1

July 10, 2015  

Attn:

U. S. Department of Transportation Docket Operations  

West Building Ground Floor, Room w12‐140  

1200 New Jersey Ave, SE Washington, DC 20590

RE: GREENWORKS, PC dba. GREENWORKS REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

§ 61.113 Private pilot privileges and limitations: Pilot in command,

§ 91.7 Civil aircraft airworthiness,

§ 91.103 Preflight action

§ 91.119 Minimum safe altitudes (c) Over other than congested areas

§ 91.151 Fuel requirements for flight in VFR conditions (b),

§ 91.405 Maintenance required (a),

§ 91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration,

§ 91.409 Inspections (a)(1) & (a)(2),

AND § 91.417 Maintenance records (a) & (b)

CONCERNING COMMERCIAL OPERATION OF DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT

TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112‐95)

Mike Faha

Principal

GreenWorks, PC

24 NW 2nd Avenue, Suite 100

Portland, OR 97209

503‐222‐5612 F‐503‐222‐2283

info@greenworkspc.com

   
2

TABLE OF CONTENTS

Page  

GLOSSARY OF ABBREVIATIONS...................................................................................3  

SUMMARY...........................................................................................................................4  

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4  

BACKGROUND....................................................................................................................4  

BASIS FOR PETITION.........................................................................................................5  

NAME AND ADDRESS OF PETITIONER.........................................................................6  

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH GREENWORKS SEEKS

EXEMPTION............................................................................................................7  

THE EXTENT OF RELIEF GREENWORKS SEEKS AND THE REASON GREENWORKS SEEKS THE

RELIEF..............................................................10

THE REASONS WHY GRANTING GREENWORKS’S REQUEST WOULD BE IN THE PUBLIC INTEREST

............................................................................................12  

THE REASONS WHY GRANTING THE EXEMPTION TO GREENWORKS WOULD NOT ADVERSELY AFFECT

SAFETY..............................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25  

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT GREENWORKS’S

REQUEST..................................................25  

CONCLUSION.....................................................................................................................25  

APPENDICES......................................................................................... 26

   
3

GLOSSARY OF ABBREVIATIONS

AGL       Above Ground Level

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  

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 Site

VMC       Visual Meteorological Conditions

VTOL       Vertical Takeoff and Landing
4

SUMMARY

GreenWorks, PC, dba. GreenWorks hereafter referred to as GREENWORKS seeks exemption from the

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 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 (DJI Phantom 3) pursuant to

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

GREENWORKS 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 and events over certain areas of the United States.  

INTRODUCTION AND INTERESTS OF THE PETITIONER

GREENWORKS The objective of GREENWORKS and our Unmanned Aircraft System (DJI Phantom 3) aerial

operations is to provide a more affordable, high‐quality production and recording system for a variety of

architectural and planning project types, specifically targeting;

• Project specific sites before and after construction

• Proposal development

• Marketing efforts

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, UAS

GREENWORKS seeks an exemption to operate DJI Phantom 3 system for compensation or hire within

the NAS. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a

Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has

a maximum gross weight of approximately 2.8 lb. while having a diagonal dimension of 23.2”, a

maximum speed of approximately 16.4’fps and a maximum flying height of 400'. The DJI Phantom 3 is

equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.  

The DJI Phantom 3 that will be operated by GREENWORKS will be registered in accordance with 49

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in

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

BASIS FOR PETITION

Petitioner, GREENWORKS, 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 the DJI

Phantom 3, UAS in the National Airspace System (NAS), and for an exemption from the requirements of

14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

91.417(a) & (b).  

In consideration of the speed, weight, size, and limited operating area associated with the unmanned

aircraft and its operation, GREENWORKS’ operation of DJI Phantom 3 UAS 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.  
5

Accordingly, GREENWORKS requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft

with an airworthiness certificate.  

GREENWORKS submits that the requested relief is proper since an equivalent level of safety will be

ensured. GREENWORKS will use experienced personnel or technicians to perform maintenance,

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices

prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction

Manual). Furthermore, GREENWORKS will document and maintain all maintenance records for the DJI

Phantom 3 UAS.  

A. Name And Address Of The Petitioner.  

The name and address of the Petitioner and point of contact is:

Mike Faha

Principal

GreenWorks, PC

24 NW 2nd Avenue, Suite 100

Portland, OR 97209

503‐222‐5612 F‐503‐222‐2283

info@greenworkspc.com

B. The Specific Sections Of 14 C.F.R. From Which GREENWORKS Seeks Exemption.

1. GREENWORKS Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections

(a) and (b) prescribe the following, in relevant part:  

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an

aircraft that is carrying passengers or property for compensation or hire; nor may that

person, for compensation or hire, act as PIC of an aircraft.  

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with

any business or employment if—  

(1) The flight is only incidental to that business or employment; and  

(2) The aircraft does not carry passengers or property for compensation or hire.  

2. GREENWORKS Seeks Exemption From The Requirements Of Section 91.7(a).  

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following:  

(a) No person may operate a civil aircraft unless it is in an airworthy condition.  

3. GREENWORKS Seeks Exemption From The Requirements Of Section 91.151(b).  

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection
6

(b), states the following:  

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering

wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing and, assuming normal cruising speed, to fly after that for at least 20

minutes.

4. GREENWORKS Seeks Exemption From The Requirement Of Section 91.405(a).  

Section 91.405, entitled Maintenance required, subsection (a), states the following: 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, except as provided in paragraph (c) of this section, have

discrepancies repaired as prescribed in part 43 of this chapter[.]  

5. GREENWORKS Seeks Exemption From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

alteration, subsection (a)(1), states the following:  

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless‐‐  

(1) It has been approved for return to service by a person authorized under § 43.7 of this

chapter[.]  

6. GREENWORKS Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(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.  

7. GREENWORKS Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:  

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered

owner or operator shall keep the following records for the periods specified in paragraph (b)

of this section:  

(1) Records of the maintenance, preventive maintenance, and alteration and records of

the 100‐hour, annual, progressive, and other required or approved inspections, as

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor,

and appliance of an aircraft. The records must include‐‐  
7

(i) A description (or reference to data acceptable to the Administrator) of the work

performed; and  

(ii) The date of completion of the work performed; and  

(iii) The signature, and certificate number of the person approving the aircraft for

return to service.  

(2) Records containing the following information:  

(i) The total time in service of the airframe, each engine, each propeller, and each

rotor.  

(ii) The current status of life‐limited parts of each airframe, engine, propeller, rotor,

and appliance.  

(iii) The time since last overhaul of all items installed on the aircraft which are

required to be overhauled on a specified time basis.  

(iv) The current inspection status of the aircraft, including the time since the last

inspection required by the inspection program under which the aircraft and its

appliances are maintained.  

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or safety directive

number and revision date. If the AD or safety directive involves recurring action, the

time and date when the next action is required.  

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major

alteration to the airframe and currently installed engines, rotors, propellers, and

appliances.  

(b) The owner or operator shall retain the following records for the periods prescribed:  

(1) The records specified in paragraph (a)(1) of this section shall be retained until the

work is repeated or superseded by other work or for 1 year after the work is performed.  

(2) The records specified in paragraph (a)(2) of this section shall be retained and

transferred with the aircraft at the time the aircraft is sold.  

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this

chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.  
8

C. The Extent Of Relief GREENWORKS Seeks And The Reason GREENWORKS Seeks The Relief.

1. Extent Of Relief GREENWORKS Seeks And The Reason GREENWORKS Seeks Relief From Section

61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is

requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well

as a current and valid airman medical certificate, and who has met certain flight‐hour and currency

requirements, to conduct the proposed UAS flight operations for compensation or hire.  

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or

employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does

not carry passengers or property for compensation or hire.  

As set forth more fully below, GREENWORKS submits that an equivalent level of safety will be

maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has met

certain flight‐hour and currency requirements, demonstrating that the PIC is able to safely operate

either the DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in

this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate

distances from people, vessels, vehicles and structures.

Further, GREENWORKS submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC pursuant

to the grant of this Petition: (1) will be incidental to GREENWORKS’s business; and (2) will not carry

passengers or property for compensation or hire.  

2. Extent Of Relief GREENWORKS Seeks And The Reason GREENWORKS Seeks Relief From Section

91.7(a).

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

allow GREENWORKS to determine that the DJI Phantom 3 UAS are in airworthy condition prior to every

flight by ensuring that the UAS is in compliance with the operating documents (i.e., GREENWORKS Aerial

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

GREENWORKS seeks the requested relief because the DJI Phantom 3 UAS do not require an

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GREENWORKS will

ensure that the DJI Phantom 3 UAS are in airworthy condition based upon its compliance with the

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3) prior to every flight, and

further, determine that the aircraft are in condition for safe flight, as stated in the conditions and

limitations below.

3. Extent Of Relief GREENWORKS Seeks And The Reason GREENWORKS Seeks Relief From Section

91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the

extent required to allow flights of the battery powered DJI Phantom 3 UAS during daylight hours in
9

visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23

minutes. GREENWORKS seeks the requested relief because without an exemption from Section

91.151(b), the flight time duration of the battery powered DJI Phantom 3 UAS will severely constrain the

practicality of any aerial video or still photo flight operations that GREENWORKS proposes to conduct

pursuant to this Petition.  

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, the DJI Phantom

3 operating documents, and GREENWORKS’s proposed operating limitations, ensure that GREENWORKS

will safely operate the battery powered DJI Phantom 3 UAS during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a

total duration of 23 minutes.

4. Extent Of Relief GREENWORKS Seeks And The Reason GREENWORKS Seeks Relief From Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 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, GREENWORKS requests relief from these Sections because the DJI

Phantom 3 UAS do not require airworthiness certificates. As set forth more fully below, the DJI Phantom

3 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, GREENWORKS 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., the GREENWORKS Aerial Operations Manual, Monthly Maintenance Log, and

DJI Phantom 3 Instruction Manual). Furthermore, GREENWORKS will document and maintain all

maintenance records for the DJI Phantom 3 UAS.  

D. The Reasons Why Granting GREENWORKS Request Would Be In The Public Interest; That Is, How It

Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing GREENWORKS to safely,

efficiently, and economically perform aerial video and photography of construction sites, real estate,

events and civic landscape over certain areas of the United States.  

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and

provide significant benefits to the economy. Notably, the benefits of GREENWORKS’s proposed

operation of the DJI Phantom 3 UAS will be realized without implicating any privacy issues.  

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 UAS are battery powered and serve as a safe, efficient, and economical alternative to

the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS
10

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as

increase the safety of life and property in the air and on the ground.  

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around

airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 UAS do not require

an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and

photography missions would result in fewer aircraft that must be handled by air traffic control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 UAS.

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, will greatly

benefit the public by drastically reducing the levels of air and noise pollution generated during

traditional aerial video and still photography flight operations. By using battery power and electric

motors, the DJI Phantom 3 UAS produce no air pollution, and is the most viable environmentally

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically

utilized for aerial video and photography, while burning approximately 20‐30 gallons per hour of leaded

aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial acquisitions, also

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an

internal combustion engine.  

By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial risk to life and property in

the air and on the ground, which is usually associated with traditional manned aircraft flight operations,

will be substantially reduced or completely eliminated. Aside from the lack of flight crew members

located onboard the aircraft, the DJI Phantom 3 UAS (weighing approximately 2.8 pounds at their

maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less

physical potential for collateral damage to life and property on the ground, and in the air, compared to

the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds

with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).  

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 UAS Will Benefit The

Economy.

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical alternative to

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 UAS

will allow United States based companies, like GREENWORKS, to remain competitive and contribute to

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and

operated companies must adopt new and alternative technology in order to remain competitive.

Operating the battery powered DJI Phantom 3 UAS is one such technology that not only allows

companies greater operational flexibility compared to manned aircraft, but provides such flexibility

without the high operational cost of a traditional manned aircraft.  

By operating the DJI Phantom 3 UAS, companies such as GREENWORKS, can remain competitive and

profitable, and therefore, provide greater job stability to employees and contractors, which will

ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S.
11

companies, through commercial use of the DJI Phantom 3 UAS, provides a stable workforce that

increases consumer spending; improves local, state, and federal tax revenues; and allows companies to

invest in research and development in order to remain competitive both in the United States and

abroad.  

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades,

GREENWORKS’s proposed operation of the DJI Phantom 3 UAS will not implicate any privacy issues.

Specifically, the DJI Phantom 3 UAS will be operated only in compliance with operating documents (i.e.,

GREENWORKS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction

Manual) which requires property owner involvement as well as local law enforcement notification, and

in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14

C.F.R. § 91.119.  

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which

GREENWORKS Seeks Exemption.

1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Modernization and Reform

Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned

aircraft and its operation, GREENWORKS’s operation of the DJI Phantom 3 UAS meet the conditions of

FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

Subpart H.  

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:  

(a) In General.‐‐Notwithstanding any other requirement of this subtitle, and not later than

180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine if certain unmanned aircraft systems may operate safely in the national airspace

system before completion of the plan and rulemaking required by section 332 of this Act or

the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.‐‐In making the determination under

subsection (a), the Secretary shall determine, at a minimum‐‐ 

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight,

speed, operational capability, proximity to airports and populated areas, and

operation within visual line of sight do not create a hazard to users of the national

airspace system or the public or pose a threat to national security; and
12

(2) whether a certificate of waiver, certificate of authorization, or airworthiness

certification under section 44704 of title 49, United States Code, is required for the

operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.‐‐If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airspace system, the

Secretary shall establish requirements for the safe operation of such aircraft systems in the

national airspace system.

In seeking this exemption, GREENWORKS submits that the DJI Phantom 3 UAS can operate safely in the

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3

UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.  

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a

threat to national security considering its size, weight, speed, and operational capability.  

i. Technical Specifications Of The DJI Phantom 3 UAS.

The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 User Manual,

attached hereto as Appendix A.  

ii. The DJI Phantom 3 UAS Global Positioning Modes Enable The UAS To Remain Within A

Defined Operational Area.

The DJI Phantom 3 UAS may be operated in both manual and global positioning flight modes. A

complete description of the flight and navigational modes of the DJI Phantom 3 UAS is provided at pages

11 of the DJI Phantom 3 User Manual attached hereto as Appendix A.  

iii. The DJI Phantom 3 UAS Are Designed For Automatic Return To Home Point Or Hover In The

Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 UAS will remain stationary, in flight, for 3 seconds or

more. If, after 3 seconds, the DJI Phantom 3 UAS does not reacquire control link data from the GCS, the

UAS will assume that the Control Link is lost and the will return to the home position (i.e., failsafe mode)

via GPS, and will descend to the takeoff position and shutdown.  

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are set forth at pages 12

through 14 of the DJI Phantom 3 User Manual, attached hereto as Appendix A.  

iv. The DJI Phantom 3 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 GCS and flight control

software is provided at pages 23 through 29 of the DJI Phantom 3 User Manual.   DJI Phantom 3 User

Manual is attached hereto as Appendix A.  

b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in

Command With A Safety Observer.
13

GREENWORKS video production staff will be the only persons to act as a pilot in command (PIC) of the

DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all times during flight time.  

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, GREENWORKS proposes to commercially operate DJI Phantom 3 UAS for the

special purpose of conducting aerial video and photography over certain areas of United States,

pursuant to the following specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the following aircraft

described in the operating documents, rotorcraft UAS weighing less than 55 pounds

maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations of

any other aircraft will require a new petition or a petition to amend this grant.  

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.  

       3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a special

request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.  

5. The UAS 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.  

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.  

7. 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.  

8. 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.  

9. The operating documents and the grant of exemption must be accessible during UAS

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. Otherwise, the operator must

follow the procedures as outlined in its operating documents. The operator may update or

revise its operating documents. It is the operator’s responsibility to track such revisions and

present updated and revised documents to the Administrator upon request. The operator
14

must also present updated and revised documents if it petitions for extension or amendment

to the grant of exemption. If the operator determines that any update or revision would

affect the basis upon which the FAA granted the exemption, then the operator must petition

for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS‐80) may be

contacted if questions arise regarding updates or revisions to the operating documents.  

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for

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

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

performed and the UAS 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.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 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.  

12. 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.  

13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance,

overhaul, replacement, inspection, and life limit requirements.  

14. 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 UAS to service.  

15. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.  

16. The authorized person must make an entry in the aircraft record of the corrective action

taken against discrepancies discovered between inspections.  

17. The PIC must possess at least a private pilot certificate and at least a current third‐ class

medical certificate.  

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels,

vehicles and structures. PIC qualification flight hours must be logged in a manner consistent

with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are

permitted under the terms of the exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and experience‐
15

building flights, all persons not essential for flight operations are considered

nonparticipants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 C.F.R. § 91.119.  

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight at

night is required, a special request will be made at the FAA office closest to proposed area

of operations. Flights under special visual flight rules (SVFR) are not authorized.  

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted

on a current FAA‐published aeronautical chart unless a letter of agreement with that

airport’s management is obtained, and the operation is conducted in accordance with a

NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.  

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.  

22. If the UA loses communications or loses its GPS signal, it must return to a pre‐ 

determined location within the planned operating area and land or be recovered in

accordance with the operating documents.  

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.  

24. 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.  

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver

or Authorization (COA) prior to conducting any operations under the grant of exemption.

This COA will also require the operator to request a Notice to Airman (NOTAM) not more

than 72 hours in advance, but not less than 48 hours prior to the operation. All operations

shall be conducted in accordance with airspace requirements in the ATO issued COA

including class of airspace, altitude level and potential transponder requirements.  

26. 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 (N‐ 

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as

large as practicable.  

27. Before conducting operations, the radio frequency spectrum used for operation and

control of the UA must comply with the Federal Communications Commission (FCC) or other

appropriate government oversight agency requirements.  

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the

PIC at the Ground Control Station of the UAS any time the UAS is operating. These

documents must be made available to the Administrator or any law enforcement official

upon request.  
16

29. The UA must remain clear and yield the right of way to all manned aviation operations

and activities at all times.  

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. 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 UA 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

UA, 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).  

32. 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.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be reported to

the FAA's UAS Integration Office (AFS‐80) within 24 hours. Accidents must be reported to

the National Transportation Safety Board (NTSB) per instructions contained on the NTSB

Web site: www.ntsb.gov.  

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not

Adversely Affect Safety.

GREENWORKS submits that the equivalent level of safety established by Section 61.113(a) and (b) will be

maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that PIC has

demonstrated, by meeting minimum flight‐hour and currency requirements, that the PIC is able to safely

operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.  

Considering GREENWORKS’s proposed area of operations, and the operating limitations set forth‐above;

the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot

requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI
17

Phantom 3 UAS, GREENWORKS submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for

GREENWORKS’s specific proposed flight operations.  

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159,

11160, 11161).  

GREENWORKS will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has

demonstrated, by meeting minimum flight‐hour requirements or the DJI Phantom 3 UAS training and

currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner

consistent with this exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.  

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a

UAS pilot operating the same make and model of UAS to be used for operations under the exemption).

In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding

90 days (for currency purposes).  

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained

in compliance with applicable regulations will ensure an equivalent level of safety during

GREENWORKS’s proposed operations. The Administrator has held that prior documented flight

experience that was obtained in compliance with applicable regulations would ensure safe operations,

stating as follows:  

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose

of motion picture filming (or similar operations), the PIC must have accumulated and logged, in

a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot

including at least 10 hours logged as a UAS pilot with a multi‐rotor UAS. Prior to operations

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5

hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption. For clarification, the FAA considers these minimum hour requirements to

be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10

hours of multi‐rotor time and the 10 hours may be included in the total 25 hours of UAS

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and

landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the

flight‐hour requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The

FAA also finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and experience‐

building flights can also be conducted under the grant of exemption to accomplish the required

flight time. During training, proficiency, and experience‐building flights the PIC is required to

operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.  
18

Exemption No. 11138 at page 15.  

Accordingly, GREENWORKS will ensure safe operations by not allowing any PIC to operate the DJI

Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight‐hour and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with

the exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.  

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect

Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every

flight, GREENWORKS will ensure that the DJI Phantom 3 UAS is in an airworthy condition based upon the

UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.  

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064,

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158,

11159, 11160, 11161).  

4. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely

Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) the limitations on

the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly,

GREENWORKS will ensure that it will safely operate the battery powered DJI Phantom 3 UAS during

daylight hours in VFR conditions, with enough battery power to fly for a total duration of 23 minutes.  

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 UAS; the limitations

on the proposed flight operations; and the location of the proposed operations, will ensure an

equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured

as the DJI Phantom 3 UAS provide audible and visual warnings to the PIC at the GCS when the UAS

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

DJI Phantom 3 UAS will descend and land automatically.  

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is

not adversely affected when the technical characteristics and operating limitations of the UAS are

considered. Relief has been granted for manned aircraft to operate at less than the minimums

prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has

previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158,

11159, 11160, 11161).  
19

5. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, GREENWORKS submits that the equivalent level of safety with regard to the

regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because GREENWORKS will use trained technicians

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

techniques, and practices prescribed in the operating documents (i.e., GREENWORKS Aerial Operations

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

GREENWORKS will document and maintain all maintenance records for the DJI Phantom 3 UAS.  

Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, GREENWORKS

will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and

91.409(a)(2). A copy of the DJI Phantom 3 User Manuals are attached hereto as Appendix A and B; a

copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as Appendix C.  

Likewise, the exemption sought will not adversely affect safety because GREENWORKS will use trained

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

methods, techniques, and practices prescribed by the operating documents.  

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections

91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS will be performed

by trained technicians. Maintenance will be documented and maintained utilizing the monthly

maintenance log.  

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the

technical characteristics and operating limitations of the UAS are considered.  

In consideration of GREENWORKS’s proposed operating limitations, the operating documents, and the

technical aspects of the DJI Phantom 3 UAS, GREENWORKS submits that safety will not be adversely

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2),

and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances similar, in

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065,

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159,

11160, 11161).  

6. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R.

§ 21.16 entitled Special Conditions, GREENWORKS requests that the FAA prescribe special conditions for

the intended operation of the DJI Phantom 3 UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R.

Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS

for the limited purpose of conducting aerial video and photography over certain areas of the United
20

States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether

a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national

security; and further, provides the authority for such UAS to operate without airworthiness certification

in accordance with any requirements that must be established for the safe operation of the UAS in the

NAS.  

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 C.F.R. Part 21

do not contain adequate or appropriate safety standards, due to the novel or unusual design features of

the aircraft. Section 21.16, entitled Special Conditions, states the following:  

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special

conditions and amendments thereto for the product. The special conditions are issued in

accordance with Part 11 of this chapter and contain such safety standards for the aircraft,

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to

that established in the regulations.  

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special

conditions for Leading Edge’s intended operation of the DJI Phantom 3 UAS, which contain such safety

standards that the Administrator finds necessary to establish a level of safety equivalent to that

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

•   A Summary That Can Be Published In The Federal Register, stating: The Rules From

Which GREENWORKS Seeks Exemption:

GREENWORKS seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b),

91.7(a), 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption GREENWORKS Seeks:

This exemption will permit GREENWORKS to commercially operate an Unmanned Aircraft System

(UAS) for the purpose of conducting aerial video and photography over certain areas of the

United States.

• Any Additional Information, Views, Or Arguments Available To Support

GREENWORKS’s 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 NAS.

As such, GREENWORKS’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.  
21

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to

users of the NAS or the public, or will otherwise pose a threat to national security; and further, provides

the authority for such UAS to operate without airworthiness certification.  

As discussed in detail above, GREENWORKS will operate the DJI Phantom 3 UAS safely in the NAS,

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national

security.  

CONCLUSION

As set forth herein, GREENWORKS 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 GREENWORKS to

safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the NAS.  

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and

Reform Act of 2012, Section 333, GREENWORKS respectfully requests that the Administrator grant this

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.151(b),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate

the DJI Phantom 3 UAS commercially for the purpose of conducting aerial video and photography over

certain areas of the United States.

Dated: July 10, 2015

Respectfully submitted,

Mike Faha

Principal

GreenWorks, PC

24 NW 2nd Avenue, Suite 100

Portland, OR 97209

503‐222‐5612 F‐503‐222‐2283

info@greenworkspc.com

Appendices:

A – Link to DJI Phantom 3 Manual:  Click on link below
22