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08/07/2015

Brett	Parcell

My	Done	Share	LLC

16403	Broadway	Avenue

Snohomish,	WA	98296

(206)	650-4242

brettparcell@yahoo.com

I	formally	petition	the	Federal	Aviation	Administration	(FAA)	for	an	exemption	from	

part	21,	subpart	H;	and	Sections	45.23(b),	61.113(a)	and	(b),	91.7	(a),	91.119(c),	

91.121,	91.151(a),	91.203(a)	and	(b),	91.405(a),	91.407(a)(1),	91.409(a)(2),	and	

91.417(a)	and	(b)	of	Title	14,	Coe	of	Federal	Regulations	(14CFR).

Outlined	below	are	the	descriptions	of	the	part,	subpart	and	sections	in	which	I	

request	exemptions	and	my	reason	for	requesting	the	exemptions.

Part	21	prescribes	the	procedural	requirements	for	issuing	and	changing	design	

approvals,	productions	approvals,	airworthiness	certificates,	and	airworthiness	

approvals.	

Section	45.23(b)	prescribes	that	when	marks	include	only	the	Roman	capital	“N”	

and	the	registration	number	is	displayed	on	limited,	restricted	or	light-sport	

category	aircraft	or	experimental	or	provisionally	certified	aircraft,	the	operator	

must	also	display	on	that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	

station,	in	letter	not	less	than	2	inches	nor	more	than	6	inches	high,	the	words	

“limited”,	“restricted”,		“light-sport”,	“experimental”,	or	“provisional”,	as	applicable.	

Section	61.113(a)	and	(b)	prescribes	that:

(a) no	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	

of	an	aircraft	that	is	carrying	passengers	or	property	for	compensation	or	

hire;	nor	may	that person,	for	compensation	or	hire,	act	as	pilot	in	command	

of	an	aircraft.

(b) A	private	pilot	may,	for	compensation	or	hire,	act	as	pilot	in	command	of	an	

aircraft	in	connection	with	any	business	or	employment	if:

(1) The	flight	in	only	incidental	to	that	business	or	employment;	and

(2) The	aircraft	does	not	carry	passengers	or	property	for	compensation	or	hire.		

Section	91/7(a)	prescribes	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in	

an	airworthy	condition.

Section	91.119	prescribes	that,	except	when	necessary	for	takeoff	or	landing,	no	

person	may	operate	an	aircraft	below	the	following altitudes:
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(c) Over	other	than	congested	areas.		An	altitude	of	500	feet	above	the	surface,	

except	over	open	water	or	sparsely	populated	areas.		In	those	cases,	the	

aircraft	may	not	be	operated	closed	than	500	feet	to	any	person,	vessel,	

vehicle,	or	structure.

(1) A	helicopter	may	be	operated	at	less	than	the	minimums	prescribed	in	

paragraph	(b)	or	)c)	of	this	section,	provided	each	person	operating	the	

helicopter	complies	with	any	routes	or	altitudes	specifically	prescribed	for	

helicopters	by	the	FAA;	and

(2) A	powered	parachute	or	weight-shift-control	aircraft	may	be	operated	at	

less	than	the	minimums	prescribed	in	paragraph	(c)	of	this	section.

Section	91.121	requires,	in	pertinent	part,	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.”

Section	91.151(a)	prescribes	that	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	point	of	intended	landing	and,	assuming	normal	

cruising	speed,	(1)	during	the	day, to	fly	after	that	for	at	least	30	minutes	[emphasis	

added].

Section	91.203(a)	prohibits,	in	pertinent	part,	any	person	from	operating	a	civil	

aircraft	unless	it	has	within	it	(1)	an	appropriate	and	current	airworthiness	

certificate;	and	(2)	an	effective	U.S.	registration	certificate	issued	to	its	owner	or,	for	

operation	within	the	United	States,	the	second	copy	of	the	Aircraft	registration	

Application	as	provided	for	in	§	47.31(c).

Section	91.203(b)	prescribes,	in	pertinent	part,	that	no	person	may	operate	a	civil	

aircraft	unless	the	airworthiness	certificate	or	a	special	flight	authorization	issued	

under	§ 91.715	is	displayed	at	the	cabin	or	cockpit	entrance	that	it	is	legible	to	

passengers	or	crew.

Section	91.405(a)	requires,	in	pertinent	part,	that	an	aircraft	operator	or	owner	

shall	have	that	aircraft	inspected	as	prescribed	in	subpart	E	of	the	same	part	and	

shall,	between	required	inspections,	except	as	provided	in	paragraph	(c)	of	the	same	

section,	have	discrepancies	repaired	as	prescribed	in	part	43 of	the	chapter.

Section	91.407(a)(1)	prohibits,	in	pertinent	part,	any	person	from	operating	an	

aircraft	that	has	undergone	maintenance,	preventative	maintenance,	rebuilding,	or	

alteration	unless	it	has	been	approved	for	return	to	service	by	a	person	authorized	

under	§ 43.7	of	the	same	chapter.

Section	91.409(a)(2)	prescribes,	in	pertinent	part,	that	no	person	may	operate	an	

aircraft	unless,	within	the	preceding	12	calendar	months,	it	has	had	an	inspection	
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for	the	issuance	of	an	airworthiness	certificate in	accordance	with	part	21	of	this	

chapter.

Section	91.417(a)	and	(b)	prescribes,	in	pertinent	part,	that	–

(a) Each	registered	owner	or	operator	shall	keep	the	following	records	for	the	

periods	specified	in	paragraph	(b)	of	this	section:

(1)	Records	of	the maintenance,	preventive	maintenance,	and	alteration	and	

records	of	the	100-hour,	annual,	progressive,	and	other	required	or	approved	

inspections,	as	appropriate,	for	each	aircraft	(including	the	airframe)	and	each	

engine,	propeller,	rotor,	and	appliance	of	an	aircraft.		The	records	must	

include—

(i) A	description	(or	reference	to	data	acceptable	to	the	Administrator)	of	

the	work	performed;	and

(ii) The	date	of	completion	of	the	work	performed;	and

(iii) The	signature,	and	certificate	number	of	the	person	approving	the	aircraft	

for	return	to	service.

(3) Records	containing	the	following	information:

(i) The	total	time	in	service	of	the	airframe,	each	engine,	each	propeller,	and	

each	rotor.

(ii) The	current	status	of	life-limited	parts	of	each	airframe,	engine,	propeller,	

rotor,	and	appliance.	

(iii) The	time	since	last	overhaul	of	all	items	installed	on	the	aircraft	which	are	

required	to	be	overhauled	on	a	specified	time	basis.

(iv) The	current	inspection	status	of	the	aircraft,	including	the	time	since	last	

inspection	required	by	the	inspection program	under	which	the	aircraft	

and	its	appliances	are	maintained.

(v) The	current	status	of	applicable	airworthiness	directives	(AD)	and	safety	

directives	including,	for	each,	the	method	of	compliance,	the	AD	or	safety	

directive	number	and	revision	date.		If	the	AD	or	safety	directive	involves	

recurring	action,	the	time	and	date	when	the	next	action	is	required.

(vi) Copies	of	the	forms	prescribed	by	§ 43.9(d)	of	this	chapter	for	each	major	

alteration	to	the	airframe	and	currently	installed	engines,	rotors,	

propellers,	and	appliances.

(b)The	owner	or	operator	shall	retain	the	following	records	for	the	periods	

prescribed:	

(1)	The	records	specified	in	paragraph	(a)(1)	of	this	section	shall	be	retained	

until	the	work	is	repeated	or	superseded	by	other	work	or	for	1 year	after	the	

work	is	performed.

(2)	The	records	specified	in	paragraph	(a)(2)	of	this	section	shall	be	retained	

and	transferred	with	the	aircraft	at	the	time	the	aircraft	is	sold.
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(3)	A	list	of	defects	furnished	to	a	registered	owner	or	operator	under	§ 43.11	of	

this	chapter	shall	be	retained	until	the	defects	are	repaired	and	the	aircraft	is	

approved	for	return	to	service.

My	Drone	Share	LLC’s	exemption	requests	from	the	above	are	

detailed	below:

Unmanned	Aircraft	System:

My	Drone	Share	LLC	plans	to	operate	a	UAS,	the	PHANTOM	3	Professional,	which	

is	comprised	of	an	unmanned	aircraft	(UA	or	PHANTOM).		The	PHANTOM	3	

Professional	is	a	quad-copter	with	a	gross	weight	of	about	3	pounds.		It	is	

equipped	with	four	rotors	that	are driven	by	electric	motors,	which	is	powered	

by	batteries.		The	UA	has	a	maximum	airspeed	of	30	mph.

My	Drone	Share	LLC	plans	to	use	this	UAS	in	aerial	cinematography	and	

photography	for	enhancing	real	estate	listings,	roof	and	other	structural	

inspections,	special	events,	news,	and	other	such	tasks	for	businesses	in	the	

greater	Seattle	area	which	could	benefit	from	an	aerial	view	for	their	planning	of	

future	expansions	and/or	advertising	of	their	products	or	business.		For	most	

businesses	and	realtors	in	the	area,	standard	aerial	photography	has	been	very	

cost	prohibitive.		The	economic	impact	of	being	able	to	assist	your	business	

using	aerial	photography	would	be	substantial.

The	use	of	this	UAS	in	the	above	named	applications	greatly	reduces	the	risk	to

the	public	and	property	as	there	is	no	fuel	carried	by	the	Phantom	3	

Professional,	aircraft	noise	is	greatly	reduced	as	opposed	to	a	standard	aircraft	

or	rotorcraft	both	of	which	require	numerous	passes	or	extended	lengths	of	

hover	time	to	accomplish	the	same	task	as	the	Phantom	can	in	only	a	few	

minutes.		The	Phantom	only	weighs	about	3	pounds	and	is	by	far	a	much	smaller	

hazard	to	persons	or	property	than	a	standard	aircraft	or	helicopter	in	the	event	

of	a	catastrophic	in-flight	failure.

There	is	no	higher	priority	for	My	Drone	Share	LLC	other	than	the	safety	of	the	

public	and	property.

My	Drone	Share	LLC	makes	the	following	representations	of	its	operation	in	

which	to	abide	by	to	ensure	these	exemptions,	if	granted,	will	provide	a	level	of	

safety	at	least	equal	to	existing	rules:

The	Phantom	3	Professional	will	only	be	operated	by,	at	a	minimum,	a	private	

pilot	with	at	least	a	3rd class	airman	medical	certificate.		The	PIC	will	have	

completed	at	a	minimum,	25	hours	of	documented	flight	time	using	the	Phantom	

3	Professional	with	focus	being:

a) Collision	avoidance
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b) Loss	of	C2	link	procedures	as	outlined	in	the	Operators	manual	for	the	

Phantom	3	Professional.

c) Identification	of	inflight	hazards	i.e.	aerial	wires,	birds	in	the	area,	changing	

weather,	etc.

d) Estimating	distance	from	objects,	persons,	vehicles	and	vessels.

e) Communication	with	the	spotter(s).

f) Completed	the	Phantom	3	Professional	training	guide	maneuvers	and	skills.	

(PDF)	attached.

g) The	ability	to	recognize	persons	or	objects	that	are	not part	of	the	intended	

and	permitted	part	of	the	project	that	enter	the	500	foot	operational	area	

unless	such	persons	or	objects	are	deemed	permitted	by	the	owner	or	

controller	of	the	property	or	area	and	PIC	makes	a	safety	assessment	of	the	

risk	of	operating	closer	and	it	does	not	pose	undue	or	significant	risk.

h) The	ability	to	quickly	and	safely	land	the	Phantom	3	Professional	in	the	event	

of	intrusion	into	the	safe	zone.

1.) A	complete	pre-flight	systematic	check	by	the	PIC	of	the	Phantom’s	physical	

condition,	i.e.	props,	prop	guards,	landing	gear,	position	indicator	lights,	

battery	capacity	and	overall	airframe	condition.		If	any	of	the	above	are	not	

within	the	manufacturer’s	minimum	standards	no	flight	will	take	place	until	

such	times	as	the	issue(s)	is	repaired	to	manufacturers	standards.	

2.) Written	documentation	of	each	physical	inspection	and	repairs,	if	any,	by	the	

PIC	(pilot	in	command)	will	be	kept	with	the	Phantom	and	will	be	on-site	and	

available	for	review.

3.) Software	in	relation	to	the	Phantom’s	operation	will	be	checked	for	proper	

function.		The	most	current	DJI	vision	APP	and	the	current	firmware	will	be	

installed	to	assure	the	most	up	to	date	safety	features.

4.) Prior	to	every	flight,	the	compass	on	the	Phantom	3	Professional	will	be	

calibrated	as	to	ensure	precision	location.

5.) My	Drone	Share	LLC	will	ensure	the	altimeter	setting	on	the	Phantom	3	

Professional	is	that	of	AGL	(above	ground	level)	rather	than	GPS	or	

barometric	pressure	derived	settings.

6.) Every	safety	feature	offered	through	DJI	vision	APP	will be	enabled	for	every	

flight,	every	time.

Please	refer	to	the	attached	DJI	Phantom	3	Professional	PDF	file	for	a	

description	of	the	following	safety	features:

(6)	Enable	ground	station

(7)	Compass	calibration

(8)	Low	battery	auto	go	home

(9)	Dynamic	home	point

(10)	Current	RTH	(return	to	home)	altitude	(AGL)

(14)	Low	battery	alarm

7.) Use	of	the	DJI	Ground	Station	GUI	(graphical	user	interface)
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Refer	to	the	attached	DJI	Phantom	3	Professional	PDF	for	detailed	

descriptions.

Of	particular	interest	are	the	following:

(3)	Flight	attitude	and	radar	function

(4)	Flight	parameters-RTH	(return	to	home)	altitude,	horizontal	distance	

from	home	point,	altitude-vertical	distance	from	home	point,	speedhorizontal	flying	speed.

(6)	Flight	Battery	Level	indication

(7)	There	is	a	built	in	preflight	checklist	within	the	DJI	vision	APP	that	is	

completed	prior	to	each	flight.

(8)	Aircraft	GPS	status	– My	Drone	Share	LLC’s	Phantom	3	

Professional	will	not fly	with	less	than	(7)	GPS	Satellites	

available.

(14)	Hide	or	show	flight	parameters	– My	Drone	Share	LLC’s	

Phantom	3	Professional	will	ALWAYS	fly	with	parameters	

displayed	in	order	to	assist	in	maintaining	safe	distances	from	

persons	and	objects	and	to	adhere	to	the	flight	plan.

8.) My	Drone	Share	LLC	will	operate	with	a	minimum	of	(1)	one,	trained	spotter	

for	every	flight.		“Trained” meaning	familiarization	with	the	Phantom	3	

Professional,	its	abilities	according	to	the	operator’s	manual, as	well	as	the	

abilities	of	the	PIC.		Spotters	will participate in	documented	training	

developed in-house	prior	to	being	allowed	on	the	flight	line.		Training	will	

consist	of,	at	a	minimum,	the	following:

a) The	ability	to	roughly	identify	minimum	distance	from	objects.

b) The	ability	to	quickly	recognize	unusual	flight	

maneuvers/attitudes	of	the	Phantom	3	Professional.

c) The	ability	to	communicate	with	the	PIC	the	visual	limitations	and	

to	never	let	the	Phantom	3	Professional	out	of	the	visual	

capabilities	of	the	PIC	and	spotter(s).

d) The	ability	to	recognize	persons	or	objects	that	are	not part	of	the	

intended	and	permitted	part	of	the	project	that	enter	the	500	foot	

operational	area	unless	such	persons	and	objects	are	deemed	

permitted	by	the	owner	or	controller	of	the	property	or	area	and	

the	PIC	makes	a	safety	assessment	of	the	risk	to	those	persons	or	

objects.

e) The	ability	to	accurately	describe	to	the	PIC	the	orientation	of	the	

Phantom	in	relation	to	the	pre-set	home	point	as	well	as	the	

direction	of	travel.

f) The	training	will	take	place	under	strict,	safe	conditions	away	from	

persons	or	large	obstacles,	i.e.	large	open	fields.
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9.) Prior	to	each	flight,	the	PIC	and	the	Spotter(s)	will	perform	a	pre-flight	

briefing	detailing	the	estimated	flight	distance,	estimated	flight	level	AGL	and	

the	goal	of	the	particular	flight.		Each	preflight	briefing	will	be	documents	by	

the	PIC	to	include	flight	details,	pilot	name,	spotter(s)	name,	weather	details,	

time,	and	date.

Written	and/or	verbal	consent	will	be	obtained	from	the	person/business	

requesting	the	flight.

A	post-flight	briefing	will	also	be	conducted	and	documented	with	the	PIC	

and	the	Spotter(s).

The	documented	pre-flight,	the	raw	pictures	and/or	the	raw	video	footage	as	

well	as	the	post-flight	briefing	and	written	consent	will	be	kept	by	My	Drone	

Share	LLC	for	a	period	of	at	least	two	(2)	years.

My	Drone	Share	LLC	believes	that	given	the	size,	weight,	speed,	and	limited	

operating	area	associated	with	the	Phantom	3	Professional,	requests	for	an

exemption	from	14CFR	part	21,	Subpart	H	(Airworthiness	Certificate)	and	§	

91.203	(a)	and	(b)	(Certifications	required),	subject	to	certain	conditions	and	

limitations,	it	is	warranted	and	meets	the	requirements	for	an	equivalent	

level	of	safety	under	14	CFR	part	11	and	Section	333	of	P.L.	112-95	(Section	

333.)	

My	Drone	Share	LLC	requests	exemption	from	§	45.23	Making	of	the	aircraft.		

The	Phantom	3	Professional	does	not	have	a	cabin,	does	not	have	a	cockpit	or	

pilot	station.		Minimum	sized	lettering	and	wording	are	difficult	to	place	on	

the	Phantom	3	Professional.		My	Drone	Share	LLC	will	however	affix	a	sticker	

on	the	unit,	which	will	contain	contact	information	for	the	company	in	case	of	

aircraft	loss.

My	Drone	Share	LLC	requests	exemption	from	§§	91.405(a),	91.407(a)	(2)	

and	91.417(a)	and	(b)	Maintenance	inspections	and	feel	it	should	be	granted	

since	they	only	apply	to	aircraft	with	an	airworthiness	certificate.		My	Drone	

Share	LLC	has	developed	maintenance	inspections	and	documentation	

methods	for	the	Phantom	3	Professional	from	personal	experience	as	well	as	

the	manufacturer’s	user	manual.		(See	attached	pdf	Phantom 3	Professional	

use	manual	v1.2)

UAS	Pilot	in	Command	(PIC)

Under	§	61.113(a)	and	(b)	private	pilots	are	limited	to	non-commercial	

operations.		My	Drone	Share	LLC	will	only	use,	at	a	minimum,	a	pilot	with	a	

private	pilot	license,	current	3rd class	airmen	medical	certificate.

Under	current	regulations,	civil	operations	for	compensation	or	hire	require	

a	PIC	holding	a	commercial	pilot	certificate	per	14	CFR	part	61.		Based	on	the	

private	pilot	limitations	in	accordance	with	pertinent	part	of	14 CFR	61.113	
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(a)	and	(b),	a	pilot	holding	a	private	pilot	certificate	cannot	act	as	a	PIC	of	an	

aircraft	for	compensation	or	hire	unless	the	flight	is	only	incidental	to	a	

business	or	employment.		“However,	in	Grant	of	Exemption	No.	11062	to	

Astraeus	Aerial (Astraeus),	the	FAA	determined	that	a	PIC	with	a	private	pilot	

certificate	operating	the	Astraeus	UAS	would	not	adversely	affect	operations	

in	the	NAS	or	present	a	hazard	to	persons	or	property	on	the	ground.”		My	

Drone	Share	LLC	requests	that	an	exemption	allowing	a	private	pilot	

employed	by	My	Drone	Share	LLC	to	be	allowed	to	be	the	PIC	of	the	Phantom	

3	Professional	for	compensation	similar	to	the	grant	of	exemption	No.	11602	

to	Astraeus	Aerial.

My	Drone	Share	LLC	requests	relief	from	§	91.119(c)	because	the	aircraft	will	be	

operated	in	altitudes	below	300	feet	AGL.		Section	91.119(c)	states	that	no	person	

may	operate	an	aircraft	below	the	following	altitudes:	over	other	than	congested	

areas,	and	altitude	of	500	feet	above	the	surface,	except	over	open	water	or	sparsely	

populated	areas.		In	those	cases,	the	aircraft	may	not	be	operated	closer	than	500	

feet	to	any	person,	vessel,	vehicle,	or	structure.		My	Drone	Share	LLC	will	operate	

pursuant	to	the	following	restrictions	related	to	§	91.119:

--Operate	in	reasonably	safe	environments	that	are	closely	monitored	by	ground	

assistants	and	signage	placed	in	locations	that	would	be	considered	reasonable	

locations	for	pedestrians,	vehicles	or	vessels	to	enter	the	area.

--Within	5	miles	of	airports	and	congested	areas.		Congested	areas	will	be	defined	by	

VFR	charts	as	well	as	by	contacting	the	local	FSDO	(flight	standards	district	office).

--Conduct	all	operations	under	My	Drone	Share	LLC’s	guidelines	contained	in	the	

operating	documents	and	will	analyze	flight	data	and	other	sources	of	information	

such	as	the	manufacturer’s	website	to	constantly	update	and	enhance	safety.

--Contact	respective	airports	if	operations	will	be	within	5	miles	to	advise	them	of	

estimated	flight	time,	flight	duration,	elevation	of	flight	and	other	pertinent	

information	deemed	important	by	the	airport.

--Always	obtain	all	necessary	permissions	prior	to	operation.		Permissions	include	

but	are	not	limited	to	a	(COA) and	a	request	for	a (NOTAM) as	well	as	permission	

from	the	property	owner	or	person	in	control	of	the	property	and	when	practical	

will	be	in	writing	and	kept	on	file	for	2	years	for	review.		If	it’s	not	possible	to	obtain	

written	permission,	the	PIC	will	document	in	writing	how	permission	was	obtained	

i.e.	phone	call	with	date,	time,	and	party	information.

My	Drone	Share	LLC	requests	relief	from	14	CFR	91.121	Altimeter	Settings.		My	

Drone	Share	LLC’s	Phantom	3	Professional	has	a	barometric	altimeter	and	GPS	

derived	altitude	capabilities.		The	FAA	requires	any	altitude	reported	to	ATC	to	be	in	

feet	AGL.		My	Drone	Share	LLC	will	set	the	altimeter	on	the	Phantom	3	Professional	

to	zero	feel	AGL	rather	than	local	barometric	pressure	or	field	altitude	before	flight.

My	Drone	Share LLC	requests	relief	from	§	91.151	(a)	Fuel	Requirements	for	flight	in	

VFR	conditions	based	on	the	following:
9

No	fuel	is	used	in	the	Phantom	3	Professional	but	it	is	battery	operated.		Batteries	

have,	in	our	experience,	about	23 minutes	of	quality	flying	time.		In	the	interest	of	

safety,	My	Drone	Share	LLC	generally	lands	with	35%	of	battery	remaining,	which	

gives	about	15	minutes	of	flying	time	per	battery.		The	Phantom	3	Professional	has	a	

audible	battery	state	warning	system.		My	Drone	Share	LLC	will	always	follow	the	

manufacturer’s	minimum	battery	warning	which	is	30%	remaining.		There	is	also	an	

on-screen	warning	indicating	low-battery	capacity.		The	Phantom	3	Professional	has	

3	Return	to	Home	(RTH)	modes:	Smart	RTH,	which	will	automatically	RTH	at	all

times;	Low	Battery	RTH,	which	will	result	in	RTH	if	no	controller	action	is	taken	

within	10	seconds;	and	Fail	Safe	RTH,	which	is	automatically	activated	if	the	remote	

signal	is	lost	for	more	than	3	seconds.		In	all	cases,	the	PIC	and	Spotter	would	be	

involved	to	ensure	a	safe	and	obstruction-free	landing.		If	the	battery	level	is	too	low	

to	return	to	home,	an	emergency	landing	would	be	made	as	soon	as	safe	and	

practical.		Researching	previous	relief	requests,	relief	has	been	granted	for	manned	

aircraft	to	operate	at	less	than	prescribed	minimums,	including	Exemption	Nos.	

2689,	5745,	and	10650.		In	addition,	similar	UAS-specific	relief	has	been	granted	in	

exemption	Nos.	8811,	10808,	and	10673	for	daytime,	VFR	conditions.		My	Drone	

Share	LLC	will	adhere	to	all	VFR	minimums	as	well	as	VMC	conditions	when	

planning	and/or	executing	any	flights.		There	is	little	purpose	to	aerial	video	or	

pictures	if	the	weather	is	less	than	desirable.		Following	VFR	minimum	standards	

will	at	least	ensure	a	safe	flight.		Wind	and	forecast	weather	will	be	a	key	in	deciding	

suitable	conditions.		Local	weather	can	be	attained	from	the	nearest	airport	by	using	

AWOS.		No	flight	will	take	place	in	any	condition	that	would	potentially	be	outside	of	

the	Phantom	3	Professional	capabilities	in	wind.		My	Drone	Share	LLC	will	always	fly	

within	its	30%	minimum	remaining	battery	life	at	its	first	intended	landing	point.	

My	Drone	Share	LLC	will	obtain	an	Air	Traffic	Organization	(ATO)	issued	Certificate	

of	Waiver	or	Authorization	(COA)	prior	to	conducting	any	operations.		My	Drone	

Share	LLC	will	also	request	a	Notice	to	Airman	(NOTAM)	not	more	than	72	hours	in	

advance,	but	not	less	than	48	hours	prior	to	the	operation.		

If	there	are	any	areas	that	have	not	been	addressed,	please	contact	me	for	

supplemental	information.		

Sincerely,

Brett	Parcell

My	Drone	Share	LLC

16403	Broadway	Avenue

Snohomish,	WA	98296

(206)	650-4242

brettparcell@yahoo.com