Re: Exemption Request under Section 333 of the FAA Reform Act and Part 11 of the FAA Regulations.

Dear Sir or Madam: 

Request:

In order to provide safe videography and photography for public and business interests, I, Savannah 

Bertrand, pursuant to Section 333 of the FAA Modernization and Reform Act of2012 ("FRMA"), would 

like to formally submit for exemptions from the following Section 333 regulations:

Regulations from which the exemption is requested:

14CFR 21 H

14 CFR 45.23 (b)

14 CFR 61.113 (A) 7 (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b)(2)

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) & (b)

14 CFR 91.417 (a) & (b)

14 CFR Title 14 Chapter 1 Sub D Part 60 thru 67 - 61.1 to 61.429 

I am requesting these exemptions so I may safely fly DJI’s Phantom 3 Professional commercially 

following the guidelines of the owner’s manual, FAA guidelines, AMA (Academy of Model Aeronautics)

guidelines for safety, and guidelines set by Flysafe.
Proposed UAS and Operations

The Phantom 3 Professional weighs approximately 3 pounds, has GPS and barometric sensors, a fail-safe 

system, and is electric powered by a Lithium Polymer battery. It will be transported in proper storage to 

and from all flight areas. 

The proposed exemptions would allow me to operate the Phantom for the commercial purpose of aerial 

photography for real-estate, commercial property and agricultural needs. I also intend to use aerial photos 

to assist in the advertising needs of local non-profit businesses and churches.

Request for Exemption, Section 333 of the FAA Reform Act pertaining to Federal Aviation 

Regulations:

The Petitioner requests an exemption from the following regulations as well as any additional

regulations that may technically apply to the operation of UAS's.

14 CFR 21 H: Airworthiness Certificates

Certification Procedures for Products and Parts

Reason for Exception

It has been determined that similar UAS's do not require an airworthiness certificate as granted in 

Exemption No. 11623, 11650, 11664 and 11734.

14 CFR 45.23 (b): Marking of the Aircraft

These regulations provide that each aircraft must display "N" and the aircraft's registration number in 

letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in 

letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station.

Reason for Exception

Given the aircrafts size, these markings would be difficult to achieve. However, an equivalent level of 

safety will be achieved by following the AMA and Flysafes guidelines for safe flight.

14 CFR 61.113 (A) 7 {b): Private Pilot Privileges and Limitations

The regulation provides that no person may serve as a required pilot flight crewmember of a civil aircraft 

of the United States, unless that person: (1) has a pilot certificate or special purpose authorization issued 

under this part in that person's physical possession or readily accessible. (2) The flight is only incidental 

to that business or employment. (3) The aircraft does not carry passengers or property for compensation 

or hire.
Reason for Exception

The petitioner will follow all manufacturers’ and AMA’s safety guidelines. Additionally, the petitioner 

has gone through Flysafe’s UAS training and completed Ground School. Considering the FAA’s current 

proposals of omitting this as a future requirement, I believe the private pilots license is unnecessary 

considering the training I have had.

14 CFR 91.7 (a): Civil Aircraft Airworthiness

Civil Aircraft Airworthiness: (a) No person may operate a civil aircraft unless it is in an airworthy 

condition.

Reason for Exception

It has been determined that similar UAS's do not require an airworthiness certificate. The petitioner will 

ensure airworthiness by doing Pre-Flight, Flight, and Post Flight checks. 

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

This regulation provides that no person may operate an aircraft unless a current, approved flight manual is 

in the aircraft. 

Reason for Exception

The petitioner will have access to flight manual at ground control at all times to ensure an equivalent 

amount or safety.

14 CFR 91.119: Minimum Safe Altitudes

The regulation requires that the aircraft cannot be operated closer than 500 feet to any person, vessel, 

vehicle, or structure in populated areas. Since the aircraft will be operating at a maximum of 400 feet 

AGL, we are unable to comply with this requirement.

Reason for Exception

If I amflying over or near existing private property while providing aerial imagery, the property owner 

will be notified in person by the Petitioner. I will review the associated risks to people and property and 

will take every precaution necessary to avoid harm or destruction of property. Due to the small size of the 

UAS, the associated risks are not comparable to manned aircrafts and should be taken into consideration. 

14 CFR 91.121: Altimeter Settings

This section requires that each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is set when operating below 

18,000 feet MSL.

Reason for Exception
The Phantom 3 Professional does not have barometric altimeter. It does have a GPS that will calculate 

altitude. The Petitioner will limit flights to a maximum altitude of 400 feet AGL.

14 CFR 90.151 (a) Fuel Requirements for Flight in VFR Conditions

Fuel requirements for flight in VFR conditions: (a) No person may begin 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 ,assuming normal cruising speed.

Reason for Exception

The Phantom 3 Professional is battery operated and provides a low battery warning. The petitioner will 

not fly unless there is enough power to fly at a normal speed to land safely.

14 CFR 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration

This regulation provides as follows:

No person may operate a civil aircraft unless it has an appropriate and current

airworthiness certificate.

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 19.715

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

crew.

Reason for Exception

All the necessary documents will be at ground control with petitioner

14 CFR 91.405 (a): Maintenance Inspections

Each owner or operator of an aircraft- (a) shall have that aircraft inspected as prescribed in Subpart E of 

this part and shall between required inspections.

Reason for Exception

The Petitioner will inspect aircraft before every flight and follow a pre-flight checklist. The petitioner will 

also keep a log of any repairs done.

14 CFR 91.407 {a) {1): Maintenance
Operation after maintenance, preventative maintenance, rebuilding or alteration: (a) No person may 

operate any aircraft that has under gone maintenance, preventative maintenance, rebuilding, or alteration 

unless (1) it has been approved for return to service by a person authorized under 43.7 of this chapter.

Reason for Exception

The petitioner will follow manufacturer’s suggestions for replacement parts.

14 FR 91.409 (a){l) & (2): Inspections

Inspections: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft

unless, within the preceding 12 calendar months, it has had (1) an annual inspection in accordance with 

part 43 of this chapter and has been approved for return to service by a person authorized by 43.7 of this 

chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter. No inspection performed under paragraph (b) of this section may be substituted for any 

inspection required by this paragraph unless it is performed by a person authorized to perform annual 

inspections and is entered as an "annual" inspection in the required maintenance records.

Reason for Exception

The Petitioner will follow manufacturer's suggestions on inspections and repairs to ensure the UAS is safe 

to fly at all times. 

14 CFR 91.417 (a) & (b): Maintenance Records

Except for work performed in accordance with 91.411 and 91.413 each registered owner or operator shall 

keep the following records (l)(i) (ii)(iii) (2)(i)(ii)(iii)(iv)(v)(vi) for the periods specified in paragraph (b) 

of this section: ( 1) (2) (3)

Reason for Exception

The Petitioner will keep record of all repairs.

14CFR Title 14 Chapter 1 Subchapter D Parts 60 thru 67-61.1 to 61.429: Pilot Certification

This section pertains to flight rules, pilot certificate requirements, manuals, etc.

Reason for Exception

The Petitioner believes that these requirements are unnecessary for pilot controlled drone flights and

current FAA proposals have omitted this as a future requirement for small UAS's.
In conclusion,

I, Savannah Bertrand, the Petitioner, request exemption from the above mentioned FAA regulations so I 

can legally operate my Phantom 3 Professional for commercial uses pertaining to Real Estate, 

Commercial, and Agricultural photography and videography. 

Thank you for your time,

Savannah Bertrand, Rivergrind LLC

2930 Shady Grove Rd, Eau Claire WI 54703

(715) 383-0938

savannahburlingame@gmail.com