

system as compared to a manned aircraft. Operations will be performed only at the 

request of and with the authorization and permission of clients or their authorized 

agents in order to facilitate commerce and raise awareness of the beneficial uses of 

small unmanned air systems. 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. The conditions identified and proposed by the petitioner are drawn from 

references 1­3.

Name and Address of Petitioner

John Corona

11-02 Underwood Place

Fair Lawn, New Jersey 07410

e-mail: johncorona@optonline.net

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following 

reasons:

61.113(a) & (b); 

The petitioner requests relief in order to facilitate the utilization of pilots, who hold a 

SPORT PILOT (or greater) certificate. Any pilots operating under this exemption would 

be required to comply with any conditions as set forth and in a similar fashion to the 

previously granted exemptions.

91.119(c) 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer 

than 500 feet to the ground may require that the UA be operated closer than 500 feet to 

essential persons, or objects that would not be possible without additional relief. The 

petitioner requests modification, waiver or exemption and clarification concerning the 

terms “congested areas” and “densely populated”. The petitioner requests waiver for 

this condition to allow reasonable and responsible operations in areas of subdivisions 

and neighborhoods if required.

91.121 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS 

does not have an altimeter and instead utilizes electronic GPS with a barometric sensor 

for altitude information.

91.151(a) 

As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief 

has been granted for manned aircraft to operate at less than the prescribed minimums, 

including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS­specific relief 

has been granted in Exemption Nos. 8811, 10808, and 10673 for daytime, VFR 

conditions. The UAS provides battery power remaining in percent to the PIC. The UA 
batteries provide approximately 25 minutes of powered flight. Information provided in 

the operating documents discusses procedures regarding remaining battery power 

management. Those documents contain a condition in which the PIC will initiate a 

landing procedure when battery remaining reaches a specified level. Given the 

limitations on proposed operations and the location of those proposed operations, The 

FAA found that a reduced minimum power reserve for flight in daytime VFR conditions 

was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) 

As discussed in Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to 

inspect and ensure that the UAS is in a condition for safe flight in accordance with the 

operating documents. The FAA found that adherence to the petitioner’s operating 

documents and the conditions and limitations specified, describing the requirements for 

maintenance, inspection, and recordkeeping, were sufficient to ensure that safety would 

not be adversely affected.

The UAS

Unmanned Aircraft Systems: DJI Phantom 3 UAS

Petitioner seeks an exemption to operate DJI systems for compensation or hire

within the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 

1,280 grams (2.8 lbs.), while having a diagonal size (including propellers) of 590mm 

(23.2 inches) and a maximum speed of 16 m/s (35.7 mph) (ATTI mode, no wind). The 

DJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

User manual is available for download at:

http://download.dji-innovations.com/downloads/phantom_3/en/

Phantom_3_Advanced_User_Manual_v1.4_en.pdf

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 1­3 Conditions and Limitations 

section and believes that the procedures specified therein are reasonable and will be 

utilized in order to manage and mitigate risk and ensure public safety. A preflight 

checklist will be developed and employed to ensure that the UA airworthiness will be 

verified before launch. Airworthiness will be maintained by performance of routine 

inspections before each flight, maintaining flight and maintenance logs to record time on 

failure­prone components.
The petitioner request that in a manner similar to reference 3, he be allowed to operate 

within 5 miles of an airport provided that;

“ The UA may not operate in Class B, C, or D airspace without written approval 

from the FAA. The UA may not operate within 5 nautical miles of the geographic 

center of a non­towered airport as denoted on a current FAA­published 

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 .”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner 

is requesting a mechanism to facilitate such activities without requesting a new and 

separate exemption(s) should the need arise. Operations within class B airspace are 

not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS 

in order to facilitate commerce could lead to economic growth. Operations for this 

petition will enable service for property owners or their designees seeking an enhanced 

perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can lead to increased commerce and 

enhance personal photography. The petitioner will provide clients with photographic 

data for these purposes on a ‘for hire’ basis. A visual observer will be utilized. Liability 

insurance will be obtained commensurate with the granting of this request for 

exemption. Flight data including UA flight time, Control Unit operation time, incident, 

accident, and details concerning any deviations from normal operations will be available 

to FAA for use in collecting data regarding the use of UAS as part of this application. 

This data may be submitted to FAA via traditional means, e.g. COA Monthly Reports, or 

other means as required.

Federal Registry Summary

Pursuant to 14 C.F.R. Part 11, John Corona offers the following summary for publication 

in the Federal Register, should publication be necessary:

John Corona seeks exemption from the following sections of Title 14, Code of Federal 

Regulations §§ 

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409 (a)

(1); 91.409(a)(2); 91.417(a) & (b)
Approval of these exemptions will permit John Corona to provide aerial data collection 

using unmanned aircraft systems (“UAS”) operations. The exemptions will enhance 

safety by reducing risk to the general public and property owners from the risk and 

hazards associated with performing equivalent work through conventional manned 

aircraft.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial data collection”. 

The reason for such a general and broad based request is that the petitioner wishes to 

utilize a business strategy of horizontal integration and maximize economies of scope in 

order to capitalize on opportunities as they may arise in the future without the long 

turnaround time associated with additional exemptions. The petitioner's business model 

is based on the idea of offering ad hoc small UAS services to individuals or companies 

who wish to employ these services as a safe, effective, and legal option to enhance 

their business or hobby. Market research shows a demand for these services currently 

exists. The primary purpose of seeking this exemption is to obtain the capability to offer 

those services while remaining in compliance.

The petitioner believes the conditions identified and proposed by the petitioner are 

similar to those drawn from references 1­4, permitting the issuance of a summary grant 

where the FAA finds that it has already granted a previous exemption similar to the new 

request submitted by the petitioner for aerial data collection. 

Respectfully submitted,

John Corona