Paul K Grinold May 18, 2015

20515 Weaver Road

Watertown, NY 13601

Cell (802) 779-1093

Email: grinoldp@yahoo.com

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

Attachments: 2 through 4 are too large for submission via the submission portal.

They are available at this website for viewing or download. 

http://www.dji.com/product/phantom-3/download

1) Flight hoursPaulGrinold.pdf

2) Phantom 3 Professional User Manual (EN) v1.0

3) Phantom 3 Professional Quick Start Guide (EN) v1.0

4) Phantom 3 Safety Guidelines and Disclaimer

References:

1) FAA Exemption No. 11138, Regulatory Docket No. FAA20140481in The matter of the 

petition of DOUGLAS TRUDEAU

2) FAA Exemption No. 11136, Regulatory Docket No. FAA–2014–0508 in the matter of 

the petition of ADVANCED AVIATION SOLUTIONS LLC

3) FAA Exemption No. 11080 Regulatory Docket No. FAA20140355in the matter of the 

petition of FLYING CAM INC

Dear Sir or Madam,

In accordance with the FAA’s Guidelines for Submitting a Petition for Exemption

under section 333 of the FAA Modernization and Reform Act of 2012, I Paul K Grinold,

referred to hereafter as the petitioner, request exemption from the following sections of

Title 14, Code of Federal Regulations §§

61.113(a); 61.113(b); 91.119(c); 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409

(a)(1); 91.409(a)(2); 91.417(a) & (b);

In order to operate small unmanned aircraft systems (UAS) commercially in airspace

regulated by the Federal Aviation Administration (FAA) for the purposes of aerial
photography, cinematography, videography, and mapping that could be performed 

safely and more cost effectively with the use of small UAS at low altitude within the U.S. 

national airspace system as compared to a manned aircraft. Operations will be 

performed only at the request of and with the authorization and permission of clients or 

their authorized agents in order to facilitate commerce and raise awareness of the 

beneficial uses of small unmanned air systems. So long as such operations are 

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

the FAA as required by Section 333. The conditions identified and proposed by the 

petitioner are drawn from references 13.

The FARs

The petitioner seeks exemption from the above mentioned FARs for the following

reasons;

61.113(a) & (b); The petitioner requests relief in order to facilitate the utilization of 

pilots, who hold a PRIVATE PILOT (or greater) certificate. Any pilots operating under 

this exemption would be required to comply with any conditions as set forth and in a 

similar fashion to the previously granted exemptions.

91.119(c) As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations 

conducted closer than 500 feet to the ground may require that the UA be operated 

closer than 500 feet to essential persons, or objects that would not be possible without 

additional relief. The petitioner requests modification, waiver or exemption and

clarification concerning the terms “congested areas” and “densely populated”. The

petitioner requests waiver for this condition to allow reasonable and responsible

operations in areas of subdivisions and neighborhoods if required.

91.121 As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable 

since the UAS does not have an altimeter and instead utilizes electronic

GPS with a barometric sensor for altitude information.

91.151(a) As discussed in Exemption 11136 (ADVANCED AVIATION

SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less

than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In

addition, similar UAS specific relief has been granted in Exemption Nos. 8811, 10808,

and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in

percent to the PIC. The UA batteries provide approximately 25 minutes of powered

flight. Information provided in the operating documents discusses procedures regarding

remaining battery power management. Those documents contain a condition in which

the PIC will initiate a landing procedure when battery remaining reaches a specified

level. Given the limitations on proposed operations and the location of those proposed

operations, The FAA found that a reduced minimum power reserve for flight in daytime

VFR conditions was reasonable.

91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) As discussed in
Exemption 11138 (DOUGLAS TRUDEAU), The petitioner proposes to inspect and

ensure that the UAS is in a condition for safe flight in accordance with the operating

documents. The FAA found that adherence to the petitioner’s operating documents and

the conditions and limitations specified, describing the requirements for maintenance,

inspection, and recordkeeping, were sufficient to ensure that safety would not be

adversely affected.

The UAS

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

quad copter configuration with an advertised weight of less than 46 Ounces (1280g) 

designed primarily to carry aloft a high definition camera. It has an advertised maximum 

speed of less than 30 knots (16m/s) and a maximum climb rate of less than 1200 feet 

per minute (6 m/s). It is powered by four electric motors with a distance between motors 

of less than 14 inches (350mm) It utilizes an internal inertial measuring unit (IMU) with 

integrated barometric sensor augmented with global positioning system (GPS) along 

with visual and ultrasonic sensors to maintain its geospatial orientation and position. It is

controlled primarily through an FCC certified radio control (RC) unit. Real time video

and telemetry information is transmitted back to a ground control station allowing the

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), and 

distance from PIC, camera imagery, and control camera angle. It has failsafe modes of

operation for either loss of RC or GPS signal. The onboard flight controller can limit 

altitude of the UA. The maximum altitude can be preprogrammed by the PIC. Battery 

life limits flight times to approximately 23 minutes. The onboard flight controller will warn 

the pilot via telemetry and external lighting cues before reaching a low battery state. An

automatic termination of flight and landing will be initiated when the battery reaches a

predetermined low state. It is anticipated that flights will usually last less than 10

minutes. More information is available in attachment 2 or

http://www.dji.com/product/phantom-3/download

Risk mitigation

The petitioner has reviewed FAA exemptions reference’s 13Conditions and

Limitations section and believes that the procedures specified therein are reasonable

and will be utilized in order to manage and mitigate risk and ensure public safety. A

preflight checklist will be developed and employed to ensure that the UA airworthiness

will be verified before launch. Airworthiness will be maintained by performance of

routine inspections before each flight, maintaining flight and maintenance logs to record

time on failure prone components. The petitioner request that in a manner similar to 

reference 3, he be allowed to operate within 5 miles of an airport provided that;

“The UA may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA may not operate within 5 nautical miles of the geographic center of a non towered 

airport 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 
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.”

Operations within 5 miles of an airport are not anticipated to be routine but the petitioner

is requesting a mechanism to facilitate such activities without requesting a new and

separate exemption(s) should the need arise. Operations within class B airspace are

not requested due to the lack of mode C transponder.

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the

environmental impact as compared to similar operations conducted with manned aircraft

of greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS

in order to facilitate commerce could lead to economic growth. Operations for this

petition will enable service for property owners or their designees seeking an enhanced

perspective for characteristics, amenities, and benefits of their desired photographic

subjects that cannot be displayed through ground level videography/photography. Aerial

photography is a valuable marketing tool that can lead to increased commerce and

enhance personal photography. Crop surveying applications could lead to decreased

use of pesticides and fertilizer and conservation of water as well as increased crop

yields and decreased costs. Aerial surveying and inspections can increase work site

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

clients with photographic data for these purposes on a ‘for hire’ basis acting as an

independent contractor. A visual observer will be utilized. Liability insurance will be

obtained commensurate with the granting of this request for exemption. Flight data

including UA flight time, Control Unit operation time, incident, accident, and details

concerning any deviations from normal operations will be available to FAA for use in

collecting data regarding the use of UAS as part of this application. This data may be

submitted to FAA via traditional means, e.g. COA Monthly Reports, or other means as

required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial

photography, cinematography, videography, and mapping”. The reason for such a 

broad based request is that the petitioner wishes to utilize a business strategy of 

horizontal integration and maximize economies of scope in order to capitalize on 

opportunities as they may arise in the future without the long turnaround time 

associated with additional exemptions. The petitioner's business model is based on the 

idea of offering ad hoc small UAS services to individuals or companies who wish to 

employ these services as a safe, effective, and legal option to enhance their business or 

hobby. The petitioner’s own market research shows high demand for these services 

currently exists in the real estate market and other markets are just beginning to 

emerge. The petitioner has refrained from engaging in commercial use of the UAS. The 

primary purpose of seeking this exemption is to obtain the capability to offer those 

services while remaining in compliance. The petitioner has extensive RF and network 
engineering experience. The petitioner has been building and flying RC rotor aircraft for 

the past 6 years. The UAS the petitioner currently operates are illustrated in attachment 

1.

Respectfully submitted,

Paul K Grinold