Chris Houseman

3064 5 Mile Road

Traverse City, MI 49686

Phone: 231-642-0402

 housemanchris729@gmail.com

November 10, 2015

U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012 

and Part 11 of the Federal Aviation Regulations from 14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 

43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 

C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.113(b); 14 C.F.R. 

91.119(b)(c); 14 C.F.R. 91.121; 14 C.F.R. 151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 215; 14 C.F.R. 

91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417.

Dear Sir or Madame:

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

C.F.R. Part 11, Chris Houseman, an operator of Small Unmanned Aircraft Systems (“sUAS”) equipped to 

photograph and film scenery, construction sites, and real estate, applies for an exemption from the 

listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAS, 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.

Approval of exemptions for Chris Houseman will allow commercial operations of sUAS to photograph 

and film scenery in rural natural areas, owned construction sites and real estate. The pilot in command 

(PIC) has 157 documented sUAS flights over the course of 2 years. The requested exemption should be 

granted because operation of the proposed small UASs conducted in the strict conditions outlined 

below, will provide an equivalent level of safety, as Congress intended, while still allowing commercial 

operations. 

The lightweight aircraft, the DJI Phantom 3, covered by the exemption are far safer than conventional 

operations conducted with helicopters and fixed-wing aircraft weighing several thousand pounds 

containing pilot and crew operating in close proximity to the ground and people below. The seven 

factors Congress directed the FAA to consider when approving Section 333 exemption petitions - size, 

weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation 

within visual line of sight – each support the request. In particular, the sUAS is small, and will operate at 

slow speeds, close to the ground, far from airports and in a low risk, low population environment. In 

addition, the substantial experience of the PIC weighs heavily in favor of granting the exemption.
Table of Contents

I. Publishable Summary............................................................................................................... 5 

II. II. Petitioner’s Contact information.......................................................................................... 5 

A. The sUAS .............................................................................................................................. 6 

B. Flight Conditions .................................................................................................................. 7 

C. Flight Operations ................................................................................................................. 7 

III. Privacy ..................................................................................................................................... 9

IV. Aircraft and Equivalent Level of Safety .................................................................................. 10

V. Public Interest and Safety ...................................................................................................... 11

VI. Regulations from Which Exemption is Requested ................................................................ 12 

A. 14 C.F.R. 21(h): Airworthiness Certificates......................................................................... 12 

A. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, 

 propellers, appliances, or component parts for return to service after maintenance, 

 preventive maintenance, rebuilding, or alteration. .............................................................. 13 

B. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted under 

parts91 and 125 and §§135.411(a) (1) and 135.419 of this 

chapter.............................................. 14 

C. 14 C.F.R. 45.11: Marking of products............................................................................................. 14 

D. 14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft ........................................................... 

14 

E. 14 C.F.R. 45.29: Size of marks ........................................................................................................ 15

F. 14 C.F.R. 91.7(a): Civil aircraft airworthiness. ................................................................................ 15

G. 14 C.F.R. 91.9(b) (2): Civil aircraft flight manual, marking, and placard requirements................... 

15

H. 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard requirements. ......................

16 

I. 14 C.F.R. 91.103(b) (2): Preflight action......................................................................................... 16 

J. 14 C.F.R. 91.105: Flight crewmembers at stations. ....................................................................... 17 

K. 14 C.F.R. 91.113(b): Right-of-way rules: Except water operations. .............................................. 17 

L. 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes: General. .................................................... 18 

M. 14 C.F.R. 91.121: Altimeter Settings ............................................................................................. 18 

N. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions. ................................................ 19 

O. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required. ............................................... 19 

P. 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use ........................ 21 

Q. 14 C.F.R. 91.403: General ............................................................................................................. 21 

R. 14 C.F.R. 91.405 (a) and (d): Maintenance Required ................................................................... 21

S. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or alteration 

............................................................................................................................................... 22

T. 14 C.F.R. 91.409: Inspections ........................................................................................................ 22

U. 14 C.F.R. 91.417: Maintenance records ........................................................................................ 23
Exhibit List

DJI Phantom 3 Advanced Documents 

Exhibit 1: DJI Phantom 3 Advanced User Manual................................................................... Submitted 

Separately Exhibit 9: DJI Phantom 3 Advanced Safety Guidelines......................................... Submitted 

Separately 

Exhibit 2: DJI Phantom 3 Advanced Quick Start Guide........................................................... Submitted 

Separately 

Exhibit 3: DJI Phantom 3 Advanced Intelligent Flight Battery Safety Guidelines......................Submitted 

Separately 

Exhibit 4: DJI Phantom 3 Advanced Disclaimer and Warning................................................. Submitted 

Separately 

Exhibit 5: DJI Phantom 3 Advanced........................................................................................ Submitted 

Separately Exhibit 6: DJI Phantom 3 Advanced 

Features.................................................................................................................................. Submitted 

Separately

Exhibit 7: DJI Phantom 3 Advanced Specifications ................................................................ Submitted 

Separately
I. Publishable Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules to operate commercially a small 

unmanned aircraft system (sUAS) (55lbs or less): 

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14 C.F.R. 45.29; 14 C.F.R. 

91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R. 91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 

91.113(b); 14 C.F.R. 91.119(b)(c); 14 C.F.R. 91.121; 14 C.F.R. 151; 14 C.F.R. 91.203(a) and (b); 14 C.F.R. 

215; 14 C.F.R. 91.403; 14 C.F.R. 91.405; 14 C.F.R. 91.407; 14 C.F.R. 409; and 14 C.F.R. 91.417 

Approval of exemptions for Chris Houseman will allow commercial operations of the sUAS to 

photograph and film scenery in rural natural areas, owned construction sites and real estate. The pilot in 

command (PIC) has 157 documented sUAS flights over the course of 2 years. The requested exemption 

should be granted because operation of the proposed small UASs conducted in the strict conditions 

outlined below, will provide an equivalent level of safety, as Congress intended, while still allowing 

commercial operations. 

The lightweight aircraft, the DJI Phantom 3, covered by the exemption are far safer than conventional 

operations conducted with helicopters and fixed-wing aircraft weighing several thousand pounds 

containing pilot and crew operating in close proximity to the ground and people below. The seven 

factors Congress directed the FAA to consider when approving Section 333 exemption petitions - size, 

weight, speed, operational capability, proximity to airports, proximity to populated areas, and operation 

within visual line of sight – each support the request. In particular, the sUAS is small, and will operate at 

slow speeds, close to the ground, far from airports and in a low risk, low population environment. In 

addition, the substantial experience of the PIC weighs heavily in favor of granting the exemption.

II. Petitioner’s Contact Information

Chris Houseman

3064 5 Mile Road

Traverse City, MI 49686

Tel: 231-642-0402

housemanchris729@gmail.com
III. Chris Houseman

The requested exemption will permit the operation of one small unmanned multirotor aircraft, the DJI 

Phantom 3 Advanced. 

2. The DJI Phantom 3 Advanced

The DJI Phantom 3 Advanced is a small, unmanned multirotor aircraft, weighing 2.82 lbs., 

inclusive of batteries and technical payload. The rotorcraft can operate at a speed up to 31

knots (36 mph). The FAA has previously granted Exemption No. 11138, allowing commercial 

flight of a DJI product. Exhibit 2. 

The sUAS will have the following specifications:

Airframe: DJI Phantom 3 Advanced

Dimensions: 438x451x301mm / 17.24 x 17.75 x 11.85 in. 

Flight Control System: Internal to the DJI Phantom 3 Advanced. This includes the main controller 

(MC), which receives the battery voltage, capacity, and current, the internal measurement unit 

(IMU), which receives telemetry data (visible at the ground station), compass, GPS, and radio 

receiver (Rx). Transmitter (Tx): DJI Inspire Remote Control 

Receiver (Rx): Internal to DJI Phantom 3 Advanced

Motor: DJI 2312 

Propeller: DJI 9450, 9-inch diameter 

Data and Video Combined Link: HD Lightbridge Video Downlink 

Camera: DJI Proprietary

Batteries: LiPo 4S High voltage battery with 4480 mAh capacity 

**Please refer to Exhibits 8-15 for further information about the DJI Phantom 3 Advanced.

B. Flight Conditions 

The sUAS will be flown in airspace under 400 feet above ground level (“AGL”) and under controlled 

conditions in a closed set in rural areas. Chris Houseman will only operate its sUAS in VMC, visual 

meteorological conditions: no less than 400 feet below and no less than 2,000 feet horizontally from a 

cloud or when visibility is at least 3 statute miles from the PIC. The PIC will always make a safety 

assessment of the risk of every operation, and will only operate when it is determined that no undue 

hazards are present. 

The flight crew will consist of one Pilot in Command (PIC). Additionally, during operations, there will be

two visual observers (VO’s) will be on the lookout for any trespassers, so that the operation can be 

quickly aborted if someone unauthorized walks into the closed set. However, when flying closer than 

500 feet to nonparticipating individuals or structures, there will be barriers between the flight area and 

the nonparticipants. The sUAS will be used to film nature preserves, wineries, and photograph these 
same areas. The sUAS will be flown over both land and water. Chris Houseman will avoid congested 

areas when planning operations, and will work with the local FSDO. Chris Houseman will assess each 

location prior to flight, making sure each location abides by the aforementioned, and is safe for all 

participants. The PIC will only operate the sUAS when the locations are deemed safe.

C. Flight Operations

The purpose of each sUAS flight will be to film and photograph nature preserves for the motion picture 

and television industries safely and efficiently. 

Chris Houseman’s flight crew will consist of just himself. The DJI Phantom 3 Advanced will have the 

“return to home” function in the flight controller. Exhibit 4; Exhibit 1. Once the home and safety zones 

are set, the PIC will perform an extensive preflight safety inspection, which is based on pre-flight safety 

inspections for manned helicopters. For flights over water, the sUAS’s feet will be fitted with flotation 

devices in the event of an emergency water landing. 

1) DJI Phantom 3 Flight Procedure

To start the DJI Phantom 3 Advanced, Chris Houseman will follow the procedures set out by the 

manufacturer beginning on page 8 of the Quick Start Guide, Exhibit 2 to this petition. Additionally, Chris 

Houseman will conduct a communications check to make sure the transmitter is connected to the DJI 

Phantom 3 Advanced. 

After the pre-flight inspection has been completed and the flight crew is in place, the PIC will begin the 

flight. When flying the DJI Phantom 3 Advanced, the low battery failsafe is triggered when the DJI 

Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. This 

threshold is automatically determined based on the current aircraft altitude and its distance from the 

home spot. For more information regarding this safety procedure, please refer to Exhibit 1. Other than 

this automated emergency procedure, the PIC will manually control each flight in a visible line of sight.

IV. Privacy

There is little concern that the proposed flights will cause invasions of privacy because due to the 

altitude of the flights, and area of limited populations flights will occur. Any private property filmed or 

photographed will have written consent from the owner. 

V. Aircraft and Equivalent Level of Safety 

Chris Houseman 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 higher level of safety to operate under the current regulatory structure. These 

limitations and conditions to which Chris Houseman agrees to be bound when conducting commercial 

operations under an FAA issued exemption include: 

1. The sUAS will weigh no more than 55 lbs. 

2. Flights will be operated within line of sight of a pilot.

3. When flying the DJI Phantom 3 Advanced, the low battery failsafe is triggered when the DJI Intelligent 

Flight Battery is depleted to a point that may affect the safe return of the aircraft. This threshold is
automatically determined based on the current aircraft altitude and its distance from the home spot. 

Please refer to Exhibit 1. 

4. The sUAS will remain clear and yield the right of way to all other manned operations and activities at 

all times. 

5. Flights will be operated at an altitude of no more than 400 feet AGL. 

6. Minimum crew for each operation will consist of the sUAS PIC. 

7. Prior to each day’s activity, the PIC will visit the location for filming to determine if it is safe for 

filming. 

8. The operator will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not 

less than 48 hours prior to the operation. 

9. The PIC has gone through 150 flight cycles with the DJI Phantom 3 Advanced, which comprises 40 

hours of flight time. The PIC has also spent over 300 hours with a virtual trainer, and operated several 

other sUAS.

10. Written and/or oral permission from the landowners/authorized agents of the land over which 

flights will occur. 

11. 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. 

12. The DJI Phantom 3 Advanced has the capability to abort a flight in case of unexpected obstacles or

emergencies. Prior to each flight, two separate safety zones will be programmed into the sUAS 

autopilot, in the event that the home area is unsafe for an emergency landing. 

13. For DJI Phantom 3 Advanced, if the sUAS and its radio controller disconnects during flight, the 

system’s failsafe protection will come to the rescue and the multirotor will return to home and land 

automatically, rather than flying off uncontrollably or landing at an unknown location. 

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012--size, weight, speed, 

operating capabilities, proximity to airports and populated areas and operation within visual line of sight 

and national security – provide more than adequate justification for the grant of the requested 

exemptions allowing commercial operation of applicant’s sUAS in the film and photography profession 

pursuant to Chris Houseman’s rules of operation, submitted under seal for proprietary reasons.

VI. Public Interest and Safety 

Use of the sUAS will increase ground safety by eliminating the need to have multiple individuals in a 

helicopter while filming. Manned helicopters pose a risk to the pilots and onboard crew. Comparatively, 

when flying a sUAS, the pilot and crew are safely on the ground, rather than several hundred feet in the 

air, as the FAA has previously determined. Exhibit 1 at 11.

The limited weight of the DJI Phantom 3 significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. Additionally, the sUAS 

can fly at lower altitudes than manned aircraft and requires less room for takeoff and landing, allowing 

for flights to take place over smaller areas. 

VII. Regulations from Which Exemption is Requested 

14 C.F.R. 21(h): Airworthiness Certificates Chris Houseman requests an exemption from 14 C.F.R. 21(h), 

which “prescribes procedural requirements for the issue of airworthiness certificates.” 14 C.F.R. 21.171. 
The DJI Phantom 3’s small size, weight, speed, and limited operating area associated with the aircraft 

and their operation meet the statutory considerations of Section 333. 

Equivalent level of safety: Chris Houseman’s proposed exemption meets the requirements for an 

equivalent level of safety of this section, pursuant to Section 333, based upon the following factors: 

•DJI Phantom 3 Advance: 438x451x301mm / 17.24 x 17.75 x 11.85 in. 

• Light weight: no more than 55 lbs. inclusive of fuel, battery and technical payload. o DJI Phantom 3 

Advance: 6.5 lbs. inclusive of battery and technical payload. 

• Relatively slow speed: o DJI Phantom 3 Advance: the DJI Phantom 3 Advance can operate at 

speeds up to 43 knots (38 mph). 

• Operational capacity: DJI Phantom 3 Advance: the low battery level failsafe is triggered when the 

DJI 12 Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. 

The warning threshold is automatically determined based on the current aircraft altitude and its 

distance from the home point. 

• Proximity to airports: Chris Houseman will only operate in Class G airspace, and will notify ATC and 

the local FSDO prior to operations, as described above. 

• Proximity to populated areas: Chris Houseman will only operate in Class G airspace in rural, natural 

areas and work with the local Flight Standards District Offices to determine which areas to avoid 

during flights. Local FSDO may carve out areas indicated as yellow in the sectional chart and allow 

Chris Houseman to fly in these specifically designated carve-out areas. 

• Operation within visual line of sight: the PIC will always fly the sUAS within his line of sight. 

• Location: Chris Houseman will operate in rural remote areas in Class G airspace. 

• Altitude: no more than 400 feet AGL. 

• Restricted area in which the sUAS will be operated: as described previously in this petition, the 

flight crew will act as fence posts to the flight area. The sUAS will not exit that area, and the flight 

crew will watch for individuals and other aircraft entering the space. Flights will be aborted if an 

intruder enters the area. 

• Substantial experience of the PIC: the PIC has owned and operated the following models of DJI 

sUAV’s since 2013: DJI Phantom 1, DJI Phantom Vision, DJI Phantom 2, DJI Phantom Vision 2+, DJI 

Phantom 3 Advanced, DJI Phantom 3 Professional.

A. 14 C.F.R. 43.7: Persons authorized to approve aircraft, airframes, aircraft engines, propellers, 

appliances, or component parts for return to service after maintenance, preventive maintenance, 

rebuilding, or alteration

Chris Houseman requests an exemption from 14 C.F.R. 43.7. This part provides, inter alia, that the 

holder of a mechanic certificate or a repair station certificate may approve an aircraft, airframe, 

aircraft engine, propeller, appliance, or component part for return to service. 

Equivalent level of Safety: The requested exemption will provide an equivalent level of safety for 

the DJI Phantom 3 Advance, because Chris Houseman will repair and maintain the sUAS in 

accordance with the manufacturer’s directions and recommendations. 

B. 14 C.F.R. 43.11: Content, form, and disposition of records for inspections conducted under parts 

91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
Chris Houseman requests an exemption from 14 C.F.R. 43.11(b). This part provides, inter alia, for the 

listing of discrepancies and placards by inspectors. The sUAS, due to its small size, does not have 

room for placards to be placed in or on it and no inspections for sUAS have been certified by FAA at 

the present time. 

Equivalent level of safety: To achieve an equivalent level of safety, Chris Houseman will keep log 

books of all maintenance and repairs. These log books will include the information meant for the 

placards. This meets an equivalent level of safety to 14 C.F.R. 43.11(b) because, as envisioned in the 

August 8, 2014 Memorandum, “Interpretation regarding whether certain required documents may 

be kept at an unmanned aircraft’s control station,” the log books will be kept at the ground station 

were the PIC and flight crew will have immediate access to them. 

C. 14 C.F.R. 45.11: Marking of products

Chris Houseman requests an exemption from 14 C.F.R. 45.11. This part provides, inter alia, that the 

manufacturers of aircraft, engines, propellers, mark such aircraft, engines, or propellers with an 

approved fireproof identification plate. The sUAS, due to its small size, does not have room for 

fireproof placards to be placed in it. Any required placards could become hazardous, due to the 

additional weight and strain placed on the sUAS. Any additional weight or placards on the sUAS 

could create a risk, due to the small size and nature of the DJI Phantom 3 Advance. 

Equivalent level of safety: To achieve an equivalent level of safety, Chris Houseman will keep 

information related to the DJI Phantom 3 Advance, including their user manuals and log books at the 

ground station, and affix their N-Numbers, once obtained from the FAA Registration Office, as large 

as practicably possible. The requested exemption provides an equivalent level of safety to 14 C.F.R. 

45.11 because the relevant documentation containing the serial numbers will be at the ground 

station with the PIC, where it will be useable in the event of an emergency. 

D. 14 C.F.R. 45.27: Location of marks; nonfixed-wing aircraft

Chris Houseman requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, that each 

operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, 

fuselage, boom, or tail the marks required by §45.23. The DJI Phantom 3 Advance, due to its small 

size, does not have a cabin, fuselage, boom or tail to display the marks required by §45.23. 14 

Equivalent level of safety: Chris Houseman has received his N-Numbers for the DJI Phantom 3 

Advance, and will display these marks on the body of the aircraft as large as practicably possible. 

This exemption provides an equivalent level of safety to 14 C.F.R. 45.27 because the sUAS will be 

registered with the FAA Aircraft Registration Branch. In the event of incident, the sUAS will be 

traceable to Chris Houseman. 

E. 14 C.F.R. 45.29: Size of marks

Chris Houseman requests an exemption from 14 C.F.R. 45.27. This part provides, inter alia, at 

subpart (3) that the registration marks for rotorcraft must be at least 12 inches high. Such a display 

will be impracticable, due to the small size of the sUAS. 
Equivalent level of safety: Chris Houseman will affix its registration number as large as practicably 

possible on the body of the DJI Phantom 3 Advance. This exemption provides an equivalent level of 

safety to 14 C.F.R. 45.29 because the sUAS will be registered with the FAA Aircraft Registration 

Branch. In the event of incident, the sUAS will be traceable to Chris Houseman. 

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

The FAA has previously stated that no exemption is required for this section in the MPAA 

Exemptions. Exhibit 1 at 19. Chris Houseman requests the same determination be made for this 

petition. Alternatively, Chris Houseman requests an exemption from 14 C.F.R. 91.7(a). 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 

standard will exist for determining airworthiness. Equivalent level of safety: Chris Houseman will 

keep the DJI Phantom 3 Advance’s maintenance and safety information at the ground station, where 

it will be readily accessible to the PIC and the VO before, during, and after operations. This 

exemption provides an equivalent level of safety to 14 C.F.R. 91.7(a) because the PIC, based on his 

knowledge of the aircraft and the documents available, will be able to make the determination as to 

the airworthy condition, in accordance with 14 C.F.R. 91.7(b). 

G. 14 C.F.R. 91.9(b) (2): Civil aircraft flight manual, marking, and placard requirements

The FAA previously stated that no exemption is required for this section. Exhibit 2 at 17. Chris 

Houseman requests the same determination to be made for this Petition. 

Alternatively, Chris Houseman requests an exemption from 14 C.F.R. 91.9(b) (2). This part provides: 

"(b) 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 15 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." 

First, there does not currently exist a method of approving manuals for sUAS. Second, given the size 

and configuration of the sUAS, there is no space to carry such a flight manual on the aircraft. In 

addition, carrying the manual on the aircraft would be pointless, since there is no pilot or other 

person on board who could read or use it. The equivalent – and in fact a greater - level of safety will 

be maintained by keeping the flight manual at the ground control point where the pilot flying the 

sUAS will have immediate access to it. 

On August 8, 2014, the FAA issued a memorandum entitled “Interpretation regarding whether 

certain required documents may be kept at an unmanned aircraft’s control station.” This document 

stated, in part “maintaining these documents at the pilot’s control station would meet the intent of 

the rule as the pilot would be able to produce the documents for his or her own information or to an 

FAA inspector.” Exhibit 1. 

Equivalent level of safety: Chris Houseman will keep its flight manual at the ground station, where 

both the PIC and VO can access it. An equivalent level of safety to 14 C.F.R. 91.9(b) (2) is provided 

because the intent of this rule – the pilot having access to this material during flight – is met. 

H. 14 C.F.R. 91.9(c): Civil aircraft flight manual, marking, and placard requirements
Chris Houseman requests an exemption from 14 C.F.R. 91.9(c). This part provides: "(c) No person 

may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 

45 of this chapter." As stated above, Chris Houseman has submitted AC Form 8050-1 to the FAA 

Registration Office in order to obtain his N-Number (N108FF), and has obtained his N-Number which 

will be placed on the body of the aircraft in lettering as large as practicably possible. The sUAS, due 

to its small size, does not have room to contain fireproof placard or to display aircraft marks in a 

conventional size. However, Chris Houseman will place his N-Numbers on the “arms” or fuselage of 

the aircraft in lettering as large as practicably possible, once obtained from the FAA. 

Equivalent level of safety: Chris Houseman has obtained his N-Number (N108FF) from the FAA 

Registration Office and will place it body of the aircraft as large as practicably possible. An 

equivalent level of safety to 14 C.F.R. 91.9(c) is met because the Suas will be registered with the FAA 

and identifiable in the event of an incident. 

I. 14 C.F.R. 91.103(b) (2): Preflight action

Chris Houseman requests an exemption from 14 C.F.R. 91.103(b)(2). This part provides: "Each pilot 

in command shall, before beginning a flight, become familiar with all available information 

concerning that flight. This information must include—... (b) For any flight, runway lengths at 

airports of intended use, and the following takeoff and landing distance information: ... (2) For civil 

aircraft other than those specified in paragraph (b) (1) of this section, other reliable information 

appropriate 16 to the aircraft, relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and temperature." Because flights of 

the sUAS will not be at airports, Part 91.103(b) (2) does not apply. 

Equivalent level of safety: The Chris Houseman PIC will, before beginning a flight, become familiar 

with all available and relevant information concerning the craft and that flight, including wind and 

temperature. However, as the flights of the sUAS will not begin or end at airports, the airportrelated information required in Part 91.103(b)(2) does not apply. As a condition to the approval of 

exemption, Chris Houseman shall perform the preflight operations set forth in its operations 

manual. 

J. 14 C.F.R. 91.105:

Flight crewmembers at stations. Chris Houseman requests an exemption from 14 C.F.R. 91.105 since 

this part is not applicable due to the sUAS carrying no flight crewmembers. 

Equivalent level of safety: The requested exemption will achieve an equivalent level of safety 

because Chris Houseman will not operate the aircraft unless someone is at the controls at all times. 

Each flight will be manual, with the exception of the DJI Phantom 3 Advance’s emergency return-tohome and stabilization features. This will achieve an equivalent level of safety to 14 C.F.R. 91.105 

because the flight crew will be at their stations at all times during the flight. The stations will not be 

on the aircraft, but on the ground. 

K. 14 C.F.R. 91.113(b): Right-of-way rules: Except water operations

Chris Houseman requests an exemption from 14 C.F.R. 113(b) to the extent that it applies to 

overhead aircraft operating at or above 500 feet AGL as the sUAS will be operating no higher than 

400 feet AGL. This part provides: “(b): General. When weather conditions permit, regardless of 

whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall 
be maintained by each person operating an aircraft so as to see and avoid other aircraft. When a 

rule of this section gives another aircraft the right-of way, the pilot shall give way to that aircraft and 

may not pass over, under, or ahead of it unless well clear." For example, if another aircraft is 

operating overhead at 10,000 feet AGL there is no danger posed to that other aircraft if the sUAS is 

operating under it or ahead of it at or beneath 400 feet AGL. 

Equivalent Level of Safety:

Chris Houseman will operate its sUAS to see and avoid and give way to other aircraft that should 

enter airspace at or below 400 feet AGL, and will give right-of-way to manned aircraft. This will 

provide an equivalent level of safety to 14 C.F.R. 91.113(b) because the sUAS has significantly 

greater mobility than a much larger, manned aircraft. As a result, the PIC will be able to react and 

respond much more quickly than the other pilot.

L. 14 C.F.R. 91.119(b) and (c): Minimum safe altitudes: General.

Chris Houseman requests an exemption from 14 C.F.R. 91.119 subparts (b) and (c). This regulation 

provides: "Except when necessary for takeoff or landing, no person may operate an aircraft below 

the following altitudes: (b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest 

obstacle within a horizontal radius of 2,000 feet of the aircraft. (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 closer than 500 feet to any person, vessel, vehicle, or 

structure.” 

Chris Houseman requests an exemption to allow it to conduct flight operations closer than 500 feet 

to vessels, vehicles and structures when the owner/controller of any such vessels, vehicles or 

structures grants permission for the operation and the PIC makes a safety assessment of the risk of 

operating closer to those objects and determines that it does not present an undue hazard. Chris 

Houseman also requests an exemption allowing it to fly closer than 500 feet to participating 

individuals. 

Equivalent level of safety:

Chris Houseman will not operate the sUAS any higher than 400 feet AGL, and the majority of flights 

will be closer to 100 feet AGL. Furthermore, while Chris Houseman will not be operating over any 

congested areas, the sUAS will necessarily be flown closer than 500 feet to the natural areas and 

structures it will be filming (as well as closer than 500 feet to the ground). When planning 

operations, Chris Houseman will work with local FSDO to determine the proper location for filming. 

Additionally, prior to each operation, Chris Houseman’s flight crew will conduct a safety assessment 

and will not operate its sUAS without determining that there are no undue safety hazards. Chris 

Houseman will also have a buffer zone to prevent unauthorized individuals from entering into the 

flight area. Chris Houseman’s VOs will serve as fence posts on the outer edges of the flight 

operational area in order to actively monitor the space for unauthorized and nonparticipating 

individuals. Should one appear, Chris Houseman will safely land the sUAS in a manner meant to 

avoid the unauthorized/nonparticipating individual. This will provide an equivalent level of safety to 

14 C.F.R. 91.119(b) and (c) because the PIC and flight crew will make a safety assessment of the risk 

of operating, and determine that it does not present an undue hazard. 

M. 14 C.F.R. 91.121: Altimeter Settings
Chris Houseman requests an exemption from 14 C.F.R. 91.121. This Part provides guidelines for 

altimeter use in maintaining the cruising altitude or flight level of the aircraft. Chris Houseman is not 

requesting a general exemption from the requirement that its sUAS have an Altimeter. The DJI 

Phantom 3 Advance’s flight controller has an internal measurement unit (“IMU”). The IMU has a 

built-in internal sensor and a barometric altimeter that measures both attitude and altitude. Exhibit 

4, Exhibit 1. Rather, Chris Houseman requests an exemption from the requirement to set its 18 

altimeter to a station along the route, or out of an airport, because the DJI Phantom 3 Advance will 

not be traveling point-to-point and is limited in the distance it can travel from the PIC. Additionally, 

Chris Houseman will not be flying into or out of an airport. 

Equivalent Level of Safety:

Chris Houseman‘s operation of the sUAS will not exceed 400 feet AGL and will be operated in a 

fashion that is not a sustained cruising flight such as a manned aircraft will typically fly. The operator 

will be able to observe and control the maximum height of the sUAS through the telemetry features 

of the transmitter and on the laptop at the ground station. The telemetry features of both the 

GT80X and DJI Phantom 3 Advance provide altitude information from the onboard flight controller. 

Additionally, the sUAS will be operated within the line of sight. Therefore, the equivalent level of 

safety provided by Section 91.121 will be met. The FAA has previously granted this exemption. 

Exhibit 2. 

N. 14 C.F.R. 91.151: Fuel requirements for flight in VFR conditions

DJI Phantom 3 Advanced is powered by electricity, using lithium polymer batteries that currently 

have a flight limit of approximately no more than 18 minutes, with optional batteries of 4480 mAh 

and flight times up to 22 minutes. Exhibit 1. Therefore, due to the limitations of the batteries, it is 

currently impossible to comply with Part 91.151. However, the sUAS will be operated in a manner 

with at least the equivalent level of safety as that of a manned aircraft complying with Part 91.151. 

Operation of a sUAS with less than 30 minutes of reserve fuel does not engender the type of risks 

that Section 91.151(a) was intended to alleviate. During the entire flight, the PIC will always have a 

visual line of sight of the sUAS and the VO will be monitoring the battery life via the telemetry 

display on the laptop at the ground station. The sUAS will always have enough power to land safely, 

given the minimum level of reserve capacity of the batteries. 

When flying the DJI Phantom 3 Advanced, the low battery failsafe is triggered when the DJI 

Intelligent Flight Battery is depleted to a point that may affect the safe return of the aircraft. This 

threshold is automatically determined based on the current aircraft altitude and its distance from 

the home spot. For more information regarding this safety procedure, please refer to Exhibit 1. 

Applicant believes that an exemption from 14 CFR §91.151(a) is entirely consistent with the scope of 

similar exemptions already granted to other operations, including the MPAA Exemptions. Exhibit 9. 

Equivalent level of safety: Chris Houseman will land the DJI Phantom 3 Advanced when the low 

battery level failsafe is triggered. The proposed exemption meets an equivalent level of safety to 14 

C.F.R. 91.151 because, given the limitations on Chris Houseman’s proposed operations and the 

location of those operations, a reduced minimum power reserve for flight in daylight VFR conditions 

is reasonable. 
O. 14 C.F.R. 91.203(a) and (b): Civil aircraft: Certifications required

Chris Houseman requests an exemption from 14 C.F.R. 91.203(a) and (b). This section provides in 19 

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... (2) An effective U.S. 

registration certificate issued to its owner... (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.” 

There are currently no procedures by which the FAA can approve airworthiness certificates for sUAS. 

However, Chris Houseman has submitted an AC Form 8050-1 to the FAA Registration Office and has 

obtained his N-Number (N108FF), which will be placed on the body of the aircraft as large as 

practicably possible, and the PIC will have the operator’s manual and log book at the ground station, 

which have of the relevant testing and data information for each sUAS. 

Additionally, the autopilot systems for the DJI Phantom 3 Advanced provides a number of safety 

features, including the failsafe automatic return to home if the radio control link is broken. Because 

of the use of GPS with the sUAS, the operator will set the initial location of flight takeoff ("home 

position"), and two alternative “safety zones” the sUAS can be directed to, should the home position 

become unsafe. If the radio control link is broken, the Autopilot system will recognize this broken 

control link and cause the sUAS to automatically return to the home position as recorded by the GPS 

instrumentation. Because the sUAS team will mark off an area with traffic cones that has a 50-100 

foot diameter that will be used as the “home position” for the sUAS to return, no one will be 

standing in the way of the path. More information about the DJI Phantom 3 Advance’s flight control 

system can be found on page 12 of its user manual, submitted as Exhibit 1. 

In the restricted environment and under the conditions proposed, operation of the sUAS will be at 

least as safe as a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness 

certificate. Chris Houseman will not accept assignments from clients who are within 5 miles of 

controlled airspace without first gaining written and/or oral permission from air traffic control. 

Equivalent level of safety: The DJI Phantom 3 is no more than 6 pounds. The sUAS will be tightly 

controlled and monitored by the operator and the observer and in compliance with the 

requirements of the FAA’s grant of this petition and all local public safety requirements. This will 

ensure safety and security for the area of operation. The FAA will have advance notice of all 

operations because Chris Houseman will notify both ATC and the local FSDO prior to operating, as 

outlined above. These safety enhancements provide a greater degree of 20 safety to the public and 

property owners than conventional operations conducted with airworthiness certificates issued 

under Subpart H. Lastly, application of these same criteria demonstrates that there is no credible 

threat to national security posed by the UAS, due to its size, speed of operation, location of 

operation, and inability to carry a substantial payload. Granting the proposed exemption will achieve 

an equivalent level of safety to 14 C.F.R. 91.203(a) and (b) because of the small size of the sUAS and 

the operational limits set out above. 

P. 14 C.F.R. 91.215: ATC Transponder and Altitude Reporting Equipment and Use
This section requires that installed Air Traffic Control (ATC) transponder equipment must meet 

specific performance and environmental requirements, and aircraft must be equipped with an 

operable coded radar beacon transponder. 

The DJI Phantom 3 is not equipped with ATC transponder equipment. It is designed to fly in limited 

airspace under the control of a ground station. Because the sUAS used by Chris Houseman will not 

be flying into or near airports, and will fly no higher than 400 feet AGL, they will not share airspace 

with manned aircraft and there is very low risk of collision. In addition, because there will be no 

need to have contemporaneous communication with ATC Control, due to the short distances, short 

flight times, and restricted altitude the sUAS will operate within, Chris Houseman requests an 

exemption from this section. Additionally, the sUAS is too small to contain ATC transponder 

equipment in any form factor that is known to be available commercially at a reasonable cost. 

Equivalent level of safety: An equivalent level of safety to 14 C.F.R. 91.125 will be met because Chris 

Houseman will not fly his sUAS into or near airports. All operations will be below 400 feet AGL, so 

there is very low risk of collision with any manned aircraft. The DJI Phantom 3 will always be flown 

within the line of sight of the PIC. Chris Houseman will contact local ATC before operations to issue a 

NOTAM, and the local FSDO with its flight plan. Chris Houseman will also give right of way to 

manned aircraft as they do appear. 

Q. 14 C.F.R. 91.403: General

This section requires that the owner or operator of an aircraft is primarily responsible for 

maintaining that aircraft in an airworthy condition. Chris Houseman will adhere to this requirement. 

However, this Section also limits maintenance to that “prescribed in this subpart and other 

applicable regulations, including part 43 of this chapter.” Because of this limitation, and because of 

the exemptions under Part 43 requested above, Chris Houseman requests an exemption from this 

Section. 

Equivalent level of safety: This exemption meets the requirements for an equivalent level of safety 

pursuant to Section 333 because of its small size, light weight, relatively slow speed, and use in 

controlled rural environments, as described previously in this petition. Chris Houseman will conduct 

maintenance and repairs of the DJI Phantom 3 under the supervision and direction of the sUAV’s

manufacturer and designer. 

R. 14 C.F.R. 91.405 (a) / (d): Maintenance Required 

This section requires that aircraft be inspected as prescribed by Section E, 14 C.F.R. 21 

§§91.401-91.421. As shown below, Chris Houseman is applying for an exemption for these sections, 

due to the fact that its operators will inspect the sUAS prior to each flight and keep a record of all 

maintenance that is done. Additionally, prior to each operation, Chris Houseman will conduct a preflight safety check of the DJI Phantom 3. This safety check is listed in the operations manual, 

submitted confidentially. Because the Sections discussed below are concerned with manned aircraft, 

and as such have inspection requirements designed for the safety of passengers, they are 

inapplicable to Chris Houseman. 
Chris Houseman is also applying for an exemption to subpart (d) of this section, which requires a 

placard to be installed and references §43.11. As noted previously, Chris Houseman requests an 

exemption to the placard requirement, because, due to the small size of the sUAS, there is no room 

to place the placard. As an alternative and to achieve an equivalent level of safety, Chris Houseman

keeps logbooks detailing all repairs. 

Despite the requested exemption from subparts (a) and (d) of this section, Chris Houseman will 

follow subparts (b) and (c) of this subpart. 

Equivalent level of safety: The requested exemption will meet an equivalent level of safety to 14 

C.F.R. 405 (a) and (d) because Chris Houseman will repair and maintain the DJI Phantom 3 by 

following the manufacturer’s specifications. 

S. 14 C.F.R. 91.407: Operation after maintenance, preventive maintenance, rebuilding, or 

alteration

This section prevents any aircraft from operation that “has undergone maintenance, preventative 

maintenance, rebuilding, or alteration unless (1) [i]t has been approved for return to service by a 

person authorized under § 43.7 of this chapter; and (2) [t]he maintenance record entry required by 

§43.9 or §43.11, as applicable, of this chapter has been made.” 

However, Chris Houseman has requested an exemption from §§ 43.7 and 43.11 as described 

previously. The capability of the operators to maintain and repair the sUAS meets the requirements 

for an equivalent level of safety pursuant to Section 333 for both sUAS, their intended use, and the 

rural operating environment. Additionally, due to the small size of the sUAS, there is no room to 

place inspection placards. 

Therefore, because Chris Houseman has requested an exemption from 43.7 and 43.11, Chris 

Houseman respectfully requests an exemption from 91.407. 

Equivalent level of safety:

To achieve an equivalent level of safety, Chris Houseman will regularly inspect and maintain his 

sUAS in the manner required for manned aircraft, under the supervision of and at the direction of 

the manufacturer of the DJI Phantom 3. Chris Houseman will repair and maintain the DJI Phantom 3

by following the manufacturer’s specifications. 

T. 14 C.F.R. 91.409: Inspections

This section lays out the requirements for inspections of aircraft. Chris Houseman respectfully 

requests an exemption from these requirements because they are intended to maintain the safety 

22 of manned aircraft significantly larger and capable of significantly longer flights than is sUAS. 

Equivalent level of safety: The requested exemption will meet or exceed the level of safety 

achieved by adherence to 14 C.F.R. 91.409 because Chris Houseman’s inspection and maintenance 

procedures of the DJI Phantom 3 are as identical as possible to the inspection and maintenance 

procedures of manned aircraft. Chris Houseman will repair and maintain the DJI Phantom 3 by 

following the manufacturer’s specifications. 

U. 14 C.F.R. 91.417: Maintenance records
Chris Houseman respectfully requests an exemption from this Section, as it is only applicable for 

aircraft with an airworthiness certificate. Because Chris Houseman will not have an airworthiness 

certificate, this Section is inapplicable. 

Equivalent level of safety: The requested exemption will provide an equivalent level of safety to 

14.C.F.R. 91.417 because Chris Houseman will keep detailed maintenance records on every part as it 

is replaced, including but not limited to propellers, batteries, and electrical components.