**REABC, LLC** Samuel A. Langham Private Pilot Certification Number 3532778

138 32 nd Avenue South Jacksonville Beach, FL 32250 O (904) 249 -3403. F (904) 249 -3441. C (904) 613 -9122. salangham@reabc.com

Page **1** of **6** November 2 3 , 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 U nmanned 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** Th e UAS to be used will be the DJI Phantom 3 quadcopter aircraft, a remote control ler 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

Page **2** of **6** The remote control ler 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 operation s such as maximum flight altitude and radius limits. I t also provides important safety features such as manufacturer programmed n o -fly zones and the ability to set a home point and automated return to home abilities. Other safety features of the Phantom 3 are include d within the m anufacturer'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 INFORMATI ON**  **AND CONSIDERATIONS**
 Operations will be made only with the a ircraft 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 n ot exceeding design specifications at all times (36 mph in no wind environment).
 The maximum altitude of o perations 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 th e VO at all times during flight operation s . The PIC and the VO will be able to verbally communicate with each other at all times during flight operations. PIC will b e 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

Page **3** of **6**  Prior to each flight th e 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 visibl e 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 day light 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 pre determined 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 con duct 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 operati ons 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,REABC, LLC

Page **4** of **6** vessels, vehi cles 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 pe rmission 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 wil l 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 amend ments 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 require d clarification or additional information. We look forward to worki ng with your office. Very truly yours,

REABC, LLC by Samuel A. Langham , its managing member Addend a Phantom 3 Professional SpecificationsREABC, LLC ADDENDA

Page **5** of **6**REABC, LLC ADDENDA

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