January 6'', 2016 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave 

Washington, DC 20590 

Re: Request for exemption under Section 333 of the FHA Modernization and Reform Act of 2012 and 

Part 11 of the Federal Aviation Regulation. 

Name and Address of the Petitioner: 

Jacob Gould 

28 Buckingham Place 

Saint Charles, MO 63301 

314-402-0736 

Jacob.gould@outlook.com 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 

C.F.R. Part 11, Jacob Gould, 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: 

14 CFR 21h 

14 CFR 45.23 (B) 

14 CFR 61.113 (A) 7 (b) 

14 CFR 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 CFR 91.103 (b) 

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)(1) & (2) 

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. 

Application and Operations: 
Land Surveying and Mapping 

Aerial Photography 

Surveying of Status of Land Development Projects 

Crop and Pasture Assessments 

Real Estate Photography 

Exterior Photographs and videos 

Equipment Inspections 

Visual Monitoring of Equipment 

The Petitioner believes the use of the UAS'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 UAS to be used is the DJI Phantom 3 Professional. This UAS features as quad rotor, unmanned 

aircraft and handheld ground control station. The DJI Phantom 3 Professional has a max gross weight of 

approximately 2.8 pounds, diameter (rotor span) 23.75 inches, width of 12.5 inches, and height of 8.1 

inches. The DJI Phantom 3 Professional is equipped with four rotors driven by a lithium battery with 

electric motors. 

Here is an overview of the proposed aircraft specifications. Additional design and operational 

specifications are contained in the DJI Phantom 3 Operating Manual (Attachment A). 

Weight (including battery and propellers) 

Diagonal size {including propellers) 

Max Ascent Speed 

Max Descent Speed 

Hover Accuracy 

Max Speed 

1280g 

590mm 

5 m/s 

3 m/s 

Vertical:+/- 0.1 m (when Vision Positioning is active) 

16 m/s (Ani mode, no wind) 

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 

Certification Procedures for Products and Parts 

Equivalent Level of Safety 

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

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. 

Equivalent Level of Safety 

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

will not have an entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be 

placed. Given the size of the UAS, two inch lettering will be impossible. 
14 CFR 61.113 (A) 7 (b): Private Pilot Privileges and Limitations 

The regulations 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 is only incidental to that business or employment. (3) The aircraft does not carry passengers or 

property for compensation or hire. 

Equivalent Level of Safety 

The Petitioner will follow all manufacture's' training program and safety manual. I also believe these 

requirements are unnecessary to pilot controlled drone flights. 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. 

Equivalent Level of Safety 

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. 

Equivalent Level of Safety 

The equivalent level of safety will be maintained by keeping the manufactures Operations Manual at the 

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

14 CFR 91.103 (b): Preflight Instruction 

This regulation requires each pilot in command to take certain actions before flight to insure the safety 

of flight. 

Equivalent Level of Safety 

As FAA approved rotorcraft flight manuals will not be provided for the aircraft and exemption will be 

needed. The Petitioner will take all actions including reviewing weather, flight battery requirements, 

landing and takeoff distances and aircraft performance date before initiation of flight. 

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. 

Equivalent Level of Safety 

The use of UAS will be flown no higher than 400 feet AGL 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, or property assessments, landowners will be notified in person by the Petitioner, 

or 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 in 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. 

Equivalent Level of Safety 

Most UAS do not have a barometric altimeter. It does have a GPS that will calculate altitude. The 

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

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 underVFR 

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 

to at least 30 minutes. 

Equivalent Level of Safety 

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

UAS to the launch point. The Petitioner will not initiate a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly an normal cruising speed to the intended landing point 

and all flights will be conducted during daylight hours. 

14 CFR 61.203 (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. 

Equivalent Level of Safety 

The UAS registration number will be properly displayed following the new rules set in place on 

December 21", 2015. The UAS will also be properly registered on the website. Since no airworthiness 

certification will be issued for UAS's it is impossible to follow the above requirements. 

14 CFR 91.405 (a): Maintenance Inspections 

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

the 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. 

Equivalent Level of Safety 

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 the 

chapter. 

Equivalent Level of Safety 
The Petitioner who has the responsibility for the operation and safety of the UAS will follow the 

manufactures suggested replacement parts. 

14 CFR 91.409 (a)(1) & (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. 

Equivalent Level of Safety 

The Petitioner will follow manufacturer's suggestions to ensure that the UAS is in condition safe for 

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

of this section: (1) (2) (3) 

Equivalent Level of Safety 

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. 

14 CFR 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. 

Equivalent Level of Safety 

The Petitioner believes that these requirements are unnecessary for pilot controlled drone flights and 

current FAA proposals have omitted his as a future requirement for small UAS's. 

In Conclusion: 

I, Jacob Gould, the Petitioner request 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 Applications and Operations pertaining to my Real Estate and Farming work 

in a safe and controlled environment. 

Sincerely, 

Jacob Gould 

28 Buckingham Place 

Saint Charles, MO 63301 

314-402-0736