## Sonya Lee Ricker 1125 Clarence Lane Morristown, TN 37814
423

- 312

- 5017 sonyaricker@yahoo.com

Pursuant to Section 333 of the FAA Modern ization and Reform Act of 2012 and 14 C.F.R. Part 11, Sonya Ricker, an operator of the DJ Phantom 3 Professional Unmanned Aircraft System (“UAS”) seeks exemption from the Federal Aviation Regulations as described below. I have successfully completed the course of study from the National Drone School on July 15 th , 2015 and will obtain all FAA required UA S training, including all applicable regulations, guidance documents, charts, radio communications procedures, human factor and crew reso urce
managemen t, basic small UAS aerodynamics, decision

- making and safe operating procedures in order to safely operate the UA S , including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and structures.

I plan to pr ovide daytime aerial photography and videography services to real estate age nts, landowners, and vendors, over private /commercial property
, in order to lessen the amount of time and cost on the public’s behalf, as well as to limit the need for additional U AVs and manned aircraft in the air. As manned aircraft and helicopters conducting aerial photography weigh thousands of pounds and are operated by onboard pilots and crew, I believe I can significantly reduce the potential for harm to participating and non participating individuals and property in the event of an incident. These risk are substantially eliminated by the use of the
UA V , due to weight and no onboard pilot or crew.

I will be operating the DJ Phantom 3 Professional, which features new flight safety modes including Failsafe and Return to Home. This UAV weighs 1280g (2.82 lbs.) including battery and propellers, with a maximum speed of 16m/s. This model of UAV complies with part 15 of the FCC Rules and is fitted with Vision Positioning, typically used in indoor environments for real estate purposes. The built

- in camera and integrated gimble maximize stability, weight, and size. The Phantom 3 Pro remote controller is a multi

- functioning wireless communication device and operates at 2.4 GHz with a battery level display for safe flight operation.

It is in light of this attitude and in the spirit of the proposed rules for circulation that applicant specifically
requests a waiver of the requirement to hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The capabilities and experience of the operator are detailed further in Appendix A, and the failsafe capabilities that are a cor e of the design of the proposed UAS exceed those found in traditional airframes. Given the greatly reduced potential for injury and/or damage of UAS operation in accordance with the enclosed exemption requests, applicant wishes to forgo the requirement to assign operation of the aircraft to an operator who may hold an airman certificate, but lack the necessary experience in operating a multirotor UAS. Applicant will understand that approval of this exemption request is in accordance with the highlighted

s pecifi cities noted in this paragraph.

As the operator, I will place limits on altitud es of 400’ above ground level, operate during daytime hours only, and provide a visual line of sight, utilizing an additional observer for all flights , who will not be pil ots, but REGULATIONS FOR WHICH EXEMPTION IS
BEING SOUGHT:

14 C.F.R. Part 21; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b) (2); 14 C.F.R. 91.109(a); 14 C.F.R. 91.119; 14 C.F.R. 91.105; 14 C.F.R. 91.151(a); 14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a) (1); 1 14 C.F.R. 91.409(a) (2); 14 C.F.R. 91.417(a)will attend ground training, communications procedures, proper visual scan techniques, and appropriate
sections of the Aeronautical Information Manual to understand the proper roles as an observer. I will also provide an alert to all other users in the National Airspace System during operation. I will be flying the DJ Phantom III which allows for the global positioning system or lost link event with a pre

- coordinated, predictable automated flight maneuver , providing a significant level of safety.

A preflight safety inspection will be conducted and documented on all equipment prior to each flight and will include, but not limited to:

• Verification of all transmitter and onboard camera and batteries are fully functioning.

• Ensure no frequency confli cts with both video and receiver.

• Properly secured motor and mounting check.

• Landing gear, propellers, and video equipment check.

• Preflight GPS location installation.

• Conduct 3’

- 5’ thirty second preflight hover.

A pre

- flight plan /log , including topographi cal maps, will be prepared prior to all flights and will include , but are not limited to: planned altitude, weather conditions, powerlines and cables, animals, people, property, buffer zones between aircraft and personnel, while minimizing departures and landings in populated areas. In addition, a post flight log will be documented on all flights and will include a post flight inspection of all equipment.

I have included a copy of my certificate of completion , a copy of my flight log, and the manual for the DJ Phantom 3 Pro. I appreciate your time and consideration of my request

.

Respectfully, 

# Sonya Ricker

Sonya Ricker 1125 Clarence Lane Morristown, TN 37814
423

- 312

- 5017



# APPENDIX AEXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES
SUBJECT TO EXEMPTION

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a) (1)

Section 91.203(a) (1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft and the limited operating a rea associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and Section
333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airw orthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the UAS
involved.

In this case, an analysis of these criteria demonstrates that Sonya Ricker UASs operated wit hout an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The UASs wil l remain
less than 55 lbs. and will not carr y a pilot or passenger, will not carry flammable fuel, and will operate exclusively within an area pre

- disclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by both the operat or, pursuant to the conditions set forth above, and by local public safety requirements. The FAA will have advance notice of all operations through the filings with the FSDO. Receipt of the prior permission of the land owner, or controlling authority, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safety. The UASs construction with absorbent material provides at least an equivalent leve l of safety to that of such operations being conducted with conventional aircraft that would be orders

- of magnitude larger and would be carrying passengers, cargo, and flammable fuel.

14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation r equires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UASs without an airworthiness certificate, no standard will exist for airworthiness of the UASs. G iven the size of the aircraft and the requirements that have presumably already been met in the approved standard operating procedures (for instance, the Maintenance & Inspection Manual and Safety Checklist), an equivalent level of safety
will be achieved by ensuring compliance with the operating manuals prior to each flight.

14 C.F.R. § 91.9(b) (2): Civil Aircraft Flight Manual in the Aircraft.

The regulation provides:No person may operate a U.S.

- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The equ ivalent level of safety will be achieved by keeping the flight manual at the ground control point where the pilot flying the UAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulation: Exemption Nos. 8607 , 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.109(2)

This regulation provides that flight crewmembers must keep a safety belt fastened while at a crewmember station. UASs are by definition not manned and therefore maintain an equivalent level of safety without the use of safety belt since no danger is posed due to no persons being aboard the
aircraft.

14 C.F.R. § 91.121(a)

This regulation requires that aircraft be operated at altitude in reference to an altimeter set to applicable barometric pressure. According to the Flight Manuals and information included with this exemption request the UASs operated by Sonya Ricker u ses GPS positioning, and the DP3 Pro uses, in addition, a specialized sensor that li mits the aircraft altitude to a predetermined height set by the PIC during preflight inspections. This, in addition to all flights being conducted by VLOS, assures altitude restrictions will be maintained by the PIC. Given the nature of the flight being li mited to an upper altitude limit, the limited area of operations, the See a nd Avoid procedures set forth and in light of the UASs not being operated at VFR or IFR cruising altitudes an equivalent level of safety will be achieved.

14 C.F.R. § 91.109(a) & 91.319(a) (1): Flight Instruction

These regulations provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. UASs are a remotely piloted aircraft and by design, do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. If instruction is accomplished through a training pro gram, as set forth in an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level of safety will be achieved by Sonya Ricker

.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Due to the flight characteristics of
the UASs (vertical takeoff and landing, and ability to hover) as well as the nature of the type of flights conducted by UASs and the similarity to helicopters Sonya Ricker requests to operate in accordance with section 91.119(d). The equivalent level of safet y will be achieved given the size, weight, speed, andmaterial with which the UASs are built. Furthermore; No flight will be taken without the permission of the land owner or those who control the land. Because of the advance notice to the landowner, all

a ffected individuals will be notified of the flights. Compared to aerial photography or videography operations conducted with aircraft or rotorcraft weighing far more than the UAS and carrying flammable fuel, any risk associated with these operations will b e far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low

- altitude operations of the UAS will maintain separation between these small

- UAS operations and the operations of conventional
aircraft th at must comply with Section 91.119, give right of way to all manned aircraft.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “a flight in a rotorcraft under VFR conditions

un less (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; Or (2) at night, to fly after th at for at least 20 minutes.” Given the limitations on its proposed operations and the location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable. Sonya Ricker believes that an exemption from 14 CFR § 91.1 51(b) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the small UAS, without 20 minutes of reserve fuel does not engender the type of risk s that Section 91.151(b) was meant to prevent given the size and speed at which the UAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safety. Additionally, limiting flights to a 20 minute reserve would greatly reduce th eir utility. In the unlikely event that the UAS should run out of fuel, it would simply land. Given its weight and construction material, the risks are less than contemplated by the current regulation.

Sonya Ricker believes that an equivalent level of s afety can be achieved by maintaining a reserve battery capacity in excess of the amount required for the UAS to return to a safe location, or the location in which it was launched (whichever is longer) at all times during operation. Operation will be term inated and the UAS landed prior to reaching this threshold.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration.

This regulation provides as follows:

(a) . . . No person may operate a civil aircraft unless it has . . . an appropriate and
current airworthiness certificate. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or c ockpit entrance so that it is legible to passengers or

crew.

Sonya Ricker UASs have no cockpit or cabin to place or carry certification. As such, the exemption and any other certifying document from the FAA will be maintained with the ground station, an d placed in amanner as to be clearly visible to any government official or person authorized in the controlled operations environment.

An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the UAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. § 91.405 (a) ; 407(a) (1) ; 409(a) (2) ; 417(a): Maintenance Inspections

Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as pro vided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. . . .” Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a) (2) requires an annual inspection for the issuance o f an airworthiness certificate.

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. Mainten ance on Sonya Ricker aircraft will be accomplished by the owner/operator pursuant to the manuals, provided by th e manufacturer. An equivalent level of safety will be achieved because the UAS is small in size, will operate only in restricted predetermined

a reas and is not a complex mechanical device. As provided in the attached Maintenance Manual and the Safety Checklist, which were reviewed as part of the application, the operator of the UAS will ensure that it is in working order prior to initiating flight , perform required maintenance, and keep a log of any maintenance that is performed

.

# This Certificate certifies that 

# Sonya Ricker Having satisfactorily completed the course of study And having passed the required examination in Flying,Controlling

, Maneuvering and FAA Rules & Regulations is a 

# Qualified for UAV Flight

Given under my hand on the 16th Day of July, 2015 

# Ken Taboh

## Aircraft Weight (including battery and propellers) 1280 g Diagonal size (including propellers) 590 mm
Max Ascent Speed 5 m/s
Max Descent Speed 3 m/s
Hover Accuracy Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m Horizontal: +/- 1.5 m
Max Speed 16 m/s (ATTI mode, no wind)
Max Altitude Above Sea Level 6000 m Operating Temperature 0°C to 40°C
GPS Mode GPS/GLONASS



## Camera Sensor Sony EXMOR 1/2.3” Effective pixe ls: 12.4 M (total pixels: 12.76 M)
Lens FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞ ISO Range 100-3200 (video) 100-1600 (photo) Shutter Speed 8s -1/8000s Image Max Size 4000 x 3000 Still Photography Modes Single Shot Burst Shooting: 3/5/7 shots Auto Exposure Bracketing (AEB): 3/5 Bracketed Frames at 0.7EV Bias Time-lapse Video Recording Modes 

## Phantom 3 Professional UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 

## Phantom 3 Advanced 2.7K: 2704 x1520p 24/25/30 (29.97) FHD: 1920x1080p 24/25/30/48/50/60HD: 1280x720p 24/25/30/48/50/60 Supported SD Card Types Micro SD Max capacity: 64 GB. Class 10 or UHS-1 rating required
Max Bitrate of Video Storage 

## Phantom 3 Professional 60 Mbps 

## Phantom 3 Advanced 40 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: MP4, MOV (MPEG-4 AVC/H.264) Operating Temperature 0°C to 40°C



## Gimbal Controllable Range Pitch -90° to +30° Stabilization 3-axis (pitch, roll, yaw)



## Vision Positioning Max Velocity Less than 8 m/s (when 2 m above ground) Altitude Range 50 cm-300 cm Operating Range 50 cm-300 cm Operating Environment Surface with clear pattern and adequate lighting (Lux > 15)



## Remote
Controller Operating Frequency 2.400 GHz-2.483 GHz
Max Distance 2000m (outdoors and unobstructed) Video Output Port USB Operating Temperature 0°C- 40°C Battery 6000 mAh LiPo 2S Mobile Device Holder For tablet or phone
Receiver Sensitivity (1%PER) -101 dBm ±2 dBm
Transmitter Power (EIRP) FCC: 20 dBm CE: 16 dBm Working Voltage 1.2 A @7.4 V

## Battery Charger Voltage 17.4 V Rated Power 

## Phantom 3 Professional

100 W 

## Phantom 3 Advanced

57 W



## Intelligent Flight Battery Capacity 4480 mAh Voltage 15.2 V Battery Type LiPo 4S Energy 68 Wh
Net Weight 365 g
Max Flight Time Approximately 23 minutes Operating Temperature -10°C to 40°C
Max Charging Power 100 W



## App / Live
View Mobile App DJI GO
EIRP 100mW
Power Spectral Density 6.9mW/MHz
Live View Working Frequency 2.4GHz ISM
Live View Quality 720P @ 30fps (depending on cond itions and mobile device) Latency 220ms (depending on conditions and mobile device) Required Operating Systems iOS 8.0 or later Android 4.1.2 or later Recommended Devices iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus Android: Samsung tabs 705c, Sams ung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 mini, SONY Z3 EXPERIA, MI 3, MI PAD