October 13, 2015

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE.,

Washington, DC 20590

TRINITY TEAM LLC

PO BOX 361

CAPSHAW AL 35742

615.430.5945

trinityteamllc@nym.hush.com

Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation

Regulations

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform Act") and 14 C.F.R. Part 11, Team 

Trinity LLC seeks an exemption from Federal Aviation Regulations ("FARs") detailed below for the following described 

Unmanned Aerial System called in this application the Unmanned Aircraft System, or UA System, which includes an unmanned 

aircraft and ground station-based equipment and crew:

THE UNMANNED AIRCRAFT (UA):

- A lightweight (2.8lb gross weight with all on-board equipment), battery operated 4-motor rotorcraft in the form of a 

quadcopter that takes off and lands vertically, manufactured by DJI, Phantom 3 Professional that includes all the 

following equipment in flight:

- An on-board flight computer with GPS navigation and location ability that receives signals for flight controls from a 

ground-based transmitter/controller.

- An on-board camera capable of capturing imagery in the form of full color, high definition still photos and video.

- An on-board telemetry system that delivers flight data from the on-board flight computer to the on-board radio 

transmitter including altitude AGL, horizontal and vertical speed, compass direction of flight and direction back to its 

launch site.

- A 2.4GHz on-board radio transmitter that transmits live video from the on-board camera plus all the flight data from 

the telemetry system described above.

THE GROUD STATION -BASED PART OF THE SYSTEM:

- A Pilot in Command (PIC) in operational control of a flight operation from beginning to end and who controls the UA 

while in the air.

- A 2.4GHz radio transmitter/controller operated by the PIC to control the UA while in flight.

- A radio receiver receiving live video and flight data from the on-board camera and computer projects it all together 

onto a screen for the PIC to view during flight.

- A Visual Observer (VO) is a person who provides a second pair of eyes to visually track the UA while in flight.

The requested exemption would support an application for a commercial Certificate of Authorization to use the above 

described UA System to support aerial photography of real estate property, structural and agricultural inspections.

The UA, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fuel, it 

operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety 

and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 22 

minutes, this is offers little or no risk to national security.
Low level oblique photos and video from several angles are far more effective than ground-based imagery for displaying the 

characteristics of large, complex properties with several buildings and large trees. The alternative could be to charter a fullsized helicopter for this purpose, which has proven more costly than many potential clients are able to afford. The benefits of 

reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real

estate property.

The UA System will be operated in the field with both a PIC and a VO in accordance with FAA Policy N 8900.227 Section 14 

"Operational Requirements for UAS" and with the following Restrictions:

a) No flight will be made with a UA Gross weight exceeding 2.8pounds

b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no more than 50 knots 

and no further than 3/4 NM from the PIC

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times 

during a flight operation

d) Operations will be restricted to flights over property with the permission of the property owner

e) The PIC must have accumulated and logged 25 hours of total time as a UA rotorcraft pilot and at least ten hours 

logged as a UA pilot with a similar UA type

f) All required permits will be obtained from state and local government prior to operation

g) The UA System will not be operated over densely populated areas

h) The UA System will not be operated at air shows

i) The UA System will not be operated over any open-air assembly of people

j) The UA System will not be operated over heavily trafficked roads

k) The UA System will not be operated within 5 NM of an airport or heliport

l) Operations will be restricted to day only and weather conditions equivalent to VFR

m) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location

n) No flight may be made without a Pre-Flight Inspection by the PIC before each operation to ascertain that the UA is in 

a condition safe for flight (see Appendix A).

The PIC and VO will meet the requirements outlined in FAA Policy N 8900.227 Section 16 personnel qualifications. 

Additionally, the PIC and VO will perform maintenance on the system and will complete a course of maintenance instruction 

as part of their initial training.

We submit that the combination of the UA's light weight, flight performance and ability, fully qualified flight crew and strict 

operation under the guidelines established in 8900.227, and under all of the Restrictions (a) through (n) listed above, the FAA 

can have full confidence that the operation will have an equivalent or greater level of safety than manned aircraft performing 

the same mission.

The name and contact information of the applicant:

Michael Johnson

TRINITY TEAM LLC

PO BOX 361

CAPSHAW AL 35742

615.430.5945

trinityteamllc@nym.hush.com
The regulations from which the exemption is requested are listed below. Beside each regulation number is the page of the 

attached Addendum upon which each may be found together with our proposed equivalent level of safety for each regulation:

- 14 CFR Part 21 Addendum Page 1

- 14 CFR 91.203 Addendum Page 1

- 14 CFR 45.23, 45.29 Addendum Page 2

- 14 CFR 91.9 Addendum Page 2

- 14 CFR 61.113, 61.133 Addendum Page 2

- 14 CFR 91.109, 91.119, 91.121 Addendum Page 3

- 14 CFR 91.151 Addendum Page 3

- 14 CFR Subpart E (91.401 - 91.417) Addendum Page 3

- -FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(l) Addendum 1 Page 4

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

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

Regards,

Michael Johnson

Owner

TRINITY TEAM LLC

PO BOX 361

CAPSHAW AL 35742

trinityteamllc@nym.hush.com

615.430.5945
ADDENDUM

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY

Trinity Team LLC, requests an exemption from the following regulations as well as any additional regulations that may 

technically apply to the operation of the UA System:

14 CFR Part 21, Subpart H: Airworthiness Certificates

This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to 

develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for the UA

System under either or both of the following provisions:

21.191 Experimental certificates.

Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new 

aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the 

airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights 

to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the 

regulations.

Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and 

customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well.

The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. 

Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be 

at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission.

If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR 

Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety 

outlined in the previous paragraph.

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.

The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a 

registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides that the airworthiness certificate 

be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."

At a maximum gross weight of 2.8pounds, the UA is too small to carry documentation, does not have an entrance, and is not 

capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that 

documents deemed appropriate for this aircraft by the FAA will be co-located with the crew at the ground control station and 

available for inspection upon request. In order to identify the aircraft, we propose that the information found on 

airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following 

information plus the word “EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23

14 CFR 45.23 Display of marks; general and 45.29 Size of marks.

These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches 

high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to 

the cabin, cockpit, or pilot station. The UA does not have an entrance in which the word "EXPERIMENTAL" can be placed, and 

may not have a registration number assigned to it by the FAA.
We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the 

aircraft where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the 

designation. Additionally, will be registered and the N registration number will be displayed on the fuselage in a font size as 

large as practicable for the dimensions of the aircraft. 

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We 

assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while 

operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry 

documentation, the documentation would not be available to the crew during flight operations.

To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved UA Flight Manual 

(Appendix A) must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and 

limitations.

The regulation 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) The flight is only incidental to that business or employment; and (2) The aircraft does not carry 

passengers or property for compensation or hire.

Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the FAA, and have logged 

25 hours of flight experience in this type of UA.

Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though 

the intent of this application is to conduct a business.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests

The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft 

has fully functioning dual controls."

The UA System ground-based control station consists of a small hand-held radio transmitter and while it does not offer a 

second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With 

both student and instructor having "hands-on" the controls during flight, we feel that this technique meets the intent 91.109 

and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General.

The regulation states 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. In order to 

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

flown over. The aircraft will not be operated over congested areas or over any open air assembly of persons. The property 

owner will be briefed on the expected route of flight and the associated risks to persons and property on the ground. The 

aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to

persons or property on the surface. Therefore we maintain that due to the small size of the UA, the hazard to persons, 

vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 

NM of the aircraft.
The UA will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with 

other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the UA 

on-board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

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 feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The UA is 

battery operated and the maximum duration of flight from a single battery charge is 18 minutes with a 20% reserve. Since the 

aircraft will never fly more than 3/4 NM from the point of intended landing, a full battery charge at launch will ensure that we 

meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an 

equivalent interpretation with the word "energy".

14 CFR Subpart E (91.401- 91.417)- Maintenance, Preventive Maintenance, 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 perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft 

for return to service." As provided in the Pre-Flight Checklist in Appendix A, the PIC will ensure that the aircraft is in an 

airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. 

Maintenance perfom1ed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections

and updating software and firmware for the on-board computer. All other maintenance will be performed by the 

manufacturer or their designated repair facility. The PIC will document work perfom1ed in accordance with 91.417. We feel 

that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.

8900.227 Paragraph 16(c)(4) PIC Medical. and Paragraph 16(e)(l) Observer Medical.

This policy provides that both the PIC and VO must have a valid FAA second-class medical certificate issued under part 67 in 

order to perform as a pilot or observer. 

The UA maximum gross weight is 6.5 pounds, it is constructed of carbon fiber and plastic and the PIC is not on board. Both the 

PIC and the VO are required to be in VLOS. Given the unlikely event that both the PIC and VO become medically incapacitated 

while the aircraft is in flight, the UA will return autonomously to the site of launching and land without crew intervention.

Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot carrying passengers in a 

large aircraft is an unnecessary burden. We propose that the minimum medical requirements for the PIC and VO be vision 

corrected to 20/20 and a valid, state issued driver's license. The 20/20 vision requirement will ensure that the PIC and VO can 

see and avoid air traffic; a licensed driver is medically qualified to operate a much larger vehicle.
APPENDIX A- FLIGHT MANUAL

FLIGHT RESTRICTIONS

a) No flight will be made with a VA Gross weight exceeding 55 pounds;

b) All operations must occur in FAA Class G airspace at no more than 400' A GL, at an airspeed of no more than 50 knots 

and no further than 3/4 NM from the PIC;

c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate verbally at all times 

during a flight operation;

d) Operations will be restricted to flights over property with the permission of the property owner; 

e) The PIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a minimum of 100 flight 

cycles and 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a VA pilot with a similar VA 

type;

f) All required permits will be obtained from state and local government prior to operation;

g) The UA System will not be operated over densely populated areas;

h) The UA System will not be operated at air shows;

i) The UA System will not be operated over any open-air assembly of people;

j) The UA System will not be operated over heavily trafficked roads;

k) The UA System will not be operated within 5 NM of an airport or heliport;

a. Operations will be restricted to day only and weather conditions equivalent to VFR;

l) The PIC will brief the VO and property owner about the operation and risk before the first flight at each new location;

m) No flight may be made without a successful Pre-Flight Inspection by the PIC before each operation to ascertain that 

the VA is in a condition safe for flight.

PREFLIGHT CHECKLIST:

PRIOR TO TAKEOFF

- Phantom (UV) & Ground Station (RC) battery charged

- iPad charged

- (UV) Propellers installed and tightened

- Remove gimbal lock

- iPad volume to MAX

- iPad Wifi & BT OFF

- iPad to Ground Station (RC) cable attached

- Ground Station (RC) ON

- Ground Station (RC) in P-Mode

- DJI GO App Launched

- Phantom (UV) ON

- Check values :

o Reset Compass

o IMU values (0, 1, 1400-1600)

o Gain values

o Max height

o Return To Home height 

o R/C EXP & Gain (0,5-0,4-0,5)

o VPS ON (if indoor flight)

o Satellite status

- CHECK AND VERIFY HOME POINT

TAKEOFF

- Hover 30 seconds & check stability
REFERENCE DOCUMENTS:

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_en_0915.pdf

http://download.dji-innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf