New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

Docket Management System

U.S. Department of Transportation

1200 New Jersey Ave., SE

Washington, D.C. 20590

December 1, 2015

Re: Exemption Request Pursuant To Section 333 of the FAA Reform Act of 2012

Dear Sir or Madam,

Pursuant to §333 of the FAA Modernization and Reform Act of2 012 (the Reform Act) and 14 C.F.R. Part 11,

New England Aerial Solutions (NEAS), operator of Small Unmanned Aircraft Systems (sUASs) seeks an 

exception from Federal Aviation Regulations detailed herein for the operation of Unmanned Aerial Systems, 

for the purpose of lightweight aerial imaging and aviation safety education.

New England Aerial Solutions also hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of its sUASs, so long as such operations are conducted 

within and under the conditions outlined herein or as may be established by the Federal Aviation 

Administration (FAA) as required by §333.

New England Aerial Solutions:

The name and address of the applicant is: New England Aerial Solutions Attn: David Price Ph:+ l 

(603)-943-2125 Email:davidgprice@comcast.net, Address: 41 Gifford Way, Duxbury, MA 02332

Our operation includes a single UAS, manufacturer DJI, referred to hereinafter as the Phantom 3 Pro. The DJI 

Phantom 3 Pro has the following flight and safety relatable features: 

• Phantom 3 is a UAS Quadcopter made by DJI that has a fixed gimbal and camera attached to the bottom. The 

Phantom 3 has a maximum weight of 1280 grams, and a maximum range of up to 3.1 miles (5 km). 

• The Phantom 3 has built in telemetry to allow the operator to see all onboard information relating to the 

safety of flight including but not limited to battery percentage remaining, overall health of the operating 

system, built-in GPS for position hold and automatic return-to-home, and multiple fail-safes for maximum 

safety. 

• The onboard camera allows the operator to record High Definition video, as well as take camera stills. The 

video is transmitted real-time to the control and operator allowing the operator to see images to all sides of the 

UAS utilizing an Apple iPad Air as a monitor for operations. 

• DJI Phantom 3 Pro is limited to a maximum assent rate of 5 m/s (11 mph) and has a maximum decent rate of 

3 m/s (6.7 mph). It also has a limitation of maximum speed of 16 m/s or 35 mph

• The Phantom 3 Pro will be operated with a 4480 mAh lithium polymer battery allowing for flight times of 

approximately 20 minutes. (The Phantom 3 allows for a pre-set to indicate 30% battery remaining, which 

will be set to this as a warning reminder to allow for safe landing times).
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

Ground Based Guidance and Control System used with the Phantom 3 Pro: 

• DJI Phantom 3 Pro is controlled using a DJI transmitter, operating on a 2.4GHz frequency to a maximum 

range of 5km. (Specific operating range of 2.400-2.483GHz.) These specifications fall within FCC guidelines 

for operators. Powered by a lithium polymer battery it has a 4 hour time between charges. 

• The DJI Phantom 3 transmitter has a built in GPS allowing the Phantom 3 to always know where to return to 

in the event of a failure. 

• The Phantom 3 Pro transmitter will be controlled by a single operator, but will utilize a Visual Observer when 

necessary. 

Flight Control Operator : 

• The exclusive operator will be the owner of the Phantom 3 Pro. (David G. Price). David Price is a licensed 

Commercial Pilot (Certificate # 3372009) with over 25 years in aviation education.

Request for Exemption

New England Aerial Solutions respectfully requests a grant of an exemption of the following sections of Title 

14 of the Code of Federal Regulations:

• 14 CFR 45.23 (b);

• 14 CFR Part 21 (h);

• 14 CFR 61.1 13 (a) & (b);

• 91.7 (a);

• 91.9(b)(2);

• 91.103(b);

• 91.109;

• 91.119;

• 91.12 1;

• 91.151(a);

• 91.203(a) & (b);

• 91.405 (a);

• 91.407 (a) (1 );

• 91.409 (a) (2);

I. The Extent of Relief New England Aerial Solutions Seeks and the Reason It Seeks Such Relief:

New England Aerial Solutions submits this application in accordance with the Reform Act, 112 P.L. 95 2

§§331-334, seeking relief from any currently applicable federal aviation regulations (FARs) pertaining to 

UASs (unmanned aircraft systems) and operating to allow New England Aerial Solutions to conduct 

commercial photographic, aviation education safety programs and courses, and other flight operations within 

the U.S. national airspace system.
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

The Reform Act in §332 provides for such integration of civil UASs into our national airspace system as it is in 

the public's interest to do so. New England Aerial Solutions's lightweight UASs meets the definition of "small 

unmanned aircraft" as set forth in §331 and combined with a perfect safety record in similar industries, New 

England Aerial Solutions's light duty UASs are ideal recipients of exemption by the intent of the Reform Act.

Considerations for relief include a combination of sUAS physical characteristics, safety features, and safe

practices identified in §333:

• sUAS weight,

• sUAS overall size,

• sUAS speed over ground,

• sUAS flight zone characteristics,

- Non-operation near airports (civilian or military),

- Tightly controlled operation in populated areas,

• Operation of the UAS by VLOS.

The reason for specific consideration is outlined below:

14 C.F.R. Part 21 Subpart H: Airworthiness Certificates

14 C.F.R. §91.203 (a) (1) 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 

and limited operating area associated sUASs, an exemption from Part 21 Subpart H meets the requirements

of an equivalent level of safety under Part 11 and §333 of the Reform Act. 1l1e Federal Aviation Act (49

U.S.C.§4470 1 (f)) and §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 particular sUAS. In all cases, an analysis of 

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft 

(fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions 

proposed.

The sUAS to be operated by New England Aerial Solutions is less than 11kg. with maximal payload consisting 

of remote sensing instrumentation, carries neither no persons, carries no explosive or flammable materials 

including combustible fuels, and operates exclusively within a secured area. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the pilot (PIC), 'spotter' role 

designated to act as both the remote sensing controller and secondary monitor for safety issues, and a 

technician, which assists in matters related to maintaining the sUAS and also monitors for safety concerns and 

liaisons to the on-site safety officials. These enhancements to current safety practices and regulations, which 

already apply to civil aircraft, provide a greater degree of safety to the public and property owners than 

conventional aircraft operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, 

Subpart H. Lastly, application of these same criteria demonstrates that there is no intrinsic credible threat to 

national security posed by the UAS, due to its size, speed of operation, location of operation, lack of intrinsic 

explosive materials or flammable liquid fuels, and inability to carry a substantial external load.
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

14 C.F.R. §45.23 (b). Marking of the Aircraft

Under this part, it is required that each operator must display on that aircraft marks consisting of the Roman 

capital “N” followed by the registration number of the aircraft. Our UAS is too small to attach the “N” 

number. We seek exemption from this part as we will be attaching the registration or serial number as required 

on the UAS.

Further markings include the use of flashing green LED illumination on the underside of the sUAS frame 

which stands at contrast against a blue or white sky.

14 C.P.R. §61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

§61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry a pilot

or passengers, the proposed operations can achieve the equivalent level of safety of current operations by

requiring a ground crew member to have a private pilot's license rather than a commercial pilot's license to

operate this sUAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely

controlled with no persons on board. The area of operation is controlled and restricted, and all flights are

planned and coordinated in advance. The risks associated with the operation of the sUAS are so diminished

from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that

allowing operations as requested with a private pilot in the ground crew exceeds the present level of safety

achieved by 14 C.P.R. §61.1 13 (a) & (b).

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

Under this part, “no person may operate a civil aircraft unless it is in airworthy condition.” We seek exemption 

from this part, as there will be no airworthiness certificate issued for the aircraft, should this exemption be 

granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft and 

the requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, a 

subset of which are provided in enclosed Supplemental material, an equivalent level of safety will be provided.

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

§91.9 (b) (2) provides: no aircraft may operate without a manual onboard the aircraft. 

The UAS operated by NEAS is not large enough to carry such operating manual. We will however carry a 

current manufacturer manual in the UAS carrying case along with the operator on all flights. 
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

14 C.F.R. §91.103: Preflight action

This regulation requires each pilot prior to flight will become familiar will all available information pertaining 

to that flight including runway lengths, flight information, weather, etc. For any flight, runway lengths at 

airports of intended use, and the following takeoff and landing distance information include; all applicable 

information relating to aircraft performance, airport elevation, runway slope, aircraft gross weight, wind and 

temperature. 

We respectfully seek exemption from this part as our operator, while utilizing all available information for the 

safe operation of the UAS, will not have the above information available for most flights. The PIC will take all 

actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft 

performance data before initiation of flight. Further, we have proprietary manuals created with the help of 

sUAS experts, the manufacturer, the regional sUAS vendor and policy holding insurer and continue to work 

with these organizations to ensure best safe practices are adhered to.

14 C.P.R. §91.1 09: Flight instruction

§91.103 states 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. sUASs and remotely piloted

aircraft, by their design do not have fully functional dual controls. sUAS flight control is accomplished through 

the use of a remote controller that communicates with the aircraft via radio communications. 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. The equivalent level of safety provided by the fact that neither a pilot 

nor passengers will be carried in the aircraft and by the size and speed of the aircraft. Enhancing this safety is 

the technology inherent in the remote controls utilizing digital communications which is paired to the sUAS 

making it nearly impossible to unintentionally or intentionally have the control communications interrupted.

14 C.F.R. §91.119: Minimum safe altitudes

§91.119 establishes safe altitudes for operation of civil aircraft. §91.119 (d) allows helicopters to be operated

at less than the minimums prescribed, provided the person operating the helicopter complies with any route

or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that closely mimics the

behavior of a helicopter, and the exemption requests authority to operate at altitudes up to 400 AGL, an 

exemption may be needed to allow such operations. As set forth herein, the UAS will never operate at higher

than 400 AGL or beyond unaided visual line of sight, whichever is closer. It will however be operated in a

restricted area with security officials tasked with ensuring public safety, and where buildings and people will 

not be exposed to operations without their pre-obtained consent and training.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location 

where it is operated. No flight operation will be taken without the permission of the property owner in the case 

of private property or local officials in the case of public property or private property with public interests.

Because of the advance notice to the property owner and participants in the remote sensing activity, all affected 

individuals will be aware of the planned flight operations. Compared to flight operations with aircraft or 

rotorcraft weighting far more than the maximum 11kg of New England Aerial Solutions's sUAS proposed 
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

herein and the lack of flammable fuel, any risk associated with these operations is far less than those presently 

presented with conventional aircraft operating at or below 500 AGL. In addition, the low-altitude operations of 

the sUAS will ensure separation between these small- UAS operations and the operations of conventional 

aircraft that must comply with §91.119.

14 C.F.R. §91. 121: Altimeter Settings

This section pertains to setting an altimeter setting below 18000ft to a reported altimeter reporting station 

setting. 

New England Aerial Solutions seeks exemption from this part as our UAS has no way of setting an alternate 

altimeter setting. With a built-in electronic altimeter, the Phantom 1 uses real-time data to determine altitude 

for each flight. Operating less than 400ft AGL, we feel our UAS will have little to no impact on other 

participating aircraft. Also, with flights not to exceed 16 minutes (22 minute battery, and landing at 30% 

battery remaining) our UAS will not need to recalibrate its altimeter while in flight. An equivalent level of 

safety will be achieved by the operator, confirming the altitude of the launch site shown on the GPS altitude 

indicator before flight.

14 C.F.R. §91.15l (a): Fuel Requirements for Flight in VFR Conditions

This section contains requirements for fuel in VFR flight for combustion engines. 

We seek exemption from this part as our UAS is powered by battery only. We feel our operations will not 

compromise safety to either the operator or property as we have set forth a procedure to land our UAS when 

the battery level reaches 30%, or approximately 6 minutes flight time remaining. The Phantom 3 Pro has built 

in battery telemetry that feeds information real time to the operator and an alarm notifies the operator of 

minimum battery level remaining. 

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

The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following:

(1) 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.

The sUAS fully loaded weighs no more than 1280 grams and is operated without an onboard pilot. As such, there

is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent 

level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the 

sUAS will have immediate access to them, to the extent they are applicable to the sUAS.
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

14 C.P.R. §91.405 (a): Maintenance Required

This section contains requirements for the operator to maintain and have inspected the aircraft in accordance 

with Part 43 of the CFR. Under this section it is required to keep maintenance logbooks with the aircraft. It 

also requires the aircraft to contain placards of the inoperative equipment. 

We seek exemption from this part as our UAS will not be operating with inoperative equipment and is too 

small to carry logbooks. We also seek exemption due to no certified maintenance technicians will work on the 

UAS. Under this exemption Realistic Image will be completing pre-flight and post-flight inspections, and any 

required maintenance or repairs will be completed by the manufacturer, DJI, or one of its certified technicians.

14 C.P.R. §91.407(a) (1): Operation After Maintenance

This part requires an aircraft that has undergone repair, rebuilding, alterations, or general maintenance to be 

approved by an authorized person required by CFR 43.9 and CFR 43.11. 

We seek exemption from this part as these inspections do not pertain to our operation of the UAS. The operator 

will be responsible for determining the airworthiness of the UAS prior to each flight. After maintenance 

provided by the manufacturer, the operator will complete test flights before any operation in the vicinity of 

persons or property to assure all systems are functioning normally.

14 C.P.R. §91.409 (a) (2): Maintenance Inspections

This part requires an aircraft that has undergone repair, rebuilding, alterations, or general maintenance to be 

approved by an authorized person required by CFR 43.9 and CFR 43.11. 

We seek exemption from this part as these inspections do not pertain to our operation of the UAS. The operator 

will be responsible for determining the airworthiness of the UAS prior to each flight. After maintenance 

provided by the manufacturer, the operator will complete test flights before any operation in the vicinity of 

persons or property to assure all systems are functioning normally.

II. Commercial and Public Benefits

New England Aerial Solutions believes that granting this exemption request furthers the public interest by 

providing a safe (by way of an unmanned system) and efficient means to meet technical problems solvable by 

elevated data collection instruments. New England Aerial Solutions's client base are typically small to medium 

sized businesses looking to increase their awareness of structures or landscape on their respective properties 

through data collection by photographic, and/or videographic imagery. By moving these functions onto sUAS 

based aircraft, the potential for loss of life or property is diminished due to the greater control in a smaller and 

safer aircraft that holds no persons. Second, there are no reactive or combustible materials on board the sUAS 

and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme 

maneuverability of New England Aerial Solutions UASs allow the PIC to avoid hazards. Lastly, due to the 

nature of the remote sensing instrumentation onboard, the sUAS can maintain quite a safe distance between the 

aircraft and the object(s) undergoing scrutiny. Accordingly, New England Aerial Solutions's UASs have 

operated and will continue to operate at

and above current safety levels.
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

A. The costs and benefits of your proposed action to society in general and specific groups within society

As described above, New England Aerial Solutions's will be small to medium businesses seeking a remote 

sensing solution to specific issues before a larger effort on their part would come underway. Examples include 

real estate, and construction efforts. Additionally, training will be provided to other sUAS operators in order to 

improve industry safety and education.

1. The effect of an exemption for New England Aerial Solutions on the quality of the natural and social 

environments

Utilizing sUASs minimizes the requirement for conventional aircraft. This eliminates the need for an on board 

pilot, time consuming adherence to regulations surrounding bookkeeping and submission of flight paths to 

local civil or military airports, and detrimental effects to the environment caused by operating a combustible 

fuel based, large scale aircraft, with restrictions on the proximity to the target for remote sensing.

Ill. Flight Capabilities and Characteristics of New England Aerial Solutions UASs

Pursuant to 112 P.L. 95 §333 (a), concerns for public safety are mitigated by the overall capabilities and

characteristics of the sUAS. 1

New England Aerial Solutions UASs utilizes four (4) rotating propellers for balance, control and stability. The 

total span of the sUAS is 590 mm (including the propellors) allowing for stable flight or landing even with the 

sudden onset of detrimental environmental conditions.

New England Aerial Solutions's sUAS is designed to primarily hover in place to capture photographic data and 

then operate at less than a 16 m/s maximum speed. The UAS is capable of vertical and horizontal operations 

but, in practice, is operated only within unaided VLOS of the PIC. In addition to the PIC, New England Aerial 

Solutions employs a spotter (VOS role)which is within unaided verbal communication range. These personnel 

are supplemented by safety offcials provided by the client who are instructed to cordon off and otherwise 

minimize pedestrian access in the flight zone of the client's grounds.

All of New England Aerial Solutions' s UASs utilize LiPo (lithium polymer) battery based power sources, 

decreasing safety risks from more easily combustible, fuel based, power sources. Flight times generally last 

between eight (8) to ten (10) minutes allowing the staff to work with small flight areas per phase. New England 

Aerial Solutions further restricts flight time by not operating its sUASs with less than thirty percent battery 

capacity. Further safety management systems in place include a GPS mode that allows New England Aerial 

Solutions sUASs to hover in place if communication with the PIC is lost and optionally follow a set of 

waypoints at a set speed and height to a 'home base' predesignated safe landing zone.
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

IV. Reasons Why an Exemption to New England Aerial Solutions Will Not Adversely Affect Safety Standards

New England Aerial Solutions's contends that operation of it's sUASs will not "create a hazard to users of the 

national airspace system or the public:' as stated in 112 P.L. 95 §333 (b). Given the small size and weight of 

New England Aerial Solutions's sUAS, combined with their operation in cordoned off and well-controlled 

areas, New England Aerial Solutions's sUASs falls within Congress's contemplated safety zone. New England 

Aerial Solutions sUASs have an established safety record bolstered by multi-point preflight checklist, 

awareness of their surroundings, and intimate knowledge of the behavior of the sUAS platform in many 

weather conditions. This safety record and implemented operational practices demonstrate an awareness of 

public safety.

New England Aerial Solutions operations routinely provide a level of safety at least equal to existing rules, and 

in nearly every instance, exceeds existing rules. New England Aerial Solutions works closely with regional 

experts as well as the sUAS’s manufacturer to support this aircraft to create a safe platform that has been tested 

throughly by the manufacturer with a proven record for safety and solid designs.

New England Aerial Solutions does not operate its UASs on or near airports and generally has only operated 

its sUAS on private grounds with cordoned off areas or areas under the control of the property owner. New 

England Aerial Solutions will determine the areas needed to fulfill the clients' goals and only operates its UASs 

in these flight zones and only in compliance with well regarded safety protocols set forth initially by the RC 

UAS trade and hobby groups and recently codified by relevant FARs.

New England Aerial Solutions standardized the following practices to ensure safe operation of it's UASs:

• Work with on-site personnel to plan the flight goals,

• Work with on-site personnel to restrict access to non-essential persons,

• Operation by unaided VLOS operation only,

• Operation in phases 10 minutes in length,

• Operation to minimal 25% battery power,

• Operation of device to GPS aided readout to 390ft at maximum,

• Numerous pre-programmed fail -safes that ensue specific behavior per issue,

• Three main roles supplemented by on-site safety personnel,

• Employ controlled lifecycle management of components to guard against multiple failures,

• Preform a site check day(s) before flight to identify potential issues,

• Subscribe to relevant local weather and safety alerts,

• Expertly choose data collection instruments and accessories to minimize flight requirements or

expertise,

New England Aerial Solutions has experience in similar professional aviation fields and has adapted this 

experience in its use of UASs to increase safety. In combination to the ever expanding knowledge repositories 

from hobbyists and experts alike. New England Aerial Solutions is constantly evolving it's practices when 

there is a clear benefit to operations or increased safety.
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

V. Emergency Procedures

• Loss of Remote Signal

- The flight package features an optional enhanced fail-safe which returns the UAS to the 

home base waypoint via the same path taken to point of lost signal.

- The UAS will then preform a hover over this waypoint and then a controlled landing.

• Loss of GPS signal

- The system will operate in GPS assisted mode with three (3) satellites.

- At loss of three (3) GPS satellites, manual mode can be activated or the flight package can 

be programmed to preform a controlled landing to the home base waypoint.

- Ground based height ranging is preformed by a separate system and so loss of GPS will not 

impact controlled landing in a safe manner.

• Loss of Engine Power

- In the event of one (1) (or to two oppositely positioned) rotor or motor failure the system 

will enter into controlled spin where all controls are translated based on current 

orientation and will behave as normal operation to the PIC to ensure a safe landing,

- In the event of multiple rotor or motor failures the flight package can be configured to 

preform a safe landing or attempt operation to home base waypoint.

- Note : Behavior of the landing location is highly dependent on the position and number of

rotors/motors that are affected.

• Loss of Ground Control Software

- This will not affect operation of the flight. The unit will be piloted to a safe landing area and 

then landed so that examination of the link can be made.

A. Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register,

should it be determined that publication is needed:

New England Aerial Solutions {applicant) seeks an exemption from the following rules: 14 C.P.R. §21, subpart 

H; 14 C.F.R 45.23(b); 14 C.P.R. §§61.113( a) & (b); 91.7 (a); 91.9 (b) (2); 91.103{b); 91.109; 91.119; 91.121; 

91.151(a); 91.203(a) & (b); 91.405 (a); 91.407 (a) (1 ); 91.409 (a) (2); 91.409 (a) {2) and 91.417 (a) & (b) to 

operate commercially a small unmanned vehicle (11kg or less) in elevated photographic and aviation safety 

education operations.

Approval of exemptions allowing commercial operations of sUASs in the media industry and safety education 

industry will improve safety by reducing risk associated with conventional aircraft operations and other means 

of elevated remote sensing involving persons. The public benefit served by approval of this petition is 

increased safety awareness of characteristics of difficult imaging targets. A sUAS weighing fewer than 1l kg 

and powered by sealed batteries eliminates virtually all associated risk inherent in operating conventional 

aircraft in close proximity to buildings or persons or otherwise elevating persons to a position they would be 

able to collect needed data. The operation of small UASs, weighting less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions 
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial 

operations.

As identified and described herein, David Price, New England Aerial Solutions, is an experienced, 

recognized commercial pilot and aviation educator with over 25 years of experience in aviation education 

with a perfect safety record.

The FAA has been given the authority to issue the exemption to New England Aerial Solutions pursuant 

to the Federal Aviation Act, 85 P.L. 726 (1958), and as such, we humbly seek your consideration and 

approval of this petition.

Best Regards,

David G. Price

Owner, New England Aerial Solutions

41 Gifford Way, Duxbury, MA 02332

603-943-2125

davidgprice@comcast.net

encl: Supplement A: Physical characteristics of UAS

encl: Supplement B: Flight Operation and Procedures Manual (FOPM) related to operation

encl: Supplement C: Receipt of Phantom 3 Pro
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

Supplement A : Physical Characteristics of New England Aerial Solutions's UAS

The Phantom 3 Professional’s flight controller features several important upgrades, including a new flight 

mode. Safety modes include Failsafe and Return-to-Home. These features ensure the safe return of your 

aircraft if the control signal is lost. The flight controller can also save critical flight data from each flight to the 

on-board storage device. The new flight controller also provides increased stability and a new air braking 

feature.

GENERAL FEATURES

▪ Epic Aerial Video

▪ Live HD View

▪ Complete Control

▪ Powerful Mobile App

▪ Vision Positioning

▪ Easy to Fly

▪ Worry-free Autopilot

▪ Intelligent Battery

▪ Supports Adobe DNG RAW

▪ Unmatched Propulsion

▪ SDK Development

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 Service Ceiling Above Sea Level 6000 m (Software altitude limit: 120 m above takeoff 

point)

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

VISION POSITIONING

▪ Max Velocity: Less than 8 m/s (when 2 m above ground)

▪ Altitude Range: 30 cm-300 cm

▪ Operating Range: 30 cm-300 cm</td></tr>

▪ Transmitter Power:CE: 25mw; FCC: 100mw

▪ Operating Environment: Surface with clear pattern and adequate lighting (Lux > 15)
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

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)

▪ Max Bitrate Of Video Storage: 60 Mbps

▪ Operating Temperature: 0°C to 40°C

REMOTE CONTROLLER

▪ Operating Frequency: 2.400 GHz-2.483 GHz

▪ Max Distance: 2000m (outdoors and unobstructed)

▪ 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

DJI VISION APP

▪ EIRP: 100mW

▪ Live View Working Frequency: 2.4GHz ISM

▪ Live View Quality:720P @ 30fps (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 S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 

mini
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

Supplement B : Summary Sections of Flight Operations and Procedure Manual (FOPM)

This manual describes the notable roles, tasks, and operations performed by MS photography/MS Aerial. The

aim is to document everything that is needed to be done during a mission, so it can act as a reference point

for team members.

Roles and Responsibilities

As much as is possible, New England Aerial Solutions staff attempt to have redundancy in expertise and skillsets related to operations of the UAS.

Pilot in Command (PIC)

• Piloting the UAV. This will include:

- Takeoff,

- Normal Flight,

- Flight during emergency procedures,

- Landing,

• Assembling the UAV

• Performs pre-flight checks of the firmware,

• Performs pre-flight checks of the hardware,

• Preforms pre-flight checks of the software.

Spotter

• Relays notable flight parameters such as flight times, battery strength, metrics from the UAS.

• Primary communication link between pilot and on-site safety personnel,

• Will hold physical documents related to current flight,

• Preforms pre-flight checks of the data collection equipment,

• Monitors ground and greater above-ground environment for safety concerns

Technician

• Assembling the UAV,

• Preforms pre-flight checks of the hardware,

• Performs pre-flight checks of the software,

• Secondary communication link between pilot and on-site safety personnel,

• Relays to the Spotter and records notable flight parameters metrics from the UAS,

• Monitors ground and greater above-ground environment for safety concerns
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

Pre-Flight Checklist (Before Power Applied)

• Check for physical damage and any missing hardware,

• Check all electronics present and connected/check cord connections are tight.

• Confirm all batteries charged,

• Check all rotors and moving parts for debris that would prevent proper operation.

• Check weather patterns the night beforehand.

• Check camera equipment for proper operation.

Before Takeoff Checklist (After Power Source Applied)

• Confirm proper power reading of battery,

• Run hardware based systems check,

• Run software based systems check,

• Check flight LED array,

• Confirm proper radio link to flight controller,

• Confirm proper radio link to data collection device controller,

• Confirm secondary controller connection to UAS onboard flight controller,

• Confirm waypoints and geofences are accurate to current flight,

• Confirm desired behavior of emergency failsafes,

• Check with on-site safety personnel for any changes in goals.

In-Flight Checklist

• Check with on-site safety personnel for a safe flight area for first flight,

• Record relevant metrics in flight log,

• Check for ground hazards at home-base and rectify,

• Confirm > 8 satellite GPS lock,

• Confirm initial state of controllers,

• Initialize rotors and check for proper operation,

• Perform controlled flight to hover mode approximately 5m above ground,

• Perform controlled multi-axis roll procedure to check for proper orchestrated rotor operation,

• Perform controlled multi-axis (if applicable) control procedure of camera,

• Switch controller mode to radial based, check proper operation to maximum 5m distance to PIC and

return to initial position,

• Return UAS to normal orientation,

• Perform controlled flight to hover mode approximately lm above ground,

• Land the UAS and check for proper de-initialization of rotors,

• Operate UAS to each waypoint position until maximum flight time is achieved,

• Return UAS to normal orientation,

• Perform controlled flight to hover mode approximately 1m above ground,

• Land the UAS and check for proper de-initialization of rotors,

• Remove power to the flight package,

• Remove power to controllers,

• Complete flight log.
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

Standing Procedures

• The Pilot, Spotter, and Technician will be the only New England Aerial Solutions staff members in the 

forward flight area. On-site personnel will be within verbal range and behind New England Aerial Solutions 

staff.

• The maximum power used to control the device is soft limited to 75% in order to maintain power in

reserve for unforeseen conditions,

• Flight time is limited to 15 minutes and goals will be planned in phases to be accomplished during this

time.

• Flight time is limited to reserving 25% battery power,

• Flight height is soft limited to visible and unaided line of sight (VLOS), and hard limited to 300ft,

whichever is less.

• Flight time is limited to operation in safe environmental conditions,

• Flight staff will maintain proximity so as to be in clear and unaided verbal range,

• The PIC will announce all movements to New England Aerial Solutions and on-site staff so that non-PIC 

staff members can identify possible safety concerns before operation of the UAS to the next waypoint or 

position,
New England Aerial Solutions

41 Gifford Way, Duxbury, Massachusetts 02332 davidgprice@comcast.net 603-943-2125

Supplement C: Receipt of Phantom 3 Pro