UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Maverick Drone Systems

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

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

OPERATION OF BLADE 350QX AP AND DJI INSPIRE 1 UNMANNED 

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on December 1, 2015

Maverick Drone Systems

12931 Eagle Creek Parkway

Savage, MN 55378

Tel: (612) 554-4705
2

TABLE OF CONTENTS

Page 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER.............................................................8

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

SYSTEMS SEEKS EXEMPTION............................................................................ 9

THE EXTENT OF RELIEF MAVERICK DRONE SYSTEMS SEEKS AND THE 

REASON MAVERICK DRONE SYSTEMS SEEKS THE RELIEF................12

THE REASONS WHY GRANTING MAVERICK DRONE SYSTEMS’S 

REQUEST WOULD BE IN THE PUBLIC INTEREST ......................................17

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................20

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......35

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT MAVERICK DRONE SYSTEMS’S REQUEST...36 

CONCLUSION....................................................................................................................36

APPENDICES........................................................................................38
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

SUMMARY
4

MAVERICK DRONE SYSTEMS seeks exemption from the requirements of 14 

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System 

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

exemption will permit MAVERICK DRONE SYSTEMS to operate an Unmanned Aircraft 

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

construction sites, real estate, special events, and landscape over certain areas of the United 

States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

MAVERICK DRONE SYSTEMS provides its clients with expertise and 

knowledge in advanced technologies and solutions to increase efficiency, productivity and 

effectiveness. MAVERICK DRONE SYSTEMS also provides its clients with the highest 

quality digital content for use in their commercial, personal, and non-profit multimedia 

projects. MAVERICK DRONE SYSTEMS has over 15 years of professional experience in 

Information Technology and is recognized as an expert in network infrastructure, computer 

systems, and multimedia content creation. The company has over 11 years of RC model 

aviation including helicopters and fixed wing aircraft in addition to recreational/hobby

experience in aerial video and photography. The objective of MAVERICK DRONE 

SYSTEMS’s aerial video and photography operations is to provide high quality imaging

and editing (under 400 ft) for all purposes of real estate, golf courses, marinas, agriculture, 

search and rescue applications, mapping and thermal imaging, bridge and highway

inspections, construction/engineering projects, and recreational markets in Minnesota and 
5

the surrounding states as well as special events. They also provide sales, service and 

training of drone use for customers.

BACKGROUND

Unmanned Aircraft Systems: Phantom 3 Professional, Inspire 1, DJI s1000, and 

Actiondrone AD1

MAVERICK DRONE SYSTEMS seeks an exemption to operate DJI and 

Actiondrone systems for compensation or hire within the NAS. The Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 are vertical takeoff and landing 

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

electronic tablet or smart phone systems. The Phantom 3 Professional has weighs 35.5 oz, 

and can travel 16 m/s. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 

ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a 

maximum speed of approximately 42 knots. The DJI S1000 weighs 4.2 kg and is 386 mm 

in length. The Actiondrone is 4.8 lbs, is 17.13 inches wide, and has a maximum speed of 

17.9 mph. The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs 

are equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. 

The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs that 

will be operated by MAVERICK DRONE SYSTEMS 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.
6

BASIS FOR PETITION

Petitioner, MAVERICK DRONE SYSTEMS, 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 Phantom 3 Professional; 

Inspire 1; DJI s1000; and Actiondrone AD1 UASs in the National Airspace System (NAS), 

and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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

with the unmanned aircraft and its operation, MAVERICK DRONE SYSTEMS’s 

operation of Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs 

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, MAVERICK DRONE SYSTEMS requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set 

forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. 

MAVERICK DRONE SYSTEMS submits that the requested relief is proper since 

an equivalent level of safety will be ensured. MAVERICK DRONE SYSTEMS will use 

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

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

operating documents (i.e., Monthly Maintenance Log, and all user instruction manuals). 

Furthermore, MAVERICK DRONE SYSTEMS will document and maintain all 
7

maintenance records for the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs.

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

privileges and limitations: Pilot in command, is requested by MAVERICK DRONE 

SYSTEMS to the extent necessary to allow a Pilot in Command (PIC) holding a private 

pilot or higher level certificate, as well as an airman medical certificate, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is 

able to safely operate the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 UASs in a manner consistent with this exemption, including evasive and emergency

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

structures. 

MAVERICK DRONE SYSTEMS seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, MAVERICK DRONE SYSTEMS submits that he will 

ensure that the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1UASs 

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 Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 Instruction Manuals), and that 

the aircraft are in a condition for safe flight. 

MAVERICK DRONE SYSTEMS also seeks an exemption from the requirements 

of Section 91.121, entitled Altimeter Settings, as the Phantom 3 Professional; Inspire 1; DJI 

s1000; and Actiondrone AD1 UAs will not have a typical barometric altimeter onboard. 
8

However, altitude information of the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1UAs 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 

MAVERICK DRONE SYSTEMS’s operation of the Phantom 3 Professional; Inspire 1; 

DJI s1000; and Actiondrone AD1 UASs within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, MAVERICK DRONE SYSTEMS seeks an exemption from the 

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

MAVERICK DRONE SYSTEMS submits that safety will not be affected by operation of 

the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs during 

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), 

with enough battery power to fly for a total duration of approximately 13.5 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, MAVERICK DRONE SYSTEMS provides 

the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

MAVERICK DRONE SYSTEMS

12931 Eagle Creek Parkway

Savage, MN 55378

Tel: (612)554-4705

Email: Tom.shaw@maverickdrone.com
9

B. The Specific Sections Of 14 C.F.R. From Which MAVERICK DRONE SYSTEMS

Seeks Exemption. 

1. MAVERICK DRONE SYSTEMS Seeks Exemption From The 

Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. MAVERICK DRONE SYSTEMS Seeks Exemption From The 

Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. MAVERICK DRONE SYSTEMS Seeks Exemption From The 

Requirements Of Section 91.121. 

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

part: 

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

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

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

within 100 nautical miles of the aircraft; 
10

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. MAVERICK DRONE SYSTEMS Seeks Exemption From The 

Requirements Of Section 91.151(b).

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

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly 

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

fly after that for at least 20 minutes. 

5. MAVERICK DRONE SYSTEMS Seeks Exemption From The Requirement 

Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. MAVERICK DRONE SYSTEMS Seeks Exemption From The 

Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter[.] 

7. MAVERICK DRONE SYSTEMS Seeks Exemption From The 

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 
11

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

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. MAVERICK DRONE SYSTEMS Seeks Exemption From The 

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

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

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

(i) A description (or reference to data acceptable to the Administrator) of 

the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance. 
12

(iii) The time since last overhaul of all items installed on the aircraft which 

are required to be overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief MAVERICK DRONE SYSTEMS Seeks And The Reason 

MAVERICK DRONE SYSTEMS Seeks The Relief. 

1. Extent Of Relief MAVERICK DRONE SYSTEMS Seeks And The Reason 

MAVERICK DRONE SYSTEMS Seeks Relief From Section 61.113(a) And 

(b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a 

private pilot or higher level certificate, as well as a current and valid airman medical 
13

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, MAVERICK DRONE SYSTEMS submits that an 

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

Phantom 3 Professional, Inspire 1, DJI s1000, and Actiondrone AD1 UAS unless that PIC 

has met certain flight-hour and currency requirements, demonstrating that the PIC is able

to safely operate the Phantom 3 Professional, Inspire 1, DJI s1000, and Actiondrone AD1 

UAS in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.

Further, MAVERICK DRONE SYSTEMS submits that all flights of the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to MAVERICK DRONE

SYSTEMS’s business; and (2) will not carry passengers or property for compensation or 

hire. 

2. Extent Of Relief MAVERICK DRONE SYSTEMS Seeks And The Reason 

MAVERICK DRONE SYSTEMS Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow MAVERICK DRONE SYSTEMS to determine that the Phantom 
14

3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs are in airworthy

condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the MAVERICK DRONE SYSTEMS Aerial Operations 

Manual, Monthly Maintenance Log, and Phantom 3 Professional; Inspire 1; DJI s1000; 

and Actiondrone AD1 Instruction Manuals). 

MAVERICK DRONE SYSTEMS seeks the requested relief because the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

MAVERICK DRONE SYSTEMS will ensure that the Phantom 3 Professional; Inspire 1; 

DJI s1000; and Actiondrone AD1 UASs are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 Instruction Manual) prior to 

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

in the conditions and limitations below.

3. Extent Of Relief MAVERICK DRONE SYSTEMS Seeks And The Reason 

MAVERICK DRONE SYSTEMS Seeks Relief From Section 91.121. 

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

flight operations of the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the 

PIC at the ground control station (GCS). Since the FAA requires that any altitude 

information concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), MAVERICK DRONE SYSTEMS seeks the requested relief 

because the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UA’s 
15

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

pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 UAs are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each 

flight, and provides the PIC with altitude information of the UA on the heads-up display of 

the GCS. 

4. Extent Of Relief MAVERICK DRONE SYSTEMS Seeks And The Reason 

MAVERICK DRONE SYSTEMS Seeks Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered 

Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs during daylight 

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 13.5 minutes to the first point of intended landing and, assuming normal 

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

seeks the requested relief because without an exemption from Section 91.151(b), the flight 

time duration of the battery powered Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UAs will severely constrain the practicality of any aerial video or still 

photo flight operations that MAVERICK DRONE SYSTEMS proposes to conduct 

pursuant to this Petition. 
16

Significantly, as set forth below, the technical specifications and operating 

documents of the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs, and MAVERICK DRONE SYSTEMS’s proposed operating limitations, ensure that 

MAVERICK DRONE SYSTEMS will safely operate the battery powered Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), with enough 

battery power to fly for a total duration of 13.5 minutes to the first point of intended 

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

5. Extent Of Relief MAVERICK DRONE SYSTEMS Seeks And The Reason 

MAVERICK DRONE SYSTEMS Seeks Relief From Sections 91.405(a), 

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

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

only apply to aircraft with an airworthiness certificate, MAVERICK DRONE SYSTEMS

requests relief from these Sections because the Phantom 3 Professional; Inspire 1; DJI 

s1000; and Actiondrone AD1 UASs do not require airworthiness certificates. As set forth 

more fully below, the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, MAVERICK DRONE SYSTEMS will use trained technicians to 

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

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

MAVERICK DRONE SYSTEMS Aerial Operations Manual, Monthly Maintenance Log, 

and Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 Instruction 

Manuals). Furthermore, MAVERICK DRONE SYSTEMS will document and maintain all 

maintenance records for the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs.
17

D. The Reasons Why Granting MAVERICK DRONE SYSTEMS’s Request Would 

Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing 

MAVERICK DRONE SYSTEMS to safely, efficiently, and economically perform aerial 

video and photography of construction sites, real estate, special events, film sets, and 

landscape over certain areas of the United States.

Additionally, use of the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of MAVERICK DRONE 

SYSTEMS’s proposed operation of the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs will be realized without implicating any privacy issues. 

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

The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs are 

battery powered and serve as a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned 

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a Phantom 

3 Professional, Inspire 1, DJI s1000, and Actiondrone AD1 UAS would reduce the amount 

of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety

of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs do not require 

an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air 
18

traffic control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

2. The Public Will Benefit From The Safety And Efficiency Of The Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs. 

Conducting aerial acquisitions with the Phantom 3 Professional; Inspire 1; DJI

s1000; and Actiondrone AD1 UASs, instead of manned aircraft, will greatly benefit the 

public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and 

electric motors, the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs produce no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The Phantom 3 Professional; Inspire 1; DJI s1000; 

and Actiondrone AD1 UAs, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAs are propelled by battery powered electric motors, 

rather than an internal combustion engine. 

By using the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs to perform aerial acquisitions, the substantial risk to life and property in the air and 

on the ground, which is usually associated with traditional manned aircraft flight 

operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the Phantom 3 Professional; Inspire 1; 

DJI s1000; and Actiondrone AD1 UAs have less physical potential for collateral damage to 

life and property on the ground, and in the air, compared to the manned aircraft that 
19

typically conduct similar operations (weighing approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs Will Benefit 

The Economy. 

In addition to being safe and efficient, the Phantom 3 Professional; Inspire 1; DJI

s1000; and Actiondrone AD1 UASs are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs will allow United States 

based companies, like MAVERICK DRONE SYSTEMS, to remain competitive and 

contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs is one such technology

that not only allows companies greater operational flexibility compared to manned aircraft, 

but provides such flexibility without the high operational cost of a traditional manned 

aircraft. 

By operating the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 UASs, companies such as MAVERICK DRONE SYSTEMS, can remain competitive 

and profitable, and therefore, provide greater job stability to employees and contractors, 

which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the Phantom 3 Professional; 

Inspire 1; DJI s1000; and Actiondrone AD1 UASs, provides a stable workforce that 
20

increases consumer spending; improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to remain competitive both in 

the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, MAVERICK DRONE SYSTEMS’s proposed operation of the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs will not implicate any

privacy issues. Specifically, the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs will be operated only in compliance with operating documents, 

the MAVERICK DRONE SYSTEMS Aerial Operations Manual, Monthly Maintenance 

Log, and Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 Instruction 

Manuals) which requires property owner involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which MAVERICK DRONE SYSTEMS Seeks 

Exemption. 

1. Reasons Why The Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UAs Meet The Conditions Of The FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, MAVERICK DRONE SYSTEMS’s 

operation of the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs meet the conditions of FMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 
21

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, MAVERICK DRONE SYSTEMS submits that the 

Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs can operate

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The Phantom 3 Professional; Inspire 1; DJI s1000; 

and Actiondrone AD1 UASs Demonstrate Its Safe Characteristics.
22

The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs do

not create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The Phantom 3 Professional; Inspire 1; 

DJI s1000; and Actiondrone AD1 UASs.

The technical specifications of the Phantom 3 Professional; Inspire 1; DJI s1000; 

and Actiondrone AD1 UASs are attached hereto as Exhibits A, B, C and D.. 

ii. The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 UASs Autonomous Flight And Navigation Modes Enable The 

UASs To Remain Within A Defined Operational Area. 

The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs

may be operated in both manual and fully autonomous flight modes. A complete 

description of the flight and navigational modes of the Phantom 3 Professional; Inspire 1; 

DJI s1000; and Actiondrone AD1 UASs is provided in the user manuals. 

iii. The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 UASs Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the Phantom 3 Professional; Inspire 1; DJI s1000; 

and Actiondrone AD1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 

3 seconds, the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs

do not reacquire control link data from the GCS, the UAs will assume that the Control 

Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and 

will descend to the takeoff position and shutdown. 

iv. The Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 GCS And Its Operation.
23

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

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 GCS and flight control software 

is provided in each individual user manuals. 

b. Flight Operations Of Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

MAVERICK DRONE SYSTEMS will only utilize certificated pilots who possess a 

current and valid airman medical certificate to act as a pilot in command (PIC) of the 

Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs. Additionally, 

a safety observer will assist all pilots during flight time.

c. Flights Of Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, MAVERICK DRONE SYSTEMS proposes to 

commercially operate Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs for the special purpose of conducting aerial video and photography over certain 

areas of United States, pursuant to the following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: Phantom 3 Professional; Inspire 1; DJI

s1000; and Actiondrone AD1 Unmanned Aircraft Systems. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground 

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

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 
24

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

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

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 
25

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

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

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 
26

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to 

the Administrator upon request. 

21. The UA may not be operated less than 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. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

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

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle.
27

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

MAVERICK DRONE SYSTEMS submits that the equivalent level of safety

established by Section 61.113(a) and (b) will be maintained because no PIC will be 

allowed to operate the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone 

AD1 UASs unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the Phantom 3 Professional, 

Inspire 1, DJI s1000, and Actiondrone AD1 UAS in a manner consistent with the 
28

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Considering MAVERICK DRONE SYSTEMS’s proposed area of operations, and 

the operating limitations set forth-above; the parallel nature of private pilot aeronautical 

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the Phantom 3 Professional, 

Inspire 1, DJI s1000, and the Actiondrone AD1 UAS, MAVERICK DRONE SYSTEMS

submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for MAVERICK DRONE 

SYSTEMS’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

MAVERICK DRONE SYSTEMS will not allow any PIC to operate the Phantom 3 

Professional, Inspire 1, DJI s1000, or the Actiondrone AD1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements, that the PIC is able to safely 

operate the Phantom 3 Professional, Inspire 1, DJI s1000, or the Actiondrone AD1 UAS in 

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

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

Specifically, the PIC must have accumulated and logged, in a manner consistent 

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 
29

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during MAVERICK DRONE SYSTEMS’s proposed operations. 

The Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, MAVERICK DRONE SYSTEMS will ensure safe operations by not 

allowing any PIC to operate the Phantom 3 Professional, Inspire 1, DJI s1000, or the 

Actiondrone AD1 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the Phantom 3 
30

Professional, Inspire 1, DJI s1000, or the Actiondrone AD1 UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, MAVERICK DRONE SYSTEMS will ensure that the 

Phantom 3 Professional, Inspire 1, DJI s1000, or the Actiondrone AD1 UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and

as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

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

because the altitude information of the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UAs will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path and altitude. This altitude information, combined with 

MAVERICK DRONE SYSTEMS’s operation of the Phantom 3 Professional; Inspire 1; 

DJI s1000; and Actiondrone AD1 UAs within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information 
31

will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a 

zero altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs; (2) the limitations on the 

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

Accordingly, MAVERICK DRONE SYSTEMS will ensure that it will safely operate the 

battery powered Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAs 

during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 13.5 minutes to the first point of intended landing and, assuming normal 

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

Here, as in Exemption No. 11109, the technical specifications of the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs; the limitations on the 

proposed flight operations; and the location of the proposed operations, will ensure an 

equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety 

will be ensured as the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs provide audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at approximately 33% 
32

remaining battery power, and again at approximately 10% remaining battery power. At the 

critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 UASs will descend 

and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, MAVERICK DRONE SYSTEMS submits that the 

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

requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b) will be met because MAVERICK DRONE SYSTEMS will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

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

the MAVERICK DRONE SYSTEMS Aerial Operations Manual, Monthly Maintenance 

Log, and Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 Instruction 

Manuals). Furthermore, MAVERICK DRONE SYSTEMS will document and maintain all 
33

maintenance records for the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs. 

Since the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1

UASs will be inspected as prescribed by the operating documents, MAVERICK DRONE 

SYSTEMS will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the Phantom 3 Professional; Inspire 1; DJI 

s1000; and Actiondrone AD1 User Manuals are attached hereto as Exhibit C and D; a copy

of the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UAS 

Maintenance LOG is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because 

MAVERICK DRONE SYSTEMS will use trained technicians to perform maintenance, 

alterations or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs will be 

performed by trained technicians. Maintenance will be documented and maintained 

utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 
34

In consideration of MAVERICK DRONE SYSTEMS’s proposed operating 

limitations, the operating documents, and the technical aspects of the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs, MAVERICK DRONE 

SYSTEMS submits that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). 

The FAA has previously granted relief specific to UAS in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, MAVERICK DRONE 

SYSTEMS requests that the FAA prescribe special conditions for the intended operation of 

the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs, which 

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

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs 

for the limited purpose of conducting aerial video and photography over certain areas of 

the United States for compensation or hire. FMRA Section 333 sets forth the requirements 

for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security; and further, provides the authority for such 
35

UAS to operate without airworthiness certification in accordance with any requirements 

that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the Phantom 3 Professional; Inspire 1; DJI s1000; and 

Actiondrone AD1 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not 

contain adequate or appropriate safety standards, due to the novel or unusual design 

features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Leading Edge’s intended operation of the Phantom 3 

Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs, which contain such safety 

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

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b).

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

From Which MAVERICK DRONE SYSTEMS Seeks Exemption: 

MAVERICK DRONE SYSTEMS seeks exemption from the requirements of 14 

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b). 
36

A Brief Description Of The Nature Of The Exemption MAVERICK DRONE 

SYSTEMS Seeks: 

This exemption will permit MAVERICK DRONE SYSTEMS to commercially 

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

video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support 

MAVERICK DRONE SYSTEMS’s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, MAVERICK DRONE SYSTEMS’s request 

for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 

C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, MAVERICK DRONE SYSTEMS will operate the 

Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs safely in the 

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security. 

CONCLUSION

As set forth herein, MAVERICK DRONE SYSTEMS seeks an exemption pursuant 

to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the Phantom 3 Professional; Inspire 1; DJI 

s1000; and Actiondrone AD1 UASs commercially, without an airworthiness certificate, for 
37

the limited purpose of conducting aerial video and photography over certain areas of the 

United States. By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing MAVERICK DRONE SYSTEMS to 

safely, efficiently, and economically operate the Phantom 3 Professional; Inspire 1; DJI 

s1000; and Actiondrone AD1 UASs commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, MAVERICK DRONE SYSTEMS

respectfully requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to 

operate the Phantom 3 Professional; Inspire 1; DJI s1000; and Actiondrone AD1 UASs 

commercially for the purpose of conducting aerial video and photography over certain 

areas of the United States.

Dated: December 1, 2015

Respectfully submitted,

MAVERICK DRONE SYSTEMS

_________________________

MAVERICK DRONE SYSTEMS

12931 Eagle Creek Parkway

Savage, MN 55378

Tel: (612) 554-4705
38

Appendices:

A – Phantom 3 Professional Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet

C – DJI s1000 Specifications Data Sheet

D- Actiondrone AD1 Specifications Data Sheet

E - Monthly Maintenance Log
39

APPENDIX A

DJI PHANTOM 3 PROFESSIONAL SPECIFICATIONS

Maverick Drone Systems only utilizes safe and reliable UASs. DJI Phantom 3 Pro is an 

industry leader in small UAS production. DJI Phantom 3 Pro UASs are loaded with ground 

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

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

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

addition, DJI software provides real-time altitude and location information to the PIC via 

the linked monitor (smart phone/tablet devices).

Aircraft

Supported Battery – 3000mAh 3S 11.1V 20C Li-Po Battery

Weight (Battery & Propellers Included) – 35.5 oz (1280 g)

Hover Accuracy (Ready to Fly) – Vertical: .5m; Horizontal: 1.5m

Max Yaw Angular Velocity - 2000/s

Max Tilt Angel - 350

Max Ascent Speed – 5m/s

Max Descent Speed – 3m/s

Max Flight Speed – 16m/s (NOT RECOMMENDED), no wind

Camera

Video Resolution: Up to 4K @ 30 fps

Photo Resolution: 12 Megapixal

Video Format:MP4 or MOV

Photo Format: Adobe DNG RAW and JPEG

Features: Adjustable White Balance, ISO, Exposure, Shutter Speed and 

color filters

Gimbal Controllable range: Pitch -90 to +30 degrees
40

APPENDIX – B

DJI INSPIRE 1/ DJI Inspire 1 Pro

Maverick Drone Systems only utilizes safe and reliable UASs. DJI is an industry leader in 

small UAS production. DJI UASs are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can 

also be set to limit flight to no higher than a predetermined and set altitude as well as limit 

flight to a predetermined and set distance. In addition, DJI software provides real-time 

altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices)

DJI Inspire 1/Inspire 1 Pro

AIRCRAFT

Model – T600

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

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

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

Max Tilt Angle - 350

Max Ascent Speed – 5m/s

Max Descent Speed – 4m/s

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

Max Flight Altitude – 4500m

Max Wind Resistance – 10m/s

Max Flight Time – Approximately 18 minutes

Motor Model – DJI 3510

Propeller Model – DJI 1345

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

Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

GIMBAL

Model – ZENMUSE X3

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

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

Angular Vibration Range - ±0.030

Mounting – Detachable

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

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

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

CAMERA

Name – X3 (Zenmuse X5 for Inspire 1 Pro)

Model – FC350 
41

APPENDIX B- PAGE 2

Total Pixels – 12.76M (16 mp for Inspire 1 Pro)

HD Video Recording – UHD(4K) 

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

TRANSMITTER

Name – C1

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

Communicating Distance (unobstructed) – 2000m

Output Power – 9W

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

Battery – 600mAh LiPo 2S
42

APPENDIX C

DJI S1000 SPECIFICATION SHEET

WEIGHT AND SIZE: Frame Arm Length:386mm

Frame Arm Weight (with Motor, ESC, Propeller ):

325g

Center Frame Diameter:332mm

Center Frame Weight(with Landing Gear Mounting 

Base, Servos): 330g

Landing Gear Size: 

460mm(Length)X511mm(Width)X350mm(Height)

(Top width: 155 mm)

MOTOR: Stator Size:41x14mm

KV:400rpm/V

Max Power:500W

Weight(with Cooling Fan):158g

FLIGHT PARAMETERS: Takeoff Weight:6.0kg~11.0kg

Total Weight: 4.2Kg

Power Battery:LiPo

(6S、10000mAh~20000mAh、(Min)15C)

Max Power Consumption:4000W

Hovering Power Consumption:1500W (@9.5Kg 

Takeoff Weight)

Hover Time:15min

(@15000mAh & Takeoff Weight 9.5Kg)

FOLDABLE PROPELLER: Material:High strength performance engineered 

plastics

Size:15x5.2 inch

Weight:13g
43

APPENDIX D

ACTIONDRONE AD1

SIZE 17.13 in (435 mm)

WEIGHT 4.8 lbs (2.18 kg)

CRUISING SPEED: 17.9 mph (8 m/s)

FLIGHT ENDURANCE: 20 Minutes

BATTERY: 1 LiPo

MODES: Autonomous GPS, Manual, Attitude

ACRES COVERED: 100 sq.m in 7 mins (10km/sec)

TELEMETRY RANGE: 1 mi (1.6 km) 

WIND TOLERANCE: 20 mph (72 km/h)
44

APPENDIX – E

month:_________(year:________

UAS$#:$___________

Date(Issue(

Discovered

Date(Issue(

Addressed

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other:

MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted

Maintenance(Performed(By:(((

Print(&(Sign