William H Rudiger 

1 Wilson Rd #14577 

Annapolis, MD 21412 

U.S. Department of Transportation 

Docket Operations, M-30 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Exemption Request Section 333 of the FAA Reform Act of2012 

References: 

January 26,2016 

1) FAA Exemption No. 11410, Regulatory Docket No. FAA -2015-0186 in the matter of the 

petition of RALPH J. APEL 

2) FAA Exemption No. 11341, Regulatory Docket No. F AA-20 15-003 7 in the matter of the 

petition of BOB SOKOLER 

3) FAA Exemption No. 11728 Regulatory Docket No. FAA-2015-0850 in the matter of the 

petition of ALON SICHERMAN 

4) FAA Exemption No. 11728 Regulatory Docket No. FAA-2015-2773 in the matter of the 

petition of MANUEL HEREDIA III 

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 of2012, I William Hampton Rudiger, 

referred to hereafter as the petitioner, request exemption from the following sections of Title 14, 

Code of Federal Regulations§§ 

61.113 (a) & (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(l), 

91.409(a)(1) & (2), and 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, mapping, crop surveying, inspections and other flight operations 

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 petitioner seeks exemption from the above-mentioned F ARs for the following 

reasons; 

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

pilots, who hold a Sport pilot (or greater) certificate. The petitioner holds and maintains a Private 

Pilot's license. 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. 

91.7(a): Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to 

the extent required to allow petitioner to determine that the DJI Phantom 3 Advanced UAS is in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the Monthly Maintenance Log and Phantom 3 Advanced Instruction 

Manual). Additionally a thorough visual and physical inspection will be performed to asses the 

general condition of the UAS before each flight. Petitioner seeks the requested relief because the 

Phantom 3 Advanced UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, petitioner will ensure that the DJI Phantom 3 Advanced 

UAS is in airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 3 Advanced Manual) prior to every flight, and 

further, determine that the aircraft is in condition for a safe flight. 

91.119(c): The petitioner requests waiver to allow reasonable and responsible operations 

in areas of subdivisions and neighborhoods if required. 

91.121: This 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)(1): The UAS provides battery power remaining in percent to the PIC. The UA 

p_11tteries prov.idepowerfor approximately 23 miJ:mtes offlightfo:LDJI Phantom 3 Advanced ... 

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): Since Sections 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an 

airworthiness certificate, the petitioner requests relief from these Sections because the DJI 

Phantom 3 Advanced UAS does not require an airworthiness certificate. The DJI Phantom 3 

Advanced UAS meets the conditions ofFMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, the petitioner will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 
and practices prescribed in the UAS operating documents (i.e., Monthly Maintenance Log, and 

DJI Phantom 3 Advanced Instruction Manual). Furthermore, the petitioner will document and 

maintain all maintenance records for the Dn Phantom 3 Advanced UAS. 

TheUAS 

The DJI Phantom 3 Advanced UAS is a highly successful consumer grade small 

rotorcraft in the quadcopter 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 ofless than 30 knots (16m/s) and a maximum climb rate ofless than 1200 feet per minute 

(5 m/s). It is powered by four electric motors with a distance between motors ofless than 14 

inches (350mm) It utilizes an internal inertial measuring unit (IMU) with integrated barometric. 

sensor augmented with global positioning system (GPS) 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), distance from 

PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either loss 

of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight time 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 on 

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

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 corruuensurate 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, mapping, crop surveying, inspections and other flight operations". 

The reason for such a general and 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 111ay 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 

discussions with realtors and other UAS operators shows that there is significant demand for 

these services.