1 

UNITED STATES 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video 

Solutions Inc. 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEM 

 PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on December 18, 2015 

Dana L. Strumpher - President 

Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service 

And Aerial Photography & Video Solutions Inc. 

35 Twilight Lane 

Springfield, IL. 62712 

217-529-5354 
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TABLE OF CONTENTS 

 Page 

 GLOSSARY OF ABBREVIATIONS...................................................................................................3 

 SUMMARY...................................................................................................................................4 

 INTRODUCTION AND INTERESTS OF PETITIONER.......................................................................4 

 BACKGROUND.............................................................................................................................4 

 BASIS FOR PETITION....................................................................................................................5 

 NAME AND ADDRESS OF PETITIONER...................................................................................6 

 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH STRUMPHER ENTERPRISES 

 INC. dba AMERISPEC HOME INSPECTION SERVICE and AERIAL PHOTOGRAPHY 

 & VIDEO SOLUTIONS INC.WHICH SKYSALT SEEKS EXEMPTION.............................................6 

 

 THE EXTENT OF RELIEF STRUMPHER ENTERPRISES INC. dba AMERISPEC HOME 

 INSPECTION SERVICE and AERIAL PHOTOGRAPHY & VIDEO SOLUTIONS INC. SEEKS 

 AND THE REASON STRUMPHER ENTERPRISES INC. dba AMERISPEC HOME 

 INSPECTION SERVICE and AERIAL PHOTOGRAPHY & VIDEO SOLUTIONS INC. SEEKS THE 

 RELIEF.....................................................................................................................................8 

 THE REASONS WHY GRANTING STRUMPHER ENTERPRISES INC. dba AMERISPEC 

 HOME INSPECTION SERVICE and AERIAL PHOTOGRAPHY & VIDEO SOLUTIONS INC. 

 REQUEST WOULD BE IN THE PUBLIC INTEREST ....................................................................12 

 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

 SAFETY..................................................................................................................................14

 

 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER........................................24 

 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT 

 STRUMPHER ENTERPRISES INC. dba AMERISPEC HOME INSPECTION SERVICE and 

 AERIAL PHOTOGRAPHY & VIDEO SOLUTIONS INC. REQUEST ..............................................25 

 CONCLUSION..............................................................................................................................25 

 APPENDICES...........................................................................................................................................26 
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GLOSSARY OF ABBREVIATIONS 

 AGL Above Ground Level 

 AOI Area of Interest 

 ATC Air Traffic Control 

 ATO Air Traffic Organization 

 AV Aerial Vehicle 

 CFR Code of Federal Regulations 

 COA Certificate of Authorization 

 FAA Federal Aviation Administration 

 FAR Federal Aviation Regulation 

 GCS Ground Control Station 

 GPS Global Positioning System 

 LOL Loss of Link 

 NAS National Airspace System 

 NOTAM Notice to Airman 

 PIC Pilot In Command 

 Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

 SO Safety Observer 

 SOP Standard Operating Procedures 

 UA Unmanned Aircraft 

 UAS Unmanned Aircraft System 

 VFR Visual Flight Rules 

 VLOS Visual Line of Site 

 VMC Visual Meteorological Conditions 

 VTOL Vertical Takeoff and Landing 
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SUMMARY 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 1.7(a), 

 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate 

 an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act 

 of 2012 (FMRA). This exemption will permit Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. to operate an Unmanned Aircraft 

 System (UAS) for the commercial purpose of conducting aerial video and photography for 

 residential and commercial real estate inspections, real estate photography, special private events, 

 and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. provides its clients with expertise and knowledge in residential and 

 commercial inspections and solutions to increase efficiency, productivity and effectiveness. 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. also provides its clients with high quality digital content for use in their 

 personal projects. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service has over 5 

 years of professional experience in video and photography of real estate and is recognized as an 

 expert in their field. The objective of Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. aerial video and photography operations is 

 to provide high quality imaging for a variety of commercial/private events, and residential uses, 

 specifically targeting: 

 * Residential & Commercial Real Estate Inspections 

 * Real Estate Video & Photography for listings 

 * 3D Mapping of Properties 

 * Special Private Events (Wedding Videos and Photography) 

 * Increase public knowledge of UAS and promote safe UAS operations. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 UAS 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. seeks an exemption to operate DJI systems for compensation for hire within 

 the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

 Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 

 has a maximum gross weight of approximately 2 pounds 13 ounces, while having a length of 18 

 inches, width of 13 inches, height of 8 inches, and a maximum speed of approximately 30 

 knots. The DJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery 

 powered electric motors. 
5 

 The DJI Phantom 3 UA will be operated by Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. and will be registered in 

 Accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

 Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

 Marking. 

BASIS FOR PETITION 

 Petitioner, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc., pursuant to the provisions of the Federal Aviation Regulations 

 (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

 Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially

 operate the DJI Phantom 3 UAS in the National Airspace System (NAS), and for an exemption from 

 the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

 In consideration of the speed, weight, size, and limited operating area associated with the 

 unmanned aircraft and its operation, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc.’s operation of DJI Phantom 3 UAS meets the 

 conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

 accordance with 14 C.F.R. Part 21, Subpart H. 

 Accordingly, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. requests relief from Sections 91.405(a), 91.407(a)(1), 

 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance 

 that only apply to aircraft with an airworthiness certificate. 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. submits that the requested relief is proper since an equivalent level of safety 

 will be ensured. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. will use experienced personnel or technicians to perform 

 maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

 and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI 

 Phantom 3 Instruction Manual). Furthermore, Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. will document and maintain all 

 maintenance records for the DJI Phantom 3 UAS. 

 Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot 

 privileges and limitations: Pilot in command, is requested by Strumpher Enterprises Inc. dba 

 AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. to the 

 extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

 certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

 minimum flight- hour and currency requirements, that the PIC is able to safely operate the 

 DJI Phantom 3 UAS in a manner consistent with this exemption, including evasive and emergency 

 maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 
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 the DJI Phantom 3 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. 

 Part 21, Subpart H. As such, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

 Aerial Photography & Video Solutions Inc. submits that they will ensure that the DJI Phantom 3 UAS 

 is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with 

 the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), 

 and that the aircraft is in a condition for safe flight. 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. also seek an exemption from the requirements of Section 91.121, entitled 

 Altimeter Settings, as the DJI Phantom 3 UA will not have a typical barometric altimeter onboard. 

 However, altitude information of the DJI Phantom 3 UA will be provided to the PIC via Global 

 Positioning System (GPS) equipment and radio communications telemetry data link, which 

 downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude 

 information, combined with Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and

 Aerial Photography & Video Solutions Inc.’s operation of the DJI Phantom 3 within visual line of 

 sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

 Additionally, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. seek an exemption from the requirements of Section 91.151(b), 

 entitled Fuel requirements for flight in VFR conditions. Strumpher Enterprises Inc. dba AmeriSpec 

 Home Inspection Service and Aerial Photography & Video Solutions Inc. submits that safety will not 

 be affected by operation of the DJI Phantom 3 UAS during daylight hours in visual meteorological 

 conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

 duration of approximately 18 minutes to the first point of intended landing and, assuming normal 

 cruising speed, to fly after that for at least 5 minutes. 

 In accordance with 14 C.F.R. § 11.81, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. provides the following information in support 

 of its petition for exemption: 

 A. Name and Address of The Petitioner. 

 The name and address of the Petitioner and point of contact is: 

 Dana L. Strumpher – President 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service 

 35 Twilight Lane 

 Springfield, IL. 62712 

 Phone: 217-529-5354 

 Email: dstrumpher@amerispec.net

 Dana L. Strumpher – President 

 Aerial Photography & Video Solutions Inc. 

 35 Twilight Lane 

 Springfield, IL. 62712 

 Phone: 217-691-8254 

 Email: iknowhomes@comcast.net
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 B. The Specific Sections Of 14 C.F.R. from which Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. Seeks Exemption. 

1. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirements of Section 

61.113(a) And (b). 

 Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections 

 (a) and (b) prescribe the following, in relevant part: 

 (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an 

 aircraft that is carrying passengers or property for compensation or hire; nor may that 

 person, for compensation or hire, act as PIC of an aircraft. 

 (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

 business or employment if— 

 (1) The flight is only incidental to that business or employment; and 

 (2) The aircraft does not carry passengers or property for compensation or hire. 

2. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirements of Section 

91.7(a). 

 Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirements of Section 

91.121. 

 

 Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

 (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

 aircraft, as the case may be, by reference to an altimeter that is set, when operating— 

 (1) Below 18,000 feet MSL, to-- 

 (i) The current reported altimeter setting of a station along the route and within 100 nautical 

 miles of the aircraft; 

 

 (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

 current reported altimeter setting of an appropriate available station; or 

 (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport 

 or an appropriate altimeter setting available before departure. 
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4. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirements of Section 

91.151(b). 

 Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

 following: 

(b) No person may begin 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, to fly after that for at least 20 minutes. 

5. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirement of Section 

91.405(a). 

 Section 91.405, entitled Maintenance required, subsection (a), states the following: 

 Each owner or operator of an aircraft— 

(a) 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[.] 

6. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirements of Section 

91.407(a)(1)

 Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

 alteration, subsection (a)(1), states the following: 

 (a) No person may operate any aircraft that has undergone maintenance, preventive 

 maintenance, rebuilding, or alteration unless— 

(1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter[.] 

7. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirements of Sections 

91.409(a)(1) And 91.409 (a) (2). 

 Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had – 
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(1) An annual inspection in accordance with part 43 of this chapter and has been approved 

 for return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 

of this chapter. 

8. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

Photography & Video Solutions Inc. Seek Exemption from the Requirements of Sections 

91.417(a) And 91.417(b).

 Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include— 

 (i) A description (or reference to data acceptable to the Administrator) of the work 

 performed; and 

 (ii) The date of completion of the work performed; and 

 (iii) The signature, and certificate number of the person approving the aircraft for return 

 to service. 

 

 (2) Records containing the following information: 

 (i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

 (ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

 appliance. 

 (iii) The time since last overhaul of all items installed on the aircraft which are required to 

 be overhauled on a specified time basis. 

 (iv) The current inspection status of the aircraft, including the time since the last 

 inspection required by the inspection program under which the aircraft and its 

 appliances are maintained. 

 (v) The current status of applicable airworthiness directives (AD) and safety directives 

 including, for each, the method of compliance, the AD or safety directive number and 

 revision date. If the AD or safety directive involves recurring action, the time and date 

 when the next action is required. 

 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to 

 the airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 
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(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

 shall be retained until the defects are repaired and the aircraft is approved for return to 

 service. 

 C. The Extent of Relief Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

 Aerial Photography & Video Solutions Inc. Seek and the Reason AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. Seek The Relief. 

 

1. Extent of Relief Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

Aerial Photography & Video Solutions Inc. Seek and the Reason AmeriSpec Home Inspection 

Service and Aerial Photography & Video Solutions Inc. Seek Relief from Section 61.113(a) 

And (b). 

 Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

 command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

 level certificate, as well as a current and valid airman medical certificate, and who has met certain 

 flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

 compensation or hire. 

 This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

 private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

 business or employment if: (1) The flight is only incidental to that business or employment; and (2) 

 The aircraft does not carry passengers or property for compensation or hire. 

 As set forth more fully below, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. submits that an equivalent level of safety 

 will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that 

 PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is able to 

 safely operate either the DJI Phantom 3 UAS in a manner consistent with the operations 

 specifications as described in this exemption, including evasive and emergency maneuvers, as well 

 as maintaining appropriate distances from people, vessels, vehicles and structures. 

 Further, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. Submits that all flights of the DJI Phantom 3 UAS, conducted 

 by the PIC pursuant to the grant of this Petition: (1) will be incidental to Strumpher Enterprises 

 Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc.’s 

 business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent of Relief Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

Aerial Photography & Video Solutions Inc. Seeks and the Reason Strumpher Enterprises Inc. 

dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Seek 

Relief From Section 91.7(a). 
11 

 Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

 required to allow Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. to determine that the DJI Phantom 3 UAS is in airworthy 

 condition prior to every flight by Ensuring that the UAS is in compliance with the operating 

 documents (i.e., the Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI 

 Phantom 3 Instruction Manual). 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. seek the requested relief because the DJI Phantom 3 UAS does not require an 

 airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Strumpher 

 Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions 

 Inc. will ensure that the DJI Phantom 3 UAS is in airworthy condition based upon its compliance with 

 the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) 

 prior to every flight, and further, determine that the aircraft is in condition for safe flight, as stated 

 in the conditions and limitations below. 

3. Extent of Relief Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

Aerial Photography & Video Solutions Inc. Seeks and the Reason Strumpher Enterprises Inc. 

dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. 

Seeks Relief From Section 91.121. 

 Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

 Operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS equipment, 

 and a radio communications telemetry data link to downlink altitude information from the UA to 

 the PIC at the ground control station (GCS). Since the FAA requires that any altitude information 

 concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

 (AGL), Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. seeks the requested relief because the DJI Phantom 3 UAS altimeter may be set 

 on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before 

 each flight. 

 Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

 sought to the extent necessary to comply with the applicable conditions and limitations stated 

 below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI 

 Phantom 3 UAS is equipped with a barometric pressure sensor and GPS equipment, which 

 automatically ensures that a ground level pressure setting will be established prior to each flight, 

 and provides the PIC with altitude information o UA on the heads-up display of the GCS. 

4. Extent of Relief Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

Aerial Photography & Video Solutions Inc. Seeks and the reason Strumpher Enterprises Inc. 

dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. 

Seeks Relief from Section 91.151(b). 
12 

 Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

 requested to the extent required to allow flights of the battery powered DJI Phantom 3 UA during 

 daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

 duration of 18 minutes to the first point of intended landing and, assuming normal cruising speed, 

 to fly after that for at least 5 minutes. Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. seeks the requested relief because without an 

 exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 

 UAS will severely constrain the practicality of any aerial video or still photo flight operations that 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video

 Solutions Inc. propose to conduct pursuant to this Petition. 

 Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, the DJI 

 Phantom 3 operating documents, and Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. proposed operating limitations, ensure that 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video

 Solutions Inc. will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in 

 visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power 

 to fly for a total duration of 18 minutes to the first point of Intended landing and, assuming normal 

 cruising speed, to fly after that for at least 5 minutes. 

5. Extent of Relief Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

Aerial Photography & Video Solutions Inc. and the Reason Strumpher Enterprises Inc. 

AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Seeks Relief 

From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

 Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

 aircraft with an airworthiness certificate, Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. requests relief from these Sections 

 because the DJI Phantom 3 UAS does not require airworthiness certificates. As set forth more fully 

 below, the DJI Phantom 3 UAS meets the conditions of FMRA Section 333 for operation without an 

 airworthiness certificate. Accordingly, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. will use trained technicians to perform 

 maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

 and practices prescribed in the UAS operating documents (i.e., the Strumpher Enterprises Inc. dba 

 AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. Aerial Operations 

 Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video

 Solutions Inc. will document and maintain all maintenance records for the DJI Phantom 3 UAS. 

 D. The Reasons Why Granting Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service 

 and Aerial Photography & Video Solutions Inc. Request Would Be In The Public Interest; That 

 Is, How It Would Benefit The Public As A Whole. 
13 

 Granting the present Petition will further the public interest by allowing the Strumpher 

 Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions 

 Inc. to safely, efficiently, and economically perform aerial video and photography for real estate, 

 special private events, and landscape over certain areas of the United States. 

 Additionally, use of the DJI Phantom 3 and UAS will decrease congestion of the NAS, reduce

 pollution, and provide significant benefits to the economy. Notably, the benefits of Strumpher 

 Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions 

 Inc. proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy 

 issues. 

 1. The Public Will Benefit From Decreased Congestion Of The NAS. 

 The DJI Phantom 3 UAS is battery powered and serves as a safe, efficient, and economical 

 alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the 

 amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a 

 DJI Phantom 3 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

 pollution, as well as increase the safety of life and property in the air and on the ground. 

 Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around 

 airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 UAS does not 

 require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video 

 and photography missions would result in fewer aircraft that must be handled by air traffic control 

 during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 UAS. 

 Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will 

 Greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

 during traditional aerial video and still photography flight operations. By using battery power and 

 Electric motors, the DJI Phantom 3 UAS produces no air pollution, and is the most viable 

 Environmentally conscious alternative to the cabin class, internal combustion engine aircraft that are 

 typically utilized for aerial video and photography, while burning approximately 20-30 gallons per 

 hour of leaded aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial 

 acquisitions, also eliminates noise pollution, as the UAS is propelled by battery powered electric 

 motors, rather than an internal combustion engine. 

 By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and 

 property in the air and on the ground, which is usually associated with traditional manned aircraft 

 flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight 

 crew members located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 2 

 pounds 13 ounces at its maximum gross weight with lengths of 15 inches by 15 inches, and with no

 fuel on board), has less physical potential for collateral damage to life and property on the ground, 

 and in the air, compared to the manned aircraft that typically conduct similar operations (weighing 

 approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel 

 capacity of 180 gallons). 
14 

3. Performing Aerial Video and Photography Operations with the DJI Phantom 3 UAS Will 

 Benefit The Economy. 

 In addition to being safe and efficient, the DJI Phantom 3 UAS is also an economical alternative to 

 using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 

 UAS will allow United States based companies, like Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. to remain competitive and 

 contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

 Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

 owned and operated companies must adopt new and alternative technology in order to remain 

 competitive. Operating the battery powered DJI Phantom 3 UAS is one such technology that not only

 allows companies greater operational flexibility compared to manned aircraft, but provides such 

 flexibility without the high operational cost of a traditional manned aircraft. 

 By operating the DJI Phantom 3 UAS, companies such as Strumpher Enterprises Inc. dba 

 AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. can remain 

 competitive and profitable, and therefore, provide greater job stability to employees and contractors, 

 which will ultimately contribute to growth of the U.S. economy. Improved financial performance of 

 U.S. companies, through commercial use of the DJI Phantom 3 UAS, provides a stable workforce that

 increases consumer spending; improves local, state, and federal tax revenues; and allows companies 

 to invest in research and development in order to remain competitive both in the United States and 

 abroad. 

 4. There Are No Privacy Issues. 

 Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video

 Solutions Inc.’s proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues. 

 Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents 

 (i.e., the Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography 

 & Video Solutions Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

 Instruction Manual) which requires property owner involvement as well as local law enforcement 

 notification, and in accordance with the Federal Aviation Regulations, including the minimum 

 altitude requirements of 14 C.F.R. § 91.119.

 

 E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

 Exemption Would Provide A Level of Safety At Least Equal To That Provided By The Rule From

 which Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 UA Meets The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333. 

 In consideration of the size, weight, speed, and limited operating area associated with the 

 unmanned aircraft and its operation, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 
15 

 Service and Aerial Photography & Video Solutions Inc. operation of the DJI Phantom 3 UAS meets 

 the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance 

 with 14 C.F.R. Part 21, Subpart H. 

 

 Section 333 provides authority for a UAS to operate without airworthiness certification and 

 sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or 

 the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

 following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

 subsection (a), the secretary shall determine, at a minimum 

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1). 

 

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft systems in 

the national airspace system. 

 In seeking this exemption, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service 

 and Aerial Photography & Video Solutions Inc. submits that the DJI Phantom 3 UAS can operate 

 safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the 

 DJI Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations. 

 a. The Specifications Of The DJI Phantom 3 UAS Demonstrates Its Safe Characteristics. 

 The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the public, or otherwise 

 pose a threat to national security considering its size, weight, speed, and operational capability. 
16 

i. Technical Specifications Of The DJI Phantom 3 UAS 

 The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 

 Specifications and Safety Data Sheet, attached hereto as Exhibit A. 

 

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable the UASs To 

Remain Within A Defined Operational Area. 

 The DJI Phantom 3 UAS may be operated in both manual and fully autonomous flight modes. A 

 complete description of the flight and navigational modes of the DJI Phantom 3 UAS is provided at 

 pages 11-17 of the DJI Phantom 3 User Manual, attached hereto as Exhibit B. 

iii. The DJI Phantom 3 UAS is Designed For Automatic Return To Home Point Or Hover In The 

Event of Loss of The Control Link Or Navigation. 

 When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3 

 seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS does not reacquire control link data 

 from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home 

 position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 

 A complete description of the Failsafe Functions of the DJI Phantom 3 UAS is set forth at pages 12 

 through 15 of the DJI Phantom 3 User Manual, attached hereto as Exhibit B. 

iv. The DJI Phantom 3 GCS And Its Operation. 

 A complete description of the operation and specifications of the DJI Phantom 3 GCS and flight 

 control software is provided at pages 23 through 38 of the DJI Phantom 3 User Manual. The DJI 

 Phantom 3 User Manual is attached hereto as Exhibits B. 

 b. Flight Operations Of DJI Phantom 3 UAS is Limited To The Line Of Sight Of A Certificated 

 Pilot in Command With A Safety Observer. 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. will only utilize certificated pilots who possess a current and valid airman 

 medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 UAS. Additionally, a 

 safety observer will assist all pilots during flight time. 

 c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

 In seeking this exemption, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service 

 and Aerial Photography Video & Solutions Inc. proposes to commercially operate DJI Phantom 3 

 UAS for the special purpose of conducting aerial video and photography over certain areas of 

 United States, pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft 
17 

 described in the operating documents, rotorcraft UAS weighing less than 55 pounds 

 maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed 

 operations of any other aircraft will require a new petition or a petition to amend this 

 grant. 

2. UAS operations under this exemption will be limited to conducting operations for the 

 purpose of aerial video and photography. 

 3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

 4. The UAS must be operated at an altitude of no more than 500 feet above ground 

 level (AGL), as indicated by the procedures specified in the operating documents unless a 

 special request is made and approved by ATC. All altitudes reported to ATC must be in 

 feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

 requires the PIC to be able to use human vision unaided by any device other than 

 corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

 6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

 requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be 

 able to communicate verbally at all times. Electronic messaging or texting is not 

 permitted during flight operations. The PIC must be designated before the flight and 

 cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

 that the SO can perform the functions prescribed in the operating documents. 

9. The SO must not perform any other duties beyond assisting the PIC with seeing and 

 avoiding other air traffic and other ground based obstacles/obstructions and is not 

 permitted to operate the camera or other instruments. 

10. The operating documents and the grant of exemption must be accessible during UAS 

 operations and made available to the Administrator upon request. If a discrepancy exists 

 between the conditions and limitations contained in the grant of exemption and the 

 procedures outlined in the operating documents, the conditions and limitations contained 

 in the grant of exemption take precedence and must be followed. Otherwise, the 

 operator must follow the procedures as outlined in its operating documents. The operator 

 may update or revise its operating documents. It is the operator’s responsibility to track 

 such revisions and present updated and revised documents to the Administrator upon 

 request. The operator must also present updated and revised documents if it petitions for 

 extension or amendment to the grant of exemption. If the operator determines that any 

 update or revision would affect the basis upon which the FAA granted the exemption, 

 then the operator must petition for amendment to its grant of exemption. The FAA’s UAS 

 Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

 revisions to the operating documents. 

11. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe 

 flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

 aircraft is prohibited from operating until the necessary maintenance has been performed 
18 

and the UAS is found to be in a condition for safe flight. The Ground Control Station must 

be included in the preflight inspection. All maintenance and alterations must be properly 

 documented in the aircraft records. 

12. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry in 

the aircraft records. 

13. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

14. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

15. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UAS to service. 

16. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

17. The authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections. 

18. The PIC must possess at least a private pilot certificate and at least a current third- class 

medical certificate. 

19. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. §61.51(b). Flights for the purposes of training the operator’s PICs 

are permitted under the terms of the exemption. However, training operations may 

only be conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 C.F.R. § 91.119. 

20. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed area 

of operations. Flights under special visual flight rules (SVFR) are not authorized. 

21. The UAS may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that 

airport’s management is obtained, and the operation is conducted in accordance with a 
19 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

22. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

23. If the UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

24. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

25. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing 

point and land the UA with 25% battery power remaining. 

26. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 

72 hours in advance, but not less than 48 hours prior to the operation. All operations shall 

be conducted in accordance with airspace requirements in the ATO issued COA including 

class of airspace, altitude level and potential transponder requirements. 

27. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) 

markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as 

practicable. 

28. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAS must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

29. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC 

at the Ground Control Station of the UAS any time the UAS is operating. These documents 

must be made available to the Administrator or any law enforcement official upon request. 

30. The UAS must remain clear and yield the right of way to all manned aviation operations 

and activities at all times. 

 31. The UAS may not be operated by the PIC from any moving device or vehicle. 

 32. Flight operations must be conducted at least 500 feet from all nonparticipating persons 

 (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, 

 and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

 of such vessels, vehicles or structures has granted permission and the PIC has made a 

 safety assessment of the risk of operating closer to those objects and determined that it 
20 

 does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a). 

33. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

 land owner/controller or authorized representative will be obtained for each flight to be 

 conducted. 

34. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported to 

 the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to 

 the National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

 Web site: www.ntsb.gov. 

 2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

 And (b) Would Not Adversely Affect Safety. 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. submits that the equivalent level of safety established by Section 61.113(a) and 

 will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC 

 has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able 

 to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including 

 evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

 vehicles and structures. 

 Considering Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. proposed area of operations, and the operating limitations set 

 forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

 commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

 safely operate the DJI Phantom 3 UAS, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection

 Service and Aerial Photography & Video Solutions Inc. submits that the additional manned 

 airmanship experience of a commercially certificated pilot would not correlate to the airmanship 

 skills necessary for Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography Video Solutions Inc.’s specific proposed flight operations. 

 The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

 circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

 11153, 11156, 11158, 11159, 11160, 11161). 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has 

 demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3 UAS training 

 and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a 
21 

 manner consistent with this exemption, including evasive and emergency maneuvers and 

 maintaining appropriate distances from people, vessels, vehicles and structures. 

 Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours 

 as a UAS pilot operating the same make and model of UAS to be used for operations under the 

 exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings 

 in the preceding 90 days (for currency purposes). 

 As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

 obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video 

 Solutions Inc. proposed operations. The Administrator has held that prior documented flight 

 experience that was obtained in compliance with applicable regulations would ensure safe 

 operations, stating as follows: 

 In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of 

 motion picture filming (or similar operations), the PIC must have accumulated and logged, in a

 manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

 least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption 

 No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

 operating the same make and model of UAS to be used for operations under the exemption. For 

 clarification, the FAA considers these minimum hour requirements to be inclusive rather than 

 additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time

 and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the 

 hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

 currency purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption

 No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely 

 conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight 

 experience that was obtained in compliance with applicable regulations would satisfy this 

 requirement. Training, proficiency, and experience-building flights can also be conducted under 

 the grant of exemption to accomplish the required flight time. During training, proficiency, and 

 experience-building flights the PIC is required to operate the UA with appropriate distances in 

 accordance with 14 C.F.R 91.119. 

 

 Exemption No. 11138. 

 Accordingly, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. will ensure safe operations by not allowing any PIC to operate 

 the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

 currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner 

 consistent with the exemption, including evasive and emergency maneuvers and maintaining 

 appropriate distances from people, vessels, vehicles and structures. 
22 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

 The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

 every flight, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. will ensure that the DJI Phantom 3 UAS is in an airworthy 

 condition based upon the UAS’s compliance with its operating documents and as stated in the 

 conditions and limitations herein. 

 

 Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

 circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

 The equivalent level of safety established by Section 91.121 will be maintained because the

 altitude information of the DJI Phantom 3 UAS will be provided to the PIC via GPS equipment and a 

 radio communications telemetry data link, which downlinks from the UA to the GCS for active 

 monitoring of the flight path and altitude. This altitude information, combined with Strumpher

 Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions 

 Inc.’s operation of the DJI Phantom 3 UAS within visual line of sight, at or below 500 feet AGL, will 

 Ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by 

 GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

 automatically established by the UAS at ground level. 

 The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances

 similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

 11158, 11159, 11160, 11161). 

 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

 A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

 Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) the 

 limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

 Accordingly, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. will ensure that it will safely operate the battery powered DJI 

 Phantom 3 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total 

 duration of 18 minutes to the first point of intended landing and, assuming normal Cruising speed, 

 to fly after that for at least 5 minutes. 
23 

 Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 UAS; the

 limitations on the proposed flight operations; and the location of the proposed operations, will 

 ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety 

 will be ensured as the DJI Phantom 3 UAS provides audible and visual warnings to the PIC at the 

 GCS when the UAS experiences low battery voltage, the first warning occurring at approximately

 33% remaining battery power, and again at approximately 10% remaining battery power. At the 

 critically low battery level, the DJI Phantom 3 UAS will descend and land automatically. 

 Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

 safety is not adversely affected when the technical characteristics and operating limitations of the 

 UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

 minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

 Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

 circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety. 

 In seeking this exemption, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

 Aerial Photography & Video Solutions Inc. submits that the equivalent level of safety with regard to 

 the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because, Strumpher Enterprises 

 Inc. AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will use 

 trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS 

 using the methods, techniques, and practices prescribed in the operating documents (i.e., the 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video 

 Solutions Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction 

 Manual). Furthermore, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and 

 Aerial Photography & Video Solutions Inc. will document and maintain all maintenance records for 

 the DJI Phantom 3 UAS. 

 Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video 

 Solutions Inc. will maintain the equivalent level of safety established by Sections 91.405(a),

 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manual is attached hereto as 

 Exhibit B; a copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as Exhibit C. 

 Likewise, the exemption sought will not adversely affect safety because Strumpher Enterprises 

 Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc. will use 

 trained technicians to perform maintenance, alterations or preventive maintenance on the UAS 

 using the methods, techniques, and practices prescribed by the operating documents. 

 Furthermore, the exemption sought would maintain an equivalent level of safety established by 
24 

 Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS will be 

 performed by trained technicians. Maintenance will be documented and maintained utilizing the 

 monthly maintenance log. 

 Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 

 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

 technical characteristics and operating limitations of the UAS are considered. 

 In consideration of Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. proposed operating limitations, the operating documents, and 

 the technical aspects of the DJI Phantom 3 UAS, Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. submits that safety will not be 

 adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

 circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

 7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

 

 In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 

 14C.F.R. § 21.16 entitled Special Conditions, Strumpher Enterprises Inc. dba AmeriSpec Home 

 Inspection Service and Aerial Photography & Video Solutions Inc. requests that the FAA prescribe 

 special conditions for the intended operation of the DJI Phantom 3 UAS, which contain such safety 

 standards that the Administrator finds necessary to establish a level of safety equivalent to that 

 established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special 

 conditions will permit safe operation of the UAS for the limited purpose of conducting aerial video 

 and photography over certain areas of the United States for compensation or hire. FMRA Section

 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the 

 NAS or the public, or otherwise pose a threat to national security; and further, provides the 

 authority for such UAS to operate without airworthiness certification in accordance with any 

 requirements that must be established for the safe operation of the UAS in the NAS. 

 Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

 operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not 

 contain adequate or appropriate safety standards, due to the novel or unusual design features of 

 the aircraft. Section 21.16, entitled Special Conditions, states the following: 

 If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

 appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 

 unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special 

 conditions and amendments thereto for the product. The special conditions are issued in 

 accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft 

 engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that 
25 

 established in the regulations. 

 

 See 14 C.F.R. § 21.16. 

 Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe 

 special conditions for Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. intended operation of the DJI Phantom 3 UAS, which contain 

 such safety standards that the Administrator finds necessary to establish a level of safety equivalent 

 to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

 F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Seeks Exemption: 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & 

 Video Solutions Inc. seek exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 

 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)& (a)(2), and 91.417(a) & (b). 

 

 A Brief Description Of The Nature Of The Exemption Strumpher Enterprises Inc. dba AmeriSpec

 Home Inspection Service and Aerial Photography & Video Solutions Inc. Seeks: 

 This exemption will permit Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service

 and Aerial Photography & Video Solutions Inc. to commercially operate an Unmanned Aircraft 

 System (UAS) for the purpose of conducting aerial video and photography over certain areas of 

 the United States. 

 G. Any Additional Information, Views, Or Arguments Available To Support Strumpher Enterprises 

 Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video Solutions Inc.’s 

 Request. 

 This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 

 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in 

 the NAS. As such, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solution’s Inc. request for exemption may be granted pursuant to the 

 authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. 

 FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard 

 to users of the NAS or the public, or otherwise pose a threat to national security; and further, 

 provides the authority for such UAS to operate without airworthiness certification. 

 As discussed in detail above, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service 

 and Aerial Photography & Video Solutions Inc. will operate the DJI Phantom 3 UAS safely in the NAS, 

 without creating a hazard to users of the NAS or the public, or otherwise pose a threat to national 

 security. 
26 

CONCLUSION 

 As set forth herein, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial 

 Photography & Video Solutions Inc. seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of 

 the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the limited purpose 

 of conducting aerial video and photography over certain areas of the United States. By granting this 

 Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

 Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography & Video 

 Solutions to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially 

 within the NAS. 

 WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and 

 Reform Act of 2012, Section 333, Strumpher Enterprises Inc. dba AmeriSpec Home Inspection 

 Service and Aerial Photography & Video Solutions Inc. respectfully requests that the Administrator 

 grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 

 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and 

 permit Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service and Aerial Photography

 & Video Solutions Inc. to operate the DJI Phantom 3 UAS commercially for the purpose of 

 conducting aerial video and photography over certain areas of the United States. 

 Dated: December 18, 2015 

 Dana L. Strumpher – President 

 Strumpher Enterprises Inc. dba AmeriSpec Home Inspection Service 

 35 Twilight Lane 

 Springfield, IL. 62712 

 Phone: 217-529-5354 

 Email: dstrumpher@amerispec.net

 Dana L. Strumpher – President 

 Aerial Photography & Video Solutions Inc. 

 35 Twilight Lane 

 Springfield, IL. 62712 

 Phone: 217-691-8254 

 Email: iknowhomes@comcast.net

 

 

 
27 

EXHIBITS INCLUDED: 

 A – DJI Phantom 3 Safety Guideline Sheet 

 B – DJI Phantom 3 Manufacturer’s User Manual 

 C – Monthly Maintenance Log