U.S. Department of Transportation

Federal Aviation Administration

Washington, DC

September 10, 2015

Petitioner

Charles H. Stinchfield III

109 Heritage Circle 

Mount Pleasant, SC 29464

843.801.5522

charlie@bluwavedesigns.com

Charles Stinchfield will be providing clients with high quality imaging for a variety of commercial, public, 

and residential uses. He is a safe and well trained drone pilot with hours of flying experience and is 

seeking an exemption from these specific requirements of Title 14 C.F.R.:

I. 91.119(b) and (c)

II. 91.121

III. 91.151(a)

IV. 91.405(a)

V. 91.407(a)(1)

VI. 91.409(a)(1) and (2)

VII. 91.417(a) and (b)

Definitions

I. AGL Above Ground Level

II. ATC Air Traffic Control

III. COA Certificate of Authorization

IV. FAA Federal Aviation Administration

V. FAR Federal Aviation Regulation

VI. GPS Global Positioning System

VII. NAS National Airspace System

VIII. PIC Pilot in Command

IX. UA Unmanned Aircraft

X. sUAS Small Unmanned Aerial System

XI. VFR Visual Flight Rules

XII. VLOS Visual Line of Site

Summary

In the instance of granting exemption, Charles Stinchfield will be operating the sUAS in order to fulfill 

contracted obligations, such as: aerial photography and videography for real estate agents, appraisers, 

property managers, general contractors; solar panel installation technicians; agriculturists; utility 

inspections (only where safe flight is attainable); chambers of commerce and associated businesses; 
wildlife conservation organizations; public departments; all other institution requiring filmography (safe 

flight permitting)

Aircraft

I. DJI Phantom 3

A. Weight (Including Battery and Propellers) 2.82 lbs

B. Diagonal Size (Including Propellers) 23.23 in

C. Max Ascent Speed 11.2 mph

D. Max Descent Speed 6.7 mph

E. Max Flight Time ~ 23 minutes

F. Remote Controller Operating Frequency 2.400 GHz - 2.483 GHz

G. Auto-Takeoff Rises to a preset height and will hover in 

place until directed where to go

H. Auto-Return Home

Remembers the exact spot it took off from 

to enable a tap of a button to return back 

home

I. Low Battery Failsafe

If the flight battery is run running low or the 

DJI Phantom 3 loses connection with the 

remote it will automatically return back 

home

Specific Sections of C.F.R from which Charles Stinchfield Seeks 

Exemption

I. Section 91.119 - Minimum Safe Altitudes

Section 91.119 states persons may operate a helicopter at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any 

routes or altitudes specifically prescribed for helicopters by the FAA. The sUAS meets this criteria as a 

helicopter and requests the ability to operate at altitudes up to 400’ AGL. Only in accordance with 

pre-obtained consent will the sUAS operate while also maintaining an altitude less than 400’ AGL. For 

comparison with traditional aircraft and rotorcraft the sUAS weighs less than 10lbs, while also 

preventing potential risks associated with flammable fuel. Lastly the 400’ AGL ceiling limits any ability for 

the sUAS to interfere with conventional aircraft operating at or above 500’ AGL.
III. Section 91.121 - Altimeter Settings

Section 91.121 states each person operating an aircraft shall maintain the 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 the current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft. In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure. The sUAS will 

reference its altitude based on GPS and will be restricted to a 400’ AGL ceiling. The PIC will also verify 

GPS elevation from multiple ground based sources prior to takeoff.

IV. Section 91.151 - Fuel Requirements for Flight in VFR conditions

Section 91.151 states no person may begin a flight in a rotorcraft 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 least 20 minutes. The sUAS 

battery powered operational flight time is not able to incorporate a 20 minute reserve window following 

successful first point of intended landing due to current battery capacity limitations. In order to provide 

adequate reserve power for return landing the sUAS will abide by a 12 minute flight time or 25% of 

remaining battery power, whichever happens first.

V. Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (2), and 91.417(a) & (b)

These sections only apply to aircraft with an airworthiness certificate, Charles Stinchfield requests 

exemption from these sections because the DJI Phantom 3 does not require airworthiness certificates. 

The sUAS is in accordance with FMRA Section 333 for operation, absent an airworthiness certificate. In 

order to insure proper maintenance the operations manual will be cited for necessary corrective 

measures. In addition, the PIC is the person most familiar with the aircraft and best suited to maintain 

the aircraft in an airworthy condition, and any sUAS conducted maintenance will be documented for the 

life of the aircrafts.

Public Interest

 Real estate agents will be able to set their listings apart with a unique perspective only available 

from sUAS photographic equipment, therefore increasing the prospect of meeting or exceeding 

the asking price.

 Property managers and contractors will have the ability to survey their property for anomalies 

while preventing human endangerment due to hazardous conditions.

 Solar panel technicians can safely inspect potential installation locations without putting 

themselves in high elevation and sloping circumstances.

 Agriculturists will have the ability to survey their land in a more timely manner and better 

document the condition of their property.

 Marketing firms and other businesses would use unique aerial photography and panoramic

video to promote marketing campaigns and increase revenue.
 Search and rescue entities could utilize the sUAS to help quickly aid in finding the location of 

person(s) while providing a better vantage point in closer quarters.

Public Safety

 Both sUAS will reduce air and noise pollution do to the aircraft being powered by a battery and 

brushless electric motors.

 These small aircraft create less potential for harm, should an emergency situation occur, thanks 

to their size and weight.

 Furthermore the lack of combustible fuel also significantly decreases their chances of producing 

harm.

Conclusion

Based on the criteria provided under the FMRA Section 333, Charles Stinchfield requests that the FAA 

grants him exemption from 14 C.F.R Sections 61.113(a) & (b), 91.119(b) and (c), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) in order to conduct contracted 

commercial sUAS operations using the DJI Phantom 3 for a wide range of industries and applications.

Kind Regards,

Charles H. Stinchfield III