Submitted by:

Donald R. Fritz

13342 Partridge Hill

San Antonio, Texas 78247

(210) 831-3436

donnyfritz@satx.rr.com

Scope:

Donald R. Fritz is petitioning to use the Phantom 3 Unmanned Aircraft System for multiple 

services, to include:

- Aerial surveying of local land and possible commercial building sites for the community

- Event Photography/Videography 

- Agriculture and Livestock monitoring

- Real Estate Photography and presentation

- Aerial filmmaking and photography

- Construction site inspections and monitoring

UAV Phantom 3:

The DJI Phantom 3 is a quad-rotor Unmanned Aircraft System (UAS) The DJI Phantom 3 has:

 A maximum gross weight of approximately 2 pounds 11 ounces

 A length of 16 inches width of 16 inches 

 Height of 8 inches

 Maximum speed of approximately 29 knots.

 Equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors

 Return Home Feature (Built in Safety)

The DJI Phantom 3 that will be operated by Donald R. Fritz 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 Markings.

The Phantom 3 UAS that Donald R. Fritz will be responsible for also utilizes a mobile ground 

station. The UAS features a safety Return to Home function that in the event of a signal loss, 

the UAS will return to a preset position and land. The Return to Home feature can also be 

triggered manually. The remote connects to your phone or tablet, and a 1080p HD view of 

everything your camera sees as you fly is displayed live.

This immersive view streams to you in absolute clarity, enabling safe flying. From takeoff to 

landing, the Phantom 3 responds to commands while automatically handling the most complex 

aspects of a safe and stable flight.
The DJI Phantom 3 transmitter used for controlling the sUAS complies with part 15 of the FCC 

rules. Operation is subject to the following two conditions: (1) This device may not cause 

harmful interference, and (2) this device must accept any interference received, including 

interference that may cause undesired operation. The DJI Phantom 3 radio transmitter used for 

controlling the sUAS is wireless technology which has been tested and found to be compliant 

with the applicable regulations governing a radio transmitter in the 2.400GHz to 2.4835GHz 

frequency range.

Request:

Donald R. Fritz seeks an exemption to operate DJI systems for compensation or hire within the 

US. The DJI Phantom 3 quad-rotors are vertical takeoff and landing (VTOL) Unmanned Aircraft 

(UA). These UAS’s use a Ground Control Station (GCS), displayed on an electronic tablet or 

smartphone. 

Petition:

Donald R. Fritz requests an exemption from: 14 CFR 61.23(a) and(c) 14 CFR 61.101(e)(4) and (5) 

14 CFR 61.113(a) 14 CFR 61.315(a) 14 CFR 91.7(a) 14 CFR 91.119(c) 14 CFR 91.121 14 CFR 

91.151(a)(1) 14 CFR 91.405(a) 14 CFR 91.407(a)(1) 14 CFR 91.409(a)(1) and (2) 14 CFR 91.417 (a) 

and (b) to the extent necessary to allow the petitioner to operate the DJI Phantom 3 

Professional UAS to perform aerial video and photographic collection. 

The Extent of Relief that Donald R. Fritz seeks:

1. Extent of Relief that Donald R. Fritz seeks regarding Section 61.113 (a) and (b) Private Pilot 

Privileges and Limitations Relief from Section 61.113 (a) and (b) is requested to allow a Pilot in

Command holding a current Private Pilots Certificate to operate the Donald R. Fritz’s Phantom

3. The flight would be complimented by a Visual Observer who, along with the pilot, will 

maintain Visual Line of Sight with the Phantom 3 at all times. All operations conducted will be 

incidental to Donald Fritz’s business. The Phantom 3 is not able to carry passengers.

2. Extent of Relief that Donald R. Fritz seeks in regards to Section 91.7(a) Civil Aircraft 

Airworthiness Relief from Section 91.7(a) is requested to allow Donald R. Fritz to determine

airworthiness of the Phantom 3. As part of this determination the following will be adhered to:

a. Prior to the Phantom 3's flight the PIC will inspect the UA to ensure it is in a condition that 

will be conducive for a safe flight. The ground control station will be included in the above 

inspection.

b. Donald R. Fritz will follow the DJI Phantom 3’s aircraft/component, maintenance, overhaul, 

replacement, inspection and life limit requirements.

c. Donald R. Fritz will comply with all DJI manufacturer Safety Bulletins.

3. Extent of Relief that Donald R. Fritz seeks in regards to Section 91.119 Minimum Safe 

Altitudes General relief from 91.119 is requested to allow Donald R. Fritz to operate the 

Phantom 3 at altitudes not to exceed 400’ AGL over private property at a distance at or greater 

than 5NM from the nearest airport as depicted on current Aeronautical Charts. Donald R. Fritz
also wishes to be granted exemption to operate at an altitude not greater than 50’ AGL (below 

tree level) between 1NM and 5NM from the nearest airport as depicted on current 

Aeronautical Charts.

Donald R. Fritz will adhere to the following in order to maintain an acceptable level of safety 

associated with operations over private property:

(a) Donald R. Fritz will display signs in the immediate vicinity of operations stating: “Aerial 

Photography In Progress. Use Caution.”

(b) Donald R. Fritz will not allow the Phantom 3 to operate at a speed greater than 20kts.

(c) Donald R. Fritz will require the UAS operator (PIC) to be fully trained on the Phantom 3 by 

adhering to the recommendations contained within the Phantom 3’s operating manual.

(d) Donald R. Fritz will have accumulated and logged, in a manner consistent with 14 CFR 

61.51(b), a minimum of 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. In addition the operator will have logged a 

minimum of 5 hours as a UAS pilot operating the make and model UAS that Flying Donald R. 

Fritz operates.

(e) Donald R. Fritz will be familiar with and able to manually institute the Phantom 3’s Return to 

Home (RTH) feature. This feature aborts a flight operation and automatically returns the UAS to 

a predetermined GPS safe point.

(f) Donald R. Fritz will not operate over private property without first finding a suitable 

alternate landing spot on the property. (g) Donald R. Fritz will abort the flight in the event of 

unpredicted obstacles or emergencies in accordance with the operating documents.

(h) Donald R. Fritz will utilize a two man flight team consisting of the Pilot in Command (PIC) 

and a Visual Observer (VO). This team will maintain visual line of sight with the Phantom 3 at all 

times and remain within hearing of one another.

(i) Donald R. Fritz will not permit flight around vessels, vehicles and structures without 

permission from the owner.

4. Extent of Relief that Donald R. Fritz seeks in regards to Section 91.121 Altimeter Settings

Relief from 91.121 is requested because the Phantom 3 utilizes electronic GPS with a 

barometric sensor.

In order to maintain an equal level of safety that 91.121 requires, the PIC of the Donald R. Fritz

UAS will abort the flight in the events that the UA loses communications with the GPS signal.

5. Extent of Relief that Donald R. Fritz seeks in regards to Section 91.151(b) Fuel Requirements 

for Flight in VFR Conditions Relief from 91.151(b) is requested to the extent that allows Donald 

R. Fritz to operate the Phantom 3 up to a point (considering wind and forecast weather

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

point and land the UA with 30% battery power remaining.

6. Extent of Relief that Donald R. Fritz seeks in regards to Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1), and (a)(2), 91.417(a) and (b) These are all associated a with Airworthiness 

certificate Relief from 91.405(a), 91.407(a)(1), and (a)(2), And 91.417(a) and (b) is requested to 
the extent that allows Donald R. Fritz to operate the Phantom 3 Quad-Copter as necessary. 

These sections are all related to airworthiness certificates of aircraft. There is not currently an 

airworthiness certificate for small UAS’s. Donald R. Fritz would comply in full to any conditions 

and limitations that the Administrator would place in order to receive an approved Grant of 

Exemption.

Public Interest:

Aerial videography and photography has been around for a long time through manned fixed 

wing aircraft and helicopters, but for small business owners, its expense has been costprohibitive. Granting this exemption to me would allow me to provide this service at a much 

lower cost. My UAS will pose no threat to the public given its small size and lack of combustible

fuel when compared to manned aircraft. The operation of my UAS will minimize ecological 

damage and promote economic growth by providing information to companies looking to 

relocate or build in the San Antonio, Texas area.

Conclusion:

As set forth herein, Donald R. Fritz 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. 

The Administrator will be assisting small business by granting this petition. In accordance with 

the FAA Modernization and Reform Act of 2012, Donald R. Fritz respectfully requests that the 

FAA Administrator grants this petition for exemption from TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS SECTIONS

61.113 (a) and (b); 91.7 (a); 91.119 (c); 91.121; 91.151 (a); 91.405 (a);

91.407 (a) (1); 91.409 (a) (1) and (2); 91.417 (a) and (b)

Thank you in advanced for your consideration, 

Donald R. Fritz

donnyfritz@satx.rr.com

(210) 831-3436