January 4, 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: F3EA Exemption Request to Operate an Unmanned Aircraft System Pursuant 

to Section 333 of the FAA Modernization and Reform Act of 2012 and Part 11 of the 

Federal Aviation Regulations from 14 C.F.R. 

To whom it may concern, 

Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 

C.F.R. Part 11, F3EA hereby applies for an exemption from the Federal Aviation 

Regulations (F ARs) identified below to allow for the commercial operation of small 

Unmanned Aircraft Systems (sUAS) for aerial data collection. The data will be used in 

support of providing a high-quality videography system to commercial and governmental 

organizations. F3EA will provide these services for military training, marketing, 

structural inspection, economic development, survey, and agriculture. F3EA employs 

current and former US Army Aviators and has developed a sUAS flight standardization 

program modeled after US Army aviation standardization programs. 

The name and address of the applicant: 

F3EA, Inc. 

Attn: Bryan C. Madden, Phone 208-890-2937 

Email: bmadden@F3EA.com 

Address: 10 Turnbull Lane, Savannah, GA, 31410 

The specific section or sections that F3EA, LLC seeks an exemption from: 

• 14 CFR § § 61.23 (a) and (c) 

• 61.101 (e)(4) and (5) 

• 61.113 (a) 

• 61.315 (a) 

• 91.7 (a) 

• 91.119 (c) 

• 91.121 

• 91.151 (a)(1) 

• 91.405 (a) 

• 91.407 (a)(l) 

• 91.409 (a)(l) and (2) 
• 91.417 (a) and (b) 

Information Regarding the UAS 

F3EA Inc. operates a DJI Phantom 3 and the DJI Inspire 111 Pro. F3EA Inc. adheres to 

the Inspire 1 User Manual, Inspire 1 Maintenance Manual, Inspire 1 Safety Guidelines, 

and Intelligent Flight Battery Safety Guidelines. The current version of the Inspire 1 

documents are available on the DJI website at http://www.dji.com/product/inspire1/download. F3EA Inc. adheres to the DJI Phantom 3 User Manual, Phantom 3 

Maintenance Manual, and Phantom 3 Safety Guidelines. The current version of the 

Phantom 3 documents are available on the DJI website at 

http ://www.dj i.com/product/phantom-3 -pro/info#downloads. These operating documents 

are accessible during UAS operations and F3EA verifies document currency prior to 

operation. F3EA procedures for preflight, inspections, maintenance, and repair come 

directly from the DJI operating documents. 

The DJI Phantom 3 has the following flight and safety features: 

• Phantom 3 is a U AS Quadcopter made by DJI that has a fixed gimbal and camera 

attached to the bottom. Phantom 3 has a maximum weight of2.82lbs. (1280 

grams), and a maximum range of 2000m. 

• 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. 

• DJI Phantom 3 is limited to a maximum assent rate of 5 m/s and has a maximum 

decent rate of3 m/s. It also has a limitation of maximum speed of 16 m/s. 

• The Inspire 1 will be operated with a 4480maH lithium polymer battery allowing 

for flight times not to exceed 23 minutes. 

The DJI Inspire 1 has the following flight and safety features: 

• Inspire 1 is a U AS Quadcopter made by DJI that has a fixed gimbal and camera 

attached to the bottom. Inspire 1 has a maximum weight of 6.47lb. (2965 grams), 

and a maximum range of 2000m. 

• Inspire 1 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 ofthe 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 U AS utilizing an Apple 

iPad Air. 
• DJI Inspire 1 is limited to a maximum assent rate of 5 m/s and has a maximum 

decent rate of 4 m/s. It also has a limitation of maximum speed of 22 m/s or 49 

mph. 

• The Inspire 1 will be operated with a 5700maH lithium polymer battery allowing 

for flight times not to exceed 22 minutes. 

Information Regarding the UAS PIC 

F3EA's UAS PICs hold an airline transport, commercial, private, recreational, or sport 

pilot certificate. The PIC will meet the flight review requirements specified in 14 CFR § 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. F3EA will not 

permit any PIC to operate unless the PIC demonstrates the ability to safely operate the 

UAS. PIC qualification flight hours and currency will be logged in a manner consistent 

with 14 CFR § 61.51(b). 

F3EA will utilize a visual observer (VO) and will operate the UAS within visual line of 

sight (VLOS) of the PIC and VO at all times. The PIC and VO will maintain the ability to 

communicate at all times, excluding the use of electronic messaging or texting. 

Information Regarding the Operation of the UAS 

F3EA's UAS operations will be conducted in Class G airspace at altitudes of 400 feet and 

below, not to exceed 87 knots. F3EA will use geo-fencing as the means to control the 

area of operations, a PIC in visual line of sight of the UAS, and a visual observer within 

constant visual line of sight of the UAS. The specific area of operations for each flight 

will be limited to the property boundaries of the property being filmed and a safety 

survey is conducted by the PIC and VO prior to all flight operations. When the property 

boundary is in close proximity to outside structures or personnel, a no-fly area is 

established through geo-fencing and flight operations will not be conducted any closer 

than 500 feet unless permission has been granted by the non-participating owner or 

controller. In the event of a loss of communication with the UAS, the UA returns to a 

pre-determined location within the private or controlled-access property. F3EA UAS 

operations always remain clear and give way to manned aviation operations at all times. 

The DJI Inspire operates on 5.725-5.825 GHz and 2.400-2.483 GHz and complies with 

the Federal Communications Commission. 

F3EA will provide commercial sUAS services to support commercial and real estate 

photography and videography. This provides a significant reduction in cost and 

improvement in safety to the public. In addition, F3EA will provide structural inspection 

services that reduces fall risk to personnel. Finally, F3EA will provide ISR support for 

military and law enforcement training with the sUAS. This will enhance the training and 

readiness of those personnel. 

Extent of Relief and Equivalent Level of Safety for Exemptions Requested 

14 CFR § § 61.23 (a) and (c) 

F3EA, Inc. seeks exemption from this regulation that outlines the medical 

certificate requirements and duration, including the operations that require a medical 

certificate (a) and operations requiring either a medical certificate or U.S. driver's license 

(b). 
• Extent of Relief: F3EA seeks the ability for the sUAS PIC to hold a current FAA 

airmen medical certificate or a valid U.S. driver's license issued by a state, the 

District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. 

• Equivalent Level of Safety: The equivalent level of safety is met in the extent of 

relief requested. The PIC will have a current FAA airman medical certificate or a 

valid U.S. driver's license. 

§ 61.101 (e)(4) and (5) 

F3EA, Inc. seeks exemption from the regulation that prohibits a recreational pilot 

from acting a pilot in command of an aircraft used for compensation or hire, or in 

furtherance of a business. 

• Extent of Relief: F3EA seeks the ability for employees qualified as recreational 

pilots to operate the UAS for compensation. 

• Equivalent Level of Safety: The UAS PIC will hold an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate. F3EA will not permit any PIC to 

operate unless the PIC demonstrates the ability to safely operate the UAS. PIC 

qualification flight hours and currency will be logged in a manner consistent with 

14 CFR § 61.51(b). During training, proficiency, and experience-building flights, 

all persons not essential for flight operations will be no closer than 500 feet from 

flight operations. 

§ 61.113 (a) 

F3EA, Inc. seeks exemption from the regulation that prohibits a private pilot to 

act a pilot in command for compensation or hire. 

• Extent of Relief: F3EA seeks the ability for employees qualified as private pilots 

to operate the UAS for compensation. 

• Equivalent Level of Safety: The UAS PIC will hold an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will meet the 

flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate. F3EA will not permit any PIC to 

operate unless the PIC demonstrates the ability to safely operate the UAS. PIC 

qualification flight hours and currency will be logged in a manner consistent with 

14 CFR § 61.51(b). During training, proficiency, and experience-building flights, 

all persons not essential for flight operations will be no closer than 500 feet from 

flight operations. 

§ 61.315 (a) 

F3EA, Inc. seeks exemption from the regulation that prohibits a sport pilot from 

acting as pilot in command of an aircraft used for compensation or hire. 

• Extent of Relief: F3EA seeks the ability for employees qualified as sport pilots to 

operate the UAS for compensation. 

• Equivalent Level of Safety: The UAS PIC will hold an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC will meet the 
flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the 

PIC is rated on his or her pilot certificate. F3EA will not permit any PIC to 

operate unless the PIC demonstrates the ability to safely operate the UAS. PIC 

qualification flight hours and currency will be logged in a manner consistent with 

14 CFR § 61.51(b). During training, proficiency, and experience-building flights, 

all persons not essential for flight operations will be no closer than 500 feet from 

flight operations. 

§ 91.7 (a) 

F3EA, Inc. seeks exemption from the regulation that restricts operation of civil 

aircraft unless it is an airworthy condition. 

• Extent of Relief: F3EA seeks relief from obtaining an airworthiness certification 

for the UAS. 

• Equivalent Level of Safety: F3EA will be responsible for maintaining and 

inspecting the UAS to ensure that it is in a condition for safe operation. Prior to 

each flight, the PIC will conduct a pre-flight inspection and determine if the UAS 

is in a condition for safe flight. F3EA will follow the UAS manufacturer's 

maintenance, overhaul, replacement, inspection, and life limit requirements for 

the aircraft and aircraft components. F3EA will comply with all manufacturer 

safety bulletins. F3EA will conduct a functional test flight after any maintenance 

or alterations to the UAS that affect the operation or flight characteristics. The 

functional test flight will be conducted by the PIC and VO, will remain at least 

500 feet from other people, and will be conducted in such a manner so as to not 

pose an undue hazard to persons and property. 

§ 91.119 (c) 

F3EA, Inc. seeks exemption from the regulation that requires operation over other 

than congested areas, except for takeoff and landing, to an altitude no lower that 500 feet 

above the surface and no closer than 500 feet to any person, vessel, vehicle, or structure. 

• Extent of Relief: F3EA requests to operate at an altitude of no more than 400 feet 

above ground level (reported in feet AGL). 

• Equivalent Level of Safety: F3EA will utilize a visual observer (VO) and will 

operate within visual line of sight (VLOS) ofthe PIC and VO at all times. The 

PIC and VO will maintain the ability to communicate at all times, excluding the 

use of electronic messaging or texting. The UAS will only be operate during Day 

VMC conditions (no SVFR). F3EA will not operate the UAS unless a minimum 

cloud clearance of 500' below or 2,000' horizontally and 3 statute miles visibility 

can be maintained from the PIC. F3EA will not operate within 5 nautical miles of 

an airport reference point denoted in the current FAA Airport/Facility Directory. 

The flight will be aborted in the event ofunpredicted obstacles or emergencies. 

§ 91.121 

F3EA, Inc. seeks exemption from the regulation that requires the use of an 

altimeter to maintain a cruising altitude or flight level. 

• Extent of Relief: The F3EA requests full relief from the use of an altimeter and 

associated altitude requirements. 
• Equivalent Level of Safety: F3EA flight operations will be conducted at an 

altitude of no more than 400 feet above ground level (reported in feet AGL) 

utilizing the onboard GPS altitude reading. F3EA will utilize a visual observer 

(VO) and will operate within visual line of sight (VLOS) of the PIC and VO at all 

times. The PIC and VO will maintain the ability to communicate at all times, 

excluding the use of electronic messaging or texting. The UAS will only be 

operate during Day VMC conditions (no SVFR). F3EA will not operate the UAS 

unless a minimum cloud clearance of 500' below or 2,000' horizontally and 3 

statute miles visibility can be maintained from the PIC. The flight will be aborted 

in the event ofunpredicted obstacles or emergencies. F3EA will not operate the 

UAS within 5 nautical miles of an airport unless permitted by a CO A. 

§ 91.151 (a)(1) 

F3EA, Inc. seeks exemption from the regulation that requires a 30 minute fuel 

reserve beyond the intended point of landing for day VFR operations. 

• Extent of Relief: F3EA seeks full relieffrom the 30 minute fuel reserve 

requirement. 

• Equivalent Level of Safety: The F3EA PIC will not conduct the flight unless 

there is enough power available for the UAS to conduct the intended operation 

and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer. 

§ 91.405 (a) 

F3EA, Inc. seeks exemption from the regulation that requires prescribed 

inspections and repairs lAW part 43 of Chapter I. 

• Extent of Relief: F3EA seeks full relief from the inspection and repair 

requirements. 

• Equivalent Level of Safety: F3EA will be responsible for maintaining and 

inspecting the UAS to ensure that it is in a condition for safe operation. Prior to 

each flight, the PIC will conduct a pre-flight inspection and determine if the UAS 

is in a condition for safe flight. F3EA will follow the UAS manufacturer's 

maintenance, overhaul, replacement, inspection, and life limit requirements for 

the aircraft and aircraft components. F3EA will comply with all manufacturer 

safety bulletins. F3EA will conduct a functional test flight after any maintenance 

or alterations to the UAS that affect the operation or flight characteristics. The 

functional test flight will be conducted by the PIC and VO, will remain at least 

500 feet from other people, and will be conducted in such a manner so as to not 

pose an undue hazard to persons and property. 

§ 91.407 (a)(1) 

F3EA, Inc. seeks exemption from the regulation that restricts operation of the 

aircraft after maintenance, preventative maintenance, rebuilding, or alteration unless it 

has been approved for return to service by a person authorized under chapter I of §43.7. 

• Extent of Relief: F3EA seeks full relief from obtaining approval from an 

authorized person under chapter I of §43.7 to approve the UAS for return to flight. 
• Equivalent Level of Safety: F3EA will be responsible for maintaining and 

inspecting the U AS to ensure that it is in a condition for safe operation. Prior to 

each flight, the PIC will conduct a pre-flight inspection and determine if the UAS 

is in a condition for safe flight. F3EA will follow the UAS manufacturer's 

maintenance, overhaul, replacement, inspection, and life limit requirements for 

the aircraft and aircraft components. F3EA will comply with all manufacturer 

safety bulletins. F3EA will conduct a functional test flight after any maintenance 

or alterations to the UAS that affect the operation or flight characteristics. The 

functional test flight will be conducted by the PIC and VO, will remain at least 

500 feet from other people, and will be conducted in such a manner so as to not 

pose an undue hazard to persons and property. 

§ 91.409 (a)(l) and (2) 

F3EA, Inc. seeks exemption from the regulation that requires an annual inspection 

and an issuance of airworthiness certificate to operate an aircraft. 

• Extent of Relief: F3EA seeks full relieffrom the annual inspection and 

airworthiness certificate requirements. 

• Equivalent Level of Safety: F3EA will be responsible for maintaining and 

inspecting the UAS to ensure that it is in a condition for safe operation. Prior to 

each flight, the PIC will conduct a pre-flight inspection and determine if the UAS 

is in a condition for safe flight. F3EA will follow the UAS manufacturer's 

maintenance, overhaul, replacement, inspection, and life limit requirements for 

the aircraft and aircraft components. F3EA will comply with all manufacturer 

safety bulletins. F3EA will conduct a functional test flight after any maintenance 

or alterations to the UAS that affect the operation or flight characteristics. The 

functional test flight will be conducted by the PIC and VO, will remain at least 

500 feet from other people, and will be conducted in such a manner so as to not 

pose an undue hazard to persons and property. 

Benefit to the Public as a Whole 

F3EA's use of a UAS to obtain aerial imagery is a safe alternative to larger manned 

aircraft, which can cause great damage and loss of life in the event of an accident. F3EA 

utilizes a U AS that does not use flammable fuel. In addition, the use of aerial imagery to 

advertise commercial and residential property promotes economic growth in the 

community by enhancing a marketer's ability in providing a unique perspective to 

potential buyers. Finally, F3EA is a company that is operating a UAS for commercial 

purposes legally in the national airspace system. The PICs for F3EA are military trained 

rotary wing aviators, ,who have a perfect track record of aviation operations and strictly 

adhere to safety protocols in the National Airspace System. · 

Summary for publication in the Federal Register 

"F3EA, Inc seeks an exemption from the following rules for the commercial operation of 

a small unmanned aerial system: 14 CFR § § 61.23 (a) and (c), 61.101 (e)(4) and (5), 

61.113 (a), 61.315 (a), 91.7 (a), 91.119 (c), 91.121,91.151 (a)(1), 91.405 (a), 91.407 

(a)(l), 91.409 (a)(1) and (2), 91.417 (a) and (b). Exemption from these regulations would 

allow F3EA, Inc to operate small unmanned aerial vehicles (55 pound or less) in areas 
with limited and controlled access for the purpose of providing high-resolution aerial 

imagery." 

Please contact Bryan Madden at 208-890-2937 or bmadden@F3EA.com with any 

questions or requests for additional information. Thank you for the consideration of our 

exemption to safely and legally operate our UAS. 

Respectfully, 

;,:-~ Tim Pearson 

President/CEO 

F3EA, Inc.