Gold Coast Aerial

1157 Bryce Way Ventura, CA 93003 (805) 415
-4055 goldcoastaerial@gmail.com
Attn: U.S. Department of Transportation , Docket Operations February 1 1 , 2016 West Building Ground Floor, Room # W12
- 140 1200 New Jersey Ave S.E. Washington, D.C. 20590
RE: Petition for Exemption to Section 333. Good morning FAA, I’m requesting an exemption to allow commercial operation of a DJI Phantom 3 Unmanned Aircraft Systems (UAS) pursuant to Section 333 of the FAA M odernization and Reform Act of 2012 (public law 112 -95) . I’m request ing exemption from the requirements of title 14 of the following Federal Regulations Sections : 21H , 45.23(b) , 61.113(a) & (b) , 91.7 (a) , 91.9(b)(2), 91.103(b), 91.119, 91.121 , 91.151(b ) , 91.203(a) & (b), 91.405(a ) , 91.407(a)(1) , 91.409(a)(1) & (a)(2) , 91.417(a) & (b) and title 14,chapter1 (d), parts 60
- 67 - 61.1 thru 61.429. Thank you for your consideration in this matter:
Peter E. Huscher Owner/operator Gold Coast Aerial 1157 Bryce Way Ven tura, CA 93003 (805) 415
-4055 goldcoastaerial@gmail.com**SUMMARY:**

Peter Huscher d ba. Gold Coast Aerial seeks an exemption from the requirements of section 14 C.F.R. sections 21H, 45.23(b), 61.113(a) & (b), 91.7(a), 91.9(b) (2) , 91.103(b), 91.119, 91.121, 91.151(b), 91.203(a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2) , 91.417(a) & (b) and title 14,chapter1(d),parts 60
- 67 - 61.1 thru 61.429, to operate an Unmanned Aircraft System (UAS) (DJI Pnatom3) pursuant to Section 333 of the FAA Moderni zation and Reform Act of 2012 (FMRA). This exemption will permit Gold Coast Aerial to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real est ate, civil landscapes, agriculture management and special events over certain areas of the United States.
**Introduction and Interests of Petitioner** Gold Coast Aerial is a privately owned and operated company that specializes in all aspects of traditiona l Digital H igh D efinition photography, videography and aerial photography. Gold Coast Aerial is located in Ventura California and serves all of California’s Gold Coast. From Santa Barbara to Santa Monica, Gold Coast Aerial uses “State of the Art” H igh
- D efi nition gyro
-stabilized aerial camera systems and Digital High D efinition photographic equipment, to provide its customers with the very best in traditional Digital H igh D efinition photography, videography and aerial photography. Gold Coast Aerial is a memb er of the UAVSA (Unmanned Aerial Vehicle Systems Association) and S.W.A.R.M. (Search With Aerial R emote Controlled Multi
- rotors). The objective of Gold Coast Aerial ’s Unmanned Aircraft System (DJI Phantom 3) operations, is to provide a more affordable, safer, high er quality service for a variety of governmental, commercial, public, residential and agricultural uses, such as:
 Construction sites (before and after)  Real Estate Appraisals and Marketing  Aerial Photography  Economic Development  Special Events Cove rage  Agriculture Monitoring  Search and Rescue  Private Requests
Gold Coast Aerial believes its Unmanned Aircraft System (DJI Phantom 3) operations will provide the community with a more affordable, safer and high er quality service as compared to fixed wing or helicopter services.**Unmanned Aircraft System:**

Gold Coast Aerial seeks and exemption to operate a DJI Phantom 3 Unmanned Aircraft System for the purpose of compensation for hire within the U.S. National Air Space. The DJI Phantom 3 UAS is a vertical take
-off and landing, unmanned aircraft. The aircraft is controlled by way of a Ground Control Station utilizing an electronic tablet monitoring system. The DJI Phantom 3 has a gross weight of approximately 2.8 lbs. while having a diagonal dimension of 23.2 inches. The DJI Phantom 3 aircraft has a maximum vertical speed of 16.4 fps and a maximum flying height of 400 feet AGL. The DJI Phantom 3 is equipped with four electric motors utilizing 4x9.5 inch props. The DJI Phantom 3 is powered by a lithium polymer battery system and ha s an approximate flight time of 25 minutes. Gold Coast Aerial’s DJI Phantom 3 unmanned aircraft system is currently registered with the FAA assigned N number N2077. DJI Phantom 3 Specifications are as foll ows:
 Assigned N Number : N2077  Name of Aircraft Manufacturer: DJI: Da
-Jiang Innovations  UAS Model Name & Model Number : Phantom 3 Professional #W343  UAS Serial Number: P76DCE15012077  UAV Class: Rotorcraft  U AV Maximum Take
-off Weight: 2.82 lbs  Category: Land and Sea  Name of Engine Manufacturer: DJI: Da
-Jiang Innovations  E ngine Model Designation: 2/2312
- P3007 CCW & 2/2312
- P3008 CW  Engine Serial Number’s: None  Number of Engines: 4  Engine Power output: approx. 1.5 lbs thrust each = 6.0 lbs total thrust  Engi ne Type: Electric
- 2CW & 2CCW  Props: 4 x 9.5” rotor props  Dimensions: approximately 23”
- measured diagonally:

**Basis for Petition:** Pursuant to the provisions of the Federal Aviation Regulations 14 C.F.R 11.61 and the FAA Modernization and Reform Act of 20 12, Section 333, the petitioner, Gold Coast Aerial requests an exemption from the requirements of title 14 for the following Federal Regulations Sections: 21H, 45.23(b), 61.113(a) & (b), 91.7 (a), 91.9 (b)(2) , 91.103(b), 91.119, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b) and title 14, chapter 1(d), parts 60
- 67 - 61.1 thru 61.429 , to commercially operate its DJI Phantom 3 within the U.S. N ational Air Space.**21H -**  **Air worthiness Certificate:**

In consideration of ma ximum speed, weight, size and limited operating are a associated with the unmanned aircraft system, the DJI Phantom 3 meets the conditions of FMRA Section 333 and therefore should not require an airworthiness certificate. Please refer to exemptions Nos. 116 23, 11650, 11664 and 11734. **45.23(b) -**  **Marking of Aircraft:** Given the size of the aircraft, 2” lettering is impossible. Petitioner request exemption to allow 1/2” lettering. Please refer to exemptions Nos. 8738, 10700, 10167 and 10167(a). **61.113(a) & (b )**  **– Private Pilot Privileges and limitations:**  Person in Charge (PIC) of the aircraft has been trained to operate Unmanned Aircraft Systems. Person in Charge (PIC) of aircraft operation has extensive experience piloting ultralights and gyroplanes and is ful ly capable of safely operating the Unmanned Aircraft Systems in all situations, including but not limited to, maintaining appropriate distances from people, vessels, vehicles and structures and performing evasive or emergency maneuvers as required. **91.7(a )**  **– Civil Air Worthiness:**  The DJI Phantom 3 UAS does not require an air worthiness certificate as per 14 C.F.R. part21, subpart H. however, Gold Coast Aerial will ensure that the DJI Phantom 3 UAS is in airworthy condition prior to every flight by determining that the aircraft is in compliance with the operating documents, such as manufactures maintenance recommendations and that the aircraft is safe to operate. **91.9(b) (2) –**  **Flight manual in Aircraft:** The DJI Phantom 3 UAS does not have adequate st orage capacity to carry its flight manual, therefore the aircraft flight manual will be located at the Ground Station for review as needed. Please refer to exemptions Nos. 8607, 8737, 8738, 9299 and 9299(a). **91.103(b) –**  **Preflight Instruction:** Petitioner will take all steps to insure a safe flight by reviewing weather conditions, flight battery condition, takeoff and landing areas and aircraft performance data prior to initiating flight. **91.119 –**  **Minimum Safe Altitude:** Petitioner request exemption to this section due to the fact that the UAS is not allowed to be operated above 400 ft. AGL in the U.S National Air Space. Gold Coast Aerial’s DJI Phantom 3 UAS will be operated in direct line of sight at all times and will not exceed an altitude above 400 ft. AG L. **91.121 –**  **Altimeter:** The DJI Phantom 3 UAS does not have an onboard altimeter, however, altitude information will be provided to the PIC by way of Global Positioning System equipment and radio communications telemetry data link, which downloads from the aircraft to the Ground Control Station , for active monitoring of the aircrafts flight path. With this attitude and telemetry information and operati ng theaircraft within visual line of sight, below 400 ft. AGL, will ensure a level of safety equivalent i f not

superior to Section 91.121. Please refer to exemption Nos. 11623, 11664 and 11734. **91.151(b) –**  **Fuel Requirements for Flight in VFR Conditions:** Petitioner submits that safety will not be affected by operation of the DJI Phantom 3 aircraft during daylig ht hours, in visual meteorological conditions, under visual flight rules, with enough battery power to fly for a duration of approximately 25 minutes. Battery power level indicators are able to show exactly how much battery power is remaining as well as ho w much time is needed for aircraft to return safely back to point of take
- off or point of origin. Aircraft is programed to return to point of origin if battery power levels fall below minimum levels . **91.203(a) & (b) –**  **Aircraft Certification and Registratio n:**  To obtain an equivalent level of safety and to meet the intent of 91.203 (a) & (b) , UAS certification and registration will be kept on file for inspection at the Ground Station location. **91.405(a) –**  **Maintenance Required, 91.407(a)(1) –**  **Operation after M aintenance, 91.409(a)(1) & (a)(2)** 

**– Inspections**  **and 91.417(a) & (b) –**  **Maintenance Records:** Petitioner request exemption as these sections set forth requirements for maintenance that only applies to aircraft that require an air worthiness certificate. Petitioner will only allow experienced personnel to perform maintenance, alterations or preventi ve maintenance on the aircraft, using methods, techniques and practices prescribed in the operating manuals. Furthermore, the petitioner will document and maintain all maintenance records for the DJI Phantom 3 aircraft. **Title 14, Chapter 1(d), Parts 60** **- 67** **- 61.1 thru 61.429**  **– Pilot Certification:**  Petitioner believes that these requirements are unnecessary for pilot controlled UAS flights and current FAA proposals have eliminated this as a future requirement for UAS operation. **Benefits to Public Interest:** Pet itioner believes that the granting of this petition will further benefit the public interest by allowing Gold Coast Aerial to safely, efficiently and economically provide aerial video and photography of construction sites, real estate, civil landscapes, ag riculture management, search and rescue and special events over certain areas of the United States. The DJI Phantom 3 UAS is battery powered and can serve as a safe, efficient, environmentally friendly, quiet and economical alternative to traditional manne d aircraft. By allowing the use of the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground will be substantially reduced or eliminated. The use of a UAS system will decrease congestion in the National Air Space, there
- by reducing risks to the general public. Use of the DJI Phantom 3 UAS will benefit the economy by allowing small United States based companies, like Gold Coast Aerial, to remain competitive and contribute to our national and local economies. **Additional Arguments to Support Request :**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in theNational Air Space. As such, Gold Coast Aerial ’s request for exemption may be granted pursuant to the

authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the National Air Space or the public, or otherwise pose a threat to national security, and furthermore, provides the authority for such a UAS to operate without airworthiness certification. As discussed in detail above, Gold Co ast Aerial will operate the DJI Phantom 3 UAS safely within the National Air Space, without creating a hazard to users of the National Air Space, the public or otherwise pose a threat to National Security. **Conclusion:** As set forth herein, Gold Coast Aerial seeks an exemption pursuant to 14 C.F.R. 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 3 U AS commercially, without an airworthiness c ertificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this petition, The FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public by allowing Gold Coast Aerial to safely, efficiently and economically operate the DJI Phantom 3 commercially within the N ational Air Space. In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Gold Coast Aerial respectfully requests that the Administrator grant this petition for an exemption from the requirements of14 C.F.R sections listed herein for the purpose of conducting aerial video, p hotography and data collection over certain areas of the United States. Respectfully submitted on February 1 1 , 2016,
Peter Huscher Owner/Operator Gold Coast Aerial 1157 Bryce Way Ventura, CA 93003 (805) 415
-4055 goldcoastaerial@gmail.com