Charles von Stackelberg

35 Lee st #18

Cambridge, MA 02139

978-239-6364

christianvonstackelberg@gmail.com

1/12/16

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Dear Sir or Madam,

Charles von Stackelberg seeks exemption from the following sections of 14 C.F.R.:

14 C.F.R. 21

14 C.F.R. 45.23 (b)

14 C.F.R. 61.113 (a) & (b) 14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.405 (a)

14 C.F.R. 407 (a) (1)

14 C.F.R. 409 (a) (2)

14 C.F.R. 417 (a) & (b)

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform 

Act) and 14 C.F.R. Part 11, Charles von Stackelberg (herein referred to as “applicant”), 

operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to conduct aerial videography and photography for the real estate and construction industry and other 

similar applications such as search and rescue, hereby applies for an exemption from 
the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its 

sUASs, 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. As described more fully below, the requested exemption would permit the operation of 

small, unmanned sUAS under controlled conditions in the NAS that is 1) limited 2) predetermined 3) controlled as to access. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

This exemption application is expressly submitted to fulfill Congress’ goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in 

the national airspace system (NAS) before completion of the rule making required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or 

the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft in the national airspace system.” Id. § 333 (c) (emphasis added). The 

Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority by its terms includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of 

this section or any sections 44702-44716 of this title if the Administrator finds the 

exemption in the public interest. 49 U.S.C. § 44701 (f) See also 49 U.S.C. § 44711 (a); 

49 U.S.C. § 44704; 14 C.F.R. § 91.203 (a) (1). The applicant’s sUASs are rotorcraft, 

weighing 55 lbs. or fewer, including payload. They operate, under normal conditions at 

a speed of no more than 40 knots and have the capability to hover, and move in the 

vertical and horizontal plane simultaneously. They will operate only in line of sight and 

will operate only within a predetermined and closed of property area under the permission of the property representative. Such operations will insure that the sUAS will 

“not create a hazard to users of the national airspace system or the public” as per the 

Reform Act Section 333 (b). Given the small size of the sUASs involved, the restricted 

sterile environment within which they will operate, and the fact that they will be flown 

by an FAA licensed aircraft pilot, the applicant falls squarely within that zone of safety 

(an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence immediately. Also due to 

the size of the UASs and the restricted areas in which the relevant sUASs will operate, 

approval of the application presents no national security issue. Given the clear direc-
tion in Section 333 of the Reform Act, the authority contained in the Federal Aviation 

Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for 

real estate and construction videography operations, the grant of the requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that 

the FAA grant the requested exemption without delay.

EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that 

have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations 

under the current regulatory structure because the proposed operations are conducted 

on closed of property under the permission of the property owner or property representative. Proposed limitations and conditions to which applicant agrees to be bound 

when conducting commercial operations under an FAA issued exemption:

• The PIC will hold a current ASEL (airplane, single engine, land) certificate, and either 

an FAA-issued airman medical certificate, or a current U.S. driver’s license. Operation 

of the applicant’s sUAS will be limited to the applicant’s sole and primary pilot who 

meets these criteria who’s certification’s are listed below:

• The sUAS will weigh no more than 55 lbs.

• Flights operations will be outside of five (5) nautical miles from any airport reference 

point (ARP). If asked to operate within five (5) miles of an airport, the applicant will 

contact the airport's manager and control tower with all flight plans, as well as the FAA 

through a normal filing of a Form 7711-1 (or its equivalent) with the appropriate FSDO. 

Only upon approval of flight plans from all entities will we agree to, and conduct, any 

operation within five (5) miles of an airport.

• Flights will be operated within line of sight (un-aided) of a pilot and/or observer.

• Maximum total flight time for each operational flight will be 20 minutes. Flights will 

be terminated at 20% battery power reserve should that occur prior to the 20 minute 

limit, and no further flights shall be commenced on the same batteries unless they 

hold enough energy for a minimum of 5 minutes of flight time, or the minimum recommended by the craft manufacturer.

• All operations shall be conducted in accordance with an ATO-issued COA

• Flights will be operated at an altitude of no more than 400 feet AGL or, not more 

than 200 feet above an elevated platform from which filming is planned. If a structure 

being filmed or photographed has a height which exceeds 400 feet AGL, the UAS will 

not exceed 100 feet in height above the highest point on that structure.
• Minimum crew for each operation will consist of the sUAS Pilot, and the Visual Observer.

• sUAS Pilot will be Pilot in Command (PIC). The PIC will have a minimum of 30 hours of 

flight time with the specific sUAS equipment the applicant operates. The experience of 

the PIC will be certified by the applicant through background checks and, if necessary, 

testing.

• Applicant will maintain flight logs of all PICs it employs, and provide full transparency 

to the FAA regarding the logs and records of these PICs, as per 14

CFR § 61.51(b),

• Flights will be operated at a lateral distance of at least 100 feet from any inhabited 

structures, buildings, vehicles, vessels, or people not associated with the operation or 

who have not signed a waiver in advance of the operation.

• A briefing will be conducted in regard to the planned sUAS operations prior to each 

day’s production activities. It will be mandatory that all personnel involved with the 

operational duties of the flight within the boundaries of the safety perimeter be present for this briefing.

• The operator will file an FAA Form 7711-1, or its equivalent, as modified in light of 

the requested exemption, with the appropriate local Flight Standards District Ofce.

• The operator will obtain the consent of all persons involved in the filming and ensure 

that only consenting persons will be allowed within 100 feet of the flight operation, 

and this radius may be reduced to 30 feet based upon an equivalent level of safety determination. With the advanced permission of the relevant FSDO, operations at closer 

range can be approved.

• PIC and Visual Observer will have been trained in the operation of the specific sUAS 

equipment used by the applicant, and received up-to-date information on the particular sUAS to be operated.

• The PIC designated for any operation will have at least a Class 2 medical certificate.

• Visual Observer and PIC will at all times be able to communicate by voice, radio, and/

or text.

• Written and/or oral permission from the relevant property holders or property representatives will be obtained.

• All required permissions and permits will be obtained from territorial, state, county 

or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies.

• If the sUAS loses communication with the PIC or loses its GPS signal, the sUAS will 

have the capability to return to a pre-determined location within the controlled property, and land autonomously.
• The sUAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies.

• sUAS operations will not be conducted at night, as defined in 14 CFR § 1.1

• The sUAS will give way to any and all manned aviation operations and activities, at all 

times

• The sUAS will not be operated from any moving vehicle or device

• Any incidents shall be reported to the FAA’s UAS Integration ofce within 24 hours.

• During operations for closed-set motion picture and television filming and production, the PIC will have a motion picture and television operations manual (MPTOM), as 

seen in this applications docket folder.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given 

the size and limited operating area associated with the aircraft to be utilized by the 

applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS to be 

operated hereunder is 55 lbs. or less fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area. Unlike other civil aircraft, operations under this exemption will be 

tightly controlled and monitored by both the operator and under the requirements and 

in compliance with local public safety requirements, to provide security for the area of 

operation as is now done with conventional filming. The FAA will have advance notice 

of all operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater 

degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application of these same criteria demonstrates that there is no credible threat to national security posed by the sUAS due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:
When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited", "restricted", "light-sport", "experimental", 

or "provisional", as applicable. Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, 

cockpit or pilot station on which the word “Experimental” can be placed. Given the size 

of the sUAS, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f), and the equivalent level of safety 

will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) 

where the pilot, observer, and others working with the sUAS will see the identification 

of the sUAS as “Experimental”. The FAA has issued the following exemptions to this 

regulation as Exemption Numbers 10700, 8738, 10167 and 10167A. 14 C.F.R. § 

61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. The PIC will 

hold a current, FAA issued, ASEL (aircraft, single engine, land) certificate. Sections 

61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS 

will not carry a pilot or passengers, the proposed operations can achieve the equivalent 

level of safety of current operations by requiring the PIC operating the aircraft to have 

no less than 40 hours of flight time with the specific sUAS equipment the

applicant operates. The experience of the PIC will be certified by The applicant through 

background checks and, if necessary, testing. The applicant will maintain flight logs of 

all qualified PICs it employees as per 14 CFR § 61.51(b), and provide full transparency 

to the FAA regarding the logs and records of these PICs. The PIC designated for any 

operation will hold an FAA issued pilots license, and have at least a Class 2 medical 

certificate, or U.S issued driver’s license. The risks associated with the operation of the 

sUAS are so diminished from the level of risk associated with commercial operations 

contemplated by Part 61 when drafted, that allowing operations of the sUAS by a PIC 

meeting the standards of the applicant (listed above) exceeds the present level of safety achieved by 14 C.F.R. § 61.113 (a) & (b).

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. The applicant proposes that an equivalent level of safety will be 

provided by the use of the following safety checklists prior to each flight in order to 

determine if the sUAS is in condition for safe flight:

Aircraft: All adjustment points will be checked for tightness; all motors and props will 

be inspected; all wiring will be double-checked; all systems will be powered up and 

checked for errors as per the flight systems manuals.

Battery: Confirmation will be made that batteries are fully charged and installed/connected properly.
Calibration: Pre-flight motor/gyro/compass calibration followed by confirmation of no 

errors with the flight and navigation systems.

Transmitter: Confirm radio transmitter has sufcient charge, and is both working properly and receiving telemetry from the sUAS; confirm all switches are in pre-flight 

mode, and that a successful link has been established between the aircraft transmitter 

and onboard receiver. Confirm sufcient satellites are present for navigation system in 

the event of failsafe trigger Home point coordinates are confirmed recorded by navigation system prior to take-of

Surroundings/Flight Area: Conduct one last visual inspection of the take-of surroundings and area of airspace sUAS will be operating in. Confirm all people in the surrounding areas are associated with the operation being conducted.

Take-of Announcement: Before motors are started the PIC will announce to a designated Representative (person of authority) of the film crew that sUAS is ready to take-of. 

Only after the Representative has notified all persons within the surrounding areas, and 

confirmed to PIC that they have clearance to lift-of, will the motors be started and the 

sUAS will conduct its operation. A mandatory test flight will be conducted after any disassembly/reassembly; after replacement of any motors or flight electronics; after any 

pre-flight or in flight equipment errors that occur not resulting from environmental 

conditions. This will be done before commercial operation is commenced. All maintenance, overhaul, replacement, and inspections will be carried out as per the manufacturers specifications by a knowledgeable and capable person with the experience necessary to ensure safe operation of the sUAS, and documented in the aircraft’s records.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ... (2) For which an Airplane or 

Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved 

manual material, markings, and placards, or any combination thereof. The sUAS, given 

its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of safety will be 

maintained by keeping the aircraft component flight manuals at the ground control 

point where the PIC flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 

9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command 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. In order to ensure consistent and 

safe operation, the PIC will perform pre-flight inspection, maintenance, and test flights 

as described above with regards to 14 C.F.R. § 91.7 (a), as well as assess mission spe-
cific requirements (flight path, flight time, obstructions, landing and take-of hazards, 

aircraft performance, weather, etc) before commencing operation.

14 C.F.R. § 91.109: Flight instruction

Section 91.109 provides that no person may operate a civil aircraft (except a manned 

free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do 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. 5778K & 9862A. The equivalent level of safety is provided by the fact that neither 

a pilot nor passengers will be carried in the aircraft, and by the size and speed of the 

aircraft.

14 C.F.R. § 91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

(d) allows helicopters to be operated at less than the minimums prescribed, provided 

the person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 feet AGL, or not more 

than 200 feet above an elevated platform from which filming is planned, an exemption 

may be needed to allow such operations. As set forth herein, the sUAS will never operate at higher than 400 feet AGL with the exception that in circumstances where the 

sUAS is used to survey or photograph a structure whose height exceeds 400 feet AGL, 

the UAS will not be operated more than 100 feet above the highest point on the structure. It will however be operated in a restricted area with security perimeter, where 

buildings and people will not be exposed to operations without their pre-obtained 

consent. The equivalent level of safety will be achieved given the size, weight, and 

speed of the sUAS as well as the location where it is operated. No flight will be taken 

without the permission of the property owner or local ofcials. Because of the advance 

notice to the property owner and participants in the filming activity, all afected individuals will be aware of the planned flight operations. Compared to flight operations 

with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk associated with these operations is far less 

than those presently presented with conventional aircraft operating at or below 400 

AGL in the movie industry. In addition, the low-altitude operations of the sUAS will ensure separation between these small UAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. § 91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or an 

appropriate altimeter setting available before departure.” As the sUAS may not have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be nee-
ded. An equivalent level of safety will be achieved by the operator, pursuant to the 

safety check list and live flight data monitoring, confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight.

14 C.F.R. § 91.151 (a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane under 

VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising 

speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to 

fly after that for at least 45 minutes.” The battery powering the sUAS provides no more 

than 20 minutes of powered flight. To meet the 30 minute reserve requirement in 14 

C.F.R. § 91.151, sUAS flights would not be possible due to the reserve requirement 

being equal to the maximum flight time. Given the limitations on the sUAS’s proposed 

flight area and the location of its proposed operations within a predetermined area, a 

longer time frame for flight in daylight or twilight VFR conditions is reasonable. The 

applicant believes that an exemption from 14 C.F.R. § 91.151 (a) falls within the scope 

of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to 

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly 

controlled area where only people and property owners or ofcial representatives who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not 

engender the type of risks that Section 91.151 (a) was intended to alleviate given the 

size and speed of the small UAS. Additionally, the limitations created by this requirement for sUAS flights would essentially make null any utility for which the exemption 

will be granted. The applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 20% of battery power— whichever happens 

first. This restriction would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. Similar exemptions have 

been granted to other operations, including Exemptions 2689F, 5745, 10673, and 

10808.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) 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 §91.715 

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

The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard 

pilot. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. An equivalent level of safety will be achieved by 

keeping these documents at the ground control point where the pilot flying the sUAS 

will have immediate access to them, to the extent they are applicable to the sUAS. The 

FAA has issued numerous exemptions to this regulation. A representative sample of 
other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 

9816A, and 10700.

14 C.F.R. § 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall have that aircraft 

inspected as prescribed in subpart E 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...,” and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to 

aircraft with an airworthiness certificate, these sections will not apply to the applicant. 

Maintenance and inspections will be done in accordance with the sUAS Manufacturer's 

Manual, and will be performed by employees of the applicant following the guidelines 

and practices provided to us bythe sUAS Manufacturer. An equivalent level of safety 

will be achieved because these small UASs are very limited in size and will carry a small 

payload and operate only in restricted areas for limited periods of time. If mechanical 

issues arise the sUAS can land immediately and will be operating from no higher than 

400 feet AGL. The PIC will ensure that the sUAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. 

Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Additional Views

Regarding Privacy:

All flights will occur over private or controlled access property with the property representative or owner’s prior consent and knowledge. Filming will be of people who have 

also consented to being filmed or otherwise have agreed to be in the area where 

filming will take place. All flights will occur in accordance with any state or local laws 

regarding privacy.

Additionally, our company seeks to conform to privacy regulations what we believe are 

necessary, and imminent, if the UAS industry is to be accepted by the general public, 

and therefore the motion picture and TV industries.

Overall Safety and Benefits of Granting Exemption:

1. Helping to shed a positive light on the commercial use of UAS and to set an example 

in safety and professionalism within the industry and hobby as a whole, by the following standards.

• Encouraging others to spend the necessary time required to be an experienced pilot.

• Being an outward advocate for FAA compliance, stressing the importance of safety 

and

 following FAA protocol. Line of sight only flights, below 400 feet in altitude, in nonrestricted
 airspace.

• Pre and Post-Flight checklists to ensure that batteries, components, and the integrity 

of the

 aircraft are in order.

• Utilizing a Pilot’s Assistant to ensure that equipment has not been damaged in transport,

 assist with maintenance, verify that the pilot’s pre and post-flight checklists have 

been

 performed properly, and to assist with safety education before, during, and after the 

flight(s).

• Respecting and maintaining public privacy.

• Never flying over people or crowds.

• Never flying under the influence of alcohol or other substances.

• Never flying near or around power lines.

• Never flying in high winds or bad weather.

• Providing professional education to the public.

2. Use of UAS verses full scale helicopters provide a safer environment for filming.

3. Provide economic growth for the public by allowing the public to hire Charles von 

Stackelberg, and allowing Charles von Stackelberg to grow and take on employees.

Current UAS Systems Operated by Charles von Stackelberg:

DJI Phantom 3 professional

The DJI phantom 3 is a quad copter that utilizes a revolutionary new flight controller 

that allows for

extremely accurate flight both in and outdoors, and boasts a 4K camera, and flight times

exceeding 20 minutes. This unit also has a built in 720p video transmission system, 

complete

with full telemetry.

Aircraft Weight: 2.8 lb

Dimensions (diagonal including propellers): 23.2 in

Propeller: Plastic, Model 9450
Motor: DJI Phantom Motor

Flight Controller: DJI Professional

Video Downlink: Built-in 720p

Batteries: 4S 4480MAH

Pre-Flight Procedure

• Check the reliability of the Multi-Rotor.

• The flight battery and transmitter battery must be fully charged.

• Always turn on the transmitter first and then the Multi-Rotor.

• Watch for visible damage such as loose screws, broken, unbalanced or damaged propellers,

 faulty connectors or solder joints, broken pipes, etc.

• The propeller must be in a good condition and securely mounted. The rotors must 

spin smoothly. Please ensure that there are no objects are in the rotational plane of the 

propellers or within a distance that poses a risk of obstruction. Rotating propeller 

ends are dangerous to touch - never touch a rotating propeller with fingers or other 

body parts.

• Ensure the appropriate to the audible beeps when auto lipo-detection is enabled. 6 * 

beep means 6s Lipo

• Ensure that the selected channel on the remote control is free and that you're within 

range of the transmitter.

• Ensure the sensors are calibrated (when the motors are of move yaw and gas stick 

into upper left corner until it beeps).

• Diferent settings can result in fundamentally diferent flight characteristics and occupation of the Channel functions. Make sure that you are familiar with the setting and 

its features.

• After starting the motors, check that all motors are running and rotate evenly. Please 

fly carefully at a low altitude until you know that everything is working fine.

• Perform a pre-flight check (see checklist below).

• Start manually - switch of altitude control and GPS.

Pre-Flight Checklist

• Weather conditions are suitable.

• Frame and all screws are tight.

• Propeller not damaged and tightly fixed.
• Battery fully charged and securely mounted.

• Transmitter battery charged and the antennas are free.

• Channel of the transmitter is not busy. If 35/40/70MHz or other MHz-RC-controls 

are in operation simultaneously, the used channels must be checked with the other 

pilots (not necessary for 2.4 GHz systems).

• Check RC(TX/RX) operation range (on the ground!) from time to time (and before 1st 

flight).

• Ensure there is nothing in the danger zone of the propeller.

• Ensure enough space for launch and flight.

• Ensure the GPS module (if any) has GPS fix. If CH or PH is active it will beep every second.

 Check that when you switch to GPS mode, there will be an audible beep.

• For manual start ensure GPS and altitude controls are turned of.

• Ensure sensors are calibrated and that the right setting is loaded.

• Ensure the trim of the remote control is in neutral position.

In-Flight Procedure

• Do not take risks! Your own safety and that of your environment depend on the good 

behavior of the pilot. Always maintain a safe distance from people, animals and objects. Improper operation can cause serious injury and property damage! Never fly 

towards viewers and avoid flying over spectators.

• Keep in mind that viewers could get close to the Multi-Rotor, without being aware of 

potential dangers.

• Always turn of the Multi-Rotor first and disconnect the flight battery before turning 

of the transmitter.

• Only fly in line of sight. In the case of manual control, you must be able to see the 

position and altitude. Never fly over 400 feet.

• Never rely 100% on functions such as GPS, compass, or altitude control. You must 

always be able to take manual control of the Multi-Rotor.

• Reduce the throttle or switch of the motors in case of a crash or failure.

• Do not fly in restricted air space, such as in the vicinity of airports, etc.

• Pay attention to under-voltage warning -flying on an empty battery can cause damage to the Lipos and crash.

• If a defect or malfunction has occurred, it must be corrected before the next start.

• When using GPS, take note that the position of the Multi-Rotor can change suddenly.
Post-Flight Procedure

• Disconnect the battery and check all over for damage. Make sure that there is no 

damage to the propellers.

• See the Handling and safety precautions of Lipo batteries.

• If the Multi-Rotor is involved in a crash or hard landing the sensors and electronics 

might be

 damaged. Before the next start everything must be checked.

Similar granted petitions are as follows: 2/18/2015 Picture Factory, Inc., 2/13/2015 

Capital Aerial Video, LLC., 2/10/2015 Blue-Chip UAS, 2/3/2015 Helinet Aviation Services, LLC., 2/3/2015 Alan D. Purwin, 1/29/2015 Slugwear, bda Likeona Tree, 

1/29/2015 Team 5, 1/29/2015 Shotover, 1/23/2015 AeroCine, 1/23/2015 Burnz Eye 

View, 1/6/2015 Douglas Trudeau, 12/10/2014 Clayco, 10/10/2014 Flying Cam, 

9/25/2014 Astraeus Aerial, 9/25/2014 Aerial MOB, 9/25/2014 Pictorvision, 

9/25/2014 HeliVideo Productions, 9/25/2014 Snaproll Media, 9/25/2014 RC Pro Productions Consulting, dba Vortex Aerial.

In Summary, Charles von Stackelberg with its pilot and observer seek exemption from 

the following regulations: 14 C.F.R. Part 21, 14 C.F.R. Part 45.23 (b), 14 C.F.R. Part 

91.7 (a), 14 C.F.R Part 91.9 (b)(2), 14 C.F.R. Part 91.103, 14 C.F. R Part 91.109 (a), 14 

C.F.R. Part 91.119, 14 C.F.R. Part 91.121, 14 C.F.R., Part 91.151 (a), 14 C.F.R. Part 

91.203 (a) & (b) , 14 C.F.R. Part 91.405 (a), 407 (a)(1), 409 (a)(1) & (2), 417 (a) & (b), to 

commercially operate their sUAVs, weighing under 55 pounds, in a safe manure and to 

provide the public awareness and safety.

If granted the exemption from the FAA Charles von Stackelberg will continue to abide 

by the FAA regulations and policies set in place. If granted the exemption Charles von 

Stackelberg will submit a Certificate of Waiver or Authorization (COA) before any commercial jobs are performed. Commercial operations would include but are not limited 

to, aerial footage for the film industry, TV productions, real estate, construction, aerial 

timelapses, surveying for development, agriculture inspection, search and rescue, supporting local law enforcement, fire departments, inspectors, structural engineers and 

aerial mapping.

Sincerely,

Charles von Stackelberg

1/12/2016