Sonya Lee Ricker

1125 Clarence Lane

Morristown, TN 37814

423-312-5017

sonyaricker@yahoo.com

Pursuant to Section 333 of the FAA Modernization 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 15th, 2015 and will obtain all FAA required UAS training, including all applicable 

regulations, guidance documents, charts, radio communications procedures, human factor and crew resource 

management, basic small UAS aerodynamics, decision-making and safe operating procedures in order to safely 

operate the UAS, including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles, and structures.

I plan to provide daytime aerial photography and videography services to real estate agents, 

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 UAVs 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 nonparticipating 

individuals and property in the event of an incident. These risk are substantially eliminated by the use of the 

UAV, 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 core 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 

specificities noted in this paragraph.

As the operator, I will place limits on altitudes 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 pilots, 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 conflicts 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 topographical 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 A 
EXEMPTION 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 area 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 airworthiness 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 without 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 will remain 

less than 55 lbs. and will not carry 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 operator, 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 level 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 requires 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. Given 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 equivalent 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 uses GPS positioning, and the DP3 Pro uses, in 

addition, a specialized sensor that limits 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 limited to an upper 

altitude limit, the limited area of operations, the See and 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 program, 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 safety will be achieved given the size, weight, speed, and 
material 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 

affected 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 be 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 that 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 

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 – (1) During the day, to fly after that for at least 

30 minutes; Or (2) at night, to fly after that 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 § 91.151(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 risks 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 their 

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 safety 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 terminated 

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 cockpit 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, and placed in a 
manner 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 provided 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 of 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. Maintenance on Sonya Ricker aircraft will be accomplished 

by the owner/operator pursuant to the manuals, provided by the manufacturer. An equivalent level of 

safety will be achieved because the UAS is small in size, will operate only in restricted predetermined 

areas 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 pixels: 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 24/25/30/48/50/60 
HD: 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 conditions 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, Samsung 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