Requested Exemptions

14 CFR 61.23(a) and (c)

Our current pilot holds a commercial helicopter rating. However, our VO may pursue an FAA airman 

certificate in the future. Therefore we request relief from 61.23(a) and (c) to allow any pilot that holds 

an FAA airman certificate to operate a UAS under this exemption with a U.S. issued driver’s license, in 

lieu of an FAA-issued medical certificate. Our PICs will, of course, comply with 61.53, Prohibition on 

operations during medical deficiency.

14 CFR 61.101(e)(4) and (5)

14 CFR 61.113(a)

14 CFR 61.315(a)

We request relief from 61.101(e)(4) and (5) and 61.113(a) to allow a PIC holding a recreational or private 

pilot certificate to operate a UAS for compensation and hire, subject to limitations. We also request 

relief from 613.15(a) to permit the holder of a sport pilot certificate to act as the PIC of UAS operated 

under this exemption, if issued. 

14 CFR 91.7(a)

Based upon previously issued exemptions No. 11481 and No. 11138, we submit that our aircraft, a DJI 

Phantom 3 Advanced and a DJI Phantom 1, will not require an airworthiness certificate. We request 

relief from 91.7(a) as we believe the PIC can safely determine whether the aircraft are in a condition for 

safe flight.

14 CFR 91.119(c)

In order to safely integrate with the NAS, we request relief from 91.119(c) because our aircraft would be 

operated at altitudes below 500 feet AGL. Our UASs are rotorcraft and 91.119 (d)(1) seems like a more 

reasonable minimum safe altitude standard providing that permission has been granted from 

nonparticipants and that said nonparticipants are sufficiently protected from the UAS and/or debris in 

the event of an accident/incident.

14 CFR 91.121

Because both of our aircraft, the DJI Phantom 3 Advanced and the DJI Phantom 1 utilize electronic global 

positioning systems with a barometric sensor; we request relief from 91.121.

14 CFR 91.151(a)(1)

Our aircraft use battery power instead of fuel and the duration of our flights are much shorter than the 

listed minimums for fixed-wing or rotorcraft. Based upon previously issued exemptions, we request 

limited relief from 91.151(a)(1) that would prohibit the PIC from beginning a UAS flight unless 

(considering wind and forecast weather conditions) there is enough available power for the UAS to 

operate for the intended operational time and to operate thereafter for at least five minutes or with the 

reserve power recommended by the manufacturer if greater.
E. 14 CFR 91.405(a); 407(a)(1) and (2); 417(a) and (b)

These regulations apply to aircraft with an airworthiness certificate and we submit, based upon 

previously issues exemptions No. 11481 and No. 11138, that our aircraft will not require an 

airworthiness certificate.

We believe we can achieve an equivalent level of safety with relief from the aforementioned 

regulations, as such shows in our operational procedures, as well as the multiple safety system checks 

onboard the UAS’s. An inspection will be performed by the PIC prior to each flight. Issues not addressed 

in the operational manual will be addressed through the manufacturer by qualified maintenance 

personnel. 

The DJI Phantom aircraft we operate are equipped with software that performs automated system 

checks; the failure of any check prevents take-off. And in the case of any failures during flight, such as 

low battery or loss of ground control functions and/or signal, our UAS’s are programmed with the return 

to home function and will automatically return to their original take-off position on the ground. 

Operational Procedures

Mission Planning

Each flight is preceded by a mission evaluation between the PIC, VO, and any participating parties 

(property owners, observers). This evaluation covers the mission goals and an assessment of safety 

concerns. 

Preflight

Weather – check NOAA to confirm weather conditions in the area meet day VFR minimums. 

Operational Area – Confirm that aircraft user manual and any other necessary documentation (pending 

exemption approval) including written permission from property owners is readily available. Confirm 

that nonparticipants are not in the area or are appropriately sheltered in the event of accident or 

incident.

Landing Area – ensure a firm takeoff/landing surface. If departing from other than firm surface (grass, 

gravel) utilize the portable landing pad. Ensure appropriate distance from obstacles and confirm that the 

planned flight path can be executed. Confirm appropriate abort sites if mission cannot be completed as 

planned.

Equipment – visually inspect aircraft: check blades, body, and landing gear for cracks or flaws. Inspect 

battery: check connection terminals, check leads for wear, check case for cracks or flaws. Inspect 

remote: before powering on, check that each button properly actuates and ensure that control sticks 

have full range of motion. Ensure auxiliary flight timer is functioning.

Proceed to manufacturer’s preflight checklist:

1. Remote controller, Intelligent Flight Battery, and mobile device are fully charged. 
2. Propellers are mounted correctly and firmly. 

3. Micro-SD card has been inserted, if necessary. 

4. Gimbal is functioning normally. 

5. Motors can start and are functioning normally. [VO - start auxiliary flight timer now]

6. The DJI Pilot app is successfully connected to the aircraft. 

DJI Pilot app, check values: Compass status, IMU values, Gain values, Max height, RTH height, R/C EXP & 

Gain, satellite status. Confirm GPS signal is sufficient for safe flight. Set Home Point.

Hover pre-takeoff checks – Bring UAS to 8 foot AGL hover, confirm GPS signal, check altitude readout. 

Confirm battery and UAS LEDs are functioning normally. Check that all control inputs are functioning 

normally. 

Conduct flight. Ensure PIC and VO are a safe distance from landing site. Land, power off. VO – stop 

auxiliary flight timer.

Post-flight

Confirm power off on UAS and remote. Touch each motor to check for inordinately high temperature. 

Visually inspect blades, body, and landing gear for flaws or cracks. Remove battery from UAS. If 

necessary, clean UAS with a damp cloth.

Before leaving the landing area, record flight in battery performance log.

Return to base of operations. Download flight data. PIC and VO log flight time after comparing manually 

recorded flight time to onboard flight log.

Inspections

Thorough inspections occur every four flights or if the time between flights exceeds 14 days. The 14 day 

time period has been established based upon the frequency of firmware updates for the DJI Phantom 3.

Visually inspect UAS (body, landing gear) for cracks or flaws.

Inspect blades for wear. Check that blades are mounted to the correct motor and are tensioned 

properly.

Clean all surfaces.

Check battery wires, terminals, and case.

DJI pilot app: Check battery error log.

Firmware – if a new version is available, review release notes, then install. If an update was required, 

perform thorough control checks followed by a test flight while following normal operating procedures 

and safety checks.