Gold Coast Aerial

1157 Bryce Way

Ventura, CA 93003

(805) 415-4055

goldcoastaerial@gmail.com 

Attn:

U.S. Department of Transportation, Docket Operations February 11, 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 Modernization and Reform Act of 2012 (public law 

112-95). I’m requesting 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

Ventura, CA 93003

(805) 415-4055

goldcoastaerial@gmail.com 
SUMMARY:

Peter Huscher dba. 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 Modernization 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 estate, 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 traditional 

Digital High Definition 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” High-Definition gyro-stabilized aerial camera systems and Digital 

High Definition photographic equipment, to provide its customers with the very best in traditional 

Digital High Definition photography, videography and aerial photography. Gold Coast Aerial is a member 

of the UAVSA (Unmanned Aerial Vehicle Systems Association) and S.W.A.R.M. (Search With Aerial 

Remote Controlled Multi-rotors). The objective of Gold Coast Aerial’s Unmanned Aircraft System (DJI 

Phantom 3) operations, is to provide a more affordable, safer, higher 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 Coverage

 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 higher 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 has 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 follows:

 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

 UAV Maximum Take-off Weight: 2.82 lbs

 Category: Land and Sea

 Name of Engine Manufacturer: DJI: Da-Jiang Innovations

 Engine 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

 Engine 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 2012, 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. National Air Space.
21H - Air worthiness Certificate:

In consideration of maximum speed, weight, size and limited operating area 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. 11623, 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 fully 

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 storage 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. AGL. 

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 operating the 
aircraft within visual line of sight, below 400 ft. AGL, will ensure a level of safety equivalent if 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 

daylight 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 how 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 Registration:

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 Maintenance, 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 preventive 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:

Petitioner 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, agriculture 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 manned 

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 the
National 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 Coast 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 UAS commercially, without an airworthiness certificate, 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 National 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, photography and data collection over certain areas of the United States.

Respectfully submitted on February 11, 2016,

Peter Huscher

Owner/Operator

Gold Coast Aerial

1157 Bryce Way

Ventura, CA 93003

(805) 415-4055

goldcoastaerial@gmail.com