UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. FAA-2007-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

DRAGO ENTERTAINMENT INC.

Federal Employer ID #: 20-2189152

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

 SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF a) DJI PHANTOM 2 and b) DJI INSPIRE 1 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on August 2, 2015 

DRAGO 

ENTERTAINMENT 

INC.

Joe Drago, President 

630 Oldstone Place

SimiValley Ca, 93065

818-419-1940

joe@drago-ent.com
2	

TABLE OF CONTENTS 

Page 

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

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

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

BACKGROUND................................................................................................................5 

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

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

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

DRAGO ENTERTAINMENT INC, INC. 

SEEKS EXEMPTION .......................................................................................7

THE EXTENT OF RELIEF DRAGO ENTERTAINMENT INC.

SEEKS AND THE REASON DRAGO ENTERTAINMENT INC. 

SEEKS THE RELIEF........................................................................................................10

THE REASONS WHY GRANTING DRAGO ENTERTAINMENT INC.’S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ...............................................13 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY............................................................................................................16

CONCLUSION.................................................................................................................32 
3	

GLOSSARY OF ABBREVIATIONS 

AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOTAM 

PIC 

Section 333 

VO 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of 2012 (FMRA) 

Visual Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 
4	

SUMMARY

DRAGO ENTERTAINMENT, Inc. seeks exemption from the requirements of 

14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & 

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

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

exemption will permit DRAGO ENTERTAINMENT, Inc.to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

photography for real estate photography, wedding videography, special events, film sets 

and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is Joseph C. Drago, Owner/President of DRAGO 

ENTERTAINMENT, Inc. a Federally recognized Incorporation. It is my mission to 

provide my clients with expertise and knowledge in all aspects of picture, video & audio 

production, as well as provide them with advanced technologies & solutions that will 

increase 

efficiency, productivity and effectiveness. DRAGO ENTERTAINMENT, Inc. also 

provides clients with the highest quality digital content for use in their commercial, 

personal, and non-profit multimedia projects. DRAGO ENTERTAINMENT Inc. has 

8 years of professional experience in photography and videography and has become 

recognized as an expert in this field. DRAGO ENTERTAINMENT Inc. has 3 years of 

recreational/hobby experience in all aspects of aerial video and photography. The 

objective of DRAGO ENTERTAINMENT Inc. aerial video and photography 

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

residential uses, specifically targeting: 

• Real Estate Videography and Photography

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Creation of commercial messages for Television.

• Search and Rescue Operations

• Motion Picture Filming

• Increase public knowledge of UAS and promote safe UAS operations.
5	

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 2, and DJI Inspire 1 UASs 

DRAGO ENTERTAINMENT Inc. seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 2 and DJI Inspire 1 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 has a 

maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 

16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 

29 knots. 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 1 UAs are equipped 

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

The DJI Phantom 2 and DJI Inspire 1 UAs that will be operated by DRAGO 

ENTERTAINMENT Inc.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, DRAGO ENTERTAINMENT Inc., 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 2, DJI Inspire 1 UASs 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), 91.121, 

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, DRAGO ENTERTAINMENT Inc.

operation of DJI Phantom 2 and DJI Inspire 1 UASs 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. 

Accordingly, DRAGO ENTERTAINMENT Inc. 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. 

DRAGO ENTERTAINMENT Inc. submits that the requested relief is proper 

since an equivalent level of safety will be ensured. DRAGO ENTERTAINMENT Inc.

will use experienced personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and practices 

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

Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, DRAGO 

ENTERTAINMENT Inc.will document and maintain all maintenance records for the 

DJI Phantom 2 and DJI Inspire 1 UASs. 
6	

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

pilot privileges and limitations: Pilot in command, is requested by DRAGO 

ENTERTAINMENT Inc. 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, 

that the PIC is able to safely operate the DJI Phantom 2 and DJI Inspire 1 UASs in a 

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

maintaining appropriate distances from people, vessels, vehicles and structures. 

DRAGO ENTERTAINMENT Inc. seeks relief from Section 91.7(a), entitled 

Civil aircraft airworthiness, because the DJI Phantom 2 and DJI Inspire 1 UASs do not 

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

such, DRAGO ENTERTAINMENT Inc. submits that they will ensure that the DJI 

Phantom 2 and DJI Inspire 1 UASs are in an airworthy condition, prior to every flight, 

by determining that the UASs are in compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual), 

and that the aircraft are in a condition for safe flight. 

DRAGO ENTERTAINMENT Inc. also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ 

and DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, 

altitude information of the DJI Phantom 2 and DJI Inspire 1UAs 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 DRAGO ENTERTAINMENT 

Inc.’s operation of the DJI Phantom 2 and DJI Inspire 1 UASs within visual line of sight, 

at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally,DRAGO ENTERTAINMENT Inc. seeks an exemption from the 

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

conditions. DRAGO ENTERTAINMENT Inc. submits that safety will not be affected 

by operation of the DJI Phantom 2 and DJI Inspire 1 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 approximately 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. 

In accordance with 14 C.F.R. § 11.81, DRAGO ENTERTAINMENT Inc.

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: Joe Drago c/o Drago Entertainment Inc.

630 Oldstone Place Ca, 93065

818-419-1940

joe@drago-ent.com
7	

B. The Specific Sections Of 14 C.F.R. From Which DRAGO ENTERTAINMENT Inc. Seeks 

 Exemption. 

1. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section

Part 21, Subpart H 

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1) 

2. DRAGO ENTERTAINMENT Inc. 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. 

3. DRAGO ENTERTAINMENT Inc. 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. 

4. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section

 91.121. 

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-- 

 (1) 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)(1)(i) of 

 this section, the current reported altimeter setting of an appropriate 

 available station; or 
8	

(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. 

5. DRAGO ENTERTAINMENT Inc. 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. 

6. DRAGO ENTERTAINMENT Inc. 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[.] 

7. DRAGO ENTERTAINMENT Inc. 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[.] 

8. DRAGO ENTERTAINMENT Inc. 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. 
9	

9. DRAGO ENTERTAINMENT Inc. 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-- 

(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. 
10

C. The Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason 

DRAGO ENTERTAINMENT Inc. Seeks The Relief. 

1. DRAGO ENTERTAINMENT Inc. Seeks Exemption From The Requirements Of Section Part

21, Subpart H

Given the size and limited operating area associated with the UAS to be utilized by 

DRAGO ENTERTAINMENT Inc., an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. 

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed UAS 

operations.

2. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason

DRAGO ENTERTAINMENT Inc. 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, DRAGO ENTERTAINMENT Inc. submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate 

the DJI Phantom 2 UAS or DJI Inspire 1 UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate 

either the DJI Phantom 2 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. 
11

Further, DRAGO ENTERTAINMENT Inc. submits that all flights of the DJI Phantom 2 

and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) 

will be incidental to DRAGO ENTERTAINMENT Inc.' business; and (2) will not carry 

passengers or property for compensation or hire. 

3. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason

DRAGO ENTERTAINMENT Inc. 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 DRAGO ENTERTAINMENT Inc. to determine that the DJI Phantom 2 

and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that 

the UAS is in compliance with the operating documents (i.e., the DRAGO 

ENTERTAINMENT Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 and DJI Inspire 1 Instruction Manual). 

DRAGO ENTERTAINMENT Inc. seeks the requested relief because the DJI Phantom 2 

and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. Therefore,DRAGO ENTERTAINMENT Inc. will ensure 

that the DJI Phantom 2 and DJI Inspire 1 UASs are in airworthy condition based upon 

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

Phantom 2 and DJI Inspire 1 Instruction Manual) prior to every flight, and further, 

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

limitations below. 

4. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason

DRAGO ENTERTAINMENT Inc. Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the DJI Phantom 2 and DJI Inspire 1 UASs, 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), DRAGO 

ENTERTAINMENT Inc. seeks the requested relief because the DJI Phantom 2 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 DJI 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. 
12

5. Extent Of Relief DRAGO ENTERTAINMENT Inc Seeks And The Reason DRAGO

ENTERTAINMENT Inc. 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 2 

and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), 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. DRAGO ENTERTAINMENT Inc. seeks the requested relief because without 

an exemption from Section 91.151(b), the flight time duration of the battery powered 

DJI Phantom 2 and DJI Inspire 1 UAs will severely constrain the practicality of any 

aerial video or still photo flight operations that DRAGO ENTERTAINMENT Inc.

proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 and 

DJI Inspire 1 UASs, the DJI Phantom 2 and DJI Inspire 1 operating documents, and 

DRAGO ENTERTAINMENT Inc.’s proposed operating limitations, ensure that DRAGO 

ENTERTAINMENT Inc. will safely operate the battery powered DJI Phantom 2 and DJI 

Inspire 1 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 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. 

6. Extent Of Relief DRAGO ENTERTAINMENT Inc. Seeks And The Reason

DRAGO ENTERTAINMENT Inc. 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, DRAGO ENTERTAINMENT Inc.

requests relief from these Sections because the DJI Phantom 2 and DJI Inspire 1 UASs 

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

2 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, DRAGO ENTERTAINMENT Inc. will 

use trained technicians to perform maintenance, alterations, or preventive maintenance on 

the UASs using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the DRAGO ENTERTAINMENT Inc. Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). 

Furthermore, DRAGO ENTERTAINMENT Inc. will document and maintain all 

maintenance records for the DJI Phantom 2 and DJI Inspire 1 UASs. 
13

D. The Reasons Why Granting DRAGO ENTERTAINMENT Inc. 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 DRAGO 

ENTERTAINMENT Inc. to safely, efficiently, and economically perform aerial video 

and photography of, real estate, wedding films, special events, precision agriculture, land 

survey & appraisal, construction sites, equipment & roof inspections, film sets and 

landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 2 and DJI Inspire 1 UASs will decrease congestion 

of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, 

the benefits of DRAGO ENTERTAINMENT Inc.’s proposed operation of the DJI 

Phantom 2 and DJI Inspire 1 UASs will be realized without implicating any privacy 

issues. 

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

The DJI Phantom 2 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 2 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 2 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 2

and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 2 and DJI Inspire 1 UAS’s, 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 2 and DJI 

Inspire 1 UASs 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 2 and DJI Inspire 1 

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. 
14

By using the DJI Phantom 2 and DJI Inspire 1 UAS’s 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 and DJI Inspire 1 UAs (weighing approximately 2 pounds 

11 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 2

 and DJI Inspire 1 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 and DJI Inspire 1 UASs are 

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

operations. As such, operation of the DJI Phantom 2 and DJI Inspire 1 UASs will allow 

United States based companies, like DRAGO ENTERTAINMENT Inc., 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 2 and DJI Inspire 1 UASs 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 2 and DJI Inspire 1 UASs, companies such as DRAGO 

ENTERTAINMENT Inc., 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 2 and DJI Inspire 1 UASs, 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, DRAGO ENTERTAINMENT Inc.’s proposed operation of the DJI Phantom 2 

and DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI 

Phantom 2 and DJI Inspire 1 UASs will be operated only in compliance with operating 

documents (i.e., the DRAGO ENTERTAINMENT Inc. Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual) 

which requires 
15

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.
16

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 DRAGO ENTERTAINMENT Inc. Seeks 

Exemption. 

1. Reasons Why The DJI Phantom 2 and DJI Inspire 1 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, DRAGO ENTERTAINMENT Inc.s operation of the 

DJI Phantom 2 and DJI Inspire 1 UAS’s 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

(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,DRAGO ENTERTAINMENT Inc. submits that the DJI 

Phantom 2 and DJI Inspire 1 UASs 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 UASs; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 
17

a. The Specifications Of The DJI Phantom 2 and DJI Inspire 1 UASs

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 and DJI Inspire 1 UASs 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. 

i. Technical Specifications Of The DJI Phantom 2 and DJI Inspire 1 UASs.

The technical specifications of the DJI Phantom 2 and DJI Inspire 1 UASs are set forth 

by the DJI Phantom 2 and DJI Inspire 1 Specifications and Data Sheet, attached hereto 

as Exhibit A and B.

ii. The DJI Phantom 2 and DJI Inspire 1 UASs Autonomous Flight And

Navigation Modes Enable The UASs To Remain Within A Defined Operational 

Area. 

The DJI Phantom 2 and DJI Inspire 1 UASs may be operated in both manual and fully 

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

the DJI Phantom 2 and DJI Inspire 1 UASs are provided at pages 23- 41 of the DJI 

Phantom 2; and pages 12-18 and 45-52 of the DJI Inspire 1 User Manuals, attached hereto 

as Exhibit C and D. 

iii. The DJI Phantom 2 and DJI Inspire 1 UASs 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 2 and DJI Inspire 1 UAs will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 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 for the DJI Phantom 2 UAS are set forth 

at pages 32 through 34 of the DJI Phantom 2 User Manual; and for the DJI Inspire 1 at 

pages 13 through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit C and 

D. 

iv. The DJI Phantom 2 and DJI Inspire 1 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 and DJI 

Inspire 1 GCS and flight control software is provided at pages 7 through 17 of the DJI 

Phantom 2 User Manual; and pages 24 through 34 of the DJI Inspire 1 User Manual. DJI 

Phantom 2 and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. 

b. Flight Operations Of DJI Phantom 2 and DJI Inspire 1 UASs Are

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

Observer. 

DRAGO ENTERTAINMENT Inc. will only utilize certificated pilots who possess a 

current and valid 
18

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 

and DJI Inspire 1 UASs. Additionally, a visual observer will assist all pilots during 

flight time. 

c. Flights Of DJI Phantom 2 and DJI Inspire 1 UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, DRAGO ENTERTAINMENT Inc. proposes to 

commercially operate DJI Phantom 2 and DJI Inspire 1 UASs 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 UASs weighing less than 55 

pounds maximum gross weight: DJI Phantom 2 and DJI 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 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 (VO). The VO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The VO 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 VO can perform the functions prescribed in the operating documents. 

8. The VO 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
19

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 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 UASs 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 thirdclass medical certificate.
20

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-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 400 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 predetermined 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. 
21

25. 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.

26. 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.

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

operations and activities at all times.

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

29. Flight operations must be conducted at least 400 feet from all nonparticipating

persons (persons other than the PIC, VO, 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 400 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, VO, operator trainees or essential persons do not present

an undue hazard to those persons per § 91.119(a).

30. 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.

31. 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.

DRAGO ENTERTAINMENT Inc. 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 2 and DJI Inspire 1 UASs unless that PIC has 

demonstrated, by 
22

meeting minimum flight-hour and currency requirements, that the PIC is able to safely 

operate the DJI Phantom 2 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. 

Considering DRAGO ENTERTAINMENT Inc.’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 

Phantom 2 or DJI Inspire 1 UAS, DRAGO ENTERTAINMENT Inc. submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for DRAGO ENTERTAINMENT Inc.’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).

DRAGO ENTERTAINMENT Inc. will not allow any PIC to operate the DJI 

Phantom 2 or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the DJI Phantom 2 or DJI Inspire 1 UAS training and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI 

Inspire 1 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 DRAGO ENTERTAINMENT Inc.’ 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 
23

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.

Exemption No. 11138 at page 15.

Accordingly, DRAGO ENTERTAINMENT Inc. will ensure safe operations by 

not allowing any PIC to operate the DJI Phantom 2 or DJI Inspire 1 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 2 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. 

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, DRAGO ENTERTAINMENT Inc. will ensure that the 

DJI Phantom 2 or DJI Inspire 1 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 91.121 Would

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Phantom 2 and DJI Inspire 1 UAs will be 

provided to the PIC via GPS equipment and a radio communications telemetry data 

link, which downlinks from the UA to the GCS for active monitoring of the flight path 

and altitude. This altitude information, combined with DRAGO ENTERTAINMENT 

Inc.’ operation of the DJI Phantom 2 and DJI Inspire 1 UAs within visual line of sight, 

at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

The altitude information will be generated by GPS equipment installed onboard the 

aircraft. 
24

Prior to each flight, a zero altitude initiation point is automatically established by the 

UASs at ground level. 

The FAA has previously granted relief from Section 91.121 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, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

5. 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 2 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight 

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

DRAGO ENTERTAINMENT Inc. will ensure that it will safely operate the battery 

powered DJI Phantom 2 and DJI Inspire 1 UAs during daylight hours in VFR 

conditions, 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. 

Here, as in Exemption No. 11109, the technical specifications of the DJI 

Phantom 2 and DJI Inspire 1 UASs; 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 2 and DJI Inspire 1 UASs 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 Vision+ and DJI 

Inspire 1 UASs 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). 

6. 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, DRAGO ENTERTAINMENT Inc. submits that the 

equivalent level of safety with regard to the regulatory maintenance and alteration 

requirements established 
25

by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be 

met becauseDRAGO ENTERTAINMENT Inc. will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

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

ENTERTAINMENT Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 and DJI Inspire 1 Instruction Manual). Furthermore, DRAGO 

ENTERTAINMENT Inc. will document and maintain all maintenance records for the 

DJI Phantom 2 and DJI Inspire 1 UASs. 

Since the DJI Phantom 2and DJI Inspire 1 UASs will be inspected as prescribed 

by the operating documents,DRAGO ENTERTAINMENT Inc. 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 2 and DJI Inspire 1 User Manuals are attached hereto as 

Exhibit C and D; a copy of the DJI Phantom 2 and DJI Inspire 1 UAS Maintenance 

LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because 

DRAGO ENTERTAINMENT Inc. 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 2 and DJI Inspire 1 UASs 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 DRAGO ENTERTAINMENT Inc. proposed operating 

limitations, the operating documents, and the technical aspects of the DJI Phantom 2 

and DJI Inspire 1 UAS’s, DRAGO ENTERTAINMENT Inc. 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). 

7. 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, DRAGO 

ENTERTAINMENT Inc. requests that the FAA prescribe special conditions for the 

intended operation of the DJI Phantom 2 and DJI Inspire 1 UASs, which contain such 

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

equivalent to that established 
26

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

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 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 2 and DJI Inspire 1 UASs, 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 2 

and DJI Inspire 1 UASs, 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), 91.121, 91.151(b), 

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

F. A Summary That Can Be Published In The Federal Register, stating: 

The Rules From Which DRAGO ENTERTAINMENT Inc.Seeks Exemption: 

DRAGO ENTERTAINMENT Inc. seeks exemption from the requirements of 14 

C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 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 ExemptionDRAGO 

ENTERTAINMENT Inc. Seeks: 

This exemption will permit DRAGO ENTERTAINMENT Inc. to commercially operate 

an Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States. 
27

Any Additional Information, Views, Or Arguments Available To Support 

DRAGO ENTERTAINMENT Inc.'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, DRAGO ENTERTAINMENT 

Inc.’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. 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. As discussed in 

detail above, DRAGO ENTERTAINMENT Inc. will operate the DJI Phantom 2 and DJI 

Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the 

public, or otherwise pose a threat to national security. 
28

Conclusion

As set forth herein, DRAGO ENTERTAINMENT INC. seeks an exemption pursuant to14 C.F.R. 

11.61 and section 333 of the FAA Modernazation and Reform Act of 2012 (FMRA), which will 

permit the safe operation of the DJI Phantom 2 and the DJI Inspire 1 comercially, without an 

airwrthiness certificate, for the limited purpose of conducting aerial photography and videography 

over certain areas of the United States. By granting this Petition, the FAA Administrator will be 

fulfilling the Congressional mandate of the FAA (FRMA) of 2012 while also advancing the interests 

of the public, by allowing DRAGO ENTERTAINMENT INC. to safely, efficiently and economically 

operate comercially within the United States NAS.

Wherefore, in accordance with the Federal Avaiation Regulations and the FAA Modernization Act of 

2012, Section 333, DRAGO ENTERTAINMENT Inc. respectively requests that the Adminsitrator 

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

91.7(a) 91.121, 91.151(b), 91.405(a), 91.417(a)(1) & (2), and 91.417(a) & (b), and permit DRAGO 

ENTETAINMENT Inc. to operate commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: August 2, 2015

Respectfully sumitted,

DRAGO ENTERTAINMENT INC.

___________________________

Joseph C. Drago

Drago Entertainment Inc.

630 Oldstone Place

Simi Valley, CA 93065

818-419-1940 

Appendices:

A – DJI Phantom 2 Specifications Data Sheet

B – DJI Inspire 1 Specifications Sheet

C – DJI Phantom 2 Manufacturer’s User Manual

D – DJI Inspire 1 Manufacturer’s User Manual

E – Monthly Maintenance Log 
29

APPENDIX – A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS 

DRAGO ENTERTAINMENT Inc. only utilizes safe and reliable UASs. DJI is an 

industry leader in small UAS production. DJI UASs are loaded with ground breaking 

software enabling the user to set parameters which will not allow flight into controlled 

airspace. Parameters can also be set to limit flight to no higher than a predetermined and 

set altitude as well as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices) 

1.1 DJI Phantom 2 

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C)

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

1.1.3.5 HD Video Recording – 1080p30 & 720p

1.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V
30

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W
31

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

DRAGO ENTERTAINMENT Inc. only utilizes safe and reliable UASs. DJI is an 

industry leader in small UAS production. DJI UASs are loaded with ground breaking 

software enabling the user to set parameters which will not allow flight into controlled 

airspace. Parameters can also be set to limit flight to no higher than a predetermined and 

set altitude as well as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices) 

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model – T600

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C)

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s

2.2.3 Camera

2.2.3.1 Name – X3

2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M
32

2.2.3.4 Effective Pixels – 12.4M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording – UHD(4K):

 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60;

 HD: 1280x720p24/25/30/48/50/60

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C)

2.2.4 Transmitter

2.2.4.1 Name – C1

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C)

2.2.4.6 Battery – 600mAh LiPo 2S
33

APPENDIX - C 

DJI PHANTOM 2 Manufacturer’s User Manual 

User manual can be found at:

http://www.dji.com/product/phantom-2-vision/download

APPENDIX - D

DJI Inspire 1 Manufacturer’s User Manual

User manual can be found at:

http://www.dji.com/product/inspire-1/download
34

APPENDIX - E

MONTHLY(MAINTENANCE(LOG

month:'__________''year:''_________

UAS(#:(______________

Date'Issue'

Discovered

Date'Issue'

Addressed

Software'Updates

Airframe

Engines

Propellers

Camera'Gimbal

Landing'Gear

Vibration'Dampening

Other:

Maintenance'Performed'by:''''''''''''''

Print'&'Sign Issue''Description'&'Maintenance'Conducted