U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590 

Subject: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations from 14 C.F.R. Part 21, 45.27(a), 45.29 (3) (c)(d)(e)(f)(g)(h), 61.113 (a) & (b), 91.103, 

91.119, 91.121, 91.203, 91.151

Dear Sir/Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

and 14 C.F.R. Part 11, I, Joseph W. Dinwiddie, would like to apply for an exemption from the following 

Code of Federal Regulations (C.F.R) to allow commercial operation of lightweight Unmanned Aircraft 

Systems (sUAS) for aerial imaging, video, and surveillance. This video and image data will be used for 

survey analysis, safety and/or damage inspection, aerial photography, as well as search and rescue. These 

are services that will be offered and safely executed to various clients or industries with these types of 

needs. The operations of the service(s) will only be carried out with the proper approval from property 

owners and any other agencies requiring approval. Safety will be top priority before, during, and after 

operations of the services. Described herein, along with request for exemption, are details on how my 

operations will be equal to, or safer than use of traditional rotorcraft

Personal Information/Contact information

Joseph W. Dinwiddie

29020 Old Cherry Ln
Lebanon, Missouri 65536

Phone # 417-741-2267

INTRODUCTION AND INTERESTS OF THE PETITIONER

Joseph W. Dinwiddie will provide its clients with expertise and knowledge in advanced technologies and 

solutions to increase efficiency, productivity and effectiveness. Joseph W. Dinwiddie has over 8 years 

recreational/hobby experience in all aspects of aerial video and photography with remote controlled 

helicopters and planes. The objective of Joseph W. Dinwiddie’s aerial video and photography operations 

is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically 

targeting:• Aerial acquisitions used for inspections of public and private structures as well for real estate.• 

Increase public knowledge of UAS and promote safe UAS operations. • Search and Rescue operations.

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3: Joseph W. Dinwiddie seeks an exemption to operate DJI 

systems for compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or 

smart phone systems. The DJI Phantom 3 has a maximum gross weight of approximately 2 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 Phantom 3 is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. The DJI Phantom 3 UAs that will be operated by Joseph W. 
Dinwiddie 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, Joseph W. Dinwiddie, pursuant to the provisions of the Federal Aviation Regulations (14 

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

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

operate the DJI Phantom 3 in the National Airspace System (NAS), and for an exemption from the 6 

Requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91. lSl(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (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 W. Dinwiddie operation of 

DJI Phantom 3 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, Joseph W. 

Dinwiddie requests relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l ) & (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 W. Dinwiddie submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Joseph W. Dinwiddie 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 (DJI Phantom 3). Furthermore, 

Joseph W. Dinwiddie will document and maintain all maintenance records for the DJI Phantom 3. Relief 

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

Pilot in command, is requested by Joseph W. Dinwiddie to the extent necessary to allow that the PIC is 
able to safely operate the DJI Phantom 3 in a manner consistent with this 7 exemption, including evasive 

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

structures. Joseph W. Dinwiddie seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom3 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. As such, Joseph W. Dinwiddie submits that he will ensure that the DJI Phantom 3 

UAS’s 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 3 Instruction 

Manual), and that the aircraft are in a condition for safe flight. Joseph W. Dinwiddie also seeks an 

exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3

will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3

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 W. Dinwiddie operation of the DJI Phantom 3 UASs 

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

91.121. Additionally, Joseph W. Dinwiddie seeks an exemption from the requirements of Section 

91.15l(b), entitled Fuel requirements for flight in VFR conditions. Joseph W. Dinwiddie submits that 

safety will not be affected by operation of the DJI Phantom 3 UAS’ during daylight hours in visual 

meteorological conditions (VMC) 8 under visual flight rules (VFR), with enough battery power to fly for 

a total duration of approximately 20 minutes to the first point of intended landing and, assuming normal 

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

I request exemption for the purpose of Aerial Photography business.As a hobbyist flying for 8 plus years 

and always maintaining safe practices, line of sight flying, and proper maintenance and repair checklists. 
All photography I do is LOS, and performed less than 400' AGL. The aircraft I use have GPS guidance, 

and "return to home" safety feature installed and standard on DJI Phantom 3. My primary business use 

would be real estate photography, home inspections, and general photography in nature, personal and 

private events. The use of my UAV is less costly than other means of aerial photography. My flights will 

consist of using the DJI Phantom quad copter.

This is my request for exemption.

Very Respectfully 

Joseph W. Dinwiddie