U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue 

SE Washington, DC 20590 

February 16, 2016 

Request for Exemption under Section 333 of the FAA Modernization and Reform Act 

of2012 and Part 11 of the Federal Aviation Regulations. 

Name and Address of Petitioner: 

Trent Strobel 

103 Windham Circle 

Hendersonville, TN 37075 

615-574-8475 (Cell) 

Trentstrobel @me.com (Email) 

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, Trent Strobel, the Petitioner, request exemption 

from the following Federal Aviation Regulations in order to legally operate an 

Unmanned Aircraft System (UAS) in the National Airspace System. 

Regulations from which the exemption is requested: 

14CFR21 H 

14 CFR 45.23 (b) 

14 CFR 61.113 (a) & (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b)(2) 

14 CFR 91.103 (b) 

14 CFR 91.109 

14 CFR 91.119 

14 CFR 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 91.407 (a) (1) 

14 CFR 91.409 (a) & (b) 

14 CFR 91.417 (a) & (b) 

14 CFR Title 14 Chapter 1 Sub D Part 60 thru 67- 61.1 to 61.429 

The Petitioner wishes to be granted the exemption for use of the UAS of commercial 

operations list below. 
Applications and Operations: 

• 

• 

• 

• 

• 

• 

• 

• 

Construction Inspection, Management & Monitoring 

Property & Equipment Inspection 

Environmental Assessment 

Land Surveying & Topography 

Real Estate Advertising 

Aerial Photography & Cinematography 

Agriculture Observation & Monitoring 

Thermal Environmental Monitoring 

The Petitioner believes the use of the VAS's is more economical and safer to use for 

the aforementioned purposes. Use of the UAS rather than a manned aircraft is more 

economical to the consumer, and beneficial to the general public due to its small 

size, low noise and minimal potential for accident 

Characteristics of the Aircraft: 

The UASs to be used are the 3DR SOLO and OJI Phantom 3 Professional, both of 

which have wingspans of less than 24 inches (motor to motor) and ultra-light 

payload capacities (less than l .llbs.). Being such compact and portable systems, 

these platforms are ideal for precision aerial mapping missions thanks to the onboard computers, GPS systems, and the related flight management software 

(Mission Planner). This equipment allows the operator to safely and efficiently plan 

and execute missions, and then monitor them in real-time to insure safety. The 

onboard camera takes and collects high definition still images and video, which is 

later used to generate artwork, maps, and 30 models of the surveyed area. 

l. Very Light Weight 

The Phantom 3 Pro weighs 2.8 pounds and the SOLO comes in at 3.3 pounds 

with the batteries, propellers, and cameras attached. They are light enough to 

be hand launched and can gently land on almost any surface without use of a 

parachute or landing net Its low impact energy (in the case of a controlled 

emergency landing) significantly reduces the risk of hazardous situations. 

2. Electric Powered 

The 3DR SOLO & OJI Phantom 3 Pro are both electric powered and operate 

using brushless technology, making them powerful but quiet and reliable. 

The lack of noise and zero emission power sources greatly reduce the impact 

these two unmanned aerial systems have on the environment, especially 

when compared to conventional manned aircraft 

3. Semi-Automatic Flight 

These two crafts have powerful onboard computers and GPS systems, which 

monitor the parameters related to maintaining safe & stable flight. This 

allows the coordination and carrying out of highly technical and pn•cise 
missions with minimal input from the operator. Requiring minimal input 

allows the pilot to focus on the task at hand and monitor the mission as it 

takes place. Additionally, should it become necessary, the pilot has several 

options and can tell the UAS to "Go Home," "Land," "Hold," or "Resume" the 

mission. 

4. Option for Manual Control 

While monitoring the flight path of the Phantom 3 Pro or SOLO, the operator 

can override the autopilot at any time. With the flip of a switch (on the 

Phantom 3 Pro's remote controller) or push of a button (on the SOLO's 

remote controller), automated operations are halted, allowing the aircraft to 

be flown manually should it become necessary to respond to emergent 

circumstances. 

Request for Exemption, Section 333 of the FAA Reform Act pertaining to 

Federal Aviation Regulations: 

The Petitioner requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of UAS's. 

14 CFR 21 H: Airworthiness Certificates 

Certillcation Procedures for Products and Parts 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness certificate 

as granted in Exemption No. 11623, 11650, 11664 and 11734. 

14 CFR 45.23 (b }: Marking of the Aircraft 

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. 

Reason for Exception 

Even though the UAS will have no airworthiness certificate, an exemption may be 

necessary as the UAS will have not entrance to the cabin, cockpit or pilot station on 

which the work "EXPERIMENTAL" can be placed. Given the size of the UAS, two-inch 

lettering will be impossible. The word "EXPERIMENTAL" will be placed on the 

fuselage in compliance with 45.29 (f). The FAA has issued the following exemptions 

to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A. 

14 CFR 61.113 (A) 7 {b): Private Pilot Privileges and Limitations 

The regulatiOn provides that no person may serve as a required pilot flight 

crewmember of a civil aircraft of the United States. unless that person: ( 1) has a 

pilot certificate or special purpose authorization issued under this part in that 

person's physical possession or readily accessible. (2) The flight 1s only incidental to 

that business or employment. (3) The aircraft does not carry passengers or property 

for compensation or hire. 
Reason for Exception 

The Petitioner will follow all manufacturers' training programs and safety manuals. 

Additionally, current FAA proposals have omitted this as a future requirement for 

small UAS's. 

14 CFR 91.7 (a): Civil Aircraft Airworthiness 

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in 

an airworthy condition. 

Reason for Exception 

It has been determined that similar UAS's do not require an airworthiness 

certificate, however the petitioner will ensure airworthiness through the combined 

use of the manufacture's operations manual and preflight checks. 

14 CFR 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft 

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. 

Reason for Exception 

The equivalent level of safety will be maintained by keeping the flight manual at the 

ground control point where the pilot flying the UAS will have immediate access to it. 

The FSS has issued the following exemptions to this regulation: Exemption #8607, 

8737, 8738, 9299, 9299A to list a few. 

14 CFR 91.103 (b): Preflight Instruction 

This regulation requires each pilot in commend to take certain actions before flight 

to insure the safety of flight. AS FAA approved rotorcraft flight manuals will not be 

provided for the aircraft an exemption will be needed. The petitioner will take all 

actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight. 

14CFR91.109: Flight Instruction 

The regulation provides that "No person may operate a civil aircraft that is being 

used for flight instruction unless that aircraft has fully functioning dual controls." 

Reason for Exception 

UAS's and remotely piloted aircraft, by their design so not have fully functional dual 

controls. Flight control is accomplished through the use of a control box that 

communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functional dual controls for a number of 

aircraft and for flight instruction in experimental aircraft (See exemption Nos. 5778 

K & 9862 A). The equivalent level of safety provided by the fact that neither a pilot 

nor passenger will be carried in the aircraft and by the size and speed of the aircraft. 
14 CFR 91.119: Minimum Safe Altitudes 

The 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 

Reason for Exception 

The use of UAS will be flown no higher than 400 feet AGL in LOS over developed and 

developing residential areas that may be considered congested areas. That will not 

always be the case when providing a 'Property Survey' flight because they could be 

conducted over empty lots or acreages with no structures. In the case of flying over 

or near existing private property while providing aerial imagery, property 

inspections, and property assessments, landowners will be notified in person by the 

Petitioner, or by a card left behind by the Petitioner if requested. The Petitioner will 

review with the landowners of associated risks to people and property. Due to the 

small size of the UAS the associated risk to persons, vessels, vehicles and structures 

is not comparable to manned aircraft and should be taken into consideration. 

14 CFR 91.121: Altimeter Settings 

This section requires that each person operating an aircraft shall maintain the 

cruising altitude or flight level of that aircraft, as the case may be, by reference to an 

altimeter that is set, when operating below 18,000 feet MSL. 

Reason for Exception 

Most UAS do not have a barometric altimeter. If does have a GPS that will calculate 

altitude. The Petitioner will limit flights to a maximum altitude of 400 feet AGL as 

granted in Exemption No. 11623, 11664, and 11734. 

14 CFR 90.151 (a) Fuel Requirements for Flight in VFR Conditions 

Fuel requirements for flight in VFR conditions: (a) No person may begin a flight in 

an airplane under VFR conditions unless (considering wind and forecast weather 

conditions) there is enough fuel to fly to the first po\nt of intended landing and, 

assuming normal cruising speed. (1) During the day, to fly after that for at least 30 

minutes. 

Reason for Exception 

The UAS provides a low battery warning to indicate when you should return the 

UAS to the launch point In addition, a "low" and "critical" battery level warnings 

and implemented a "Return to Home" action in these situations. The Petitioner will 

not initiate a night unless batteries are fully charged, and will make sure to reserve 

25% of the battery life for returning home, giving plenty of time to get back to the 

landing point. 
14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration 

This regulation provides as follows: 

• No person may operate a civil aircraft unless it has an appropriate and 

current airworthiness certificate. 

• No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization 

issued under 19.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. 

Reason for Exception 

To obtain an equivalent level of safety and meet the intent of91.203, 

documentation will be housed at a ground control point where the pilot is flying the 

UAS for immediate access to the extent they are applicable to the VAS's. In doing 

some research the FAA has issued numerous exemptions to this regulation. 

14 CFR 91.405 (a): Maintenance Inspections 

Each owner or operator of an aircraft- (a) shall have that aircraft inspected as 

prescribed in Subpart of this part and shall between required inspections, except as 

provided in paragraph (c) of this section. have discrepancies repaired as prescribed 

in part 43 of this chapter. 

Reason for Exception 

The Petitioner shall inspect the aircraft prior to every flight The Petitioner also will 

follow the manufacturer's recommended preflight checklist and make any repair 

necessary before flights occur. The Petitioner will also maintain a log of any 

maintenance or repairs performed. 

14 CFR 91.407 {a) {1): Maintenance 

Operation after maintenance, preventative maintenance, rebuilding or alteration: 

(a) No person may operate any aircraft that has under gone maintenance, 

preventative maintenance, rebuilding. or alteration unless (1) it has been approved 

for return to service by a person authorized under 43.7 of this chapter. 

Reason for Exception 

The Petitioner who has the responsibility for the operation and safety of the UAS 

will follow the manufactures suggested replacement parts. 

14 FR 91.409 (a)O) & (2): Inspections 

Inspections: (a) Except as provided in paragraph (c) of this section, no person may 

operate an aircraft unless, within the preceding 12 calendar months, it has had (1) 

an annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by 43.7 of this chapter; or (2) 

An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter. No inspection performed under paragraph (b) of this section 

may be substituted for any inspection required by this paragraph unless it is 

performed by a person authorized to perform annual inspections and is entered as 

an "annual" inspection in the required maintenance records. 
Reason for Exception 

The Petitioner will follow manufacturer's suggestions to ensure that the UAS is in a 

condition for safe flight at all times. 

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

Except for work performed in accordance with 91.411 and 91.413 each registered 

owner or operator shall keep the following records (l)(i) (ii)(iii) 

(2)(i)(ii)(iii)(iv)(v)(vi) for the periods specified in paragraph (b) of this section: (1) 

(2) (3) 

Reason for Exception 

The Petitioner will keep a record of all repairs and modifications. The Petitioner also 

proclaims to use approved manufactured parts for all repairs and modifications. 

14CFR Title 14 Chapter 1 Subchapter D Parts 60 thru 67-61.1 to 61.429: Pilot 

Certification 

This section pertains to flight rules, pilot certificate requirements, manuals, etc. 

Reason for Exception 

The Petitioner believes that these requirements are unnecessary for pilot controlled 

drone flights and current FSS proposals have omitted this as a future requirement 

for small UAS's. 

In Conclusion: 

I, Trent Strobel, the Petitioner request for exemption from the above mentioned 

Federal Aviation Regulations in order to legally operate an Unmanned Aircraft 

System (UAS) in the National Airspace System in order to perform the Applications 

and Operations listed above in a safe and controlled environment. The Petitioner 

hopes for a timely consideration as I have made a considerable investment in time 

and finances on this project. 

Trent S robel 

103 Windham Circle 

Hendersonville, TN 37075 

(615)-574-8475 (Cell) 

trentstrobel@me.com (E-mail)