September 8, 2015 

Craig W, Spirko 

6921 Paseo Del Serra 

Los Angeles, CA 90068 

Mobile: 323-691-9191 

Email: mail@spirko.com 

Docket Operations, M-30; U.S. Department of Transportation (DOT), 1200 New Jersey Avenue, 

SE., Room W12-140, West Building Ground Floor, Washington, DC 20590-0001 

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. FAA20140355in the matter of the petition of 

FLYING CAM INC 

Dear Sir or Madam, 

In accordance with the FAA's Guidelines for Submitting a Petition for Exemption under section 3 3 3 if the 

FAA Modernization and Reform Ad if 2012, I Craig W Spirko, 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 photography, cinematography, 

videography, and othe~ 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 1-3. 
TheFARs 

The petitioner seeks exemption from the above mentioned PARs for the following reasons; 

61.113(a) & (b); 

The petitioner requests relief in order to facilitate the utilization of an experienced UAS operator 

with the addition of a trained observer. All pre-flight inspection, maintenance and flight logs will be 

saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the 

purpose of safely integrating civil UAS operation in the National Airspace System. 

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. 

The petitioner will primarily operate the UAS between ground level and 200 feet. The UAS will be 

operated over designated properties with the owner's consent and while maintaining a safe distance 

from persons. The petitioner will compile flight data from the logs. This data may assist the FAA in 

development of regulations for commercial operations in low-risk, controlled environments. 

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 UAS specific 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 UAS 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 record keeping, 

were sufficient to ensure that safety would not be adversely affected. 

TheUAS 

The DJI Phantom 3 is a highly successful consumer grade small rotorcraft in the quadcopter 

configuration with an advertised weight of 9.2 lbs. designed primarily to carry aloft its integrated 

high definition camera. It has an advertised maximum speed of less than 32 knots (16m/s) and a 

maximum climb rate of less than 1200 feet per minute (6 m/s). It is powered by four electric motors 

with a distance between motors of less than 14 inches (350mm). It utilizes an internal inertial 

measuring unit (IMU) with integrated barometric sensor augmented with global positioning system 

(GPS) to maintain its geospatial orientation and position. It is controlled primarily through an FCC 

certified radio control (RC) unit. Real time video and telemetry information is transmitted back to a 

ground control station allowing the operator and/ or PIC to monitor battery level, GPS signal 

strength, altitude (AGL), distance from PIC, camera imagery, and control camera angle. It has 

failsafe modes of operation for either loss of RC or GPS signal. Altitude can be limited by the 

onboard flight controller and maximum altitude can be preprogrammed by the PIC. Battery life 

limits flight times to approximately 20 minutes. The onboard flight controller will warn the pilot via 

telemetry and external lighting cues before reaching a low battery state. An automatic termination of 

flight and landing will be initiated when the battery reaches a predetermined low state. It is 

anticipated that flights will usually last less than 10 minutes. More information is available in 

attachment 1. 

Risk mitigation 

The petitioner has reviewed FAA exemptions reference's 1-3 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 failure prone components. These documents will be made available to the FAA and 

SoT to assist in future implementation of safety standards and regulations. The petitioner will only 

operate the UAS over designated properties with the owner's consent. Flight plans will be 

predetermined to limit the UASs flight time and limit safety concerns. The petitioner will take into 

account distance from persons and potential flight obstacles prior to operating the UAS. UAS 

operation will always be within VLOS of the PIC and the observer. 

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. Aerial surveying and inspections can increase work site 

efficiency, improve volumetric estimations and reduce risks. The petitioner will provide clients with 

photographic data for these purposes on a 'for hire' basis acting as an independent contractor. A 

visual observer will be utilized. 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 or other means as required. 

PIC and Conclusion 

The petitioner is a f:tltn and television Director/Director of Photography with 30 yrs. professional 

experience, a Private Pilot (Certificate Number: 3567612) with a current Third Class Medical 

Certificate and 700+ hrs. total flight time, a Light Sport Repairman (Certificate Number: 3567612,) 

as well as an avid UAS enthusiast with more than 10 yrs. experience flying radio controlled aircraft. 

The petitioner is requesting this exemption for the purposes of "aerial photography, 

cinematography, videography, inspections and other flight operations." 

The petitioner has and will refrain from engaging in commercial use of UAS until such time as it can 

be done safely and legally. Of course persons and property safety is paramount, and the petitioner 

would also never consider jeopardizing his privileges as a Private Pilot and aircraft owner. 

Respectfully submitted, 
PHANTOM 3 

Quick Start Guide 

V1.2 

ttachment 1 

Spirko Section 333 

Exemption Request 

Phantom 3 Professional 

It's time to meet your Phantom 3 Professional. 

The Phantom 3 Professional's camera recolds video at up to 4K and captures 12 megapixel photos. 

Review the diagram below for a full list of your Phantom 3 Professional's parts: 

1. Gimbal and Camera 9 A1rcraft Status Indicators 

2. Vision Positionmg System 10 Antennas 

3 Camera M1cro-SD Card Slot 11 Intelligent Flight Battery 

4 Aircraft Micro-USB Port 12 Power Button 

5. Camera Status Indicator 13. Battery Level Indicators 

6. Front LEOs 14. L1nk Button 

7 Motors 15. Camera Micro-USB Port 

8 Propellers 
Appendix 

• Aircraft 

Weight (Including Battery) 

Max. Ascent Speed 

Max. Descent Speed 

Max Speed 

Max Flight Altitude 

Max Flrght Time 

Operating Temperature Range 

GPS 

•Gimbal 

Controllable Range 

• Vision Positioning 

Velocity Range 

Altitude Range 

Operating Range 

Operating Environment 

• Camera 

Sensor 

lens 

ISO Range 

Electronrc Shutter Speed 

Image Max Size 

Sllfl Photography Modes 

Video Recordrng Modes 

Max. Bitrate of Video Storage 

Supported File Formats 

Supported SO C.<Jrd Types 

Operating Temperature Range 

• Remote Controller 

Operatmg Frequency 

Max. Transmission Drstance 

Video Output Port 

Operating Temperature Range 

Battery 

Mobile Devrce Holder 

Transmitter Power (EIRP} 

Working Voltage 

• Charger 

Voltage 

Rated Power 

j280g 

5m/s 

3 m/s 

16 m/s (A Til mode, no wind) 

6000 m 

Approximately 23 mtnutes 

0°C to 40°C 

GPS/GLONASS 

Pitch· - 90° to +30° 

I ~ 

~<aQ ~ _; 

sf"1,0 zB9"'"' 

<8 m/s (Altitude 2m) 

30 cm-300 em 

30 cm-300 em 

~ 

Surface with clear pattern and adequate lighttng (lux> 15) 

Sony EXMOR 1/2 3" Effecttve ptxels:12.4 M (total pixels 12.76 M) 

FOV (Field Of View) 94° 20 mm (35 mm format equivalent) f/2 8 

100-3200 (vtdeo) 100-1600 (photo) 

8 s-1/8000 s 

4000 X 3QQQ 

Stngle shot 

Burst shoottng 3/5/7 frames 

Auto Exposure Brackettng (AEB): 3/5 bracketed frames at 0.7EV Bias 

Time-lapse 

UHD. 4096x2160p 24/25, 3840x2160p 24/25/30 

FHD 1920x1080p 24/25/30/48/50/60 

HD· 1280x720p 24/25/30/48/50/60 

60Mbps 

FAT32/exFAT Photo JPEG, DNG Vtdeo. MP4/MOV (MPEG-4 AVC/H 264) 

Mtcro-SD, Max capacity 64GB. Class 10 or UHS-1 rating required 

O"C to 40"C 

2 400 GHz-2.483 GHz 

2 km {outdoors and unobstructed) 

USB 

O"Cto40"C 

6000 mAh LiPo 28 

Tablets and smartphones 

FCC: 20 dbm; CE:16 dbm 

1.2A@74V 

17 4 v 100W 

~ ~~ "' 71mm 

• Intelligent Right Battery ( PH3-4480 mAh-15.2 V) 

~ 

Capacity 4480 mAh 

Voltage 15.2 V 

Battery Type UPo 4S 

Energy 68 Wh 

Net Weight 

Operating Temperature 

Max. Charging Power 

365g 

-10°C to 40°C 

100W 

*- Thts Quick Start Gutde is subject to change without prior notice. 

C€1313 £RollS ll FCCID: SS3WM3231SD3 FCCID; SS3·GL3001SDI 

Thisdeviceccmplie•withpatllSollheFCCRul~"" 

Operaliooi•subje<:ttothefollowi~glwacondltians. 

{I)Thisde.;cemaynotc.omeharmfulinterference.and 

{2)this<levicemu•la«<eptanyinterferencereceive<l.including 

interferencethatmaycau.eunde•iredoperatiorl. 

Preparing Your Phantom 3 Professional Before Flying 

Read the User Manual and watch the video tutorials in the OJ! GO app or on the official OJI website (WNW.dji.com), and 

read the following documents included in the box before using your Phantom 3 Professional for the first time: Phantom 3 

Professional Quick Start Guide, Phantom 3 Professional I Advanced Safety Guidelines and Disclaimer, Phantom 3 Professional I 

Advanced Intelligent Flight Battery Safety Guidelines, In the Box. 

1. Download the OJI GO App 

Search 'DJI GO' on the App Store or Google Play and 

download the OJ! GO app to your mobile device. 

OJI GO app 

2. Watch the Tutorial Videos 

Watch the tutorial videos on www.dji.com or in 

the DJI GO app. 

Phantom 3 tutorial videos 

• For the best experience, use a mobile dev1ce that runs tOS 8.0 or above or Androtd 4.1.2 or above. 

3. Check Battery Levels 

Pressing the Power Button once on either your Intelligent Flight Battery or Remote Controller displays the battery level. 

Be sure to fully charge both batteries before your first flight. 

Low .- Battery Level _,.. Htgh Low .- Battery Level _,.. Htgh 

©©:©i:® 

c 'r' oo oo :'oo:® 

'" 

4. Charging the Batteries 

• Only use the official DJJ Phantom 3 Professional charger. Remove the Intelligent Flight Battery from the aircraft before 

charging. 

• It is recommended that you turn off the Intelligent Flight Battery or Remote Controller before charging. 

• Connect the charger to a suitable power source (1 00-240V 50/60Hz). 

• Connect the charger to the Intelligent Flight Battery or Remote Controller. The LEOs will display the current charge level, 

and when fully charged, they will automatically turn off. 

Remove the Intelligent 

Flight Battery 

Pute 
-" 

' 

• Manual Takeoff and Landing (Stick configurations are for MODE 2): 

Start the motors by pulling both control sticks to the bottom 

inside (or outside) corners. Release the st'1cks once the 

motors start. Slowly push the left stick (throttle stick) up to 

takeoff. 

Start I Stop the motors Left stick up (Slowly) 

[G. ~~sal· 

To land, gently pull the left stick (throttle stick) 

down to lower the aircraft until 'rt touches the 

ground. Then pull both sticks to the bottom inside 

corners to stop the motors. 

Left st1ck down (Slowly) 

Q 

• Never stop the motors mid-flight. otherw1se the a1rcraft Will crash. Only stop the motors when on the ground or as required 1n 

emergency situations to reduce the risk of damage or Injury. 

• You cannot takeoff 1f the Intelligent Flight Battery is not sufficiently charged and the Critical low Battery Warning is active. 

• The Intelligent Fl1ght Battery must warm up if the outside temperature IS low A warn1ng will appear 1n the DJI GO app in thiS scenano 

• Once spinn1ng, the rotating propellers can be dangerous Do not start the motors when there are people nearby and always fly 

in a wide-open area 

• Power off your Phantom 3 Professional before switchmg off tho Remote Controller after landing 

• Return to Home: 

1. Press and hold the Return to Home Button on your 

Remote Controller until the LED surrounding the button 

starts bknking white and starts beeping. Your Phantom 

3 Professional ~viii return to the set Home Point. Press 

the button once to stop the procedure. 

2. The DJI GO app will warn you if your Phantom 3 

Professional's battery level falls under a certain level. This 

warning threshold can be set in the app. The aircraft will 

land immediately if the battery power reaches a critical 

level and the Critical Low Battery Level Warning appears. 

~ • 3. Failsafe: The Phantom 3 Professional will enter Return to 

Home Mode if the signal to the Remote Controller is lost. 

RTH Button The app's RTH Button 

• While returning home. you can still control your Phantom 3 

Professional's altitude to avoid any obstacles 

Appendix 

Aircraft Status Indicators Remote Controller Status LED 

#- Slowly: Safe to fly, GPS working :jit Remote Controller is functioning normally, 

. but is not connected to the aircraft. 

::'@;;'::: X2 Continuously: Vision Positioning ~-~ . . . 

''' s stem workin , no GPS \~J Rem_ote Controller 1s func~Jonmg normally 

y g and IS connected to the a1rcraft. 

R- Slowly: P-ATTI or A TTl Mode 

:::R-:: Quickly: Not connected 

to the Remote Controller 

:::~::: B-8-B ... Aircraft Low Battery Level Waming 

''' or Remote Controller error. 

ij; 8-8-... Remote Controller has been 

idle for 5 minutes. :+: Slowly: Low Battery Level Warning 

:::~:::Quickly: Critical Low Battery Level Warning 

·• Solid: Critical error 

:::~::: /:8: Blinking Alternately: 

Compass calibration required 

For more 1nformatron: 

http://www.dji.com/phantom3 

Camera Controls 

• Adjust the camera parameters using 

the Camera Settings Dial on the 

Remote Controller or through the DJI 

GO app. Press the Shutter Button or 

Video Recording Button to capture 

photos or record videos. 

• Adjust the gimbal's tilt using the 

Gimbal Dial. 

• Download photos and videos from 

the Micro-SO card to your mobile 

device through the DJI GO app. 

You can also use a SO-card reader 

to export files to your computer. 

©2015 DJI. All Rights Reserved 

D~,., ~~a b, DJI P"~tc>d ,~ Ch,no 

PHANTOtv13