UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

Petition for Exemption 14 CFR 11.81

IN THE MATTER OF THE PETITION FOR EXEMPTION OF SUPER-FIE'D LLC. FOR AN EXEMPTION 

SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS SECTIONS PART 21 SUBPART H, 91.103(b), 91.105, 91.109, 91.119, 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION+ UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC 

LAW 112-95)

Submitted on 9/25/2015

Arnie Fie owner Super-Fie'd LLC

8001 Andrew Franklin Drive

Denver, NC 28037

704 302 3232

ArnieFie@Yahoo.com
Introduction:

E. Arnold Fie II, the owner of Super-Fie'd LLC, seeks exemption from the requirements of 14 

C.F.R § 91.103(b), 91.105, 91.109, 91.119, 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) to operate an Unmanned Aircraft System pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

allow Super-Fie'd LLC to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of real estate, special events, film sets and 

construction sites within the United States.

Super-Fie'd LLC was created in 2015 to provide a "for-hire" entity where the owner's talent, 

skill, and knowledge of remote control craft can become a blossoming small business for the 

betterment of the society in which it operates. Arnie Fie owner of Super-Fie'd LLC is very 

accomplished in competitive remote control racing in the USA, has consulted, produced, tested, 

and developed a myriad of remote control products during his 27 years in the remote control 

market including testing and proving of individual components that are used commonly in 

today's UAS such as the motors, speed control units, spread-spectrum radios, and lithiumpolymer batteries. This experience makes the operator a unique and very qualified person for 

exemption due to his intense knowledge of the components of the craft plus proven skill when 

it comes to operating a remote craft. 

Super-Fie'd LLC seeks an exemption to operate DJI brand UAV systems for compensation or hire 

within the National Airspace System. Super-Fie'd LLC desires to operate a DJI Phantom 

2, Phantom 2 Vision+, Phantom 3, and Inspire 1. These Unmanned Aerial Vehicles are all four 

bladed “quad” copter allowing for vertical takeoff and landing. The units are powered by a 

Lithium Polymer battery which supplies

power to four of the motors. It is controlled wirelessly through a Ground Control Station 

allowing it to be operated using a remote and an electronic tablet or smart phone system. All 

listed UAV comply with all FCC radio frequency regulations and a proof of FCC compliance letter 

can be provided upon request.
Specifications for UAV listed:

-DJI Phatom 2: top speed 29 knots, gross weight approx. 2.20lbs, cubic size of 16"x16"x8".

-DJI Phantom 2 Vision+: top speed 29 knots, gross weight approx. 2.75lbs, cubic size of 

16"x16"x8". 

-DJI Phantom 3: top speed 31 knots, gross weight approx. 2.82lbs, cubic size of 18"x18"x8".

-DJI Inspire 1: top speed 43 knots, gross weight approx. 6.50lbs, cubic size of 18"x18"x12".

If this petition is granted, the UAV listed will be operated by Super-Fie'd LLC will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, and 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.
Statements in response to safety concerns and sections of 14 C.F.R. Super-Fie'd LLC seeks 

exemption:

Petitioner, Super-Fie'd LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate an UAS in the National Airspace

System (NAS), and for an exemption from the following requirements:

-14 C.F.R. Part 21, Subpart H

Based on its size, weight and speed it meets the conditions of FMRA Section 333 and therefore, 

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Safety will not be affected without an airworthiness certificate because the process of obtaining 

an airworthiness certificate is geared toward the certification of manned aircraft and not small 

UAVs. Small UAVs, like the UAS listed for use are in a separate category of aircraft, as FMRA 

Section 333 recognizes.

-14 C.F.R 91.103 (b)

Super-Fied'd LLC seeks an exemption from the requirements of Section 14 C.F.R. 91.103(b) 

entitled Preflight Action. If this petition is granted, Super-Fie'd LLC will be operating an UAS 

which does not require a runway. The UAS listed for use all take off vertically without a runway. 

Therefore it is impossible for the PIC to calculate runway takeoff and landing distances.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Super-Fie'd LLC believes that safety will be enhanced without the need for a runway 

Additionally, the size and weight of the UAS is so small, that any takeoff or landing accident 

would cause minimal damage to persons or property when compared to manned aircraft 

takeoff and landing accidents.
-14 C.F.R 91.105

Super-Fie'd LLC seeks an exemption from the requirement of Section 14 C.F.R. 91.105, entitled 

flight crew members at stations. Because this is an Unmanned Aerial Vehicle, it is operated 

from the ground. Therefore, the operator has no need to wear seat belts while flying. SuperFie'd LLC believes the UAV can be safely operated from the ground and still maintain safety of 

flight.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Super-Fie'd LLC believes that UAVs are much safer because the PIC is safely on the ground. Any 

inflight turbulence does not affect the safety of the PIC. In the event of a crash, the PIC risks 

significantly less physical damage from the UAV than he or she would if inside a manned aircraft 

during a crash. For this reason, Super-Fie'd LLC believes that safety is actually improved by 

operating a UAV instead of a manned aircraft.

-14 C.F.R 91.109

Super-Fie'd LLC seeks an exemption from the requirement of Section 14 C.F.R. 91.105, entitled 

Flight Instruction; Simulated instrument flight and certain flight tests. Super-Fie'd LLC believes 

that all forms of flight instruction given on the UAV can safely be given using a dual operator 

ground station. Using two remotes, the instructor has the ability to override the student if 

needed, ensuring the instructor has full control over the UAV at all times while given flight 

instruction. Without this exemption, it would be impossible for Super-Fie'd LLC to give any type 

of UAV flight instruction.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Super-Fie'd LLC believes that the same level of safety will be maintained during flight 

instruction because the instructor has full control of command at all times while giving flight 

lessons. In the event that the student begins to lose command the instructor can take 

command exactly as it is done in manned aircraft.
-14 C.F.R. 91.119

Super-Fie'd LLC seeks an exemption from the requirement of Section 14 C.F.R. 91.119 from the 

minimum safe altitude requirements. This Section prescribes the minimum safe altitudes under 

which aircraft may not operate, including 500 feet above the surface and away from any 

person, vessel, vehicle, or structure in non-congested areas. Section 91.119(d)(1) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated “without 

hazard to persons or property on the surface,” provided that “each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA. To provide the intended inspections, the UAS will normally need to be operated within a 

range of approximately 25 feet from the infrastructure being inspected. Accordingly, due to the 

nature of the proposed operations, the Operator and the designated observer may at times be 

less than 500 feet away from structures during the operation, and an exemption is therefore 

required.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Super-Fie'd LLC believes that compared to flight operations with rotorcraft weighting far more 

than the maximum 55 pounds allowable and the lack of flammable fuel any risk associated with 

these operations is far less than those presently presented with conventional aircraft. An 

equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as 

the location where it is operated. As set forth the UAS will be operated in a restricted area 

where buildings and people will not be exposed to unnecessary and unplanned operations. 

Because of the advance notice all affected individuals will be aware of the planned flight 

operations. Furthermore by operating at such lower altitudes the UAS will not interfere with 

other aircraft that are subject to the minimum safe altitude regulations.

-14 C.F.R 91.121

Super-Fie'd LLC also seeks an exemption from the requirements of Section 14 C.F.R. 91.121, 

entitled Altimeter Settings, as the listed UAS for use all do not have a barometric altimeter. 

The UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. Altitude information is provided to the PIC via the 

telemetry data link. This information is displayed to the PIC via the ground station tablet 

interface. This altitude information, combined with visual line of sight will ensure a level of 

safety equivalent to that of Section 14 C.F. R. 91.121.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Super-Fie'd LLC believes that safety will still be maintained because the PIC still has altitude 

information available to him or her at all times during the flight. This combined with attitude 

and ground speed information keeps the PIC situationally aware of the UAS and its 

surroundings.
-14 C.F.R 91.151(b)

Super-Fie'd LLC seeks an exemption from the requirements of Section 14 C.F.R. 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Super-Fie'd LLC believes that the 

standard Lithium Polymer batteries that power the UAS listed will be adequate for the short 

flights needed for this operation. The listed UAS have enough battery power to fly for a total 

duration of approximately 13 minutes with an additional 5 minutes of reserve power for 

additional flying at normal speed. Super-Fie'd LLC seeks the requested relief because without an 

exemption from Section 91.151(b), it would not be possible to fly the listed UAS. This would 

severely constrain the practicality of any aerial video or still photo flight operations that SuperFie'd LLC proposes to conduct pursuant to this Petition.

Furthermore, safety will be ensured as the UAV listed provide audible and visual warnings to 

the PIC at the ground station when the UAV experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the UAV will descend and land 

automatically at the home or safe zone.

The Reason Why Granting The Exemption Would Not Adversely Affect Safety:

Super-Fie'd LLC believes that safety will still be maintained because the listed UAV would 

always be flown within line of sight. This ensures that a landing can immediately be made 

within seconds or minutes. Additionally, the ability to takeoff or land vertically allows the UAV 

to land on virtually any flat surface. This ensures that the UAV will have plenty of battery 

reserves allowing it to always be able to safely land after a flight.
-14 C.F.R 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b).

Super-Fie'd LLC requests relief from these sections as these sections set for the requirements 

for maintenance that only apply to aircraft with an airworthiness certificate on the 

premise the listed UAV do not require airworthiness certificates as set forth in the conditions of 

FMRA Section 333.

A maintenance logbook will be developed to record all maintenance, alterations or repairs 

made on the UAV. Prior to any revenue flight, the PIC will be required to determine 

the condition of the UAV in a manner consistent with this exemption.

Super-Fie'd LLC will use an experienced technician to perform maintenance, alterations, or 

preventive maintenance on the UAVs using the methods, techniques, and practices prescribed 

in the UAV operating documents (Monthly Maintenance Log, and UAV Instruction Manual). 

Furthermore, Super-Fie'd LLC will document and maintain all maintenance records for the listed 

UAV. Super-Fie'd LLC submits that it will ensure that the listed UAV is in an airworthy condition 

prior to every flight by determining that the UAVs are in compliance with the operating 

documents (Maintenance Log, and UAV Instruction Manual) and that the aircraft is in a 

condition for safe flight.

Super-Fie'd LLC will appropriately operate the listed UAV in accordance with the manufacturer’s 

operating manual. The exemption sought will not adversely affect safety because Super-Fie'd 

LLC will use an experienced technician for maintenance and alterations on the UAV using the 

methods, techniques, and practices prescribed by the operating documents. Super-Fie'd LLC 

believes that safety will not be affected because the procedures established above ensure 

the listed UAV will always be maintained and operated in a structured, organized and 

consistent manner. Using the procedures above ensures that each flight is executed with all 

precautions considered.
The reasons why granting Super-Fie'd LLC’s request would be in the public interest and how it 

would benefit the public as a whole.

1) Expanding the availability of affordable aerial photos for industry.

Granting this petition will further the public interest by expanding the availability of 

economically affordable aerial cinematography and photography. Historically, the public has 

used aerial photos for a variety of reasons. These aerial photos and videos have been obtained 

using manned aircraft, costing hundreds and thousands of dollars per hour to operate. Granting 

this petition will increase the quality of aerial photography services, while at the same time 

decreasing the price.

This service will allow for the following:

-Enhanced and dynamic real estate marketing, benefiting property owners and real estate 

agents

-Crop surveying for the agricultural industry (field drainage monitoring, crop insurance 

documentation, pesticide monitoring, etc), which will lead to increased farming efficiency 

benefiting both farmers, consumers, and environment.

-Insurance claim documentation for insurance companies such as hail damage, crop damage, 

bridge collapses, flooding, etc. which will benefit the insurance companies and consumers of 

insurance products.

-Construction progress for residential, commercial, and industrial construction companies.

-Wetland and water drainage mitigation for public works departments, which will enhance the 

ability of civil engineers to plan for water drainage mitigation

-Power line and pipeline utility inspection services for utility companies.

-Liberty for potential applications to freely develop.

The increased efficiency and lower cost of operating a UAV for aerial applications will benefit 

the economy as a whole by allowing scarce resources, such as aircraft fuel and talent of 

personnel to be used in other areas of the business or economy in whole. This will ensure that 

the United States remains competitive on the global market for aerial applications and ensure 

that more jobs stay located within the United States.
2) Increased Public Safety

The listed UAV all weighing less than 7 pounds pose a very small threat to people and property 

on the ground in the event of an uncontrolled landing. The damage a roughly 7 lb UAV can do is 

very small compared to the damage that a 4000 lb aircraft with hundreds of gallons of fuel 

onboard and human life. In other words use of the UAV has less physical potential for collateral 

damage to life and property compared to a manned aircraft.

3) Reduced Levels of Air and Noise Pollution

Using the listed UAV to conduct aerial operations instead of manned aircraft will greatly benefit 

the public by reducing the levels of air and noise pollution. Small UAVs are much more energy 

efficient than traditional manned aircraft. By using battery power with electric motors the listed 

UAV produce no air pollution and are much more environmentally friendly than the traditional 

internal combustion aircraft engines that are typically utilized for aerial video and photography. 

These manned aircraft burn approximately 10-25 gallons per hour of aviation fuel. The listed 

UAV also eliminate a lot of noise pollution as the small propeller blades and electric motors 

produce only a fraction of the noise level that traditional fixed-wing aircraft or helicopters 

produce.

4) Reduced Congestion of the National Airspace System

Granting this request also benefits the public as a whole by reducing the quanity of manned 

aircraft and relieving of congestion of the NAS. By reducing the number of manned aircraft 

operating in the NAS this will relieve the air traffic control system of air traffic control 

communication volume and tasks of air traffic controller to monitor the manned aircraft in their 

area. Also because the listed UAV do not need a runway or airport to operate this would result 

in fewer aircraft being handled by air traffic control during all phases of flight operations. This 

will allow the air traffic control system to focus their resources more on the needs of other 

types of manned flights. 
Planned Intent of Operation of UAV by Super-fie’d LLC.

1: The UAV may not be operated at a speed exceeding 50 knots.

2: The UAV must be operated at an altitude of no more than 400 AGL.

3: The UAV must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

4: All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must 

be able to communicate verbally at all times. Electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perform the functions prescribed in the operating documents.

5: The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

6: The operating documents and the grant of exemption must be accessible during UAV 

operations and made available to the Administrator upon request. If a discrepancy exists 

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed.
7: Prior to each flight the PIC must inspect the UAV to ensure that it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAV, the 

aircraft is prohibited from operating until the necessary maintenance has been performed 

and the UAV is found to be in a condition for safe flight. The Ground Control Station must 

be included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

8: Any UAV that has undergone maintenance or alterations that affect the UAV operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry 

in the aircraft records. 

9: The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

10: The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and the 

signature of the authorized person returning the UAV to service.

11: Each UAV operated under this exemption must comply with all manufacturer Safety 

Bulletins.
12: The UAV may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart, or within the lateral limits of class B, C or 

D airspace as denoted on a current FAA-published aeronautical chart. 

13: If the UAV loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

14: The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents.

15: The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining. 

16: All aircraft operated in accordance with the exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable.

17: The UAV must remain clear and yield the right of way to all manned aviation operations 

and activities at all times.

18: The UAV may not be operated by the PIC from any moving device or vehicle. 
19: Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC, SO, operator trainees or essential persons), vessels, 

vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonparticipating persons from the UAV and/or debris in the event of an accident. 

The operator must ensure that nonparticipating persons remain under such protection. If 

a situation arises where nonparticipating persons leave such protection and are within 

500 feet of the UAV, flight operations must cease immediately and/or; b. The aircraft is 

operated near vessels, vehicles or structures where the owner/controller of such vessels, 

vehicles or structures has granted permission and the PIC has made a safety assessment 

of the risk of operating closer to those objects and determined that it does not present an 

undue hazard, and; c. Operations nearer to the PIC, SO, operator trainees or essential 

persons do not present an undue hazard to those persons per § 91.119(a). 

20: All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

Super-Fie’d LLC will not allow any PIC to operate the UAV listed unless that PIC has 

demonstrated that they are able to safely operate the listed UAV in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.
Conclusion of Request of Exemption

My belief is simply that small UAV when used by experienced and responsible operators will

offer the society at large a safer, ecology friendly, cost effective and efficient means to 

perspectives of the world for industrial or recreational purposes. I hereby request that the 

exemption is granted to Super-fie’d LLC without delay.

Best regards,

Arnie Fie owner Super-Fie'd LLC

8001 Andrew Franklin Drive

Denver, NC 28037

704 302 3232

ArnieFie@Yahoo.com