REABC, LLC 

Samuel A. Langham

Private Pilot Certification Number 3532778

138 32nd Avenue South

Jacksonville Beach, FL 32250

O (904) 249-3403. F (904) 249-3441. C (904) 613-9122.

salangham@reabc.com

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November 23, 2015

VIA FEDERAL DOCUMENT MANAGEMENT SYSTEM

U.S. Dept. of Transportation, Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

RE: EXEMPTION REQUEST UNDER SECTION 333 OF THE FAA REFORM ACT AND PART 11 OF FAR

FOR COMMERCIAL OPERATION OF AN UNMANNED AIRCRAFT SYSTEM

DJI PHANTOM 3 PROFESSIONAL – CRAFT S/N: P76DCI09A21273

Dear Sir or Madam:

Pursuant to the Reform Act, REABC, LLC, requests a Certificate of Waiver or Authorization to operate the 

above Unmanned Aircraft System for commercial purposes (for aerial photography and videography)

within our National Airspace. To the extent required for safe UA operations, relief from the Federal 

Aviation Regulations below (and any additional applicable regulations) is being requested:

14 CFR §§

Part 21, Certification Procedures for Products and Parts, Subpart H – Airworthiness Certificates

Part 36, Noise Standards: Aircraft Type and Airworthiness Certification, as applicable 

45.29 – Size of marks

61.113(a)

91.7(a)

91.119(b) and (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)

OVERVIEW

The UAS to be used will be the DJI Phantom 3 quadcopter aircraft, a remote controller connected to a 

smartphone or tablet computer and associated software. The aircraft is powered by a rechargeable 

battery, has a gross weight (fully equipped) of 1280 g (2.8 lbs.) and a maximum airspeed is 16 

meter/second or approximately 36 mph (no wind conditions). Operational and aircraft specification as 

provided by the manufacturer are attached within the addenda. 
REABC, LLC

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The remote controller transmits on frequencies between 2.400-2.483 GHz up to a distance of 2.1 miles 

(unobstructed and free of interferences). The remote controller connects to a tablet or smartphone on 

which a computer application, the DJI GO app, provides an interface. This interface allows programming 

of flight operations such as maximum flight altitude and radius limits. It also provides important safety 

features such as manufacturer programmed no-fly zones and the ability to set a home point and 

automated return to home abilities. Other safety features of the Phantom 3 are included within the 

manufacturer's operation manual and quick start guide which can be made available upon request. 

This Unmanned Aircraft, given its size, weight, speed, and limited operating area will not adversely affect 

the public’s safety and may, in fact, provide the safest, most economical and environmentally sound 

means of acquiring the proposed aerial data. 

ADDITIONAL INFORMATION AND CONSIDERATIONS

 Operations will be made only with the aircraft specified herein unless further exemptions 

and/or exemption amendments are requested by this petitioner and issued by the FAA. 

 The UA Gross weight shall not exceed its gross designed weight of 2.8 lbs. 

 The UA will be operated at an airspeed not exceeding design specifications at all times (36 

mph in no wind environment). 

 The maximum altitude of operations will be 400 feet above ground level. 

 Visual Line of Sight (unaided) will be maintained at all times.

 All operations will utilize a Visual Observer. The UA will be operated within the VLOS of both 

the PIC and the VO at all times during flight operations. The PIC and the VO will be able to 

verbally communicate with each other at all times during flight operations. PIC will be 

designated as such before the flight and this designation shall not be transferred during flight. 

The PIC will ensure that the VO can perform all duties required of the VO at all times during 

flight operations.

 Operating Documents, which at a minimum, specify the conditions and limitation stated in 

the grant of exemption will be accessible and made available upon request to the 

Administrator or any Law Enforcement Officer during all times of operation. Additionally, any 

documents required by §§91.9 and 91.03 or used by the PIC to ensure safe operations will be 

maintained in near proximity to the ground control station. These documents will be 

available to the Administrator or to any law enforcement official upon request.

 All maintenance or alterations to the UAS will be made by the manufacturer or by a 

manufacturer approved repair company/personnel. After any such repairs the UAS will be 

tested by the PIC and accompanying VO prior to any commercial flight.

 The PIC will be responsible for maintaining and inspecting the UAS to ensure its safe 

operation. This includes following the manufacturers maintenance, overhaul, replacement 

inspection, and life limit requirements for the UA and its components.
REABC, LLC

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 Prior to each flight the PIC will conduct pre-flight inspection to assess its safe operation 

including the following manufacturer recommended items:

o Remote controller, Intelligent Flight Battery, and mobile device are fully charged.

o Propellers are mounted correctly and firmly.

o Micro-SD card has been inserted, if necessary.

o Gimbal is functioning normally.

o Motors can start and are functioning normally.

o The DJI Go app is successfully connected to the aircraft.

o The onboard compass is calibrated.

o Aircraft Status Indicators are visible and working properly.

 The UA will be operated in compliance with all manufacturer safety bulletins, 

announcements, etc.

 The operator holds a private pilot certificate and a current Third Class medical certificate.

 The operator will not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight 

hours and currency will be logged in a manner consistent with §61.51

 Operations will only occur during daylight hours and under visual meteorological weather 

conditions. Operations will only occur when wind speeds are less than 10 m/s (22.3 mph) as 

recommended by the manufacturer. The UA will not be operated less than 500 feet below or 

2,000 feet horizontally from a cloud or when visibility is less than three (3) statute miles from 

the PIC.

 The UAS will not be operated within five (5) nautical miles of an airport or heliport unless a 

letter of agreement with that airport’s management is obtained or otherwise permitted by 

the issued COA. This letter of agreement will be maintained as an Operating Document. 

 If the UAS loses communications or GPS signal the UA will be set to return to a predetermined location within the private or controlled access property.

 Operations will be aborted in the event of unpredicted obstacles or emergencies.

 Operations will not be commenced unless batteries are adequately charged to safely conduct 

the intended operations plus reserve power for an additional five (5) minutes of flight. 

 All operations will be conducted in accordance with the ATO-issued COA. If necessary, 

application will be made for a new or an amended COA if intended operations are outside the 

terms of the issued COA. 

 The UA will remain clear and give way to all manned aviation operations and activities at all 

times.

 All flight operations will be conducted at least 500 feet from all nonparticipating persons, 
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vessels, vehicles and structures unless:

o barriers or structures are present that sufficiently protect nonparticipants 

o the operator ensures that nonparticipating remain protected during flight operations

o the owners of any vessels, vehicles or structures have granted permission for close 

operation, and 

o the PIC has made a safety assessment of the risk of operation and that such operation 

does not present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered nonparticipants. 

 All flights over private or controlled-access property will be made with the permission of the 

property owner or their authorized representative. 

 Any incident or accident that transgresses the boundaries of the operational area as defined 

by the applicable COA will be reported to the FAA UAS Integration Office (AFS-80) within 24 

hours. Accidents will also be reported to the National Transit Safety Board per their 

instructions 

Thank you for your timely assistance with this important matter. If any modifications or amendments to 

this exemption request are required, please do not hesitate to contact us at (904) 249-3403. We will 

promptly modify this request as instructed and/or provide any required clarification or additional 

information. We look forward to working with your office.

Very truly yours,

REABC, LLC

by Samuel A. Langham, its managing member

Addenda

Phantom 3 Professional Specifications
REABC, LLC

ADDENDA

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REABC, LLC

ADDENDA

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