December	24,	2015

U.S.	Department	of	Transportation

West	Building	Ground	Floor

Room	w12-140	1200	New	Jersey	Ave

SE	Washington,	DC	20590

Name	and	Address	of	Petitioner:

Andre	Siegrist

815	Camp	Meeting	Road

East	Earl,	PA	17519

Email:	andresiegrist@yahoo.com

Phone:	717-413-3002

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,	Andre	Siegrist,	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:

14CFR	21	H

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	91.109

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)	&	(b)

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

from	the list below.

Applications	and	Operations:

 Aerial	Video	and	Photography

 Land	Surveying	and	Mapping

 Forest	Health	Monitoring

 Harvesting	Monitoring

 Topography

 Environmental	Assessment

 Aerial	Photography- Real	time
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:

Full	Description	of	the	UAS

The	UAS	to	be	used	is	the	DJI	Phantom	3	Standard

Manufacturer:	DJI

Model	Designation:	Standard	version	of	Phantom3	line,	Quad	copter	style	with	4	engines	and	

camera.

Serial	Number:

Class:	Rotorcraft

Takeoff	Weight:	2.6808	pounds	or	1216	grams

Category:	Both	Land	and	Sea

Number	of	Engines:	4

Engine	Type:	Electric powered	by	batteries

Characteristics	of	the	Phantom	3	Standard

1.	Very	Light	Weight

The	Phantom	3	Standard is	so	light	the	operator	can	launch	it	by	hand	and	let	it	land	on	almost	any	

surface	without requiring	a	parachute	or	landing	net.	Its	low	impact	energy	(in	the	case	of	a	

controlled	emergency landing)	also	significantly	reduces	the	risk	of	hazardous	situations.

2.	Electric-powered

The	Phantom	3S	is	electric	powered	by	batteries	that	power	4	electric	engines.

3.	Autonomous	Flights	and	GPS	Technology

The	artificial	intelligence	incorporated	within	the	P3S	allowing	for	stable	automatic	take	off,	and	

landing	with	the	DJI	GO	app.	The	GPS	technology	also	allows	for	stable	movement	and	complete	

control	of	the	aircraft,	even	if	the	pilot	is	not	moving	the	aircraft,	it	will	stay	in	place	and	stable.	The	

GPS	sensors	also	know	the	takeoff	point,	and	one	press	of	a	button	can	return	the	aircraft	to	the	

starting	point	at	a	safe	altitude,	and	lower	to	the	landing	point	where	the	aircraft	took	off	to	begin	

the	flight.			

4.	Option	for	Manual	control

Additionally,	the	P3S provides	an	override	capacity	that	allows	the	operator	to	take	manual	actions

during	the	flight	(Go	to	Home,	Go	Land,	Hold	and	Resume	the	mission)	and	also	suspends	

automated operations	and	take	manual	control	of	the	aircraft	should	it	become	necessary	to	

respond	to	emergency	circumstances,	thanks	to	the	remote	controller	provided	with	the	system.

Public	Interest	and	Benefits

Providing	the	public	with	commercial	aerial	services	that	are	much	more	economical	are	a	good	

aspect	of	this	exemption	compared	to	past	methods,	such	as	helicopters	and	airplane	services.	Will	

be	primarily	filming	video	and	taking	photos	for	Real	Estate,	and	scenery	purposes.	The	UAS	will	

pose	no	threat	to	the	public,	given	its	safety	features	and	pilot	experience,	as	well	as	the	lightweight	

and	lack	of	combustibility	of	the	aircraft.	The	UAS	will	also	benefit	the	environment	due	to	the	
battery	power	it	runs	on,	and	the	information	being	provided	by	surveying	and	forest	monitoring,	

though	this	excludes	emergencies	such	as	forest	fires	and	other	situations	where	authorities	are	

nearby.	

Safety

Flights	will	be	conducted	within	suggested	parameters	by	the	FAA. Flights	will	be	away	from	highly	

congested	areas,	cities,	airports,	national	parks,	and	no	fly	zones	(NFZ).	Flights	will	also	be	

controlled	at	a	suitable	speed,	and	under	400	feet.	Safety	will	be	the	first	priority	with	every	flight	

by	following	the	guidelines,	staying	away	from	illegal	areas,	and	using	good	judgment to	not	disturb	

or	harm	anyone.	Inspection	of	the	aircraft	will	take	place	before	each	flight	to	ensure	quality	of	the	

UAS	and	operating	parts.	Repairs	will	be	made	before	problems	arise	if	parts	become	worn,	or	

damaged.	

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

Reason	for	Exception

It	has	been	determined	that	similar	UAS's	do	not	require	an	airworthiness	certificate	as	granted	in

Exemption	No.	11623,	11650,	11664	and	11734.

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.

Reason	for	Exception

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

UAS will	have	not entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the	work	

"EXPERIMENTAL"	can	be placed.	Given	the	size	of	the	UAS,	two-inch	lettering	will	be	impossible.	

The	word	"EXPERIMENTAL"	will be	placed	on	the	fuselage	in	compliance	with	45.29	(f).

The	FAA	has	issued	the	following	exemptions	to	this	regulation	to	Exemptions	Nos.	10700,	8738,	

10167 and	10167A. 14	CFR	61.113	(A)	7	{b):	Private	Pilot	Privileges	and	Limitations

The	regulation	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.

Reason	for	Exception

The	Petitioner	will	follow	all	manufacturers'	training	program	and	safety	manual.	

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.

Reason	for	Exception

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.	We	assume	that	the	intent	of	this	requirement	is	to	ensure	that	flight	

manual information	is	available	to	the	aircrew	while	operating	the	aircraft.	We	request	an	

exemption	to	this requirement	since	the	aircraft	is	not	only	too	small	to	carry	documentation;	the	

documentation	would not	be	available	to	the	crew.

Reason	for	Exception

The	equivalent	level	of	safety	will	be	maintained	by	keeping	the	flight	manual	at	the	ground	control

point	where	the	pilot	flying	the	UAS	will	have	immediate	access	to	it.	The	FSS	has	issued	the	

following exemptions	to	this	regulation: Exemption	#8607,	8737,	8738,	9299,	9299A	to	list	a	few.

14 CFR	91.103	(b):	Preflight	Instruction

This	regulation	requires	each	pilot	in	commend	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.	The	petitioner	will	take	all	actions	including	reviewing	weather,	flight	

battery requirements,	landing	and	takeoff	distances	and	aircraft	performance	data	before	initiation	

of	flight.

14	CFR	91.109:	Flight	Instruction

The	regulation	provides	that "No	person	may	operate	a	civil	aircraft	that	is	being	used	for	flight

instruction	unless	that	aircraft	has	fully	functioning	dual	controls."

Reason	for	Exception

UAS's	and	remotely	piloted	aircraft,	by	their	design	so	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	provided	by	the	fact	that	neither	

a	pilot	nor	passenger will	be	carried	in	the	aircraft	and	by	the	size	and	speed	of	the	aircraft.

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,	the	requests	of	each	regulation	will	be	followed	as	best	as	possible.	

Reason	for	Exception

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

the	Petitioner,	or by	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	is	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.

Reason	for	Exception

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

Petitioner	will	limit	flights	to	a	maximum	altitude	of	400	feet	AGL	as	granted	in	Exemption	No.	

11623, 11664,	and	11734.

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	

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.

Reason	for	Exception

The	UAS	provides	a	low	battery	warning	to	indicate	when	you	should	return	the	UAS	to	the	launch	

point. In	addition,	a	"low"	and	"critical"	battery	level	warnings	and	implemented	a	"return	to	Home"	

(or	"Go land")	action	in	these	situations.	The	Petitioner	will	not	initiate	a	flight	unless	(considering	

wind	and forecast	weather	conditions)	there	is	enough	power	to	fly	at	normal	cruising	speed	to	the	

intended landing	point	and	all	flights	will	be	conducted	during	daylight	hours	and	at	times	not	to	be	

a	nuisance	to others.

14	CFR	91.203	(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.

Reason	for	Exception

To	obtain	an	equivalent	level	of	safety	and	meet	the	intent	of	91.203,	documentation	will	be	housed	

at	a ground	control	point	where	the	pilot	is	flying	the	UAS	for	immediate	access	to	the	extent	they	

are applicable	to	the	UAS's.	In	doing	some	research	the	FAA	has	issued	numerous	exemptions	to	

this regulation.

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 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.

Reason	for	Exception

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	this chapter.
Reason	for	Exception

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

manufactures	suggested replacement	parts.

14	FR	91.409	(a){l)	&	(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.

Reason	for	Exception

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

safe 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	(l)(i)	(ii)(iii)	(2)(i)(ii)(iii)(iv)(v)(vi)	for	the	periods	

specified	in	paragraph	(b) of	this	section:	(	1)	(2)	(3)

Reason	for	Exception

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.

14CFR	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.

Reason	for	Exception

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

and current	FSS	proposals	have	omitted	this	as	a	future	requirement	for	small	UAS's.

In	Conclusion:

I,	Andre	Siegrist,	the	Petitioner	request	for	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	the	Applications	and	Operations	pertaining	to	my	aerial	services	such	as	

aerial	photography,	and	video	among	other	applications	to	benefit	the	public.	The	Petitioner	hopes	

for	a	timely	consideration	to	perform	these	aerial	services	legally.	Please	feel	free	to	contact	me	via	

email	at	andresiegrist@yahoo.com or	by	phone	at	717-413-3002	if	you	need	additional	information	

or	have	questions.	

Thank	You,

Andre	Siegrist

Owner

815	Camp	Meeting	Road

East	Earl,	PA	17519

Email:	andresiegrist@yahoo.com

Phone:	717-413-3002