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November 4, 2015

Shayne L. Medore

201 Kathy Circle

Linden, MI, 48451

Cell: 810-569-5686

Email: shayneleemedore@gmail.com

U.S. Department of Transportation, Docket Operations

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request Section 333 of the FAA Reform Act of 2012

References:

1) FAA Exemption No. 11410, Regulatory Docket No. FAA-2015-0186 in the matter of the 

petition of RALPH J. APEL

2) FAA Exemption No. 11341, Regulatory Docket No. FAA–2015–0037 in the matter of the

petition of BOB SOKOLER

3) FAA Exemption No. 11728 Regulatory Docket No. FAA-2015-0850 in the matter of the 

petition of ALON SICHERMAN

4) FAA Exemption No. 13040 Regulatory Docket No. FAA−2015−2773 in the matter of the 

petition of Manuel P Heredia III

Dear Sir or Madam,

Please accept this Section 333 exemption application for your consideration in accordance with 

the FAA’s Guidelines for Submitting a Petition for Exemption under section 333 of the FAA 

Modernization and Reform Act of 2012, I Shayne L. Medore, referred to hereafter as the 

petitioner, request exemption from the following sections of Title 14, Code of Federal 

Regulations §§
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61.113 (a) & (b), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (2), and 91.417(a) & (b); 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace regulated 

by the Federal Aviation Administration (FAA) for the purposes of aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight operations 

that could be performed safely and more cost effectively with the use of small UAS at low 

altitude within the U.S. national airspace system as compared to a manned aircraft. Operations 

will be performed only at the request of and with the authorization and permission of clients or 

their authorized agents in order to facilitate commerce and raise awareness of the beneficial 

uses of small unmanned air systems. 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. The petitioner seeks exemption from the above-mentioned FARs for the following 

reasons;

61.113(a) & (b) The petitioner requests relief in order to facilitate the utilization of pilots, who 

hold a Sport pilot (or greater) certificate. Any pilots operating under this exemption would be 

required to comply with any conditions as set forth and in a similar fashion to the previously 

granted exemptions. 

91.7(a) Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow petitioner to determine that the DJI Phantom and Phantom 3 

Professional UASs are in airworthy condition prior to every flight by ensuring that the UASs are 

in compliance with the operating documents (i.e., the Monthly Maintenance Log, and DJI 

Phantom and Phantom 3 Professional Instruction Manual). Petitioner seeks the requested relief 

because the DJI Phantom and Phantom 3 Professional UASs do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, petitioner will ensure that 

the DJI Phantom and Phantom 3 Professional UASs are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 

and Phantom 3 Professional Manual) prior to every flight, and further, determine that the 

aircraft is in condition for a safe flight. 

91.119(c) The petitioner requests waiver to allow reasonable and responsible operations in 

areas of subdivisions and neighborhoods if required. 

91.121 This is inapplicable since the UAS does not have an altimeter and instead utilizes 

electronic GPS with a barometric sensor for altitude information.

91.151(a)(1) The UAS provides battery power remaining in percent to the PIC. The UA batteries 

provide approximately 13 minutes for Phantom and 23 Minutes for Phantom 3 Professional, of 

powered flight. Information provided in the operating documents discusses procedures 

regarding remaining battery power management. Those documents contain a condition in 

which the PIC will initiate a landing procedure when battery remaining reaches a specified level. 

Given the limitations on proposed operations and the location of those proposed operations,

The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was 

reasonable. 
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91.405(a); 91.407(a)(1); 91.409 (a)(1) & (2); 91.417(a) & (b) Since Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an 

airworthiness certificate, the petitioner requests relief from these Sections because the DJI 

Phantom and Phantom 3 Professional UASs do not require an airworthiness certificate. The DJI 

Phantom and Phantom 3 Professional UASs meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, the petitioner will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed in the UAS operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom and Phantom 3 Professional Instruction Manual). 

Furthermore, the petitioner will document and maintain all maintenance records for the DJI 

Phantom and Phantom 3 Professional UASs.

The UAS

The DJI Phantom 3 Professional is a highly successful consumer grade small rotorcraft in the 

quadcopter configuration with an advertised weight of less than 46 Ounces (1280g) designed 

primarily to carry aloft a high definition camera. It has an advertised maximum speed of less 

than 30 knots (16m/s) and a maximum climb rate of less than 1200 feet per minute (5 m/s). It is 

powered by four electric motors with a distance between motors of less than 14 inches 

(350mm). It utilizes an internal inertial measuring unit (IMU) with integrated barometric sensor 

augmented with global positioning system (GPS) to maintain its geospatial orientation and 

position. It is controlled primarily through an FCC certified radio control (RC) unit. Real time 

video and telemetry information is transmitted back to a ground control station allowing the 

operator and/or PIC to monitor battery level, GPS signal strength, altitude (AGL), distance from 

PIC, camera imagery, and control camera angle. It has failsafe modes of operation for either 

loss of RC or GPS signal. Altitude can be limited by the onboard flight controller and maximum 

altitude can be preprogrammed by the PIC. Battery life limits flight times to approximately 

between 13- 23 minutes depending on flight conditions. The onboard flight controller will warn 

the pilot via telemetry and external lighting cues before reaching a low battery state. An 

automatic termination of flight and landing will be initiated when the battery reaches a 

predetermined low state. It is anticipated that flights will usually last less than 10 minutes. 

More information is available on http://www.dji.com/product/

Public interest

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce the 

environmental impact as compared to similar operations conducted with manned aircraft of 

greater proportions, carrying a crew and flammable fuel. Additionally, use of the UAS in order 

to facilitate commerce could lead to economic growth. Operations for this petition will enable 

service for property owners or their designees seeking an enhanced perspective for 

characteristics, amenities, and benefits of their desired photographic subjects that cannot be 

displayed through ground level videography/photography. Aerial photography is a valuable 
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marketing tool that can lead to increased commerce and enhance personal photography. Crop 

surveying applications could lead to decreased use of pesticides and fertilizer and conservation 

of water as well as increased crop yields and decreased costs. Aerial surveying and inspections 

can increase work site efficiency, improve volumetric estimations and reduce risks. The 

petitioner will provide clients with photographic data for these purposes on a ‘for hire’ basis 

acting as an independent contractor. A visual observer will be utilized. Liability insurance will be 

obtained commensurate with the granting of this request for exemption. Flight data including 

UA flight time, Control Unit operation time, incident, accident, and details concerning any 

deviations from normal operations will be available to FAA for use in collecting data regarding 

the use of UAS as part of this application. This data may be submitted to FAA via traditional 

means, e.g. COA Monthly Reports or other means as required.

Conclusion

The petitioner is requesting this exemption for the purposes of “aerial photography, 

cinematography, videography, mapping, crop surveying, inspections and other flight 

operations”. The reason for such a general and broad based request is that the petitioner 

wishes to utilize a business strategy of horizontal integration and maximize economies of scope 

in order to capitalize on opportunities as they may arise in the future without the long 

turnaround time associated with additional exemptions. The petitioner's business model is 

based on the idea of offering ad hoc small UAS services to individuals or companies who wish to 

employ these services as a safe, effective, and legal option to enhance their business or hobby. 

The petitioner’s own market research shows pent up demand for these services currently exists 

in the real estate market and other markets are just beginning to emerge. 

In addition the petitioner is an active Licensed Private Pilot, Certificate Number 3221316 with 

over 20 years flying experience as a PIC. The petitioner also has over 30 years of experience 

flying high powered model aircraft of all varieties but not limited to drones including instruction 

at his AMA local flying field. It is my belief that with my extensive background in aviation, flying 

and RC experience, this exception would provide a safe, environmentally friendly, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery.

Respectfully submitted 

Shayne L. Medore

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AMA Academy of Model Aeronautics
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AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

MSL Mean Sea Level

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform act of 2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing