## 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 a n exemption from these specific requirements of Title 14 C.F.R.:
I . 91.119(b) and (c) I I. 91.121 III . 91.151(a) I V. 91.405(a) V . 91.407(a)(1) V I. 91.409(a)(1) and (2) V II. 91.417(a) and (b) 

## Definitions I. AGL Above Ground Level II. ATC Air Traffic Control III. COA Certificate of Authorization IV. FAA Federa l 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 bu sinesses;wildlife conservation organizations; public departments; all other inst itution req uiring 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 pre set 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 **f rom**  **w hich**  **Charles Sti nchfield 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 specificall y 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 tha n 400’ AGL. For comparison with traditional aircraft and rotorcraft the sUAS weighs less th an 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 airc raft 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 th at aircraft, as the case may b e, 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 nautica l 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 departu re. 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 foreca st weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cr uising speed, to fly after that for at least 20 minutes. The sUAS battery powered operati onal flight time is not able to incorporate a 20 minut e reserve window following suc cessful 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 powe r, 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 do es not require airworthiness certificates. The sUAS is in accordance with FMRA Section 333 for operation, absent an airworthiness certifi cate. In order to insure proper maintenance the operations manual will be cited for ne cessary corrective me asures. 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 equi pment, therefore increasing the prospect of meeting or exceeding the asking price.

 Property managers and contractors will have the a bility to survey their property for anomalies while preventing huma n endangerment due to hazardous conditions.

 Solar panel technicians can safely inspect potential installation locations wi thout putting themselves in high eleva tion and sloping circum stances.

 Agriculturists will have the ability to survey the ir land in a more timely manner and better document the condition of their property.

 M arketing firms and other businesses would use unique aerial photography and pano ramic video to promote market ing 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 clos er quarters. 

## Public Safety

 Both sUAS will reduce air and noise pollution do t o the aircraft being powered by a battery and brushless electric motors.

 These small aircraft create less potentia l 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 Secti on 333, Charles Stinchfield requests that the FAA grants him exemption from 14 C.F.R Sect ions 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 commercia l sUAS operations using the DJI Phantom 3 for a wide range of industries and applications. Kind Regards, Charles H. Stinchfield III