Will Cooper

3703 Inglewood Blvd

Apt. 204

Los Angeles, CA 90066

Tel. 727­403­8505

willcooper.com

U.S. Department of Transportation May 26, 2015

Docket Management System

1200 New Jersey Ave S.E.

Washington, D.C. 20590

Re: Request for Exemption under Section 333 of the FAA Modernization and Reform Act of 2012

and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R.

Richter Studios

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform

Act) and 14 C.F.R. Part 11, Antonelli Law files this petition for exemption on behalf of Richter

Studios (“Richter”), an operator of Small Unmanned Aircraft Systems (“UAs”) for aerial

cinematography. Specifically, petitioner seeks an exemption from the Federal Aviation

Regulations (“FARs”) listed in Appendices A and B to allow commercial operation of its UAs, so

long as such operations are conducted within and under the conditions outlined herein or as may

be established by the FAA in a grant of this petition. This request is substantially similar to other

data collection petitions previously approved, and should be considered under the expedited

summary grant procedure.

Approval of the exemption for petitioner will allow commercial operation of the DJI

Inspire 1 in Class G airspace nationwide unless otherwise prescribed by an Air Traffic

Organization (ATO) issued COA. This UA has been previously approved for commercial

operations in Exemption Nos. 11204, 11224, 11254, 11279, 11280, 11288, 11295, 11301, 11303,

11313, 11314, 11318, 11323, 11327, 11336, 11342, 11359, 11377, 11384, 11385, and 11394. The

UA covered by this petition is a small battery­powered craft, weighing approximately 6.5 lbs.,

inclusive of battery and payload. Operation of the UA under the strict conditions proposed below

will provide an equivalent level of safety, as Congress intended, while still allowing commercial

operations. Operations using these UAs are far safer than conventional operations conducted with

helicopters and fixed­wing aircraft that weigh thousands of pounds, carry highly flammable fuel,

and operate in close proximity to the ground, trees, infrastructure, and people.

Congress directed the FAA to consider seven factors in deciding whether to approve

Section 333 exemption petitions ­ size, weight, speed, operational capability, proximity to airports,

proximity to populated areas, and operation within visual line of sight. In this case, each factor

supports the exemption request. In particular, the UA is small, and will operate at slow speeds and

close to the ground. It will be able to more safely and efficiently conduct operations that would otherwise involve

involve risk of injury or death. The substantial increase of safety and decrease of risk to human life and property

weighs heavily in favor of granting the exemption.
For your ease in reviewing this petition, please refer to the table of contents which begins on page 3. If we can

provide any additional information to assist your understanding or review of this document, please don not hesitate to

contact us at 727­403­8595 or via email at info@willcooper.com

Thank you,

Will Cooper

Photographer * Cinematographer

Of Counsel

Will Cooper

Sport Pilot

Type Rated in:

Diamond DA­20

Third Class Medical Certificate
Table of Contents

I. Publishable Summary...................................................................................................................... 5

II. Petitioner’s Contact Information.................................................................................................... 5

III. Proposed Operations ........................................................................................................................ 6

A. The UAs ......................................................................................................................... 6

B. The Crew ........................................................................................................................ 6

C. Flight Conditions............................................................................................................ 7

D. Flight Operations............................................................................................................ 7

IV. Aircraft and Equivalent Level of Safety ....................................................................................... 8

VI. Proposed Conditions of the Exemption......................................................................................... 8

VI. Privacy ............................................................................................................................................. 12

VII. Public Interest and Safety................................................................................................................ 12

VIII. Regulations from Which Exemption is Requested.............................................................. 13

Appendix A: FARs as to which Richter wishes the same determination to be made as has

been made previously............................................................................................................ 13

Appendix B: Richter’s argument for exemption from 14 CFR §§ 61.23(a) and (c),

61.101(e)(4) and (5), 61.113(a), 61.315(a)............................................................................ 18

1. The FAA and foreign regulators recognize that obtaining a manned aircraft pilot

license is unnecessary for safe operation of a UA...................................................... 18

2. The FAA does have, and has already, exercised the authority to exempt petitioners

from the airman certificate requirement ..................................................................... 20
Exhibit List

Exhibit 1: Phantom 3 Quick Start Guide ...................Submitted separately due to upload constraints

Exhibit 2: Phantom 3 User Manual............................Submitted separately due to upload constraints

Exhibit 3: Safety Guidelines ......................................................................................................... 21

Exhibit 4: Disclaimer and Warning .............................................................................................. 31

Exhibit 5: Intelligent Flight Battery Safety Guidelines ................................................................ 50

Exhibit 6: Phantom 3 Maintenance Manual..................................................................................... 54

Exhibit 7: Phantom 3........................................................................................................................ 56

Exhibit 8: Phantom 3 Features ......................................................................................................... 64

Exhibit 9: Phantom 3 Specifications................................................................................................ 78
I. Publishable Summary

Pursuant to 14 C.F.R. §11, the following summary is provided for publication in the

Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules:

14 C.F.R 21(h); 14 C.F.R. 43.7; 14 C.F.R. 43.11; 14 C.F.R. 45.11; 14 C.F.R. 45.27; 14

C.F.R. 45.29; 14 C.F.R. 61.23(a) and (c); 14 C.F.R. 61.101(e)(4) and (5); 14 C.F.R.

61.113(a); 14 C.F.R. 61.315(a); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b)(2); 14 C.F.R.

91.9(c); 14 C.F.R. 91.103(b)(2); 14 C.F.R. 91.105; 14 C.F.R. 91.109; 14 C.F.R.

91.113(b); 14 C.F.R. 91.119 (c); 14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 14 C.F.R.

91.203(a) and (b); 14 C.F.R. 91.215; 14 C.F.R. 91.403; 14 C.F.R. 91.405(a); 14 C.F.R.

91.407(a)(1); 14 C.F.R. 409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b) to operate

commercially small unmanned aircraft systems (UAs) (6.5 lbs. or less).

Approval of the exemption requested by petitioner will allow commercial operation of

the DJI Phantom 3 for the purpose of aerial cinematography in Class G airspace

nationwide, unless otherwise prescribed by an ATO­issued COA. The requested

exemption should be granted because operation of a small UA weighing approximately

6.5 lbs. (2.9 kg.), inclusive of battery and payload, conducted in the strict conditions

outlined below, will provide an equivalent level of safety, while still allowing

commercial operations. The lightweight aircraft covered by the exemption are far safer

than conventional operations conducted with helicopters and fixed­wing aircraft

weighing thousands of pounds and carrying highly flammable fuel, and operating in

close proximity to the ground and people. The seven factors Congress directed the FAA

to consider when approving Section 333 exemption petitions ­ size, weight, speed,

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

operation within visual line of sight – each support the request. In particular, the aircraft

are small, and will operate at slow speeds, and close to the ground. The substantial

increase of safety and decrease of risk to human life, coupled with the low risk use of

UAs to conduct these operations, weigh heavily in favor of granting the exemption.

II. Petitioner's Contact Information

Will Cooper

CEO

Whiskey Charlie Aerials

3703 Inglewood Blvd

Los Angeles, CA 90066

Tel: 312­201­8310

Email: info@willcooper.com
III. Proposed Operations

A. The UAs

The requested exemption will permit petitioner to operate the DJI Phantom 3 (Professional). The Phantom 3

(Professional)

has been previously approved for commercial operation in Exemption Nos. 11204, 11224, 11254,

11279, 11280, 11288, 11295, 11301, 11303, 11313, 11314, 11318, 11323, 11327, 11336, 11342,

11359, 11377, 11384, 11385, and 11394.

This petition, along with Exhibits 1­9 which include the supporting documentation of the

UA, are hereinafter referred to as the “operating documents.” The specific conditions of the

proposed exemption that relate to the characteristics of the UAs are numbers 1, 5, and 16­20 in

Section VI below. Each has been adopted or imposed by the FAA in numerous previous grants of

Section 333 exemption petitions. The Inspire 1 has the ability to hover and move in the vertical

and horizontal planes simultaneously.

The Phantom 3 has the following specifications or equivalent:

Airframe: DJI Phantom 3 ­ Professional

Control system: internal to the Phantom 3. This includes the main controller (MC), which receives

the battery voltage, capacity, and current, the internal measurement unit (IMU), which receives

telemetry data, compass, and GPS.

Maximum speed: 43 knots

Weight, inclusive of battery and technical payload: 6.5 lbs. (2.9 kg.)

Transmitter (Tx): DJI Phantom Remote Control

Receiver (Rx): internal to the control system

Motors: DJI 3510

Propellers: 13” x 4

Combined data and video link: HD Lightbridge

Gimbal: Zenmuse X3

Batteries: Lithium Polymer 6S High voltage battery with 4500­5700 mAh capacity

Telemetry display: DJI GO App

Automatic return to home procedure: If Tx signal is lost for more than three seconds and the UA

is under 65 ft. (20 m.) AGL, the UA will rise to 65 ft. AGL, travel horizontally to the predesignated

home spot, hover for 15 seconds, then land. If the UA is above 65 ft. AGL, travel

horizontally to the pre­designated home spot, hover for 15 seconds, then land.

B. The Crew

The crew will consist of a pilot in command (PIC) and a visual observer (VO). The PIC

and VO will have been trained in operation of UAs generally and received up­to­date information

on the UA to be operated pursuant to this grant. The PIC will receive Inspire­specific training to

ensure proficiency on the platform.

The specific conditions of the proposed exemption that relate to the training and

characteristics of the crew are numbers 3 and 6­9 in Section V below. Each has been adopted or

imposed by the FAA in numerous previous grants of Section 333 exemption petitions.
C. Flight Conditions

The UA will be used for aerial cinematography in Class G airspace (unless otherwise

prescribed by an ATO­issued COA) under 200 feet above ground level (“AGL”) and under

controlled conditions over restricted property. Petitioner will work with the local FSDO when

planning operations. Petitioner will only operate its UA in visual meteorological conditions

(VMC). The UA will at all times be no less than 500 feet below and no less than 2,000 feet

horizontally from a cloud, and petitioner will not conduct operations unless visibility is at least 3

statute miles from the PIC. The flight crew will always make a safety assessment of the risk of

every operation, and will only operate when it is determined that no hazards are present.

Additionally, petitioner will follow DJI’s guidelines for flight conditions. These are found

in Exhibit 2, beginning on page 45 of that document.

The specific conditions of the proposed exemption that relate to the flight conditions in

which the UA will be operated are numbers 2, 4, 16, and 28­29 in Section V below. Each has been

adopted or imposed by the FAA in numerous previous grants of Section 333 exemption petitions.

D. Flight Operations

The purpose of the UA flights for which exemption is requested will be for aerial

cinematography. Every UA flight will use at minimum a two person flight crew: a PIC and a VO.

Petitioner will limit flights to 200 ft. AGL, and requests the FAA to allow it to operate no

closer than 175 ft. from nonparticipating individuals when operating at or below 65 ft. AGL.

Petitioner will be able to maintain the safety of nonparticipants while decreasing the nonparticipant

parameter, by applying the same ratio the FAA has previously determined to be safe.

Petitioner anticipates that every flight, even one that is planned to be at 30 ft. AGL, may

rise to 65 ft. AGL if the automatic return­to­home program is activated.

Petitioner has selected the 175 ft. “nonparticipant parameter” by looking at the FAA’s

“safety ratio” for previous Section 333 approvals. Under the new “blanket 200 ft. COA” procedure,

an approved operator may operate their UA up to 200 ft. AGL while keeping nonparticipants 500

ft. away from operations, giving the following ratio:

Nonparticipant parameter

Maximum height AGL = Safety Ratio

By multiplying the maximum height AGL of an operation by 2.5, petitioner will maintain

this same “safety ratio” previously approved by the FAA. For example, if an operation will have

a maximum AGL of 100 ft., petitioner will require nonparticipants to remain at least 250 ft. from

the operational area.
For operations that will take place at or below 65 ft. AGL, application of the “safety ratio” would require

nonparticipants to remain at least 162.5 ft. from the operational area. In an

abundance of caution, petitioner will increase this distance an additional 12.5 ft. to maintain a 175

ft. perimeter from the operational area. Regardless of this minimum, petitioner will require a

greater perimeter should it determine one is necessary for a given operation.

Before conducting an operation, the flight crew will examine the operational area to

identify at least two potential safe emergency landing areas, should nonparticipating individuals

enter into the flight area.

Additionally, petitioner will follow DJI’s guidelines for flight operations, including DJI’s

preflight checklist. Please refer to the following exhibits:

Exhibit 2 beginning on page 49 of that document

Exhibit 3

Petitioner will follow DJI’s maintenance guidelines found in Exhibit 6. Only individuals

who have experience and training on the Phantom 3 system will be approved to conduct inspection

and maintenance. If it is determined that the UA requires more specific maintenance than can be

conducted in­house, petitioner will send the UA to the manufacturer or manufacturer­certified

repair center to be repaired.

The specific conditions of the proposed exemption that relate to flight operations are

numbers 11­12, 17­25, and 32­35 in Section V below. Each has been accepted or imposed by the

FAA in numerous previous grants of Section 333 exemption petitions.

IV. Aircraft and Equivalent Level of Safety

Petitioner proposes that the exemption apply to UAs that have the characteristics and that

operate with the limitations proposed herein. These limitations provide for a level of safety at least

equivalent to or higher than manned aircraft operations under the current regulatory structure.

Section V below identifies the limitations and conditions to which petitioner agrees to be bound

when conducting commercial operations under a grant of this petition. Appendix A contains a

matrix connecting (i) the specific proposed condition with (ii) the FAR provision for which it

provides equivalent level of safety and (iii) one or more recent Section 333 exemption grants in

which the FAA recognized this equivalent level of safety.

Approval of the commercial operations outlined in this petition presents no national security

issue. Petitioner is willing to require its PICs to undergo a background check, including the

proposed Transportation Security Administration Vetting process, to ensure that no national

security threat is present. Operation and Certification of Small Unmanned Aircraft, 80 Fed. Reg.

9543 at 9572 (proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45, et al.).

V. Proposed Conditions of the Exemption

1. The UAs, including battery and technical payload will weigh no more than approximately 2.8

lbs. (1.2 kg.).

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

of utility and infrastructure inspections in Class G airspace nationwide, unless otherwise

prescribed by an ATO issued COA.
3. Flights will be operated within line of sight of a PIC and VO.

4. Flights will be operated at an altitude of no more than 200 feet AGL, as indicated by the

procedures specified in the operating documents. All altitudes reported to ATC must be in feet

AGL.

5. The UA will not be flown at an indicated airspeed exceeding 43 knots.

6. Minimum flight crew for each operation will consist of the UA PIC and a VO.

7. The PIC will have completed UA­specific training provided by the manufacturer prior to

commercial operations.

8. The petitioner will not permit any PIC to operate unless the PIC meets its qualification criteria

and demonstrates the ability to safely operate the UA in a manner consistent with how the UA

will be operated under this exemption, including evasive and emergency maneuvers and

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours and currency will be logged in a manner consistent with 14 CFR

§61.51(b). A record of the PIC training will be documented and made available upon request

by the Administrator. Training operations will only be conducted during dedicated training

sessions. During training, proficiency, and experience­building flights, all persons not essential

for flight operations will be considered nonparticipants, and the PIC will operate the UA with

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

9. The VO will not perform any other duties beyond assisting the PIC with seeing and avoiding

other air traffic and other ground based obstacles/obstructions, and will not be permitted to

operate the camera or other instruments.

10. The PIC will be designated before the flight and will not be allowed to transfer his or her

designation for the duration of the flight. The PIC will ensure that the VO can perform the

functions prescribed in these conditions and the operating documents.

11. A briefing will be conducted in regard to the planned UA operations prior to each day’s

activities. It will be mandatory that all personnel who will be performing duties in connection

with the operations be present for this briefing.

12. Prior to each flight, the PIC will inspect the UA, including the Ground Control Station, to

ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UA, the PIC will not operate the UA until the necessary maintenance has

been performed and the UA is found to be in a condition for safe flight. All maintenance and

alterations will be properly documented in the aircraft records.

13. Petitioner will conduct a functional flight test on any UA that has undergone maintenance or

alterations that affect the UA operation or flight characteristics, e.g. replacement of a flight

critical component. The PIC who conducts the functional test flight will make an entry in the

aircraft records.

14. The petitioner will carry out its maintenance, inspections, and record keeping requirements, in

accordance with the UA manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements set forth in the operating documents.

Maintenance, inspection, alterations, and status of replacement/overhaul component parts will
be noted in the aircraft records, including total time in service, description of work

accomplished, and the signature of the authorized person returning the UA to service. The

authorized person will make an entry in the aircraft record of the corrective action taken against

discrepancies discovered between inspections.

15. The UA will be operated within visual line of sight (VLOS) of the PIC and VO at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses. PIC and VO will at all times be able to communicate verbally. They will not

be permitted to use electronic messaging or texting to communicate during flight operations.

16. The PIC will not begin 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 prepare to

land with at least 25% battery power remaining.

17. Actual total flight time for each operational flight will result in no less than a 25% battery

reserve.

18. The UA will have the capability to abort a flight in case of unexpected obstacles or

emergencies.

19. The UA will be programmed so that if it loses communications or loses its GPS signal, it will

return to a pre­determined location within the planned operating area and land or be recovered

in accordance with the operating documents

20. If the UA and its radio control link disconnect during flight, the system’s failsafe protection

will be triggered and the multirotor will return to home and land automatically, rather than

flying off uncontrollably or landing at an unknown location.

21. The operating documents required under 14 CFR §§ 91.9 and 91.203 will be maintained and

available to the PIC at the Ground Control Station of the UA any time the UA is operating.

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

upon request. If a discrepancy exists between the conditions and limitations in the exemption

grant and the procedures outlined in the operating documents, the grant conditions and

limitations will take precedence and will be followed. Otherwise, the petitioner will follow the

procedures outlined in its operating documents. If it updates or revises its operating documents,

it will present updated and revised documents to the Administrator upon request. If the

petitioner determines that any update or revision would affect the basis upon which the FAA

granted the exemption, then the Petitioner will petition for an amendment to the grant of

exemption.

22. Petitioner will obtain written and/or oral permission from the landowners/authorized agents of

the landowners over which flights will be conducted.

23. Petitioner will obtain all required permissions and permits from territorial, state, county or city

jurisdictions, including local law enforcement, fire, or other appropriate governmental

agencies.

24. UA operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations

will be conducted under visual meteorological conditions (VMC). Flights will not be

conducted under special visual flight rules (SVFR).
25. The petitioner will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or

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

Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but

not less than 24 hours prior to the operation. All operations will be conducted in accordance

with airspace requirements in the ATO issued COA, including class of airspace, and altitude

level.

26. The UA will not be operated within 5 nautical miles of tower­controlled airport reference point

as denoted on a current FAA­published aeronautical chart unless a letter of agreement with

that airport’s management has been obtained, and the operation is conducted in accordance

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

management will be made available to the Administrator upon request.

27. The UA will 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.

28. All operations shall be conducted in Class G airspace or as otherwise prescribed in an ATO

issued COA.

29. All aircraft operated in accordance with this exemption will be identified by serial number,

registered in accordance with 14 CFR part 47, and have identification (N­Number) markings

in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

30. Before conducting operations, petitioner will ensure that the radio frequency spectrum used

for operation and control of the UA complies with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

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

activities at all times.

32. The UA will not be operated by the PIC from any moving device or vehicle.

33. Petitioner will conduct all flight operations at least 175 feet from all nonparticipating persons,

vessels, vehicles, and structures unless one of the following three conditions is met:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the

UA and/or debris in the event of an accident. The petitioner will ensure that

nonparticipating persons remain under such protection. If a situation arises where

nonparticipating persons leave such protection and are within 175 feet of the UA, the PIC

will ensure that flight operations cease immediately.

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.

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).
34. Petitioner will report any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA to the FAA's UAS

Integration Office (AFS­80) within 24 hours. Petitioner will report accidents to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site:

www.ntsb.gov.

VI. Privacy

There is little concern that the proposed flights will cause invasions of privacy. All flights

will occur over either (a) public rights of way where there is no expectation of privacy; or (b) over

private property with permission of the landowner/authorized agent and consent of participating

individuals.

If data collected is made available for public view, all images containing uninvolved

persons will be blurred or blacked­out. No attempt will be made to identify any individuals filmed

during the flights except in cases where they are trespassing upon or damaging customer property,

or interfering with the petitioner’s or its customers’ operations.

VII. Public Interest and Safety

The planned UA use will increase ground safety for aerial cinematography operations. This

type of data collection has previously been done by manned aircraft or by individuals on the

ground. Both are more time consuming and are more expensive than using a UA. Use of manned

aircraft poses enhanced risk to the pilot and onboard crew, who would be several hundred feet in

the air. Additionally, manned aircraft carry highly flammable fuel.

The enhanced safety and reduced environmental impact achieved using a UA and carrying

no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying

crew in addition to flammable fuel, gives the FAA good cause to find that the UA operation

enabled by this exemption is in the public interest.

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012 – size,

weight, speed, operating capabilities, proximity to airports and populated areas and operation

within visual line of sight and national security – provide more than adequate justification for the

grant of the requested exemption allowing commercial operation of petitioner’s UA in the utility

and infrastructure inspection industries, pursuant to Whiskey Charlie's rules of operation.

The FAA has previously approved the Inspire 1 for similar commercial operations in the following Exemptions:

11279 (aerial photography);

11288 (aerial photography);

11313 (aerial cinematography and photography); 11359 (photography);

11336 (aerial photography);

11377 (aerial videography and cinematography); and 11385 (aerial videography and cinematography).
VIII. Regulations from Which Exemption is Requested

Appendix A: FARs as to which Richter wishes the same determination to be made as has been made

previously.


Appendix B: Richter’s argument for exemption from 14 CFR §§ 61.23(a) and (c),

61.101(e)(4) and (5), 61.113(a), 61.315(a).

Richter requests an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5),

61.113(a), 61.315(a), so that the PIC of the UA will not be required to possess any pilot license

(sports, recreational, private or commercial). As the FAA and numerous other national airspace

regulators have recognized, UA operations conducted by persons who do not hold a pilot’s license

can still achieve the equivalent level of safety of current operations by manned aircraft with pilots

holding any level of pilot’s license.

Although it recognizes that a pilot’s license is unnecessary for safe UA operation, the FAA

has to date declined to allow grant exemptions under Section 333 that would permit individuals

who possess any pilot license (sports, recreational, private or commercial) to conduct commercial

UA operations. It has specified two reasons for declining to do so. First, it has stated that it does

not possess the authority under Section 333 to exempt individuals from the requirement under 49

U.S.C. §44711 to hold an airman certificate authorizing the airman to serve in the capacity for

which the certificate was issued. Exemption No. 11110 at 14. Second, the FAA has concluded that

the Department of Homeland Security (DHS) security screening required of all certified airmen

meets the statutory requirement in Section 333 that operations not pose a threat to national security.

Exemption No. 11110 at 15.

Richter respectfully requests that the FAA reconsider its position. There is no dispute that

it is unnecessary for an operator of a UA to go through the rigorous process of becoming a certified

pilot in order to safely operate a UA. In addition, the FAA does have the authority to exempt UA

operators from the requirement in 49 U.S.C. §44711to hold an airman certificate for “serv[ing] in

the capacity for which the certificate was issued.” Indeed, it has exercised that authority repeatedly

in the Section 333 process. Finally, the FAA’s security concerns can be addressed by a variety of

methods involving operator background checks to be conducted by government agencies.

1. The FAA and foreign regulators recognize that obtaining a manned aircraft

pilot license is unnecessary for safe operation of a UA.

The FAA, like the other national airspace regulators that have considered the issue, has

concluded that UA operations conducted by persons who do not hold a pilot’s license can still

achieve the equivalent level of safety of current operations by manned aircraft with pilots holding

any level of pilot’s license. In its recent UAS NPRM, the FAA stated:

“While these airman certification requirements are necessary for manned aircraft

operations, they impose an unnecessary burden for many small UAS operations.

This is because a person typically obtains a private or commercial pilot certificate

by learning how to operate a manned aircraft. Much of that knowledge would not

be applicable to small UAS operations because a small UAS is operated differently

than manned aircraft. In addition, the knowledge currently necessary to obtain a

private or commercial pilot certificate would not equip the certificate holder with

the tools necessary to safely operate a small UAS... Thus, requiring persons

wishing to operate a small UAS to obtain a private or commercial pilot certificate

imposes the cost of certification on those persons, but does not result in a significant

safety benefit because the process of obtaining the certificate does not equip those

persons with the tools necessary to mitigate the public risk posed by small UAS

operations.” Operation and Certification of Small Unmanned Aircraft, 80 Fed. Reg.
9543 at 9550 (proposed Feb. 23, 2015 (to be codified at 14 C.F.R. Parts 21, 43, 45,

et al.).

The FAA’s conclusion that manned aircraft flying experience is unnecessary for the

operation of a UA is supported by research by the FAA and the Army Research Laboratory. They

demonstrate that UAs, even those much larger than the UAs proposed by petitioner, can be safely

flown by non­certificated pilots with a small amount of training. For example, one Army Research

Laboratory study concluded:

"[T]he specific motor skills needed to control the radio­controlled UAV would have

to be learned by aviators independently of the motor skills learned in flying an

aircraft. In particular, the somatic and visual cues that pilots use during aircraft

landings would not be useful (and perhaps even counterproductive) for the

different skill sets and perceptual viewpoint necessary for radio­controlled

landings.”

Additional research reports lend further support for the exclusion requested. For example,

a report sponsored by the FAA concluded that "We know that certain systems, like the U.S. Army

Hunter and Shadow systems, are successfully flown by pilots with no manned aircraft

experience."2

In addition, foreign government airspace regulators that have examined the issue have

consistently recognized that the skills required to fly a manned aircraft are irrelevant to operating

a UA. For that reason, they have concluded that UA operators do not need to have a private or

commercial pilot’s license. Canada, for example, does not require a pilot’s license to operate a

UA. Transport Canada requires training of UA operators, but that training is limited to pilot ground

school and flight operation training on UAs, not manned aircraft.3 Moreover, Canada allows this

training to be “provided by other pilots, manufacturers, [UA] flight training organizations or . . .

self taught.” 4

_________________________

1 Michael J. Barnes, Beverly G. Knapp, Barry W. Tillman, Brett A. Walters & Darlene Veliki,

Crew systems analysis of unmanned aerial vehicle (UAV) future job and tasking environments,

Technical Report ARL­TR­2081, Aberdeen Proving Ground, MD: Army Research Laboratory,

page 12 (2000), available at http://www.dtic.mil/dtic/tr/fulltext/u2/a374230.pdf.

2 Kevin W. Williams, Unmanned Aircraft Pilot Medical Certification Requirements, Report

DOT/FAA/AM­07/3, FAA Civil Aerospace Medical Institute, page 2, (2007), available at

http://fas.org/irp/program/collect/ua­pilot.pdf. While the authors speculated that UA use in

populated areas may change this assessment, indicating further research was needed to address

this concern, this concern is inapplicable as petitioner’s flights will not be in congested areas. See

also Jason S. McCarley & Christopher D. Wickens, Human Factors Implications of UAVs in the

National Airspace, Institute of Aviation, Aviation Human Factors Division, University of Illinois

at Urbana­Champaign, 13 (2004), available at

http://www.tc.faa.gov/logistics/grants/pdf/2004/04­G­032.pdf.

3 See Civil Aviation, Standards, Transport Canada, Advisory Circular: Guidance Material for

Operating Unmanned Air Vehicle Systems under an Exemption at 14 and 18­22, (Nov. 27, 2014)

available at http://www.tc.gc.ca/media/documents/ca­opssvs/ac­600­004.pdf.

4 Id. at 14.
Similarly, the United Kingdom’s Civil Aviation Authority (CAA) recognized that

determining “Remote Pilot qualification requirements on the same basis as manned aircraft may

yield requirements that are too inflexible, too onerous and inappropriate for UAS operations.”5 As

a result, the CAA only requires UA operators to demonstrate UA operator competence.6 While

there are a variety of ways to demonstrate competence, the most common is to complete a course

that will lead to a ground exam and flight test. Australia, too, requires only passage of a UAspecific

ground school program in lieu of a manned airman certificate.7 Finally, more than a dozen

countries, including Germany, Italy, France, Spain and the Netherlands, have adopted the National

UAS Certificate for Small Unmanned Aircraft (BNUC­S) Standard for UA pilot certification.8

This standard results in a type­specific UA certificate and does not require the operator to have a

pilot’s license. The process involves taking a short ground school course, passing a ground school

test and then passing a practical test on commercial operation of the specific UA per the UA

manufacturer’s operations manual.

All of this experience and evidence indicates that the proposed exemption will provide a

greater level of safety than operations under 14 C.F.R. §61.113. In this instance, the PICs will have

gone through training as described above in Section III B. This training and education is focused

on UAs generally, and in particular on the aircraft to be operated, rather than taking additional

time and risk to train on a manned aircraft, weighing several thousand pounds and carrying highly

flammable fuel.

The FAA has concluded in the NPRM that such UA­specific training is more than

sufficient to provide an equivalent level of safety for UA operations. Sometime in the next 18­24

months, that position will be enshrined in a valid regulation. However, in the meantime, the FAA

claims it lacks the authority to relax the requirement to possess a pilot certificate. As we show in

the next section, that position is both incorrect and contradicted by the FAA’s recent decisions.

2. The FAA does have, and has already, exercised the authority to exempt petitioners

from the airman certificate requirement.

The FAA claims that it lacks authority to exempt UA operators from the requirement of 49

U.S. §44711 to hold an airman certificate authorizing the airman “to serve in the capacity for which

the certificate was issued.” See, e.g., Exemption No. 11110 at 14. This claim is inconsistent with

both (i) the statutory language of that section and Section 333, and (ii) numerous recent FAA

decisions.

The operative part of 49 USC §44711 provides that a “person may not . . . serve in any

capacity as an airman with respect to a civil aircraft, . . . used, or intended for use, in air commerce

— (A) without an airman certificate authorizing the airman to serve in the capacity for which the

_______________

5 Civil Aviation Authority, Safety Regulation Group, Unmanned Aircraft System Operations in

UK Airspace – Guidance, Section 2, Chapter 5, Page 2 (Aug. 10, 2012), available at

https://www.caa.co.uk/docs/33/CAP722.pdf.

6 Civil Aviation Authority, Unmanned Aircraft and Aircraft Systems, available at

http://www.caa.co.uk/default.aspx?catid=1995&pagetype=90.

7 Australian Government Civil Aviation Safety Authority, available at

http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_100374.

8 See EuroUSC International, “Pilot Qualification,” available at http://eurousc.com/services/pilot­qualifications/.
certificate was issued . . . “ If the FAA’s interpretation were correct, this language would require

that any person wishing to operate a UA for commercial operations have an airman certificate

authorizing the person to serve as an airman in commercial operations.

However, in all of its recent grants of Section 333 petitions, the FAA has – without

explicitly acknowledging the fact ­ exempted commercial UA operators from the §44711(A)

requirement that they hold an airman certificate authorizing them “to serve in the capacity for

which the certificate was issued.” It has done so by allowing them to operate UA so long as they

hold a private pilot’s or sport pilot’s authorization, even though such a certificate does not permit

commercial operations. Exemption No. 11062 at 15­18; Exemption No. 11110 at 14­16;

Exemption No. 11191 at 3­5; and Exemption No. 11229 at 3 and 8.

The FAA argues that it cannot exempt petitioners from the requirements of §44711

because, while the specific language of Section 333 grants it limited statutory flexibility relative

to 49 U.S.C. §44704 for the purposes of airworthiness certification, Section 333 does not provide

flexibility relative to §44711 and other sections of Title 49. Exemption No. 11110 at 14. This

argument ignores the plain language of Section 333. The relevant language of Section 333 is:

(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.

The language of Section 333(b) is permissive: it requires that the Secretary “determine, at

a minimum . . . 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).” Nothing in (b) precludes the Secretary

from determining whether or not a pilot’s license is required for operation of a UA identified under

paragraph (b)(1).
Indeed, the FAA has implicitly conceded the point by granting exemptions from the

requirement that commercial UA operators hold a commercial pilot certificate. From an analytical

standpoint, there is no difference between granting an exemption from the commercial pilot’s

license requirement and granting an exemption from the private or sport pilot’s license

requirement. Both are clearly exemptions from a specific statutory requirement in 49 U.S.C.

§44711. If the FAA has the statutory authority under Section 333(b) to do the former, it has the

same authority to do the latter.9

___________

9 The FAA has not specifically identified the statutory provision that underpins its authority to

grant the exemptions from the commercial pilot’s license requirement. Whether the statutory basis

is Section 333 or some other provision makes no difference. If there is a basis for a partial

exemption from in 49 U.S.C. § 44711, that basis also justifies an exemption from the entire

provision.
SAFETY GUIDELINES 

AND DISCLAIMER

PROFESSIONAL ADVANCED

PHANTOM 3 

V1.2 2015.9
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© 2015 DJI. All Rights Reserved. 1

Contents

Safety At a Glance 2

NOTICE 4

Glossary 4

Pre-fight Checklist 4

Disclaimer and Warning 5

FCC Compliance and Advisory 6

IMPORTANT NOTE: FCC Radiation Exposure Statement 6

FCC Class B Information 6

Before You Begin 7

Individual Parts 7

Regarding Genuine and Functional Parts 7

Remote Controller 7

Camera 8

Gimbal 8

Compass 8

Propulsion Systems 9

App 10

Firmware 10

Product Care 12

Storage and Transportation 12

Maintenance and Upkeep 12

Flight Condition Requirements 13

Weather Conditions and Surrounding Environment 13

Interference with Flight Controller, Communications, and Positioning Systems 13

Operating the Aircraft Responsibly 13

Flight Modes, Functions and Warnings 15

Flight Modes 15

Failsafe and Return to Home 15

Low Battery 16

Vision Positioning System 16

Compliance with Regulations & No-Fly Zones 17

Regulations 17

No-Fly Zones 18
2 © 2015 DJI. All Rights Reserved. 

Safety At a Glance

1. Environmental Considerations

• Always fy at locations that are clear of building and other 

obstacles.

•  DO NOT fy above or near large crowds.

• Avoid fying at altitudes above 400 feet (120 m).

• Be very careful when fying 19,600 feet (6,000 m) or more 

above sea level. 

• Fly in moderate weather conditions with temperatures between 

0° to 40° C (32° to 104° F).

2. Pre-fight Checklist

• Ensure the remote controller and aircraft batteries are fully charged.

• Ensure the propellers are in good condition and securely tightened.

• Ensure there is nothing obstructing the motors. 

• Be sure to calibrate the compass at every new fight location or if the app prompts you.

• Check that the camera lens is clean and free of stains.

3. Operation

• Stay away from the rotating propellers and motors.

• Maintain line of sight of your aircraft at all times

• DO NOT perform the Combination Stick Command when the aircraft is in midair. 

• DO NOT answer incoming calls during fight. 

• DO NOT fy under the infuence of alcohols or drugs.

• During the Return-to-Home procedure, you can adjust the altitude to avoid obstacles.

• DO NOT fy closely above refective surfaces such as water or snow, as these terrain may affect 

the performance of the Vision Positioning System.

• In the instance of a Low Battery Warning, land the aircraft at a safe location.

• After landing, frst turn off the Intelligent Flight Battery, then turn off the remote controller.

4. Maintenance and Upkeep

• DO NOT use aged, chipped or broken propellers.

• Recommended storage temperature: between 71° and 82° F (22° and 28° C).

• Refer to the Phantom 3 Intelligent Flight Battery Safety Guidelines for more information about the 

safe use of the battery.

5. Observe Local Laws and Regulations

• DO NOT fy in the No Fly Zones. You can fnd a complete list of these areas at http://fysafe.dji.com/

• The DJI No Fly Zone is not a replacement for local government regulations or good judgment.

•  Avoid fying in areas where rescue teams are actively using the airspace.

The Phantom 3 is 

NOT a toy and is not 

suitable for children 

under the age of 18.

Note that ‘Safety at a Glance’ only 

provides a quick overview of the 

safety tips. Make sure you read 

and understand the remaining 

sections of the Phantom 3 Safety 

Guidelines and Disclaimer. 
© 2015 DJI. All Rights Reserved. 3

Fly in Open Areas Calibrate the Compass Maintain Line of Sight Fly Below 

400 feet (120 m)

Avoid fying over or near obstacles, crowds, high voltage power lines, trees or bodies of water.

DO NOT fy near strong electromagnetic sources such as power lines and base stations as it may affect the onboard 

compass.

≥10m/s

DO NOT use the aircraft in adverse weather conditions such as rain, snow, fog and 

wind speeds exceeding 10 m/s or 22 mph.

Stay away from the rotating 

propellers and motors.

No Fly 

Zone

Learn more at:

http://fysafe.dji.com/no-fy
4 © 2015 DJI. All Rights Reserved. 

NOTICE

All instructions and other collateral documents are subject to change at the sole discretion of SZ DJI 

TECHNOLOGY CO., LTD. For up-to-date product information, visit http://www.dji.com and click on the 

Phantom 3 product page.

Glossary

The following terms are used throughout the product literature to indicate various levels of potential harm 

when operating this product:

 NOTICE: Procedures, which if not properly followed, create a possibility of physical property 

damage AND a little or no possibility of injury.

 CAUTION: Procedures, which if not properly followed, create the probability of physical property 

damage AND a possibility of serious injury.

 WARNING: Procedures, which if not properly followed, create the probability of property damage, 

collateral damage, and serious injury OR create a high probability of superfcial injury.

Read the ENTIRE user manual to become familiar with the features of 

this product before operating. Failure to operate the product correctly 

can result in damage to the product or personal property and cause serious injury.

This is a sophisticated product. It must be operated with caution and common sense and 

requires some basic mechanical ability. Failure to operate this product in a safe and responsible 

manner could result in injury or damage to the product or other property. This product is not 

intended for use by children without direct adult supervision. Do not use with incompatible 

components or alter this product in any way outside of the documents provided by SZ DJI 

TECHNOLOGY CO., LTD. These Safety Guidelines contain instructions for safety, operation and 

maintenance. It is essential to read and follow all of the instructions and warnings in the user 

manual, prior to assembly, setup or use, in order to operate the product correctly and avoid 

damage or serious injury.

Age Recommendation: Not for children under the age of 18. This is not a toy.

Pre-fight Checklist

1) Ensure that you are using only genuine parts and that all parts are in mint condition.

2) Ensure the remote controller, Intelligent Flight Battery, and mobile device are fully charged. 

3) Ensure that there is no foreign object stuck to the camera lens, the micro-SD card has been inserted into 

the camera, and the gimbal can rotate freely before powering it on.

4) Ensure the propellers are securely mounted onto the motors, and the motors can start and function normally.

5) Follow the on-screen instructions to calibrate the compass. 

6) Ensure the app and aircraft's frmware have been upgraded to the latest version. 

7) Ensure that your flight area is outside the No-Fly Zones and flight conditions are suitable for flying the 

aircraft. 

8) Be sure that you are NOT fying under the infuence of alcohol, drugs or any substance that may impair 

your cognitive abilities.

9) Be familiar with the selected fight mode and understand all safety functions and warnings. 

10) Be sure to observe all local regulations, obtain appropriate authorizations, and understand the risks. 

REMEMBER: It is solely your responsibility to comply with all fight regulations.
© 2015 DJI. All Rights Reserved. 5

Disclaimer and Warning

This product is NOT a toy and is not suitable for children under the age of 18. Adults should keep the 

Phantom 3 out of the reach of children and exercise caution when operating this aircraft in the presence of 

children.

This product is a fying camera that offers easy fight when in good working order as set forth below. Visit 

http://www.dji.com for the most current instructions and warnings and http://knowbeforeyoufy.org/ for more 

information about fight safety and compliance.

The information in this document affects your safety and your legal rights and responsibilities. Read 

this entire document carefully to ensure proper configuration before use. Failure to read and follow the 

instructions and warnings in this document may result in product loss, serious injury to you, or damage to 

your aircraft.

By using this product, you hereby signify that you have read this disclaimer carefully and that you 

understand and agree to abide by the terms and conditions herein. You agree that you are solely 

responsible for your own conduct while using this product, and for any consequences thereof. You agree 

to use this product only for purposes that are proper and in accordance with all applicable laws, rules, and 

regulations, including international and domestic airspace regulations, and all terms, precautions, practices, 

policies and guidelines DJI has made and may make available. 

DJI accepts no liability for damage, injury or any legal responsibility incurred directly or indirectly from the 

use of this product. The user shall observe safe and lawful practices including, but not limited to, those set 

forth in these Safety Guidelines.

Data Storage and Usage

When you use our mobile app or our products or other software, data regarding the use and operation of 

the product, such as fight telemetry data (e.g., speed, altitude, battery life, and information about the gimbal 

and camera) and operations records, may be automatically or manually uploaded to and maintained on a 

DJI-designated server. The internal storage device incorporated into the product stores various types of 

data, including fight telemetry data. You may also provide fight telemetry data and other data to us when 

you manually transmit that information from the internal storage device to us. 

The information that is automatically uploaded or manually uploaded to us does not include personal data 

(i.e., your name, address, email, or other information that specifcally identifes you), but personal data, such 

as your user name, may become associated with, used to identify, or tagged to such uploaded information 

when we store it. We separately describe how we use your user name and other personal data on our 

privacy policy at http://www.dji.com/policy. By using the product, the mobile app or other software we 

distribute, or by manually providing data to us, you consent to the following: 

• Our storage of any flight telemetry data and other data uploaded or provided to us, including in 

combination with your user name; 

• Our use of any such data uploaded or provided (including your user name) in connection providing 

support and services to you and to improve our products; 

• Our disclosure of such data uploaded or provided (including your user name) to our agents and/or 

contractors who may use it on our behalf or in connection with their relationship with us; and 

• Our disclosure of such uploaded or provided data (including your user name) as required by law, in a 

matter of public safety or policy, as needed in connection with the transfer of our business assets, or if we 

believe in good faith that sharing the data is necessary to protect our rights or property. 
6 © 2015 DJI. All Rights Reserved. 

FCC Compliance and Advisory

This device complies with part 15 of 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.

Any changes or modifcations not expressly approved by the party responsible for compliance could void 

the user’s authority to operate the equipment.

IMPORTANT NOTE: FCC Radiation Exposure Statement 

This equipment complies with FCC radiation exposure limits set forth for an uncontrolled environment. This 

equipment should be installed and operated with a minimum distance of 20 cm between the radiator and 

your body. This transmitter must not be co-located or operate in conjunction with any other antenna or 

transmitter. 

FCC Class B Information 

This equipment has been tested and found to comply with the limits for a Class B digital device, pursuant 

to part 15 of the FCC Rules. These limits are designed to provide reasonable protection against harmful 

interference in a residential installation. This equipment generates, uses, and can radiate radio frequency 

energy and, if not installed and used in accordance with the instructions, may cause harmful interference 

to radio communications. However, there is no guarantee that interference will not occur in a particular 

location. If this equipment does cause harmful interference to radio or television reception, which can be 

determined by turning the equipment off and on, the user is encouraged to try to correct the interference by 

one or more of the following measures:

Reorient or relocate the receiving antenna;

Increase the separation between the equipment and receiver;

Connect the equipment into an outlet on a circuit different from that to which the receiver is connected;

Consult the dealer or an experienced radio/TV technician for help;

DJI hereby declares that this product is in compliance with the essential requirements and other relevant 

provisions of Directive 1995/5/EC.

DJI reserves the right to update this disclaimer and the Safety Guidelines. Please visit www.dji.com and check your email 

periodically for the latest version. This disclaimer is made in various language versions; in the event of divergence among 

different versions, the English version shall prevail. 
© 2015 DJI. All Rights Reserved. 7

Before You Begin 

The following documents have been produced to help you safely operate and make full use of your 

Phantom 3:

In the Box

Phantom 3 Professional / Advanced Safety Guidelines and Disclaimer

Phantom 3 Professional / Advanced Intelligent Flight Battery Safety Guidelines

Phantom 3 Professional / Advanced Quick Start Guide

Phantom 3 Professional / Advanced User Manual 

Check all of the included parts listed in the Phantom 3 In the Box document and read the Phantom 3 Safety 

Guidelines before fight. Then prepare for your frst fight by using the Phantom 3 Quick Start Guide and 

watching all of the tutorial videos on DJI’s offcial website (http://www.dji.com). If you have questions, refer 

to the Phantom 3 User Manual in the app or on DJI’s offcial website for more comprehensive information. 

Make sure you fully understand the functionality of each individual part, the fight condition requirements, the 

key contingency warning functions/systems, and all government regulations before each fight. If you have 

any questions or problems during the assembly, maintenance or use of this product, please contact DJI or 

a DJI authorized dealer. 

Individual Parts

Regarding Genuine and Functional Parts

To avoid component malfunction, serious injury, and property damage, observe the following rules:

1) Use only genuine DJI parts or parts certified by DJI. Unauthorized parts or parts from non-DJI 

certifed manufacturers may cause system malfunctions and compromise safety.

2) Ensure there are no foreign objects (such as water, oil, soil, sand, etc.) inside of the aircraft or its 

components. 

3) Ensure the aircraft and its components – including but not limited to the remote controller, camera, 

gimbal, compass, propulsion system, and battery – are all in good working order, damage-free, 

and functioning well. Refer to the remaining sections in this document for more details on how to 

ensure the functionality of these components. 

Remote Controller

1) Ensure the remote controller is fully charged before each fight.

2) If the remote controller is powered on and has NOT been used for 5 minutes, it will sound an alert. After 10 

minutes it will automatically power off. Move the sticks or perform some other action to cancel the alert.

3) Adjust the clamp of the mobile device holder to allow a frm grip on your mobile device.

4) Ensure the mobile device holder is frmly in place and does not slip.

5) Ensure the antennas of the remote controller are unfolded and adjusted to the proper position to achieve 

optimal transmission quality.

6) Repair or replace the remote controller if damaged. A damaged remote controller antenna will greatly 
8 © 2015 DJI. All Rights Reserved. 

decrease performance.

7) Linking is required if you wish to replace your remote controller or receiver or add a new remote controller. 

Refer to the User Manual for details.

Camera

To avoid possible serious injury and property damage, observe the following rule:

1) Do NOT block any ventilation holes on the camera as the heat generated may hurt you and damage the 

device. 

1) Check camera settings before use to make sure you can adjust them to ft your needs.

2) Test the camera by shooting a few test images and check that it is operating correctly before shooting 

important pictures or videos. 

3) Do NOT remove the micro-SD card from the camera when it is powered on.

4) Photos or videos cannot be transmitted or copied from the camera if the Intelligent Flight Battery is 

powered off.

5) Be sure to power off the Intelligent Flight Battery correctly, otherwise your camera parameters will NOT 

be saved and any recorded videos may be damaged. NOTE: Regardless of the reason, DJI will not be 

responsible for any failure of an image or video to be recorded or having been recorded in a way that is 

not machine readable.

Gimbal

1) Precision elements in the gimbal may be damaged in a collision or impact, which may cause the gimbal 

to function abnormally.

2) Do NOT apply external force to the gimbal after the gimbal is powered on.

3) Do NOT add any payloads to the gimbal, as this may cause the gimbal to function abnormally or even 

lead to motor damage.

4) Remove the gimbal clamp before powering on the gimbal. Re-install the gimbal clamp to secure the 

gimbal’s position if you are going to store the aircraft for an extended period.

Compass

To avoid possible serious injury and property damage, observe the following rule:

1) Land immediately when severe drifting occurs in fight, i.e., the aircraft does NOT fy in straight lines.

1) Ensure the compass is calibrated before every flight. Failure to calibrate may lead to poor flight 

performance or a crash.

2) Do NOT attempt to calibrate your compass where there is a chance of strong magnetic interference. 
© 2015 DJI. All Rights Reserved. 9

This includes areas where there are massive metal objects, parking structures, steel reinforcements 

underground, or under bridges.

3) Do NOT carry ferromagnetic materials with you during calibration, such as keys or mobile phones.

4) The compass should always be calibrated when moving from indoor spaces to outdoor spaces.

5) If the rear LEDs show a solid red light, compass calibration has failed. Please recalibrate.

6) After successful calibration, the compass may become abnormal when you place the aircraft on the 

ground. This may be because of underground magnetic interference. Move the aircraft to another location 

and try again.

7) When to recalibrate

a) When compass data is abnormal, and the Aircraft Status Indicator is blinking red and yellow.

b) When fying in a new location, or a location that is different from your last fight.

c) When the mechanical structure of the aircraft has changed, i.e. new mounting position of the compass.

d) When severe drifting occurs in fight, i.e. the aircraft does NOT fy in straight lines.

Propulsion Systems

To avoid serious injury to yourself or others, which may be caused by the rotating propellers and 

motors, observe the following rules:

Propellers

1) Do NOT use aged, chipped, or broken propellers.

2) Always power off the aircraft before touching the propellers.

3) Be aware of the sharp edges of the propellers when mounting or removing the propellers. Wear 

gloves or take other protective measures when touching the propellers. 

4) Whenever necessary, use tools (e.g., wrench, screwdriver, pliers, etc.) to remove or install the 

propellers.

5) Ensure the propellers are securely mounted to prevent them from falling off the motors.

6) Do NOT turn on the motors when propellers are mounted and there are other people or animals in 

the immediate vicinity.

Motors

1) Ensure the motors are securely mounted and rotating smoothly.

2) Do NOT attempt to modify the structure of the motors.

3) Do NOT touch or let your hands or body come in contact with the motors after fight as they may 

be hot.

To avoid possible serious injury and property damage, observe the following rules:

1) Do NOT block any of the ventilation holes on the motors.

2) Do NOT block any of the ventilation holes on the frame arm of the aircraft.

Motors

1) Keep the motors free of dust.

2) If a motor is stuck and unable to rotate freely, execute the CSC (Combination Stick Command) to stop the 

motors immediately. 
10 © 2015 DJI. All Rights Reserved. 

Electronic Speed Controllers

1) Ensure the ESCs sound a normal tune when powered on.

App

1) Be sure to fully charge your tablet or mobile device before launching the app. A tablet is recommended 

for a better user experience. 

2) If you are using a phone as your mobile display device, be sure to continue fying safely when the phone 

receives an incoming call. Do NOT accept phone calls during fight.

3) Read all prompted safety tips, warning messages, and disclaimers carefully. Be familiar with the related 

regulations in your area. You are solely responsible for being aware of all relevant regulations and fying in 

a way that is compliant.

a) Read and understand the warning messages before using the Auto-take off and Auto-landing features.

b) Read and understand the warning message and disclaimer before setting the altitude beyond the 

default limit.

c) Read and understand the warning messages and disclaimer before switching between fight modes.

4) Land your aircraft immediately if there is an alert shown on the app.

5) Examine and check all warning messages on the checklist displayed in the app prior to each fight. 

6) Use the in-app simulator to practice your fight skills if you have never operated the aircraft or if you do not 

have suffcient experience to be comfortable operating the aircraft.

7) Beginner Mode is enabled by default when you launch the app for the frst time. The aircraft’s altitude and 

fight distance is restricted when fying in Beginner Mode. We recommend you fy in Beginner Mode to 

perfect your fight skills. Operate the actual aircraft only after you are confdent that you have mastered 

adequate fight skills. 

8) Cache the map data of the area where you intend to fy the aircraft by connecting to the Internet before 

each fight.

Firmware

To avoid serious injury to children and animals, observe the following rule:

1) Keep children and animals at a safe distance during any frmware upgrade, system calibration, and 

parameter setting procedures.

1) For safety, always update the frmware to the latest version when an upgrade notifcation is shown in the 

app.

2) Firmware upgrade notifications will prompt you to proceed with an update immediately or to update 

the frmware within three days. If you choose to ignore the current frmware update, you are required 

to accept the prompted disclaimer. You further understand and agree that the data including but not 

limited to fight telemetry data and user selection records may be uploaded to and maintained on a DJIdesignated server.

3) Be sure to download the frmware package fle from the offcial DJI website. Verify the frmware package 

fle’s integrity before upgrading.

4) Be sure to update the remote controller’s firmware to the latest version after you update the aircraft’s 
© 2015 DJI. All Rights Reserved. 11

frmware.

5) The remote controller may become unlinked from the aircraft after updating. Re-link the remote controller 

and aircraft.

6) Be sure to check all connections and remove the propellers from the motors before performing the 

frmware update.

7) Ensure there is only one frmware package fle stored on your SD card.

8) Only storage devices that are formatted for FAT32 and exFAT fle systems are supported for aircraft and 

remote controller frmware updates.

9) Delete any automatically generated .txt fles on the SD card when updating multiple remote controllers.
12 © 2015 DJI. All Rights Reserved. 

Product Care

Storage and Transportation

To avoid serious injury to children and animals, observe the following rule:

1) Small parts, such as cables and straps, are dangerous if swallowed. Keep all parts out of reach of 

children and animals.

1) Store the Intelligent Flight Battery and remote controller in a cool, dry place away from direct 

sunlight to ensure the built-in LiPo battery does NOT overheat. Recommended storage temperature: 

between 71° and 82° F (22° and 28° C) for storage periods of more than three months. Never store in 

environments outside the temperature range of -20° C to 45° C (-68° to 113° F).

2) Do NOT allow the camera to come into contact with, or become immersed in, water or other liquids. If it 

gets wet, wipe dry with a soft, absorbent cloth. Turning on an aircraft that has fallen into water may cause 

permanent component damage. Do NOT use substances containing alcohol, benzene, thinners or other 

flammable substances to clean or maintain the camera. Do NOT store the camera in humid or dusty 

areas.

3) Do NOT connect this product to any USB interface that is older than version 2.0. Do NOT connect this 

product to any "power USB" or similar devices.

Maintenance and Upkeep

1) Check every part of the aircraft after any crash or violent impact. If you have any problems or questions, 

please contact a DJI authorized dealer.

2) Regularly check the Battery Level Indicators to see the current battery level and overall battery life. When 

the battery life reaches 0%, it can no longer be used.
© 2015 DJI. All Rights Reserved. 13

Flight Condition Requirements

Weather Conditions and Surrounding Environment

The aircraft is designed to operate in good to moderate weather conditions. To avoid collision, serious 

injury and property damage, observe the following rules:

1) Do NOT use the aircraft in severe weather conditions. These include wind speeds exceeding 10 m/s, 

snow, rain, smog, heavy wind, hail, lightning, tornadoes or hurricanes. 

2) Keep the aircraft at least 30 feet (10 meters) away from obstacles, people, animals, buildings, public 

infrastructure, trees, and bodies of water when in fight. Stay even further away from the above 

objects as your altitude increases.

3) Be EXTRA cautious when operating the aircraft indoors.

1) Aircraft and battery performance is subject to environmental factors such as air density and temperature.

a) Be very careful when fying 20,000 feet (6,000 meters) or more above sea level as battery and aircraft 

performance may be reduced.

b) It is not recommend to operate the aircraft store in environments outside the temperature range of 

-20° C to 45° C (-68° to 113° F).

2) Do NOT use the aircraft near accidents, fire, explosions, floods, tsunamis, avalanches, landslides, 

earthquakes, dust, or sandstorms.

Interference with Flight Controller, Communications, and Positioning Systems

1) Fly in open areas. Tall buildings or steel structures may affect the accuracy of the on-board compass and 

block the GPS signal. 

2) Avoid interference between the remote controller and other wireless equipment. Make sure to turn off the 

Wi-Fi on your mobile device.

3) Do NOT fy near areas with magnetic or radio interference. These include but are NOT limited to: high 

voltage lines, large scale power transmission stations or mobile base stations and broadcasting towers. 

Failing to do so may compromise the transmission quality of this product or cause remote controller and 

video transmission errors which may affect flight orientation and location accuracy. The aircraft may 

behave abnormally or go out of control in areas with too much interference.

Operating the Aircraft Responsibly

To avoid serious injury and property damage, observe the following rules:

1) Make sure you are NOT drunk, taking drugs, under the infuence of anesthesia, or suffering from 

dizziness, fatigue, nausea or any other conditions, whether physical or mental, that could impair 

your ability to operate the aircraft safely.
14 © 2015 DJI. All Rights Reserved. 

2) Do NOT perform the Combination Stick Commands when aircraft is in midair, otherwise the motors 

will stop.

3) Upon landing, power off the aircraft frst, then switch off the remote controller.

4) Do NOT drop, launch, fre or otherwise project any dangerous payloads on or at any buildings, 

persons or animals, or which could cause personal injury or property damage.

1) Make sure you have been sufficiently trained and are fully aware of any contingency plans before 

accidents happen.

2) Make sure you have a fight plan and never fy the aircraft recklessly.

3) Respect the privacy of others when using the camera. Make sure you comply with local privacy laws, 

regulations, and moral standards.

4) Do NOT use this product for any reason other than general personal use. Do NOT use it for any illegal or 

inappropriate purpose (such as spying, military operations, or unauthorized investigations).

5) Do NOT use this product to defame, abuse, harass, stalk, threaten or otherwise violate the legal rights (such 

as the right of privacy and publicity) of others.

6) Do NOT trespass into private property of others.
© 2015 DJI. All Rights Reserved. 15

Flight Modes, Functions and Warnings

Flight Modes

To avoid serious injury and property damage, observe the following rule:

1) Do NOT switch from P mode to either A mode or F mode unless you are suffciently familiar with 

the aircraft’s behavior for each fight mode, since disabling GPS may result in being unable to land 

the aircraft safely.

P mode is preferred for most flying scenarios. Users can switch to A mode where and when P mode is 

unavailable. Be aware that some features are NOT available for A mode, and therefore be EXTRA cautious 

when fying in A mode.

1) P mode (Positioning): P mode works best when the GPS signal is strong. There are three different states 

of P mode, which will be automatically selected by the Phantom 3 depending on GPS signal strength and 

Vision Positioning sensors:

a) P-GPS: GPS and Vision Positioning are both available, and the aircraft is using GPS for positioning.

b) P-OPTI: If GPS is NOT available, the aircraft will use the Vision Positioning System to hover accurately. 

Note that the Vision Positioning System may NOT work properly when the Phantom 3 is fying over 

water, over surfaces without a clear pattern, or in a low light environment.

c) P-ATTI: When neither GPS nor Vision Positioning is available, the aircraft is using only its barometer for 

positioning, so only altitude is controlled.

2) A mode (Attitude): The GPS and Vision Positioning System are NOT used for positioning. The aircraft only 

uses its barometer to maintain altitude. If it is still receiving a GPS signal, the aircraft can automatically 

return home if the Remote Controller signal is lost and if the Home Point has been recorded successfully.

3) F mode (Function): Intelligent Orientation Control (IOC) is activated in this mode. Ensure you are familiar 

with IOC functions before use.

If you intend to switch to modes that disable GPS assistance (e.g., A mode), you are required to accept the 

prompted disclaimer to enable this function. If this function is enabled, you further understand and agree 

that data including but not limited to fight telemetry data and function records could be uploaded to and 

maintained on a DJI designated server.

Failsafe and Return to Home

1) The Return to Home feature will NOT work if the GPS signal is insuffcient or if GPS is not active.

2) Press the RTH (Return to Home) Button on the remote controller to bring the aircraft back to the Home 

Point instead of turning off the remote controller. 

3) Tall buildings may adversely affect the Failsafe function. Please adjust the aircraft location, altitude and 

speed while returning home to avoid obstacles.

4) Make sure to always fy the aircraft within the transmission range of the remote controller.

5) Only use the Failsafe and Return to Home functions in case of emergency, as they may be affected by the 

weather, the environment, or any nearby magnetic felds.
16 © 2015 DJI. All Rights Reserved. 

6) The aircraft cannot avoid obstacles during the Failsafe RTH; therefore it is important to set an appropriate 

Failsafe altitude before each fight.

7) When fying indoors, the aircraft cannot perform precision hovering when fying above the surfaces that do 

not have a clear pattern. Refer to the “Vision Positioning System” section for complete indoor fying criteria. 

Low Battery

1) When the Critical Battery Level Warning activates and the aircraft is descending automatically, you may 

push the throttle up to maintain the aircraft's altitude and navigate it to a more appropriate location for 

landing.

2) When battery warnings are triggered, promptly bring the aircraft back to the Home Point or land to avoid 

losing power during fight and causing damage to the aircraft, property, animals, and people.

Vision Positioning System

1) The Vision Positioning System cannot work properly over surfaces that do NOT have pattern variations. 

The effective altitude for the Vision Positioning System to function correctly is less than 8.2 feet (2.5 

meters) above ground level (AGL).

2) The Vision Positioning System may NOT function properly when the aircraft is fying over water.

3) Keep your pets away from the aircraft when the Vision Positioning System is activated, as the sonar 

sensors emit a high frequency sound that is only audible to some pets. 

4) Note that the Vision Positioning System may NOT function properly when the aircraft is fying too fast or too 

low.

5) Operate the aircraft cautiously when in any of the following situations:

a) Flying over monochrome surfaces (e.g., pure black, pure white, pure red, pure green).

b) Flying over highly refective surfaces;

c) Flying at high speeds (over 8m/s at 2 meters or over 4m/s at 1 meter);

d) Flying over water or transparent surfaces;

e) Flying over moving surfaces or objects;

 f) Flying in an area where the lighting changes frequently or drastically;

g) Flying over extremely dark (lux < 10) or bright (lux > 10,000) surfaces;

h) Flying over surfaces that can absorb sound waves (e.g., thick carpet).

 i ) Flying over surfaces without clear patterns or texture;

 j ) Flying over surfaces with identical repeating patterns or textures (e.g. tiles with same design);

k) Flying over inclined surfaces that will defect sound waves away from the aircraft

6) In the event of loss of the remote controller’s signal, the aircraft will hover for 8 seconds and then auto-land 

if it is in “P” mode.
© 2015 DJI. All Rights Reserved. 17

Compliance with Regulations & No-Fly Zones

Regulations 

To avoid non-compliant behavior, serious injury and property damage, observe the following rules:

1) Do NOT operate in the vicinity of manned aircraft, regardless of altitude. (Land immediately if 

necessary)

2) Do NOT fy the aircraft in densely populated areas, including cities, sporting events, exhibitions, 

performances, etc.

3) Do NOT fy the aircraft above the authorized altitude. Remain well clear of and do NOT interfere 

with manned aircraft operations. Be aware of and avoid other aircraft and obstacles at all times.

To avoid non-compliant behavior, serious injury and property damage, observe the following rules:

1) Do NOT fy the aircraft near or inside no-fy zones specifed by local laws and regulations. The no-fy zone 

list includes: airports, borders between two sovereign countries or regions, major cities/regions, etc., and 

is continuously updated. 

2) Do NOT fy the aircraft above the authorized altitude

3) ALWAYS keep your aircraft within visual line of sight (VLOS), and use an observer to assist if needed.

4) NEVER use the aircraft to carry illegal or dangerous goods/payloads.

1) Make sure you understand the nature/type of your fight operation (such as for recreation, for public use, or for 

commercial use) and have obtained corresponding approval and clearance from the related government 

agencies before flight. Consult with your local regulators for comprehensive definitions and specific 

requirements. For users operating their aircraft in the United States, please first visit http://www.

knowbeforeyoufy.org/ and take action appropriate to your circumstances.

2) Please note that remote controlled aircraft may be banned from conducting commercial activities in 

certain countries and regions. Check and follow all local laws and ordinances before fying as those rules 

may differ from those stated here.

3) Do NOT fy around sensitive infrastructure or property such as power stations, water treatment facilities, 

correctional facilities, heavily traveled roadways, government facilities, military zones, etc.

4) Respect the privacy of others when using the camera. Do NOT conduct surveillance operations such 

as image capture or video recording on any person, entity, event, performance, exhibition, and property 

without authorization or where there is an expectation of privacy, even if the image or video is captured for 

personal use.

5) Please be advised that in certain areas, the recording of images and videos from events, performances, 

exhibitions, or commercial properties by means of a camera may contravene copyright or other legal 

rights, even if the image or video was shot for personal use. 
18 © 2015 DJI. All Rights Reserved. 

No-Fly Zones

DJI always stresses safety during fight, and has therefore developed various aids to help users comply with 

local rules and regulations while fying. We strongly recommend that you update the frmware to the latest 

version to ensure the following features are fully updated:

No-Fly Zones

1) No-Fly Zones include but are not limited to major airports around world, borders between two sovereign 

countries or regions, major cities/regions, etc.

2) The complete list of No-Fly Zones is listed on the offcial DJI website at http://fysafe.dji.com/no-fy and is 

subject to periodic updates in line with the latest regulatory requirements without prior notice.

3) Some No-Fly Zones are comprised of several zones. Each zone features circles of various sizes. The 

aircraft will NOT be able to take off in the inner most zone of the No-Fly Zone, and will descend to the 

specifed altitude when it approaches the edge of the inner most zone. Ground station functionality is 

disabled when the aircraft is within a No-Fly Zone. 

4) Users are NOT able to set up waypoints within No-Fly Zones.

Altitude Limit

1) Fly NO higher than 400 feet (120 meters) above ground level and stay away from any surrounding 

obstacles.

If you intend to fy above the default altitude limit, you are required to accept the prompted disclaimer to 

enable the new altitude limit. If a new altitude limit is set, you further understand and agree that data including 

but not limited to fight telemetry data and altitude limit changes could be uploaded to and maintained on a 

DJI-designated server.
© 2015 DJI. All Rights Reserved.

This content is subject to change.

Download the latest version from

www.dji.com/support

If you have any questions about this document, please contact DJI by 

sending a message to DocSupport@dji.com.