April 1, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Petition under Section 333 of the FAA Modernization & Reform Act, and Title 14 Part 11 

of the Code of Federal Regulations (CFR) 

14 CFR 61.113, 

14 CFR 91.7, 

91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

Dear Sir or Madam, 

Pursuant to Section 333 of the FAA Modernization & Reform Act and 14 C.F.R. Part 11, Columbia Timber 

Company and United Country Land and Lifestyle Properties hereby jointly applies for the grant of 

exemption from certain Federal Aviation Regulations for Phantom II (Phantom) Unmanned Aircraft 

manufactured by DJI Co., Ltd. of China. 

The requested exemption would support an application for a commercial Certificate of Authorization 

(COA) to use the DJI Phantom 3 Advanced drone, , hereafter referred to as “Phantom,” to support 

forestry applications including, but not limited to, monitoring timber health for disease and insects, soil 

and erosion conditions, timber damage from storms, site preparation progress, reforestation efforts, 

contractor compliance including logging efficiency, more efficient timber analysis for potential thinning 

or scheduling for a final harvest, farm crop surveillance, real estate photography, videography, and 

aerial surveying for other commercial, rural, residential and agricultural industries and applications. 

The Phantom Unmanned Aircraft System (UAS) consists of a lightweight (4 lbs.) battery operated 

quadcopter unmanned aircraft, onboard cameras, and associated communications equipment. 

The Phantom Unmanned Aircraft (UA) has previously demonstrated to have successfully met the safety 

and operational requirements resulting in previous grants of section 333 exemption requests by other 

commercial UAS operators. 

The Phantom UA carries an onboard camera system that allows it to perform aerial photography, 

videography, and surveying. 

By approving the exemption, Columbia Timber Company and United Country Land & Lifestyle Properties

operations will create benefits to both the economy and the environment which are ultimately in the 

public interest. 

The aircraft will be operated with both a Pilot in Command and a Visual Observer in accordance with the 

following additional restrictions:

- All operations will occur at no more than 400' AGL 

- The aircraft will be operated with the permission of the property owner 
- When necessary, applicable permits will be acquired from local authorities 

- The aircraft will not be operated at air shows

- The aircraft will not be operated over heavily trafficked roads 

- Operations will be limited to day, visual meteorological conditions 

- Aircraft will remain within Visual Line of Sight at no greater than 3/4 NM of the PIC at all time 

- While the aircraft is airborne, the VO will be positioned within voice distance to the PIC 

- When necessary and applicable, Columbia Timber Company and United Country Land & 

Lifestyle Properties will file a NOTAM providing radial/DME, radius, and a date/time group for 

each operation 

For certain complex operations, Columbia Timber Company and United Country Land & Lifestyle 

Properties may assign one or two sensor/software operators to assist the operations. 

We submit that the combination of the Phantom UAV’s light weight and historically demonstrated safe 

operation and receiving approvals of multiple section 333 petitions 

- Fully qualified flight crew 

- Restricted operations under the guidelines established within the grant, the FAA can have 

confidence that Columbia Timber Company and United Country Land & Lifestyle Properties the 

operations will have an equivalent or greater level of safety of manned aircraft performing the same 

mission.

We are prepared to modify or amend any part of this request to satisfy the need for an equivalent level 

of safety. Additional documents supporting this petition will be submitted following this request. 

We look forward to working with your office. Please contact us at any time if you require additional 

information or clarification. 

Respectfully, 

Travis Davidson

Columbia Timber Company and United Country Land & Lifestyle Properties

4424 NW 13th Street, Suite C-2

Gainesville, FL 32609

352-375-1473

Travis@ColumbiaTimber.com
TABLE OF CONTENTS

NAME, ADDRESS CONTACT INFORMATION OF PETITIONER ...............................................................Page 4 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH COLUMBIA TIMBER COMPANY AND UNITED 

COUNTRY LAND & LIFESTYLE PROPERTIESS SEEKS EXEMPTION..........................................................Page 4 

THE EXTENT OF RELIEF Columbia Timber Company and United Country Land & Lifestyle Properties SEEKS 

AND THE REASONS Columbia Timber Company and United Country Land & Lifestyle Properties SEEKS 

THE RELIEF ..................................................................................................................................Pages 4 to 6 

THE REASONS WHY GRANTING Columbia Timber Company and United Country Land & Lifestyle 

Properties REQUEST WOULD BE IN THE PUBLIC INTEREST................................................................. Page 7 

THE REASONS WHY GRANTING Columbia Timber Company and United Country Land & Lifestyle 

Properties THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY ............................................. Page 8 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......................................................Page 9 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Columbia Timber 

Company and United Country Land & Lifestyle Properties REQUEST................................................Page 10 

ACRONYMS......................................................................................................................................... Pages 11 & 12
NAME, ADDRESS AND CONTACT INFORMATION OF PETITIONER

Travis Davidson

Columbia Timber Company and United Country Land & Lifestyle Properties

4424 NW 13th Street, Suite C-2

Gainesville, FL 32609

Email: Travis@Columbiatimber.com

(352) 375-1473

THE SPECIFIC SECTIONS OF 14 CFR TO BE RELIEVED FROM

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

THE EXTENT OF RELIEF COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND & LIFESTYLE 

PROPERTIESS SEEKS AND THE REASONS COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND 

& LIFESTYLE PROPERTIESS SEEKS THE RELIEF

14 CFR 61.113 Private pilot privileges and limitations:

Part 61.113 provides that no person that holds a private pilot certificate may act as pilot in command of 

an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in command 

of an aircraft in connection with any business or employment if; 

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

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

Since the aircraft cannot carry passengers or property, we request to be relieved from this regulation if 

our pilots at minimum, 

(1) Hold at least a current private pilot certificate and, 

(2) Hold a current third class medical certificate. 

By meeting conditions (1) and (2), we believe that equivalent level of safety can be achieved by 

complying with 61.113 Subparagraph (b) even though the intent of this application is to conduct a 

business. 

14 CFR 91.7 Civil Aircraft Airworthiness. 

14CFR 91.7 (a) states, “No person may operate a civil aircraft unless it is in an airworthy condition.” This 

rule prohibits the operation of an aircraft without an airworthiness certificate. Since there is no such 

existing certificate that is applicable for the Phantom UAS to properly comply with the FARs, we request 

that Columbia Timber Company and United Country Land & Lifestyle Properties to be relieved from this 

regulation. 

To provide equivalent level of safety, we will ensure that the Phantom UAS is in airworthy condition 

prior to every flight by following safety procedures described in our operating documents. 
14 CFR 91.119 Minimum safe altitudes: General

This regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 

400 feet AGL, we cannot comply with this requirement. 

To provide an equivalent level of safety we will only fly over private property with the permission of the 

land owner. The land owner will be briefed of the expected route of flight and the associated risks to 

persons and property on the ground. We maintain that due to the small size of the Phantom, the hazard 

to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be 

considered in granting the exemption. 

14 CFR 91.121 Altimeter Settings

This regulation provides that aircraft shall maintain cruising altitudes by reference to an altimeter 

setting available within 100 nautical miles of the aircraft. The Phantom aircraft will fly below 400 feet 

AGL and will not need to maintain hemispherical cruising altitudes in order to de-conflict with other 

aircraft. 

To provide an equivalent level of safety, the PIC will check and confirm the Phantom’s GPS altitude read 

out before each flight. 

14 CFR 91.151 Fuel requirements for flight in VFR conditions.

The regulation provides that no person may begin a flight in an airplane under day VFR conditions unless 

there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 

minutes. We believe the intention of this rule is to provide a reserve of energy as a safety buffer for goarounds and other delays to landing. 

The Phantom UAS is battery operated and the maximum duration of flight with full payload, from a 

single battery charge is approximately 25 minutes. We believe that equivalent level of safety can be 

achieved by limiting our flight time to 20 minutes with reserve energy 20 % (5 minutes) on the battery.

14 CFR 91 Subpart E ( 91.405, 91.407, 91.409, 91.417 ) Maintenance, Preventive Maintenance, and 

Alterations

The regulation provides that the operator is primarily responsible for maintaining the aircraft in an 

airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require 

that the aircraft be "approved for return to service by a person authorized under 43.7" after 

maintenance and inspection. It is our intention that the PIC, VO or authorized personnel to perform 

maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to 

service." 

Columbia Timber Company and United Country Land & Lifestyle Properties requests that exemptions to 

the regulations under conditions below; 

(1) Columbia Timber Company and United Country Land & Lifestyle Properties will follow 

Phantom’s manufacturer maintenance instructions, techniques and procedures 
(2) Columbia Timber Company and United Country Land & Lifestyle Properties will designate, 

train, and document the personnel who will be authorized to perform Inspection, Maintenance 

and Alterations by means of above stated maintenance instructions. Such designated personnel 

may include PIC, VO or other equivalent trained persons 

(3) To ensure equivalent level of safety, PIC will inspect the UA before each flight looking for any 

structural or mechanical malfunctions 

Due to the small size, light weight and simplicity of the Phantom UAS, we believe that the equivalent 

safety will be achieved by permitting any of the PIC, VO or equivalent trained personnel, to perform 

maintenance, inspection and alterations of the aircraft and be authorized to approve the aircraft for 

return to service.

THE REASONS WHY GRANTING COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND & 

LIFESTYLE PROPERTIES’S REQUEST WOULD BE IN THE PUBLIC INTEREST

We believe that granting our exemption request from, 

14 CFR Part 21.191 

14 CFR Part 45.23, 45.29 

14 CFR 61.113, 61.133 

14 CFR 91.9, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), is in the public’s interest and will benefit 

the public as a whole for the following reasons. 

1- Phantom is battery operated and free from the harmful emissions associated with 

the manned aircraft that are currently used for aerial photography and videography. 

As recently proven by several grants of section 333 petitions, UASs offer equivalent 

level of safety while reducing environmental impacts, which is in the public interest. 

2- Columbia Timber Company and United Country Land & Lifestyle Properties’ UAS 

operations will contribute to a positive aggregate economic impact resulting in 

creation of jobs both direct and indirectly. Economic Research estimates that the 

UAS market will grow from $6 billion to $ 94 billion over the next decade resulting in 

a new workforce development. Because Columbia Timber Company and United 

Country Land & Lifestyle Properties’ operations will create new jobs such as pilots, 

flight operation staff, and administrative supporting staff, it will directly cause 

positive economic impact, hence granting Columbia Timber Company and United 

Country Land & Lifestyle Properties’ petition will benefit the public as a whole. 

3- Congress has already proclaimed that it is in the public’s interest to integrate 

commercially flown UAS(s) into the national airspace system, hence the passing of 

the FAA Modernization and Reform Act of 2012. Granting Columbia Timber 

Company and United Country Land & Lifestyle Properties’ petition furthers the 

public’s interest as a demonstrated progression of integrating Unmanned Aircraft 

Systems into National Air Space, thus it will benefit public as a whole.

4- Proper management and monitoring forest health will insure that our area pulp 

mills and sawmills have an adequate supply of timber to maintain jobs for both the 

forest product industry as well as related industries such as building contractors and 

service employees.

5- Monitoring forest health contributes to the overall ecosystem management to help 

protect our wildlife, soil health, and water sheds. Healthy forests provide intangible 
ecoservice benefits for society. Forest cover is a major factor in regulation ambient 

temperature and hence climate levels both regionally and globally.

6- Forests sequester carbon and therefore have an important ecological function in 

fixing and storing carbon from the atmosphere. Healthy forests sequester more 

carbon than poorly functioning forests and monitoring forest health quickly and 

efficiently contributes to ecosystem services. 

THE REASONS WHY GRANTING COLUMBIA TIMBER COMPANY AND UNITED COUNTRY LAND & 

LIFESTYLE PROPERTIES THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

Columbia Timber Company and United Country Land & Lifestyle Properties believe that the grant of 

exemption from, 

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417), will not adversely affect safety by a combination 

of the reasons listed below. 

(a) We have stated in the above section “ THE EXTENT OF RELIEF COLUMBIA TIMBER COMPANY 

AND UNITED COUNTRY LAND & LIFESTYLE PROPERTIES SEEKS AND THE REASONS COLUMBIA 

TIMBER COMPANY AND UNITED COUNTRY LAND & LIFESTYLE PROPERTIESS SEEKS THE RELIEF ” 

by describing how we intend to mitigate risk and accomplish FAA equivalent and acceptable 

level of safety for each 14 CFR part. 

(b) As a result of Phantom unmanned aircraft’s size, weight, speed, operational capability, 

proximity to airports and populated areas, operation within visual line of sight combined with 

the implementation Columbia Timber Company and United Country Land & Lifestyle Properties’ 

of safety procedures, we believe that granting Columbia Timber Company and United Country 

Land & Lifestyle Properties’ exemption request will not adversely affect safety. 

(c) DJI Phantom II has demonstrated to satisfy necessary safety risk mitigation by FAA thus 

resulting in multiple grants of section 333 petitions. Because of the combination of Phantom’s 

proven success and the conditions and limitations of our operations, we believe granting 

Columbia Timber Company and United Country Land & Lifestyle Properties request will not 

adversely safety.

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

Department of Transportation

Federal Aviation Administration 

Petitioner: Columbia Timber Company and United Country Land & Lifestyle Properties Video Partners 

LLC 

Petition of exemption from sections of;

14 CFR 61.113, 

14 CFR 91.7, 91.119, 91.121, 91.151 

14 CFR 91 Subpart E (91.405, 91.407, 91.409, 91.417) 

Description of relief sought; 
Columbia Timber Company and United Country Land & Lifestyle Properties seeks an exemption for 

commercial operation of the Phantom unmanned aircraft manufactured by DJI Co, Ltd. of China. 

The Phantom unmanned aircraft system has an onboard camera system capable of acquiring high 

resolution data. 

Proposed operations will offer monitoring timber health for disease and insects, soil and erosion 

conditions, timber damage from storms, site preparation progress, reforestation efforts, contractor 

compliance including logging efficiency, more efficient timber analysis for potential thinning or 

scheduling for a final harvest, farm crop surveillance, real estate aerial photography, videography and 

aerial surveying services for other commercial industries.

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT COLUMBIA 

TIMBER COMPANY AND UNITED COUNTRY LAND & LIFESTYLE PROPERTIESS’S REQUEST

Phantom II Unmanned Aircraft System 

General Features 

 Ready to Fly, Multifunctional Quad-rotor System 

 Customized H3-2D and H3-3D Gimbal Support 

 Precision Flight and Stable Hovering 

 25min Flight Time & Smart Battery 

 Auto Return-to-Home & Landing 

 Advanced Power Management 

 Intelligent Orientation Control (IOC) 

 Easy Battery Replacement 

 Self-tightening Propeller 

 Video Downlink Support 

 CAN-Bus Expansion Module 

 Control Link radio operating frequency 2.4 GHz ISM 

 Operating Distance 0.65 miles 

Aircraft Performance 

Empty Weight 2.5 lbs.

Max Take-off Weight 4 lbs.

Max Flight Speed 30 Knots 

Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m 

Max Yaw Angular Velocity 200°/s 

Max Tilt Angle 35° 

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s 

Diagonal Length 350mm 

Flight Time 25 minutes 

No Privacy Issues 

Columbia Timber Company and United Country Land & Lifestyle Properties’ proposed operations will 

create no privacy issues because the Phantom UAS will be operating in rural areas within the boundaries 
of the properties with the landowner’s permission. Columbia Timber Company and United Country Land 

& Lifestyle Properties will also obtain any permits or authorizations from local authorities when 

necessary.

ACRONYMS

 AGL Above Ground Level 

 ALoS Acceptable Level of Safety 

 AMOC Alternative Method of Compliance 

 ASI Aviation Safety Inspector 

 ATC Air Traffic Control 

 ATCAA Air Traffic Control Assigned Airspace 

 ATS Air Traffic Service 

 AVS Aviation Safety 

 CFR Code of Federal Regulations 

 COA Certificate of Waiver or Authorization 

 CRM Crew Resource Management 

 CS Control Station 

 CRS Certified Repair Station 

 DCP Divert/Contingency Point 

 DHS Department of Homeland Security 

 DME Distance Measuring Equipment 

 DOD Department of Defense 

 DSA Detect, Sense, and Avoid System F

 AA Federal Aviation Administration 

 FCC Federal Communications Commission 

 FARs Federal Aviation Regulations 

 FIR Flight Information Region 

 FL Flight Level 

 FSIMS Flight Standards Information Management System 

 FTP Flight Termination Point 

 FTS Flight Termination System 

 GHz Gigahertz 

 GCS Ground Control Station 

 MHz Megahertz MTOW Maximum Takeoff Weight 

 NAS National Airspace System 

 NM Nautical Mile 

 NOTAM Notice To Airman 

 OPA Optionally Piloted Aircraft 

 PIC Pilot in Command 

 Phantom Phantom Unmanned Aircraft System 

 Phantom Phantom Unmanned Aircraft 

 R&D Research and Development RF Radio Frequency

 RM Risk Management 

 RNAV Area Navigation 

 RTB Return to Base 

 RVSM Reduced Vertical Separation Minimum 
 TAS Traffic Advisory Systems 

 TC Type Certificate 

 UA Unmanned Aircraft 

 UAS Unmanned Aircraft System(s) 

 UAV Unmanned Aerial Vehicle 

 VFR Visual Flight Rules 

 VMC Visual Meteorological Conditions VO Visual Observer