U.S. Department of Transportation

Docket Management System

1200 New Jersey Avenue, SE

Washington D.C. 20590

UP North Aeronautics, DBA

Alexander Favreau, Principal

1043 Manitou Dr. APT 103

Traverse City, MI 49686

Exemption List: 14CFR 

91.7(a);91.9(b)(2);91.103;91.109,91.119(c);91.121;91.151(a)(1);91.203(a)(b);91.405(a); 91.407(a)(1); 

91.409(a)(1) and (2); 91.417(a)and(b); 45.23(b); part 21; 61.113(a)(b)

To Whom it may Concern.

I am writing to pursue the reform act of 2012, and the procedures contained in 14 C.F.R 11, to request 

that Up North Aeronautics DBA be exempt from the Federal Aviation Regulations (FAR’s) listed above so 

that Up North Aeronautics DBA will be able to operate light unmanned aircraft systems (UAS) in airspace 

that is regulated by the Federal Aviation Administration (FAA); as long as operations are conducted 

within and under the conditions that are outlined herein or as may be established by the FAA as 

required by Section 333.

It is the request of the petitioner for exemptions listed above in order to safely and legally operate the 

DJI Phantom 3 Advanced UAS, in the National Airspace System for the operations of photography and 

Videography for real estate, insurance, utility and telecommunications industries. Described herein is 

the pursuance to enhance safety for the general public, flight crews, and labor forces as well as public 

awareness of UAS operations.

The main purpose for exemptions listed above is to allow Up North Aeronautics DBA utilize UAS’s for 

inspections for residential and commercial real estate inspections, construction inspections, search and 

rescue if needed, and homeowner’s insurance inspections. 

The main purpose for the requested exemption is to allow Up North Aeronautics DBA to utilize UAS’s to 

assess and inspect residences and business in the account of insurance, weather be commercial 

insurance or home owner’s insurance for claim assessment, survey construction sites, bridges and other 

civil structures. Real estate photography and videography. Allowance to inspect and use of photography 

and videography would be contingent on obtaining written consent to access these locations by the 

property owners and insurance companies. The site access would allow Up North Aeronautics DBA to 

perform and conduct flight operations which include inspections at low altitude and always within Visual 

Line of Sight (VLOS). All inspections, photography, and videography would be conducted within 300’ feet 

AGL (Above Ground Level) and utilize Pilot in Command (PIC) as well as Visual Observer (VO). Some of 

the safety measures taken to assure safety for all personnel and structures I would cordon off the site to 

alleviate excess personnel on the site, I will do so by manor factors but primarily with signs and cones 

advising of the possible hazard. Up North Aeronautics DBA and its UAS’s would alleviate the exposure 
for the insurance personnel on a day to day basis by eliminating any height factor of the manual 

inspections. Some of the inspections that would be included for the claims process would be for gutters, 

siding, windows, and roof inspections. The UAS would decrease the time it would take to do the 

inspections, this would increase productivity and assist in making the inspections more thorough. Using 

the UAS would allow the insurance personnel to stay on the ground instead of climbing a ladder either 

to inspect the roof, siding, windows, which would minimize the risk of falling, harm, or even death 

associated with this type of operation. 

The operations listed above may require flight within 100’ feet from buildings and structures. The safety 

measures that have been implemented to minimize risk and exposures of damage to any structure or 

harm to any persons on the site would include

 Written permission from the property and building owners describing potential hazards 

and outlining the flight operations.

 General Liability coverage to cover any damages

 All flight operations to follow operation manual guidelines and procedures included 

herein

Safety is of utmost importance to Up North Aeronautics DBA, we hope to perform safety by 

incorporating several flight parameters, conditions, guidelines and limitations to adhere preflight, in 

flight, and post flight operations which all are outlined in the UAS user/operator manual.

 The UAS will not exceed a ground speed of 30 Knots

 All operations will remain below 300’ Feet AGL 

 All Operations will remain in VLOS

 The UAS will weigh less than 55 pounds

 A VO will be utilized at all times and always will have verbal communication with PIC

 The Operator must follow the procedures outlined in its operator’s manuals which 

includes Protocols and Procedures, DJI user’s manual and operator’s manual, which are 

included

 All PIC’s must carry at least a private pilot license, experimental license, sport pilot 

license, or Glider license.

 All PIC’s must carry at least a Third-class medical 

 All PIC’s must meet flight review requirements specified in 14 CFR 61.56

 Prior to each flight the PIC must inspect the UAS to ensure flight safety.

 Any UAS that has undergone alterations or maintenance must undergo a functional 

flight test in accordance with the operator’s manual

 UAS aircraft component, maintenance, overhaul, replacement, inspection, and life 

limitations address by manufacturer must be followed

 Each PIC must undergo specific training for the type (multi-rotor), make and model 

aircraft and log hours appropriately. 

 PIC must maintain proficiency and currency (every 90 days) with UAS.

 Both PIC and VO must successfully complete a qualification process that is outlined in 

operators manual and must be documented

 The UAS will not be operated directly over any person, except authorized flight 

personnel only with their consent. 
 The PIC and VO will ensure that no unauthorized persons allowed within a safe distance 

deemed by physical terrain constraints, or 300’ feet. 

 Lost communication or GPS signal while in flight, the UAS must return to predetermined location and be recovered or land safely in accordance with the operator’s

manual

 The UAS must abort any flight in the event of unpredicted obstacles or emergencies in 

accordance with operator’s manual

 All operators will comply with all manufacturers safety information

 The UAS will not operate in Class B, C, or D, airspace

 The UAS will not be operated by PIC from moving device or vehicle

 At all times the UAS must remain clear and yield to all manned operations and activities 

at that time.

 All operations will be conducted under Visual Flight Rules (VFR)

 There will be no night operations as defined in 14 CFR 91.151

 The UAS will not be operated less than 500’ feet below or 2000’ feet horizontally from 

any clouds 

 The UAS will not be operated with less than 3 statute miles of visibility 

 The documentation required under 14 CFR 91.9 and 91.203 will be available to PIC at all 

times at the ground station 

 The radio frequency spectrum used for operations and control of UAS will comply with 

the Federal Communications Commission (FCC)

 Accidents will be reported to the National Transportation Safety Board (NTSB) 

 Any incident, accident, or flight operation that extends past the lateral or vertical 

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

FAA’s UAS Integration Office (AFS-80)

 The UAS operator must obtain an Air Traffic Organization (ATO) issued Certificate of 

Waiver/ Authorization (COA) prior to conducting operations.

 Up North Aeronautics DBA will operate the local Flight Standards District Office (FSDO) 

in writing 3 days prior to any operation to define activities and flight operations that are 

going to take place. 

Exemption request:

14 CFR 51, Subpart H: Airworthiness Certificates;

 The petitioner requests relief from 14 CFR 51 Subpart H taking into account the size, weight, 

maneuverability and requirements that are outlined towards airports and dense populations 

which the (business) must meet and exceed the operation limits outlined. 

14 CFR 61.113(a)(b): Private Pilot Privileges and Limitations PIC;

 Private Pilots are limited to Non-Commercial operations.

 The UAS’s used in this operation do not carry any pilots or passengers.

 Every PIC will need to must attend the pilot vetting and training to further flight skills operating 

UAS to ensure safety while flying UAS. Only then will the PIC’s that are operating the UAS’s will 

have the skills that a private pilot license does not ensure for flight of any UAS.
 Obtaining the necessary training that (business) requires will ensure and exceed current safety 

levels in relation to 14 CFR 61.113(a)(b).

14 CFR 91.103: Pre-flight:

 For preflight action every PIC must abide by operating documents which include weather, flight 

battery requirements, landing and take-off distances and aircraft performance data before 

initiating each flight, there will be no approved Aircraft Flight Manuals on board the aircraft but 

all operating documents will be available to PIC to directly follow at the ground station. 

14 CFR 91.109: Flight Instruction;

 There will not be flight instruction available, no dual controls are available on the UAS

14 CFR 91.119 (c): Minimum Safe Altitude;

 No person may operate an aircraft

o Over other than congested areas, an altitude of 500 Feet above the surface except over 

open water or sparsely populated areas.

o Sparsely populated areas and open water the aircraft may not be operated closer than 

500 Feet to any person, vessel, vehicle or structure.

 For the type of operations (photography and videography), the petitioner will operate between 

0’ feet to 300’ feet AGL, the majority of time will be within 200’ feet AGL. 

 The DJI Phantom 3 Advanced is not able to exceed speeds over 30 knots and is remarkably 

lightweight.

 UAS is equipped with GPS guided auto pilot which enables a return to home function in the 

event of loss of control by PIC.

 Post impact fire is reduced with sealed batteries.

 The primary uses for this UAS will be directly correlated with home inspection, videography, and 

photography of residence and business structures, in these cases Up North Aeronautics DBA

would need to be exempt from 14 CFR 91.119(c) to be able to fly within 500’ feet to get best 

angle of capture.

 In these operations conducted, PIC would need the expressed permission of the property owner 

and every safety precaution will be made to keep persons outside of a safe, reasonable, and 

clear area of operations, for more information on precautionary events please see the Protocols 

and Procedures section. 

91.121: Altimeter setting;

 The Petitioner requests relief from 14 CFR 91.121, the DJI Phantom 3 Advanced is equipped with 

GPS derived altitude capabilities.

14 CFR 91.151(a)(1): Fuel Requirements;

 No person may begin a flight in an airplane under VFR conditions unless PIC takes into 

consideration the wind and forecast weather conditions unless there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruise speeds. During the day to fly for at 

least 30 minutes.
 The Petitioner requests relief from 14 CFR 91.151(a) taking in consideration that the UAS is 

equipped with a battery system that has a built in power percentage indicator system. 

 The max flight time for the DJI Phantom 3 advanced has a total flight time of 23 minutes 

respectively depending on camera usage, flight conditions and other variables. The established 

amount of time on a fully charged battery will be no longer than 16 minutes, this will give the 25 

percent battery/ fuel left over with an excess of about 2 minutes for safety and considering 

flight conditions and other variables that can affect flight time. 

14 CFR 91.405 (a): Maintenance Required;

 The Petitioner requests relief from 14 CFR 91.151(a)(1), please see the Protocols and Procedures 

section on Maintenance and Maintenance Required.

14 CFR 91.407 (a)(1): Operation after Maintenance, Preventive Maintenance, rebuilding, or alteration;

 The Petitioner requests relief from 14 CFR 91.407(a)(1) please see the Protocols and Procedures 

section on Maintenance, Return to service after Maintenance, and Maintenance records.

14 CFR 91.409 (a)(1)(2): Inspections;

 The Petitioner requests relief from 14 CFR 91.409 (a)(1)(2), please see the Protocols and 

Procedures section on Inspections. 

14 CFR 91.417 (a)(b): Maintenance Records;

 The Petitioner requests relief from 14 CFR 91.417 (a)(b) please see the Protocols and Procedures 

section on Maintenance Records.

14 CFR 91.7(A): Airworthiness Certificate;

 Prohibits the operation of an aircraft without an airworthiness certificate. Request for 

exemption by petitioner based on previous exemption no. 13660. The FAA has ruled that this 

make and model of UAS does not require an airworthiness certificate.

14 CFR 91.9(B)(2): Aircraft Flight Manual;

 Requires an aircraft flight manual in the aircraft at all times. Being an unmanned system no 

pilots or passengers are on board and taking into consideration the size and weight of UAS. 

14 CFR 45.23(b): Aircraft Markings

 The petitioner requests relief from 14 CFR 45.23(b), stating that the markings on the aircraft 

must include the Roman Capital Letter “N” and must be displayed at each entrance to the 

cockpit or pilot station in letters larger than 6 inches tall and no less than 2 inches tall. Being 

that the UAS is an unmanned system, the aircraft does not have a cockpit or pilot stations. Being 

a small lightweight aircraft the requirements for 2 Inch lettering may be difficult. If required for 

Up North Aeronautics DBA to mark its aircraft on its fuselage as stated in 14 CFR 45.29 (f), 

markings will be put on the aircraft as large as possible so that the pilot, technician, VO, and 

others that are working with or near the UAS will be able to see the markings. 
Procedures and Protocols for UAS operations:

The Unmanned Aircraft system

The Petitioner will be operating the DJI Phantom 3 Advanced Quad-Rotor UAS System, this will be the 

only system to be operated by the petitioner. This system is ultra-lightweight weighing at 1,280 G. Many 

features have been implemented on/into this UAS to ensure safety. Some of the safety features that 

have been implemented into this system are GPS return to home feature which will land the aircraft to a 

predetermined safe area. The GPS also implemented that the PIC can take control while on return to 

home feature if necessary. No fly areas, the GPS will atomically know when it is about to enter, or 

takeoff in a no fly zone and will not allow the PIC to proceed with either, to ensure safety. Please see the 

attached hyperlinks that have been attached that will include operating and user documents for this 

system as additional information for this petition.

Area Security/Safety

1. The PIC of the UAS will ensure that the area of operations will be cleared of all persons that are 

deemed to be not essential to the flight. All persons that are considered to be not essential to 

the flight will be cleared of the area of operations and give a safety buffer of no less than 200’ 

feet or an amount practical during any time of operations. For the safety of the public cones and 

signs will be incorporated to assist in keeping the area of operations clear throughout the 

duration of the flight. 

Pre-Flight Inspections:

1. All PICs of the UAS must have available the pre-flight inspection for UAS given by the DJI 

Phantom 3 Advanced manuals available, and must follow the instructions given said manual. 

The PIC will certify that the preflight inspection has been accomplished in full and must provide 

date time and signature showing it was complete. The preflight inspection must include all of

the following for the UAS;

a. Aircraft:

b. Transmitter: 

c. Batteries: 

d. Motors:

e. Landing Gear:

f. Camera:

g. Gimbal Mount:

2. As a part of the preflight inspection the PIC must assure that all listed below must be attained 

prior to flight.

a. Weather Conditions:

b. Area Security:

c. Any other information that is deemed essential for safe flight:

UAS Airworthiness

1. The PIC must ensure the airworthiness of the UAS prior to each flight. Airworthiness must be 

ensured by the following

a. DJI Phantom 3 Advanced operating documents
b. Any applicable Federal Aviation Regulations

c. Requirements defined by the Administrator

2. The PIC must document

a. Preflight inspection with signature and date

b. Aircraft flight time to date

c. Any discrepancies noted (shall be addressed before any operations)

d. Certificate number

Operation Limitations:

1. The UAS must be operated in day time only defined in 14 CFR

2. Night operations for UAS are prohibited 

3. The PIC must obtain at least a Private Pilot certificate in most appropriate Class and Category

4. The PIC must obtain and carry at least a 3rd class medical certificate

5. PIC must meet the flight review requirements listed in 14 CFR 61.56 

6. PIC is required to operate the UAS in accordance with 14 CFR 91.119

7. UAS will not be operated within 5 Nautical Miles of a controlled airport denoted on a current 

FAA chart.

8. No operations are permitted in the surface of a class B, C, and D airspace or restricted area.

9. PIC needs to attain the appropriate Certificate of Authority issued by the administrator.

10. The UAS will be limited to 75% of battery power or 16 minutes 

11. The PIC will need to acquire permission from the property owner to fly within 150’ feet 

12. UAS will not be operated from a moving platform or vehicle of any type.

13. A Visual Observer (VO) must be present and must maintain VLOS at all times

14. VLOS must be maintained at all times during UAS operations

15. The only UAS to be utilized will be the DJI Phantom 3 Advanced

16. The restriction for altitude will be implemented stating all operations must be done below 300’ 

feet AGL 

17. The restriction for horizontal distance away from PIC must be within 1,000’ feet

18. The UAS must not exceed 30 Knots (35 MPH)

19. PIC must accumulate and log a minimum of 25 hours of total flight time as a UAS rotorcraft pilot

20. For PIC currency before any operations the PIC must accrue a total of 5 hours as a UAS pilot in 

the same Make/Model listed, and must log a minimum of 3 takeoffs and landings within 90 days 

prior.

21. The Maintenance of the UAS must follow the DJI Phantom 3 Advanced aircraft and component, 

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

22. In accordance with the operating documents all Maintenance, Inspections, and Record keeping 

must be up to date and must include total flight hours, description of work performed, date of 

operations and signature of operator must be included. 

23. After any maintenance or alterations that may affect the UAS, an operational flight test must be 

completed and documented. 

24. The UAS and ground control stations must be inspected and deemed airworthy conditions prior 

to any operations; if the UAS or ground station is deemed un-airworthy, all flight operations will 

be suspended until necessary maintenance has been performed and the UAS and Ground 

Station has been deemed airworthy once more. 
25. All operation documentation will be accessible to the PIC at all times and must be able to be 

presented to the Administrator upon request.

26. The UAS must comply with all of the safety bulletins from the manufacturer 

27. If the return to home function and or autopilot are suspected of malfunctioning no operations 

are permitted and any ongoing operations must cease.

28. The PIC and VO must observe the area of sky surrounding the area of operations, if any manned 

aircraft is being operated in close proximity of the operations, the UAS must give right of way to 

the manned aircraft and operations must cease to continue until the manned aircraft is clear of 

the area.

Pilot in Command Requirements

1. The PIC must hold at least a Private Pilot Certificate and a current Third Class Medical 

whenever conducting any operations. 

2. The PIC must accumulate a total of 25 hours 0f rotorcraft UAV flight time

3. The PIC must have at least 10 hours of flight time with the make and model of UAV 

4. A Preflight inspection must be performed and documented before each flight is conducted

5. The PIC must have a VO present to operate

6. The PIC must maintain and record flight information to establish currency and the operator 

must meet all requirements in this section

7. The PIC must observe and obey all Federal Aviation Regulations at all times exceptions 

include exemptions listed

Responsibilities and Requirements for Visual Observers

1. During any UAS operations a Visual Observer must be present

2. Verbal communication between the Visual Observer and the PIC must be kept at all times

3. The Visual Observer must keep Visual Line of Sight with the UAS at all times 

4. If Visual Line of Sight is lost with the Visual Observer, the PIC will be notified verbally and 

operations will cease

5. The Visual Observer will assist the PIC with operations area security to ensure that all persons 

that are not essential remain clear of area 

6. If there is a breach of unauthorized personnel, the Visual Observer will notify the PIC and all 

operations will cease until area is clear

7. The Visual Observer will assist the PIC in observing the area for any manned aircraft traffic, if 

there is any manned aircraft traffic in the proximity the Visual Observer will notify the PIC and all 

operations will cease until the area is clear.

Maintenance and Records:

1. Each UAS shall have its own and separate maintenance log book

2. The PIC shall maintain all aircraft maintenance in the specified log book specific to UAV

3. Performing repairs, inspections, overhauls and replacement of life limited components

a. Only the DJI Phantom 3 Advanced documents, handbooks, user manuals, supplements, 

etc. shall be the only approved documents for any of the maintenance listed above
4. Maintenance records must be kept with the UAS at all times and must be accessible to any 

authorized agency or the administrator upon request.

5. All required maintenance inspections, alterations or repairs must be completed by an approved 

person. Once completed the approved person must make an entry in the log book that includes

a. Date

b. Aircraft serial or operating number

c. Description of the discrepancy, inspection, alteration, or repair

d. The reference material used as guidance for repair 

e. Statement approving the aircraft to return to service

f. Signature of person who completed work

Reporting of incidents or Accidents:

1. The applicable COA operating the UAS must report any incident or accident within 24 hours to

a. FAA UAS Integration Office (AFS-80) Accidents:

National Transportation Safety Board

(WWW.NTSB.gov)

The Public Interest:

The request for this exemption is in the Public Interest as is a safe vehicle engineered to make sure that 

it is lightweight, fire resistant, and environmentally friendly resource that could make the labor force 

and environment a safer place. This system is virtually quiet from afar compared to its manned aircraft 

counter parts, it will not disrupt personnel with the noise that a manned aircraft brings. These aircraft 

can provide numerous amounts of services without risk of loss of life or harm. It has become clear that 

many areas want these systems to be integrated into the NAS, including the Congress of the United 

States of America, the consumers and many business’. Not only are these systems very efficient but the 

growing rate and wide acceptance of these systems will have a big toll in the economy. By granting this 

petition it will help the Administrative process’ to help create regulations to further safety in the future 

and guidance for the growing community that is UAS.

For any questions or concerns please send to the email address listed below

Sincerely,

Alex Favreau

1043 Manitou Dr. APT 103 

Traverse City, MI 49686

(616)438-8214

Favreaa4228@gmail.com