November 15, 2015

FROM: Ronlad Mehran Loghmani

10859 Via Los Narcisos Apt B

San Diego CA, 92129

619-995-4490

ronloghmani@gmail.com

TO: U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., S.E.

Washington, DC 20590

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

11 of the Federal Aviation Regulations contained in 14 CFR: 45.23(b), 91.103, 91.109, 

91.119, 91.121, 91.151(a), 91.203(a), 91.7(a), 91.9(b)(2), 91.405(a), 91.407(a)(1), 

91.409(a)(2), 91.417(a)(b).

To whom it may concern:

I am writing the exemption request on my own behalf, acting as pro pur – without 

counsel.

Pursuant to section 333 of the FAA Modernization and Reform Act of 2012 (the “reform 

Act”) and C.F.R. Part 11, Ronald Mehran Loghmani (petitioner, applicant, operator, 

operational control). Owner and operator of a Small Unmanned Aircraft System (sUAS) 

seek exemption from Federal Aviation Regulations detailed herein for the operation of 

lightweight aerial imaging equipment for the purpose of aerial photography, videography, 

and for search and rescue operations.

The reason this applicant requesting exemptions from listed Federal aviation Regulations 

is to allow for commercial operation of the sUAS to collect aerial images/video for real 

estate, wedding, newsgathering, and search and rescue events 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 333.1.

The Petitioner/Operation:

The petitioner – Ronald Mehran Loghmani has been a licensed pilot since 1993 currently 

holding an Airline Transport Pilot Certificate (#2524382) for Multi Engine Land and CE500 (Cessna Citation II Jet) type, and commercial pilot privileges for single Engine Land 

Airplane. The petitioner also holds a Certified Flight Instructor Certificate

(#2524382CFI) for Airplane Single/Multi Engine and Instrument Airplane. The petitioner 

has 7378 hours total time, and has served as Chief Flight Instructor / Check Instructor for 
California Flight Academy for three years.

The petitioner has 3 years experience in aerial photography from Cessna 172,172RG 

manned aircraft platform. The petitioner has been flying model aircraft for many years

including new sUAS ‘quadcopters’.

The petitioner has instilled safety protocols derived from his training as a manned-aircraft 

professional pilot in combination with working with interests on the ground to avoid and 

prevent abs UAS being a public hazard both in the air and on the ground. The petitioner 

is available to offer assistance to the FAA in developing operational and safety protocols 

for sUAS’s to be integrated into the National Airspace System(NAS). The petitioner 

believes that his exemption, if granted, would provide the FAA with an analytical, 

expanded and diverse sUAS experience to help establish the necessary requirements and 

protocols for the safe operation of such aircraft systems in numerous applications within 

the NAS.

Aircraft

The petitioner will operate a sUAS made by manufacturer DJI, model number W322. 

Serial number P77DCF19013452, FAA registered under tail number N913RL. The 

Phantom 3 Advanced description and equipment is as follows:

The Phantom 3 Advanced is a sUAS quadcopter made by DJI, that has a fixed camera

gimbal attached to a 4k camera, which sits below the aircraft fuselage. This camera 

allows the operator on the ground to see a 720p high resolution a view from the aircraft 

that can be rotated a 360 degrees angle in flight.

Max take off weigh is 2.76 pounds.

Downlink telemetry to allow the operator to see onboard information relating to safe 

operations of flight including but not limited to; battery percentage remaining, overall 

status of flight system, GPS location for position hold, auto return to home and 

operational failsafes.

The Phantom 3 Advanced is limited by its software to a maximum ascent rate of 984 feet 

per minute and an altitude of 400 feet. Its maximum forward speed is 36 statue miles per 

hour or 31 knots,

The Phantom 3 Advanced is powered by a 6000 mAh, 15.2 volt battery, providing 22 

minutes of flight time under standard conditions per specifications. The aircraft alerts the 

operator with visual and audible warnings at 35% of battery remaining. The aircraft will 

not be operated with less than 35% battery remaining, and 0-35% is kept as emergency 

reserve to power the sUAS to a safe landing location in the event of an emergency.
Ground based control and communication system

The Phantom 3 Advanced is Controlled using a DJI manufactured transmitter, operating 

on FCC authorized frequencies of the 2.4 GHz band(2.4-2.483 GHz) see manual page 57 

for radio transmitter specification. The transmitter has been approved by the Federal 

Communication Commission and bears approval logo on the transmitter.

The above listed transmitter has a lithium polymer battery powering the unit for 

approximately 4 hours charge between charges according to DJI specifications.

The Phantom 3 Advanced controller will be utilized by a single operator, but will require 

a visual observer when necessary.

The Phantom 3 Advanced when coupled with an apple ipad mini provides the operator 

with a moving map display showing exact aircraft position, and HD video from aircraft 

camera. Also the controller has its own GPS receiver establishing a “home point” on each

take off, therefore calibrating the aircraft to return to this take off point in the event of a 

control link signal or interference.

Ronald Mehran Loghmani –the petioner/operator while engaged in a sUAS flight under 

this exemption will be carrying a Yaesu FTA-550, AirBand communication radio serial 

number #4N100614. The radio is capable of transmitting and receiving radio signals on 

the IACO radio aviation band of 118.000 to 136.975 MHz. The radio has a transmitter 

power output of 5 watts AM PEP. While the sUAS is in flight in class G and E airspace 

the operator, and/or observer will monitor “guard” frequency of 121.500 MHz. If 

operations are in controlled airspace classes B,C,D.E, the operator will monitor and 

communicate directly if needed with the ATC facility in charge of that respective 

airspace. Communication with ATC will be standard aviation communication 

etiquette/procedures utilizing the sUAS’s “N” number issued by the FAA registration 

branch to identify this aircraft to ATC. Having real time radio communication with ATC 

and nearby aircraft we believe adds a significant margin of safety to our operation and 

operation of other manned aircraft in the NAS. The operator also holds an FCC restricted 

radio telephone operator permit.

Ronald Mehran Loghmani Will be the sole operator of the sUAS for each flight, and 

when necessary will partner with a Visual Observer to assist in keeping insight the sUAS 

at all times. The Visual Observer will assist the operator with obstacle clearance, people 

separation and navigation over terrain.

Operator’s - Safety Plan

• Compliance with all FAA,state, and local municipal regulations.

• Altitude of operations less than 400 Feet AGL, although most operations will be 

at “tree line level” or under 200 feet.
• Preflight aircraft inspections conducted prior to each flight per DJI Phantom 3 

Advanced operator’s guide.

• Post flight aircraft inspection conducted to each flight per DJI Phantom 3 

Advanced operator’s guide.

• Operator will conduct preflight planning, to include a weather briefing via 

DUATS or FSS, NOTAM/TFR/MOA checks, battery- power management 

calculations, and any COA requests or ATC/Airport management notifications 

done before flight. 

 

• No operations directly over people or crowds.

• Operations will be only during daylight times, in VMC conditions, weather 

minimums include 500 feet below, 2,000 feet horizontal from clouds, and 

minimum 3 statue miles visibility. No Special VFR or IFR flights will 

be conducted.

 

• Any in-flight emergencies will result in an immediate landing. There will be no 

“land when practicable” operations. 

• The Phantom 3 Advanced will be maintained per DJI instructions, and will follow 

manufacturer safety bulletins. 

• If operating near an airport or in Class B, C, D airspace under a COA, operator 

will notify ATC via telephone prior to takeoff and notify via radio utilizing the 

sUAS’s tail number. If radio or telephone communications cannot be established 

with ATC/Tower, the flight will not commence. 

• When operating in-flight, operator will monitor “GUARD” frequency of 121.5 

MHZ and comply with any emergency requests if received. 

• Operator will grant right of way to ALL other manned operations and activities at 

all times.

Lastly, the petitioner’s safety plan is to operate the aircraft within the limitations provided 

by DJI – The manufacturer. This is to include, weight and balance, speed limitations, and 

altitude limitations.

Statutory Authority

Section 333, titled “Special Rules for Certain Unmanned Aircraft Systems,” provides a 

mechanism for seeking expedited FAA authorization of safe civil sUAS operations in the 

National Airspace System (NAS). Section 333(a) states that the FAA “shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system 
before completion of the comprehensive plan and rulemaking required by section 

332(b)(1) of this Act or the guidance required by section 334 of this Act.” In Section 

332(b)(1), Congress made it clear that Section 333 provides a mechanism for “expedited 

operational authorization.” The FAA has committed to complying with this mandate by 

granting several petitions almost identical to the one at hand. See, e.g. Exemption No. 

11062, Regulatory Docket No. FAA-2014-0352 (granting regulatory exemptions to 

Astreus Aerial for operation of unmanned aircraft systems for the purpose of filming for 

the motion picture and television industry and aerial videography).

Section 333(b) identifies several factors that the FAA should consider in determining 

whether commercial sUAS operations should be approved. These include populated 

areas, and operation within visual line of sight do not create a hazard to users of the NAS 

or the public or pose a threat to national security.” See section 333(b). In addition to the 

specific authority conferred by Section 333, the FAA Administrator has general authority 

to grant exemptions from the FAA’s safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest. See U.S.C. 

44701(f).

Requested Exemptions 

14 CFR Part 21 and 14 CFR 91.203(a): Airworthiness Certificates

The petitioner seeks exemptions to apply for and maintain airworthiness certification for 

our sUAS. Model and serial numbers of our sUAS is provided above. The petitioner will 

keep his sUAS in a safe, reliable, and airworthy condition, but it may not meet all 

standards set forth by part 91.203. Petitioner/operator will assume all responsibility for 

determining that the sUAS is in a condition safe for flight, as well as a condition that will 

not harm other people or property. This will be facilitated by operator, using specific 

guidelines from the manufacturer, DJI, as well as following any guidance set for routine 

maintenance. 

14 CFR 45.23(b): Display of Marks; general 

Under this part it is required that each operator must display on that aircraft marks 

consisting of the Roman Capital “N” followed by the registration number of the aircraft.

And near the entrance to the cabin or canopy etc., in letters between 2-6 inches in size the 

word “experimental”.

The Phantom 3 Advanced sUAS is physically too small to place “N” numbers and 

“experimental” identifiers of this size specified in this section. We can comply 

completely with an “N” number and the “experimental” identifier but at a smaller size 

(around 1”) is necessary to fit on the external shell of the Phantom 3 Adavnced sUAS. 
14 CFR 91.7(a): Civil aircraft airworthiness 

This section states that no person may operate a civil aircraft unless it is in an airworthy 

condition. 

Assuming no airworthiness certificate will be required due to relief requested from 14 

CFR 21 (above), no regulatory standard exists for determining airworthiness. The 

equivalent level of safety will be achieved through the implementation of the flight 

manual and maintenance manual procedures, pilot training/experience, and analytical risk 

management for each flight. 

14 CFR 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft

This section states that no person shall operate a US registered civil aircraft for which a 

rotorcraft flight manual is not required by §21.5 unless there is available in the aircraft a 

current approved rotorcraft manual material, markings, and placards, or any combination 

thereof. The Phantom 3 Advanced sUAS, given its size and configuration has no ability 

or place to carry such a flight manual on the aircraft, not only because there is no pilot on 

board, but because there is no room or physical capacity capability to carry such an item 

on the aircraft. The equivalent level of safety will be achieved by the operator keeping the 

flight manual at the ground control station, immediately accessible by the operator during 

operations. Previous precedence is resident in Exemptions 8607, 8737, f8738, 9299, 

9299A, 9565,9565B,10167, 10167A,10602,f32827, and 10700.

14 CFR 91.103: Preflight Action

This section requires each pilot in command to take certain actions before flight to insure 

the safety of the flight. As FAA approved rotorcraft flight manuals will not be provided 

for the aircraft an exemption is requested for relief. An equivalent level of safety will be 

obtained through the operator’s use of the DJI Phantom 3 Advanced Owners manual 

along with the petitioner’s/operator’s safety plan outlined above (supra). Extensive flight 

planning under these practices will provide the equivalent level of safety. 

14 CFR 91.109: Flight Instruction

This section states that no person shall operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning 

dual controls. The Phantom 3 Advanced like almost all sUAS aircraft by their design do 

not have fully functional dual controls. Flight control is accomplished through the use of 

a control box that communicates with the aircraft via a 2.4 GHz radio communications 

link. 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 notes 5778 K and 9862A. The equivalent level of safety provided by the fact 

that neither pilot nor passengers will be carried in the aircraft and training would be 

conducted at an FAA approved training site, operating under a COA. If training would be 

conducted it should be noted that the petitioner holds a Certified Flight Instructor's 

Certificate (2524382 CFI exp. 04/2016) for single and multi engine airplane, and 

instrument airplane. 
14 CFR 91.119: Minimum Safe Altitudes

This section establishes safe altitudes for operation of civil aircraft. Section 91.119(d) 

allows rotorcraft to be operated at less than the minimums prescribed, provided the 

person operating the helicopter to be operated at less than the minimums prescribed, 

provided the person operating the helicopter complies with any route or altitudes 

prescribed for rotorcraft by the FAA. As this exemption is for a sUAS, that is a rotorcraft 

and the exemption requests authority to operate at altitudes from the surface to 400’ 

AGL, an exemption may be needed to allow such operations. As set forth herein, except 

for the limited conditions stated in the DJI Phantom 3 Advanced manual, the sUAS will 

never operate at an altitude higher than 400’ AGL. It will however be operated in a 

restricted area with a bounded security perimeter where buildings and individuals will not 

be exposed to operations without their pre-obtained consent. This level of safety will be 

achieved utilizing telemetry from the Phantom 3 Advanced sent back to the operator’s 

console. Telemetry includes the following flight data: altitude (AGL), vertical and 

horizontal speed, direction and distance from operator. The equivalent level of safety will 

be achieved given the size, weight, speed, of the sUAS as well as the location where it 

will be operated over. No flight will be taken without the permission of the property 

owner or local authorities. Because of this advance notice to the property owner, and 

participants, all affected individuals will be aware of the flight operations. Compared to 

flight operations with rotorcraft or fixed wing aircraft weighing more far more than the 

maximum 55 pounds proposed in this exemption herein and the lack of flammable fuel, 

the risks involved we believe are far less than those presently presented with 

conventional aircraft used for our stated purposes. In addition, a level of safety to aircraft 

operating in the NAS will be achieved through our flights being at the lowest altitude 

possible below 400’ AGL, and offering full right of way to approaching aircraft.

14 CFR 91.121: Altimeter Settings

This section 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 sUAS may not have a 

barometric altimeter, but instead a GPS altitude readout, an exemption may be needed. 

An equivalent level of safety will be obtained by the operator, operating the aUAS 

pursuant to the manual and safety checklist, confirming the altitude of the takeoff site 

shown on the GPS altitude indicator before each flight.

14 CFR 91.151(a): Fuel Requirements for Flight in VFR Conditions

This section prohibits an individual from beginning 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. The battery power system in the 

DJI Phantom 3 Advanced sUAS provides the aircraft with approximately 25 minutes of 

total flight time. When the Phantom 3 Advanced battery is at 25% approx. 10 minutes of 

flight time is left. As stated in our safety plan above, the sUAS will not be operated with 

less than 35% or approx. 12 minutes of flight time remaining. The operator needs relief 

from the 30 minute requirement stated in this section as that time is longer than the useful 

flight time of the aircraft altogether.
14 CFR 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

This section requires that a person carry an appropriate airworthiness certificate that is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. The 

sUAS has no onboard pilot or passenger, and no area to stow these required papers. An 

equivalent level of safety will be achieved by keeping these documents at the ground 

control point where the pilot flying the sUAS will have immediate access to them, to the 

extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this 

regulation. A representative sample of other exceptions includes Exemption numbers: 

9565, 9665, 9789, 9789A , 9797, 9797A, 9816A, and 10700.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a)(b): Maintenance Inspections

These sections 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 other 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 petitioner. Maintenance 

will be accomplished by the operator pursuant to the DJI flight manual and operating 

handbook. An equivalent level of safety will be achieved because these physically small 

and lightweight small sUAS’s are very limited in size and will carry a very small payload 

operating only in restricted operational areas for limited periods of time. If mechanical 

issues arise, the sUAS will land immediately and will be no higher than 400’AGL. As 

provided in the flight manual, the operator will ensure that the sUAS is in working order 

prior to starting a flight, performing any required maintenance beforehand. 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. 

Closing

Ronald Mehran Loghmani is committed to safe flight practices, while integrating safe 

sUAS operations to the National Airspace System (NAS). We are confident in executing 

commercial sUAS operations that are safe, and provide a service to the public. Ronald 

Mehran Loghmani is prepared to respond to any concerns and I look forward to working 

with the FAA on this important exemption. Please contact us with any follow-up 

questions or concerns.

Respectfully Submitted,

__________________________________________

Ronald Mehran Loghmani

ATP Pilot Cert # 2524382