SUMMARY

JOSEPH GRINDSTAFF/PHOTODRONE seeks exemption from the requirements of 14 C.F.R 

§§ 61. 1 13 (a) & (b), 91.7(a), 91.121, 91.151 (b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & 

(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 

of the FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit 

JOSEPH GRINDSTAFF/PHOTODRONE to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography for marketing, film sets, 

real estate photography, commercials, special events, wedding cinematography, and 

landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is JOSEPH GRINDSTAFF/PHOTODRONE and I am the Manager and owner of PC 

Boys and a startup company called Photodrone. I also hold a Commercial Flight Attendant 

certificate. I am also a retired USAF Avionics Aviation Systems Specialist. 

JOSEPH GRINDSTAFF/PHOTODRONE is also a drone builder and operator (pilot) with 

expertise and knowledge in aspects of building, programing and operating multiple types of 

UAS'S along with camera set up and operation. JOSEPH GRINDSTAFF/PHOTODRONE is also 

an experienced photographer who now wishes to provides clients with the highest quality digital 

content for use in their commercial, personal, and non-profit multimedia projects. 

JOSEPH GRINDSTAFF/PHOTODRONE has approximately 25 years of Radio Controlled 

aircraft experience including helicopters. 

The objective of JOSEPH GRINDSTAFF/PHOTODRONE aerial video and photography 

operations is to provide high quality imaging for a variety of commercial, public, and 

residential uses, along with testing of repaired drones for clients in a safe testing location 

away from all obstacles and people at all times. JOSEPH GRINDSTAFF/PHOTODRONE will 

also provide knowledge of sUAS to others and promote safe sUAS operations and conduct all 

filming operations under 200 feet. Currently JOSEPH GRINDSTAFF/PHOTODRONE 

operates for noncommercial purposes a DJI Phantom 3 with FAA certification # FA3FATCW.

JOSEPH GRINDSTAFF/PHOTODRONE does not hold a pilot’s license or certificates, 

however in compliance with FAA regulations, will hire FAA certified pilots during operation of 

SUAS for commercial purposes

Former exemptions granted by The FAA for sUAS are as follows:

DJI – Phantom 3: FAA 333 Exemption: 11783, 11788, 11711, 11696

DJI – Inspire 1: FAA 333 Exemption: 11710, 11711, 11712, 11714
BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 Plus, DJI Inspire 1 

JOSEPH GRINDSTAFF/PHOTODRONE seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 3 and DJI Inspire I are 

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 3 pounds, while having a length of 17 

inches width of 17 inches, height of 8 inches, and a maximum speed of approximately 16m/s. The 

DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. The DJI Phantom 2 and DJI Inspire I UA's are equipped with four 

main rotors; driven by electric motors powered by a Lithium Polymer battery. 

The DJI Phantom 3 and DJI Inspire 1 sUAS 's that will be operated by JOSEPH 

GRINDSTAFF/PHOTODRONE will be registered in accordance with 49 US.C 44103, 

Registration of 

Aircraft, as well as 14 CF.R Part 47, Aircraft Registration, and marked in accordance with 

14 CF.R Part 45, Identification and Registration Markings. 

BASIS FOR PETITION 

Petitioner, JOSEPH GRINDSTAFF/PHOTODRONE , pursuant to the provisions of the Federal 

Aviation Regulations (14CF.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 and the DJI Inspire 1 

sUAS in the National Airspace System (NAS), and for an exemption from the requirements 

of 14 CF.R §§ 61.113(a) & (b), 91.7(a), 91.119, 91.121, 91.l51(b), 91.405(a), 91.407(a)(I), 

91.409(a)(I) & (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, JOSEPH GRINDSTAFF/PHOTODRONE operation of DJI 

Phantom 3 and DJI Inspire 1 sUAS's meets the conditions of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 CF.R Part 21, 

Subpart H. 

Accordingly, JOSEPH GRINDSTAFF/PHOTODRONE requests relief from Sections 91.405(a), 

91.407(a)(I), 91.409(a)(I) & (a)(2), and 91.417 (a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

JOSEPH GRINDSTAFF/PHOTODRONE submits that the requested relief is proper since an 

equivalent level of safety will be ensured. JOSEPH GRINDSTAFF/PHOTODRONE will use 

experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the sUAS using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 

Instruction Manual). Furthermore, JOSEPH GRINDSTAFF/PHOTODRONE will document and 

maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 sUAS. 

Relief from certain requirements of Section 61.113( a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by JOSEPH GRINDSTAFF/PHOTODRONE to 

the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 
certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight-hour and currency requirements. JOSEPH GRINDSTAFF/PHOTODRONE 

certifies that as the PIC, is able to safely operate the 

DJI Phantom 3 and DJI Inspire 1 sUAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

JOSEPH GRINDSTAFF/PHOTODRONE seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom 3 and DJI Inspire 1 sUAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, JOSEPH 

GRINDSTAFF/PHOTODRONE submits that he will ensure that the DJI Phantom 3 and DJI 

Inspire I sUAS are in an airworthy condition, prior to every flight, by determining that the 

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

DJI Phantom 1 and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition 

for safe flight. 

JOSEPH GRINDSTAFF/PHOTODRONE also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will 

not have a typical barometric altimeter onboard. However, altitude information of the DJI 

Phantom 3 and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the 

UA to the GCS for active monitoring of the flight path. This altitude information, combined 

with JOSEPH GRINDSTAFF/PHOTODRONE operation of the DJI Phantom 3 and DJI Inspire 

1 sUAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, JOSEPH GRINDSTAFF/PHOTODRONE seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. 

JOSEPH GRINDSTAFF/PHOTODRONE submits that safety will not be affected by operation 

of the DJI Phantom 3 and DJI Inspire 1 sUAS's during daylight hours in visual 

meteorological conditions (YMC) under visual flight rules (VFR), with enough battery power 

to fly for a total duration of approximately 15.5 minutes to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, JOSEPH GRINDSTAFF/PHOTODRONE provides the 

following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

JOSEPH GRINDSTAFF/PHOTODRONE 

5432 Prince Edward Ave.

El Paso, TX. 79924

915-491-5809

Jgrind520@aol.com

B. The Specific Sections Of 14 C.F.R. from Which JOSEPH 

GRINDSTAFF/PHOTODRONE Seeks Exemption. 

1. JOSEPH GRINDSTAFF/PHOTODRONE Seeks Exemption From The Requirements 

Of Section 61.1I3(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 if1. The flight is only incidental to that business or employment; and 

II. The aircraft does not carry passengers or property for compensation or hire. 

2. JOSEPH GRINDSTAFF/PHOTODRONE 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. JOSEPH GRINDSTAFF/PHOTODRONE Seeks Exemption From The Requirements 

Of Section 91.121. 

a. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in 

part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or 

flight level of that aircraft, as the case may be, by reference to an 

altimeter that is set, when operating-Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(l)(i) 

of this section, the current reported altimeter setting of an appropriate 

available station; 

(iii)In the case of an aircraft not equipped with a radio, the elevation of 

 the departure airport or an appropriate altimeter setting available 

 before departure. 

4. JOSEPH GRINDSTAFF/PHOTODRONE Seeks Exemption From The Requirements 

Of Section 91.151(b). 

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

5. JOSEPH GRINDSTAFF/PHOTODRONE 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 
6. JOSEPH GRINDSTAFF/PHOTODRONE Seeks Exemption From The 

Requirements 

Of Section 91.407(a) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration; 

a. Subsection (a)(1), states the following: 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 

7. JOSEPH GRINDSTAFF/PHOTODRONE Seeks Exemption From The Requirements 

Of Sections 91.409(a)(1) And 91.409(a)(2). 

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

L 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. 

8. JOSEPH GRINDSTAFF/PHOTODRONE Seeks Exemption From 

The 

Requirements Of Sections 91.417(a) And 91.417(b). 

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

following: 

L 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 

(a) A description (or reference to data acceptable to the Administrator) of the work performed; 

and

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

(c) The signature, and certificate number of the person approving the 

aircraft for return to service. 

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)(l) of this section shall be retained 

until the work is repeated or superseded by other work or for I 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. 

C. The Extent Of Relief JOSEPH GRINDSTAFF/PHOTODRONE Seeks And The Reason 

JOSEPH GRINDSTAFF/PHOTODRONE Seeks The Relief. 

1. Relief From Section 61.1l3(a) And (b): 

a. 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, JOSEPH 

GRINDSTAFF/PHOTODRONE submits that an equivalent level of safety will be 

maintained because 
no PIC will be allowed to operate the DJI Phantom 3 UAS or DJI Inspire 1 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 or DJI Inspire 1 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, JOSEPH 

GRINDSTAFF/PHOTODRONE submits that all flights of the DJI Phantom 3 and DJI 

Inspire 1 sUAS, conducted by the PIC pursuant to the grant of this Petition: (1) will 

be incidental to JOSEPH GRINDSTAFF/PHOTODRONE 's business; and (2) will not 

carry passengers or property for compensation or hire. 

b. Relief from Section 91. 7( a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow JOSEPH GRINDSTAFF/PHOTODRONE to determine that 

the Dll Phantom 3 and DJI Inspire 1 sUAS are in airworthy condition prior to every 

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

JOSEPH GRINDSTAFF/PHOTODRONE Aerial Operations Manual, Monthly 

Maintenance Log, and Dfl Phantom 3 and OJI Inspire 1 Instruction Manual). 

JOSEPH GRINDSTAFF/PHOTODRONE seeks the requested relief because the DJI 

Phantom 3 and DJI Inspire 1 sUAS do not require an airworthiness certificate in 

accordance with 14 C.F .R Part 21, Subpart H. Therefore, JOSEPH 

GRINDSTAFF/PHOTODRONE will ensure that the DJI Phantom 3 and DJI Inspire 1 

sUAS are in 

airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 3 and OJI Inspire 1 User Manuals; prior 

to every flight, and further, determine that the aircraft are in condition for safe flight, 

as stated in the conditions and limitations below. Relief from Section 91.121, entitled 

Altimeter settings, may be required to allow flight operations of the DJI Phantom 3 

and DJI Inspire 1 sUAS, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry data link to downlink altitude information 

from the UA to the PIC at the ground control station (GCS). Since the FAA requires 

that any altitude information concerning UAS operations be reported to air traffic 

control (ATC) in feet above ground level (AGL), JOSEPH 

GRINDSTAFF/PHOTODRONE seeks the requested relief because the DJI Phantom 3 

and DJI Inspire 1 UA's 

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

pressure or field altitude, before each flight. Considering the limited altitude of the 

proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to 

comply with the applicable conditions and limitations stated below. As more fully set 

forth herein, an equivalent level of safety will be maintained since the Dll Phantom 2 

and DJI Inspire 1 UAs are equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the 

UA on the heads-up display of the GCS. 

c. 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 

OJI Phantom 3 and OJI Inspire 1 sUAS during daylight hours in visual 

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

of approximately 15.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. JOSEPH 

GRINDSTAFF/PHOTODRONE seeks the requested relief because without an 

exemption from 

Section 91.151 (b), the flight time duration of the battery powered OJI Phantom 3 and 
OJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still 

photo flight operations that JOSEPH GRINDSTAFF/PHOTODRONE proposes to 

conduct pursuant to this Petition. Significantly, as set forth below, the technical 

specifications ofthe OJI Phantom 3 and DJI Inspire 1 sUAS, the DJI Phantom 3 and 

OJI Inspire 1 operating documents, and the operating limitations proposed by 

JOSEPH GRINDSTAFF/PHOTODRONE , ensure that JOSEPH 

GRINDSTAFF/PHOTODRONE will safely operate the battery powered DJI Phantom 3 

and DJI Inspire 

1 sUAS during daylight hours in visual meteorological conditions (VMe), under 

visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5.

minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes. 

d. 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, JOSEPH 

GRINDSTAFF/PHOTODRONE requests relief from these Sections because the DJI 

Phantom 3 and DJI Inspire 1 

sUAS do not require airworthiness certificates. As set forth more fully below, the DJI 

Phantom 3 and DJI Inspire 1 sUAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, JOSEPH 

GRINDSTAFF/PHOTODRONE will use trained technicians to perform maintenance, 

alterations, 

or preventive maintenance on the sUAS using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., JOSEPH 

GRINDSTAFF/PHOTODRONE Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 3 and 

DJI Inspire 1 Instruction Manual). Furthermore, JOSEPH 

GRINDSTAFF/PHOTODRONE will document and maintain all maintenance records for 

the DJI Phantom 3 and 

DJI Inspire 1 sUAS. 

D. The Reasons Why Granting JOSEPH GRINDSTAFF/PHOTODRONE 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 

JOSEPH GRINDSTAFF/PHOTODRONE to safely, efficiently, and economically 

perform aerial video and photography of construction sites, real estate, and landscape 

over certain areas of the United States. 

Additionally, use of the DJI Phantom 3 and DJI Inspire 1 sUAS will decrease 

congestion of the NAS, reduce pollution, crashes and accidents caused by pilot error and 

provide significant benefits to the economy. Notably, the benefits of JOSEPH 

GRINDSTAFF’s/PHOTODRONE’S proposed operation of the DJI Phantom 3 and DJI Inspire 1 

sUAS will be realized without conflicting with or violation of any privacy issues. 

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

The DJI Phantom 3 and DJI Inspire 1 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 or DJI Inspire 

1 UAS 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 and DJI Inspire 1 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 

and DJI Inspire 1 sUAS. 
Conducting aerial media acquisitions with the DJI Phantom 3 and DJI Inspire 1 

sUAS, 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 and DJI Inspire 1 sUAS 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 

which bum approximately 20-30 gallons per hour of leaded aviation fuel. The DJI 

Phantom 3 and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial 

acquisitions, also eliminate noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine. By using the DJI 

Phantom 3 and DJI Inspire 1 sUAS 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 and DJI Inspire 1 UAs (weighing approximately 2 

pounds 14 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross 

weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches 

and 17.7 inches respectively, 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 

and DJI Inspire 1 sUAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 sUAS are 

also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 and DJI Inspire 1 sUAS will 

allow United States based companies, such as JOSEPH GRINDSTAFF/PHOTODRONE 

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 and DJI Inspire 1 sUAS 

utilizes 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 and 

DJI Inspire 1 sUAS, companies such as JOSEPH GRINDSTAFF/PHOTODRONE 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. companies, through commercial 

use of the DJI Phantom 3 and DJI Inspire 1 sUAS, 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. 

a. There is limited competition of sUAS type aircraft legally licensed to operate 

in the El Paso Texas region for this purpose, therefore operation of the DJI 

Phantom 3 and DJI Inspire 1 will greatly benefit the local community and 

provide an alternative to expensive fuel powered large aircraft that currently 

provide similar types of services.
b. JOSEPH GRINDSTAFF/PHOTOTDRONE further benefit the local economy 

by hiring FAA certified pilots, thus providing a source of employment in an 

area that the requirements for certified pilots is limited and will be a 

significant avenue for pilots to pursue additional income.

There Are No Privacy Issues.

Similar to the manned aerial media acquisition flight operations that have been 

conducted for decades, JOSEPH GRINDSTAFF/PHOTODRONE proposed operation 

of the DJI Phantom 3 and DJI Inspire 1 sUAS would not implicate any privacy issues. 

Specifically, the DJI Phantom 3 and DJI Inspire 1 sUAS will be operated only in 

compliance with operating documents (i.e., JOSEPH GRINDSTAFF/PHOTODRONE 

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

Inspire 1 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 JOSEPH GRINDSTAFF/PHOTODRONE Seeks 

Exemption. 

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 sUA V Meet The Conditions Of 

The FAA Modernization and Reform Act of2012 (FMRA) Section 333. 

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

the unmanned aircraft and its operation, JOSEPH GRINDSTAFF/PHOTODRONE 's 

operation of the DJI Phantom 3and DJI Inspire 1 sUAS 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 minimum1. 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 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 (J). 

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 

sate operation of such aircraft systems in the national airspace system. 

In seeking this exemption, JOSEPH GRINDSTAFF/PHOTODRONE submits that the DJI 

Phantom 3 and DJI Inspire 1 sUAS can operate safely in the NAS pursuant to FMRA Section 

333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 and DJI Inspire 1 

sUAS, (b) the pilot certification requirement and (c) the specific operating limitations. 

L The Specifications Of The DJI Phantom 3 and DJI Inspire 1 sUAS 

Demonstrate Its Safe Characteristics. 

The DJI Phantom 3 and DJI Inspire 1 sUAS do 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. 

11. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1 sUAS. 

The DJI Phantom 3and DJI Inspire 1 Specifications and Data Sheet, attached 

hereto as Exhibits A and B, set the technical specifications of the DJI Phantom 3 

and DJI Inspire 1 sUAS forth. 

iii. The DJI Phantom 3 and DJI Inspire 1 sUAS Autonomous Flight And 

Navigation Modes Enable The sUAS To Remain Within A Defined 

Operational Area. 

The DJI Phantom 3 and DJI Inspire 1 sUAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 3 and DJI Inspire 1 sUAS is provided at 

pages 25-35 of the DJI Phantom 3 and pages 12-16 and 45-50 of the DJI Inspire I 

User Manuals, attached hereto as Exhibit C and D. 

IV. The DJI Phantom 3 and DJI Inspire 1 sUAS 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 and DJI Inspire 1 UAs will 

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 3 and DJI Inspire 1 UAs do not reacquire control link data from the 

GCS, the UAs will assume that the Control Link is lost and the UAs 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 27 and 28 and for the DJI Inspire 1 at 

pages 13 through 15 of the DJI Phantom 3 along with complete DJI Inspire 1 User 

Manuals, attached hereto as Exhibit C and D. 

v. The DJI Phantom 3 and DJI Inspire 1 Ground Control Station ("GCS") And 

It's Operation. 

A complete description of the operation and specifications of the DJI Phantom 3 

and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 

44 of the DJI Phantom 3 User Manual and pages 23 through 33 of the DJI Inspire 

1 User Manual. DJI Phantom 3 and DJI Inspire 1 User Manuals are attached 

hereto as Exhibits C and D. 

VI. Flight Operations Of DJI Phantom 3 and DJl lnspire 1 sUAS Are Limited To 

The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

vii. AERIAL JOSEPH GRINDSTAFF/PHOTODRONE will only utilize certificated pilots who 

possess a current and valid airman medical certificate to act as a pilot in command 
(PIC) of the DJI Phantom 2 and Dfl Inspire 1 sUAS. Additionally, a safety 

observer will assist all pilots during flight time. (PIC) of the DJI Phantom 3 and DJI 

Inspire 1 sUAS. Additionally, a safety 

observer will assist the pilot during flight time. 

viii. Flights Of DJI Phantom 3 and DJI Inspire 1 sUAS Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, JOSEPH GRINDSTAFF/PHOTODRONE proposes to 

commercially operate DJI Phantom 3 and DJI Inspire 1 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 sUAS 

weighing less than 55 pounds maximum gross weight: DJI Phantom 2 and 

on Inspire 1 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 500 feet above 

ground level (AGL), as indicated by the procedures specified in the 

operating documents unless a special request is made and approved by 

A TC. 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 U AS 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 

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 f or 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 sUAS 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.

The PIC must possess at least a private pilot certificate and at least a 

current third-class medical certificate. 
17. 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-

 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.

18. 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 (YMC). 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..

19. The VA 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 

20. 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. 

21. 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. 

22. The PIC must abort the flight in the event of un predicted obstacles or 

emergencies in accordance with the operating documents. 

17. 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 VA with 25 

battery power remaining. 

18. 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. 

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 

ofthe 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 ofthe 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) 
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 night 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. 

Exemption No. 11138 at page 15. Accordingly, JOSEPH GRINDSTAFF/PHOTODRONE will ensure 

safe operations by not allowing any PIC to operate the DJI Phantom 

3 or DJI Inspire 1 U AS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the Dll 

Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

CONCLUSION 

JOSEPH GRINDSTAFF/PHOTODRONE seeks an exemption pursuant to 14 C.F.R § 11.61 

and Section 333 of the FAA Modernization and Reform Act of 20 12 (FMRA), which will 

permit safe operation of the DJI Phantom 3 and DJI Inspire 1 sUAS 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 20 12, while also advancing the interests of the public, by JOSEPH 

GRINDSTAFF/PHOTODRONE to safely, efficiently, and economically operate the DJI 

Phantom 3 and DJI Inspire 1 sUAS commercially within the NAS. WHEREFORE, in 

accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of20 12, Section 333, JOSEPH GRINDSTAFF/PHOTODRONE respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 9L7(a}, 91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

(aX2), and 91.417(a) & (b») and pennit JOSEPH GRINDSTAFF/PHOTODRONE to operate 

the DJI Phantom 3 and DJI Inspire 1 sUAS commercially for the purpose of conducting 

aerial video and photography over certain areas of the United States. 

Dated: January 26,2016 

Submitted by: 

JOSEPH GRINDSTAFF/PHOTODRONE