Precision	Air	Media	LLC

1162	Pacifica	Place

Encinitas,	CA	92024

760-212-1427

precisionairmedia@gmail.com

June	22,	2015

Exemption	Request	under	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	

Federal	Aviation	Regulations

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,	Precision	Air	Media	LLC		(PAM)	seeks	an	

exemption	from	Federal	Aviation	Regulations	(“FARs”)	detailed	below	for	the	

following	described	Unmanned	Aerial	System	referred	to	in	this	application	as	the	

PAM	System,	which	includes	an	Unmanned	Aircraft	(UA)	and	ground	station-based	

equipment	and	crew:

The	Unmanned	Aircraft	(UA):

 DJI	Phantom	3	Professional,	a	battery	operated,	light	weight	quadcopter	

which	takes	off	and	lands	vertically,	carrying	the	following	equipment:

 Sony	EXMOR	1⁄2.3”	camera

 Intelligent	flight	battery

 Flight	computer	with	GPS	navigation	and	location	ability	that	receives	signals	

for	flight	controls	from	a	ground-based	transmitter/controller

 Radio	transmitter	that	transmits	live	video	from	the	on-board	camera	plus	all	

flight	data	including	altitude,	speed,	and	direction	back	to	launch	site

The	ground	station	system:

 A	Pilot	in	Command	(PIC) in	operational	control	of	a	flight	from	beginning	to	

end,	as	well	as	control	of	the	UA	while	in	the	air

 A	remote	controller	connected	to	an	ipad	mini,	which	receives	live	video	feed	

from	the	camera	and	gives	flight	commands	to	the	UA.

 A	Visual	Observer	(VO)	is	a	person	who	provides	a	second	pair	of	eyes	to	

visually	track	the	UA	while	in	flight.

The	requested	exemption	would	support	an	application	for	a	commercial	Certificate	

of	Authorization	to	use	the	above-described PAM	system	to	support	aerial	

photography	and	video primarily	of real	estate	property, special	events,	and	

surveillance.
The	UA,	powered	by	batteries,	is	smaller,	lighter	and	more	maneuverable	than	a	

larger	aircraft	running	on	combustible	fuel.	It	operates	at	lower	altitudes	with	no	

people	on	board	and	will	thereby	reduce	current	risk	levels,	enhance	safety	and	

diminish	the	likelihood	of	death	or	serious	bodily	injury.	With	a	small	payload	and	

maximum	flight	time	of	only	20	minutes,	this	offers	little	or	no	risk	to	national	

security.

Aerial	photos	and	video	are	far	more	effective	at	displaying	characteristics	of	large	

properties,	as	well	as	creating	a	unique	vision	for special	events.	Surveying	the	land	

with	the	UA will	help	create	accurate	maps.	Helicopters	can	be	used,	but	they	are	

more	expensive	and	not	able	to	fly	as	low.	The	benefits	of	reduced	cost	and	

improved	quality	of	presentation	from	the	UA	will	be	valuable	to	and	benefit	many	

buyers	and	sellers	of	real	estate	property	as	well	as	many	citizens	and	government	

agencies	requiring	accurate	maps	in	the	local	area.

Additionally,	we	request	that	we	be	allowed	to	use	our	system	to	benefit	first	

responders	nearby	who	might	require	assistance,	including	firefighters,	police,	

sheriffs	and	the	like	while	remaining	subject	to	all	limitations	cited	in	this	

application	as	we	do	so.

Limitations	of	Operations:

1. The	PAM	system	shall	be	operated	in	daytime	only.

2. The	UAS	shall	be	operated	by	a	visual	line	of	sight	(VLOS)	at	all	times.

3. A	Visual	Observer	(VO)	maintaining	a	VLOS	will	be	utilized	at	all	times.

4. The	UAS	shall	remain	within	1000’	horizontal	distance	of	the	PIC	at	all	

times.

5. The	UAS	will	have	an	altitude	restriction	of	400’	AGL.

6. The	UAS	will	not	be	operated	at	a	speed	exceeding	30	knots.

7. Operations	documents	will	be	accessible	to	the PIC	at	all	times	and	must	

be	accessible	during	UAS	operations	and	made	available	to	the	

Administrator	on	request.

8. PIC	must	inspect	and	ensure	that	the	PAM	system	is	in	airworthy	

condition	prior	to	each	operation.	If	determined	un-airworthy,	all	

operations will	be	suspended	until	such	time	as	necessary	maintenance	

has	been	performed	and	the	UAS	is	determined	to	be	in	a	safe	condition	

for	flight.

9. An	operational	flight	test	is	required	after	any	maintenance	or	alterations	

that	may	affect	UAS	operation	or	flight.

10. UAS	maintenance	must	follow	manufactures	aircraft	and	component,	

maintenance,	overhaul,	and	replacement,	inspection,	and	life	limit	

requirements.

11. The	operator	must	carry	out	its	maintenance,	inspections,	and	record	

keeping	requirements,	in	accordance	with	the	operating	documents.	

Maintenance	and	inspection,	and	alterations	must	be	noted	in	the	aircraft	
records	including	total	flight	hours	and	the	description	of	work	

performed.

12. UAS	must	be	operated	by	a	PIC	possessing	at	least	a	private	pilot	

certificate and	at	least	a	current	Third	Class	Medical.

13. No	operation	will	come	within	5	nautical	miles	of	an	airport.

14. All	operations	will	stay	within	Class	G	airspace.

15. No	operation	will	occur	from	a	moving	platform.

16. The	PAM	system	will	not	operate	any	closer	than	100’	to	any	structure	

without	the	permission	of	the	structure,	building,	or	property	owner.

17. The	UAS	will	be	limited	to	30	minutes	of	flight	or	20%	of	battery	power,	

whichever	occurs	first.

The	regulations	from	which	the	exemption	is	requested	are	as	follows:

14	CFR	91.7(A)	Airworthiness	Certificate

Prohibits	the	operation	of	an	aircraft	without	an	airworthiness	certificate.	Petitioner	

requests	exemption	based on	previous	exemption	no.	11845.	The	FAA	has	ruled	that	

this	make	and	model	of	aircraft	(UAS)	does	not	require	an	airworthiness	certificate.

14	CFR	91.9	(B)(2)	Aircraft	Flight	Manual

Requires	an	aircraft	flight	manual	in	the	aircraft.	As	there	are	no	pilots	or	

passengers	aboard	and	given	the	size	of	the	UAS,	this	regulation	in	inapplicable.	An	

equivalent	level	of	safety	will	be	achieved	by	maintaining	a	manual	in	the	possession	

of	the	PIC.

14	CFR	91.103	Pre-flight

No	approved	Aircraft	Flight	Manual	on	board	the	UAS.	The	petitioner	asserts	that	an	

equivalent	level	of	safety	will	be	achieved	by	the PIC	taking	all	pre-flight	actions	set	

forth	in	the	operating	documents	including	weather,	flight	battery	requirements,	

landing	and	takeoff	distances	and	aircraft	performance	data	before	initiation	of	each	

flight.

14	CFR	91.109	Flight	Instruction

There	are	no	dual	controls	available	for	flight	instruction.

14	CFR	91.119	(C)	Minimum	Safe	Altitudes

States	that	no	person	may	operate	an	aircraft	below	the	following	altitudes:	over	

other	than	congested	areas,	an	altitude	of	500’	above	the	surface,	except	over	open	

water	or	sparsely	populated	areas.	In	those	cases,	the	aircraft	may	not	be	operated	

closer	than	500’	to	any	person,	vessel,	vehicle,	or	structure.	
The	petitioner	will	not	operate	any	UAS	over	an	altitude	of	400’	AGL.	There	will	be	

cases	when	the	500’	distance	from	structures	will	need	to	be	exempted.	(Example:	

Aerial	video	of	home	to	show	details	of	a	newly	installed	roof.)	In	this	type	of	

operation, every	assurance	will	be	made	to	keep	persons	outside	safe	and	clear	of	

operations.	

The	petitioner	will	implement	procedures	and	policies	to	ensure	that	any	person	in	

the	general	vicinity	of	operations	will	be	aware	of	such	operations	and	ensure	that	

all non-essential	personnel	are	cleared	of	the	area	of	operations	to	the	extent	

possible.	

14	CFR	91.121	Altimeter	Settings

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	

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

airport	or	an	appropriate	altimeter	setting	available	before	departure.”	As	the	UAS	

may	not	have	a	barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	

exemption	may	be	needed.	An	equivalent	level	of	safety	will	be achieved	by	the	

operator,	pursuant	to	the	Manual	and	Safety	Check	list,	confirming	the	altitude	of	

the	Launch	site	shown	on	the	GPS	altitude	indicator	before	flight.	

14	CFR	91.151(a)(1)	Fuel	for	Flight

No	person	may	begin	a	flight	in	an	airplane	under	VFR	conditions	unless	there	is	

enough	fuel	to	fly	to	the	first	point	of	intended	landing	and	assuming	normal	cruise	

speeds.

(a)(1)	During	the	day	to	fly	for	at	least	30	minutes

The	petitioner	requests	relief	from	this	regulation	due	to	the	fact	that	the	UAS	is	

equipped	with	a	battery	and	percentage	indicator	system.	By	limiting	flights	to	30	

minutes	or	enough	battery	reserved	to	ensure	that	the	UAS	lands	at	the	ground	

station	with	at	least	20%	of	battery	power	(whichever	happens	first)	will	maintain	

an	efficient	level	of	safety.	This	restriction	would	be	more	than	adequate	to	return	

the	UAS	to	its	planned	landing	zone	from	anywhere	in	its	limited	operating	area.

14	CFR	91.203(a)(b)	Carrying	of	civil	aircraft	Certifications	and	Registrations

Provides	for	the	carrying	of	civil	aircraft	certifications	and	registrations.	They	are	

inapplicable	for	the	same	reasons	described	above.	Operations	manuals	and	Safety	

Procedures	will	be	maintained	at	the	Precision	Air	Media	LLC	home	office	with	

copies	of	the	same	traveling	with	the	PIC.

14	CFR	91.405(a);	407(a)(1);	409(a)(2);	417	(a)&(b)	Maintenance	inspections
These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft	

inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required	

inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	

repaired	as	prescribed	in	part	43	of	this	chapter...,” and	others	shall	inspect	or	

maintain	the	aircraft	in	compliance	with	Part	43.

Given	that	these	sections	and	part	43	apply	only	to	aircraft	with	an	airworthiness	

certificate,	these	sections	will	not	apply	to	the	PAM	system.	Maintenance	will	be	

accomplished	by	the	operator	pursuant	to	the	flight	manual	and	operating	

handbook	as	referenced	in	the	Manual.	An	equivalent level	of	safety	will	be	achieved	

because	the	UAS	is	very	limited	in	size	and	will	carry	a	small	payload	and	operate	

only	in	restricted	areas	for	limited	periods	of	time.	If	mechanical	issues	arise,	the	

UAS	can	land	immediately	and	will	be	operating	from	no	higher	than	400’	AGL.	As	

provided	in	the	Manual,	the	operator	will	ensure	that	the	UAS	is	in	working	order	

prior	to	initiating	flight,	perform	required	maintenance,	and	keep	a	log	of	any	

maintenance	performed.	Moreover,	the	operator	is	the	person	most	familiar	with	

the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	to	

provide	the	equivalent	level	of	safety.

14	CFR	45.23(b)	Marking	of	the	Aircraft

Applicable	codes	of	Federal	Regulation	require	an	aircraft	to	be	marked	according	to	

certain	specifications.	Precision	Air	Media	UASs	are,	by	definition,	unmanned.	

Therefore,	they	do	not	have	a	cabin,	cockpit	or	pilot	station	on	which	to	mark	

certain	words	or	phrases.	Furthermore,	two	inch	lettering	is	difficult	to	place	on	

such	a	small	aircraft.	Regardless,	Precision	Air	Media	LLC	will,	if	required,	mark	its	

UASs	in	the	largest	possible	lettering	by	placing	the	“N”	number	on	its	fuselage	as	

required	by	14	CFR	45.29	(f)	so	that	the	PIC	and	VO	will	see	the	markings.	

14	CFR	21, Sub	Part	H	Airworthiness	Certificates

Entitled	Airworthiness	Certificates,	set	forth	requirements	for	procurement	of	

necessary	airworthiness	certificates	in	relation	to	FAR	91.203(a)(1).	The	size,	

weight	and	enclosed	operational	area	of	PAM	system	permits	exemption	from	Part	

21	because	it	meets	an	equivalent	level	of	safety	pursuant	to	Section	333	of	the	

Reform	Act.	The	FAA	is	authorized	to	exempt	aircraft	from	the	airworthiness	

certificate	requirement	under	both	the	Act	(49	USC	44701	(f))	and	Section	333 of	

the	Reform	Act.	Both	pieces	of	the	legislation	permit	the	FAA	to	exempt	UAS	from	

the	airworthiness	certificate	requirement	in	consideration	of	the	weight,	sized,	

speed,	maneuverability	and	proximity	to	areas	such	as	airports	and	dense	

populations.	The	PAM	system	meets	or	exceeds	each	of	the	elements.

14	CFR	61.113	(a)(b)	Private	Pilot	Privileges	and	Limitations	PIC

Private	pilots	are	limited	to	non-commercial	operations.	Precision	Air	Media	LLC	

can	achieve	an	equivalent	level	of	safety	as	achieved	by	current	regulations	because	
the	PAM	UASs	do	not	carry	any	pilots	or	passengers.	Furthermore,	while	helpful,	a	

pilot	license	will	not	ensure	remote	control	piloting	skill.	The	PIC	of	Precision	Air	

Media	has	had	many	hours	of	practice	and	has	mastered	the	skills	of	controlling	the	

PAM	system.	The	risk	attendant	to	the	operation	of	the	PAM	system	is	far	less	than	

the	risk	levels	inherent	in	the	commercial	activities	outlined	in	CFR	61.	Thus,	

allowing	Precision	Air	Media	LLC	to	operate	the	PAM	system	with	a	private	pilot	as	

the	PIC	will	exceed	current	safety	levels	in	relation	to	CFR	61.113(a)(b).	

The	name	and	contact	information	of	the	applicant	are:

Precision	Air	Media	LLC

Attn:	Dominic	Arguelles

Ph:760-212-1427

Email:	precisionairmedia@gmail.com

We	are	prepared	to	modify	or	amend	any	part	of	this	request	to	satisfy	the	need	for	

an	equivalent	level	of	safety.	We	look	forward	to	working	with	your	office.	Please	

contact	us	at	any	time	if	you	require	additional information	or	clarification.

Sincerely,

Dominic	Arguelles

CEO	Precision	Air	Media