September 25, 2015

Exemption No. 12991

Regulatory Docket No. FAA−2015−2794

Mr. Lee M. Woodworth

26 Union Street

Plymouth, MA 02362

Dear Mr. Woodworth:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated June 4, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. You requested to operate an unmanned aircraft system (UAS) to conduct

aerial videography and photography for construction sites, real estate, surveying, and 

landscape.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner are the DJI Phantom 2 Vision +, DJI Phantom 3, and DJI 

Inspire 1.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 
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finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner 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 UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Lee M Woodworth is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

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

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Lee M Woodworth is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision +, DJI Phantom 3, and DJI Inspire 1 when weighing less than 55 pounds 

including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 or 

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

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

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

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

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 
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documents to the Administrator or any law enforcement official upon request. The 

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

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS 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 must be logged in a manner consistent with 
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14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this 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 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

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

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on October 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

Exemption Request

Regulatory Docket Number: TBD

The following petition is submitted by Lee M. Woodworth and made to

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTATION 

WASHINGTON, DC 20591

for an exemption from Title 14, Code of Federal Regulations (14 CFR) part 21, subpart H; and

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 DJI Phantom 2 Vision +, DJI 

Phantom 3, and DJI Inspire 1 unmanned aircraft systems.

Submitted on June 4, 2015

Lee M Woodworth 

26 Union Street

Plymouth, MA 02362 

Tel: (781) 864-3151
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

TABLE OF CONTENTS 

SUMMARY...................................................................................................................................................3

INTRODUCTION..........................................................................................................................................3

BASIS FOR PETITION...................................................................................................................................3

NAME AND MAILING ADDRESS OF PETITIONER.......................................................................4

SPECIFIC SECTIONs OF 14 C.F.R. FROM WHICH LEE M. WOODWORTH SEEKS

EXEMPTION ..............................................................................................................................4

EXTENT OF RELIEF LEE M. WOODWORTH SEEKS AND THE REASON LEE M. WOODWORTH 

SEEKS THE RELIEF...........................................................................................................................7

HOW THIS REQUEST WOULD BENEFIT THE PUBLIC AS A WHOLE..........................................9

REASONS WHY THIS EXEMPTION WOULD NOT ADVERSLY AFFECT SAFTEY ....................11

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER....................................22

ANY ADDITIONAL INFORMATION, VIEWS, ARGUMENTS AVAILABLE TO SUPPORT LEE M. 

WOODWORTHS REQUEST.........................................................................................................23

CONCLUSION............................................................................................................................................................23

APPENDICES..............................................................................................................................................................24
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

SUMMARY 

Lee M. Woodworth seeks exemption from the requirements of 14 C.F.R. part 21, subpart H; and 

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), to operate an Unmanned Aircraft System (UAS) pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Lee 

M. Woodworth to operate an UAS for the commercial purpose of conduction aerial video and 

photography for construction sites, real estate, surveying, and landscape over certain areas of 

the United States. 

INTRODUCTION

Lee M. Woodworth has over 30 years of experience flying fixed wing, helicopter, and multirotor 

air craft as a hobbyist. Woodworth has been a member of the Academy of Model Aeronautics 

(AMA) since 1985 (member #209920) and is an AMA certified instructor as well as a certified 

safety officer. Woodworth has been active in the Civil Air Patrol for the past 20 years and 

taught secondary technology education for 35 years. Woodworth also has experience designing 

and engineering all types of model aircraft. 

The objective of Lee M. Woodworth’s aerial video and photography operation is to provide high 

quality imagery for a variety of commercial, public, and residential uses including: 

 Aerial inspections of public and private structures

 Aerial video and images for private and public property owners

 Aerial video and images for environmental consulting 

 Increase public knowledge of UAS and promote safe UAS operations

In order to conduct such operations, Lee M. Woodworth seeks an exemption to operate DJI 

systems, specifically the DJI Phantom 2 Vision+ and DJI Inspire 1, for compensation or hire 

within the National Airspace System (NAS). The DJI Phantom 2 Vision+ and DJI Inspire 1 are 

vertical takeoff and landing (VTOL) unmanned aircraft (UA) with a ground control station (GCS). 

All UAs will be operated by an individual with a pilot certification, current FAA airman medical 

certificate or a valid U.S. drivers’ license, and meet the flight review requirements specified in 

14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. All UAs 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 Markings.

BASIS FOR PETITION 

Petitioner, Lee M. Woodworth, 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 
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

commercially operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R part 21, subpart H; and 

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).

Name And Address Of The Petitioner:

Lee M. Woodworth

26 Union Street 

Plymouth, MA 02632

Tel: (781)864-3151

Email: LeeMWoodworth@gmail.com

Specific Sections Of 14 C.F.R. From Which Lee M. Woodworth Seeks Exemption:

1. Lee M. Woodworth 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. Lee M. Woodworth 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. Lee M. Woodworth 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--
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

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

within 100 nautical miles of the aircraft;

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

of this section, the current reported altimeter setting of an appropriate

available station; or

(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. Lee M. Woodworth 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. Lee M. Woodworth 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. Lee M. Woodworth 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. Lee M. Woodworth Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

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

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

unless, within the preceding 12 calendar months, it has had --
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

(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. Lee M. Woodworth Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b).

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

following:

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

owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

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

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

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

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

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

the work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

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

and each rotor.

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

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

the last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

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

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

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

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

required.
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

(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.

Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth Seeks The 

Relief: 

1. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 

Seeks Relief From Section 61.113(a) And (b).

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

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

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

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

proposed UAS flight operations for compensation or hire.

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

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

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

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

compensation or hire.

As set forth more fully below, Lee M. Woodworth submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2

Vision+ UAS or DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the DJI

Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the operations

specifications as described in this exemption, including evasive and emergency 

maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures.

Further, Lee M. Woodworth submits that all flights of the DJI Phantom 2 Vision+ and DJI 

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

incidental to Lee M. Woodworth’s business; and (2) will not carry passengers or 

property for compensation or hire.
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

2. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 

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 Lee M. Woodworth to determine that the DJI Phantom 2 

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

that the UAS is in compliance with the operating documents (i.e. Monthly Maintenance 

Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual).

Lee M. Woodworth seeks the requested relief because the DJI Phantom 2 Vision+ and

DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Lee M. Woodworth will ensure that the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs are in airworthy condition based upon its 

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

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

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

conditions and limitations below.

3. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 

Seeks Relief From Section 91.121.

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

operations of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, which utilize a

barometric pressure sensor, GPS equipment, and a radio communications telemetry 

data link to downlink altitude information from the UA to the PIC at the ground control 

station (GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), Lee 

M. Woodworth seeks the requested relief because the DJI Phantom 2 Vision+ and DJI 

Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

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

maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are equipped with a

barometric pressure sensor and GPS equipment, which automatically ensures that a 

ground level pressure setting will be established prior to each flight, and provides the 

PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 

Seeks Relief From Section 91.151(b).

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

requested to the extent required to allow flights of the battery powered DJI Phantom 2 

Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at 
9

LEE M. WOODWOTH – PETITION FOR EXEMPTION

least 4.5 minutes. Lee M. Woodworth seeks the requested relief because without an

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

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

aerial video or still photo flight operations that Lee M. Woodworth proposes to conduct

pursuant to this Petition.

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

Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating

documents, and Lee M. Woodworth’s proposed operating limitations, ensure that Lee 

M. Woodworth will safely operate the battery powered DJI Phantom 2 Vision+ and DJI 

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

visual flight rules (VFR), with enough battery power to fly for a total duration of 13.5 

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

fly after that for at least 4.5 minutes.

5. Extent Of Relief Lee M. Woodworth Seeks And The Reason Lee M. Woodworth 

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, Lee M. Woodworth requests relief 

from these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not 

require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 

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

without an airworthiness certificate. Accordingly, Lee M. Woodworth 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. Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 

Instruction Manual). Furthermore, Lee M. Woodworth will document and maintain all 

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

How This Request Would Benefit The Public As A Whole:

Granting the present Petition will further the public interest by allowing Lee M. 

Woodworth to safely, efficiently, and economically perform aerial video and 

photography for construction sites, real estate, surveying, and landscape over certain 

areas of the United States. Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 

1 UASs will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Lee M. Woodworth’s proposed 

operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be realized without 

implicating any privacy issues.

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

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are battery powered and serve as a 

safe, efficient, and economical alternative to the manned aircraft traditionally utilized to 

obtain aerial imagery. By reducing the amount of manned aircraft needed to perform
10

LEE M. WOODWOTH – PETITION FOR EXEMPTION

aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI

Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and

air pollution, as well as increase the safety of life and property in the air and on the 

ground.

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

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

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or 

land. Likewise, a reduction of manned aircraft conducting aerial video and photography

missions would result in fewer aircraft that must be handled by air traffic control during

the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+ 

and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 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 DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs produce no air pollution, and is the most

viable environmentally conscious alternative to the cabin class, six cylinder internal

combustion engine aircraft that are typically utilized for aerial video and photography,

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI

Phantom 2 Vision+ and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision+ and DJI Inspire 1 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 DJI Phantom 2 Vision+ and DJI Inspire 1 UAs (weighing

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths 

of 16 inches and 17.7 inches respectively, and with no fuel on board), has less physical

potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs Will Benefit The Economy.

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

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

operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will 
11

LEE M. WOODWOTH – PETITION FOR EXEMPTION

allow United States based companies, like Lee M. Woodworth, to remain competitive 

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

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new 

and alternative technology in order to remain competitive. Operating the battery 

powered DJI Phantom 2 Vision+ and DJI Inspire 1 UASs is one such technology that not 

only allows companies greater operational flexibility compared to manned aircraft, but 

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

aircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, companies such

as Lee M. Woodworth, can remain competitive and profitable, and therefore, provide 

greater job stability to employees and contractors, which will ultimately contribute to 

growth of the U.S. economy. Improved financial performance of U.S. companies, 

through commercial use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, provides a 

stable workforce that increases consumer spending; improves local, state, and federal 

tax revenues; and allows companies to invest in research and development in order to 

remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, Lee M. Woodworth’s proposed operation of the DJI Phantom 2 Vision+ and DJI

Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2

Vision+ and DJI Inspire 1 UASs will be operated only in compliance with operating

documents (i.e. Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 

Instruction Manual) 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

Reasons Why This Exemption Would Not Adversely Affect Safety:

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs Meet The Conditions 

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

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

the unmanned aircraft and its operation, Lee M. Woodworth’s operation of the DJI

Phantom 2 Vision+ and DJI Inspire 1 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.

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 
12

LEE M. WOODWOTH – PETITION FOR EXEMPTION

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, Lee M. Woodworth submits that the DJI Phantom 2 Vision+

and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ and DJI Inspire 1

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

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

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not create a hazard to users

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

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

i. Technical Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 

1 UASs.

The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 User

Manuals, attached hereto as Exhibit A and B.

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

And Navigation Modes Enable The UASs To Remain Within A Defined 

Operational Area.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs may be operated in 

both manual and fully autonomous flight modes. A complete description 

of the flight and navigational modes of the DJI Phantom 2 Vision+ and DJI 
13

LEE M. WOODWOTH – PETITION FOR EXEMPTION

Inspire 1 UASs is provided at pages 25-35 of the DJI Phantom 2 Vision+ 

and pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, attached.

iii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Are Designed For 

Automatic Return To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 

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

seconds, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not 

reacquire control link data from the GCS, the UAs will assume that the 

Control Link is lost and the UAs will return to the home position (i.e.,

failsafe mode) via GPS, and will descend to the takeoff position and 

shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 

Vision+ UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 

at pages 13 through 15 of the DJI Phantom 2 Vision+ and DJI Inspire 1 

User Manuals, attached.

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

A complete description of the operation and specifications of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 GCS and flight control software is 

provided at pages 32 through 43 of the DJI Phantom 2 Vision+ User 

Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. DJI 

Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached.

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

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

Observer.

Lee M. Woodworth will only utilize certificated pilots who possess a current and 

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

Phantom 2 Vision+ and DJI Inspire 1 UASs. Additionally, a safety observer will 

assist all pilots during flight time.

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

Pursuant To Specific Operating Limitations.

In seeking this exemption, Lee M. Woodworth proposes to commercially operate 

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purpose of 

conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations:

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

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and 
14

LEE M. WOODWOTH – PETITION FOR EXEMPTION

DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other 

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

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

for the purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 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.

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
15

LEE M. WOODWOTH – PETITION FOR EXEMPTION

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

questions arise regarding updates or revisions to the operating documents.

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

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

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

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

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

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

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

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

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

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

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

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

relevant sections of the operating documents.

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

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

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

keeping requirements, in accordance with the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized 

person returning the UAS to service.

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

manufacturer Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

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

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 
16

LEE M. WOODWOTH – PETITION FOR EXEMPTION

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

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

1.1. All operations must be conducted under visual meteorological conditions

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

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

rules (SVFR) are not authorized.

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

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

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

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

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

Administrator upon request.

21. The UA may not be operated less than 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
17

LEE M. WOODWOTH – PETITION FOR EXEMPTION

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.

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.
18

LEE M. WOODWOTH – PETITION FOR EXEMPTION

Lee M. Woodworth submits that the equivalent level of safety established by Section

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting 

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

the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Considering Lee M. Woodworth’s proposed area of operations, and the operating 

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

requirements to those of commercial pilot requirements (See Exemption No. 11062); 

and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ or DJI 

Inspire 1 UAS, Lee M. Woodworth submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for Lee M. Woodworth’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). 

Lee M. Woodworth will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS training and currency 

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

Inspire 1 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 

hours of those hours as a UAS pilot operating the same make and model of UAS to be 

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

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

purposes).

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

was obtained in compliance with applicable regulations will ensure an equivalent level 

of safety during Lee M. Woodworth’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 
19

LEE M. WOODWOTH – PETITION FOR EXEMPTION

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, Lee M. Woodworth will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has

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

the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in 

a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety.

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

prior to every flight, Lee M. Woodworth will ensure that the DJI Phantom 2 Vision+ or 

DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its 

operating documents and as stated in the conditions and limitations herein. 

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

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

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

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety.

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

the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will be 
20

LEE M. WOODWOTH – PETITION FOR EXEMPTION

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 Lee M. Woodworth’s operation of the 

DJI Phantom 2 Vision+ and DJI Inspire 1 UAs within visual line of sight, at or below 400 

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

information will be generated by GPS equipment installed onboard the aircraft. Prior to 

each flight, a zero altitude initiation point is automatically established by the UASs at 

ground level. 

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

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

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

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

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

Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 

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

2 Vision+ and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; 

and (3) the location of the proposed flight operations. Accordingly, Lee M. Woodworth

will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ and DJI 

Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly 

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

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

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and 

the location of the proposed operations, will ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the 

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs provide audible and visual warnings to the 

PIC at the GCS when the UAs experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 

10% remaining battery power. At the critically low battery level, the DJI Phantom 

Vision+ and DJI Inspire 1 UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

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

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

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

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

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

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

11157, 11158, 11159, 11160, 11161).
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LEE M. WOODWOTH – PETITION FOR EXEMPTION

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, Lee M. Woodworth 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 Lee M. Woodworth 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 Lee M. 

Woodworth Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, Lee M. Woodworth will 

document and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI 

Inspire 1 UASs. 

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

by the operating documents, Lee M. Woodworth will maintain the equivalent level of 

safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the 

DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibit C 

and D; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Lee M. 

Woodworth will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents. 

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

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

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance 

log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Lee M. Woodworth’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs, Lee M. Woodworth 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).
22

LEE M. WOODWOTH – PETITION FOR EXEMPTION

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, Lee M. Woodworth requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 

2 Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established 

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

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

special conditions will permit safe operation of the UAs for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

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

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

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

21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate 

safety standards, due to the novel or unusual design features of the aircraft. Section 

21.16, entitled Special Conditions, states the following: 

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

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

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

engine or propeller, he prescribes special conditions and amendments thereto 

for the product. The special conditions are issued in accordance with Part 11 of 

this chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16. 

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

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

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, which contain such safety 

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

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

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

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

A Summary That Can Be Published In The Federal Register:

Lee M. Woodworth 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).
23

LEE M. WOODWOTH – PETITION FOR EXEMPTION

A Brief Description Of The Nature Of The Exemption Lee M. Woodworth Seeks:

This exemption will permit Lee M. Woodworth to commercially operate an Unmanned

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

certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support Lee M. Woodworth’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, Lee M. Woodworth’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, Lee M. Woodworth will operate the DJI Phantom 2 Vision+ 

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

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

CONCLUSION 

As set forth herein, Lee M. Woodworth 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 DJI Phantom 2 Vision+ and DJI Inspire 1 UASs commercially, without an 

airworthiness certificate, for 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 Lee M. Woodworth to safely, efficiently, 

and economically operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs commercially 

within the NAS.

Wherefore, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, Lee M. Woodworth 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 DJI Phantom 2 Vision+ and DJI Inspire 1 

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

areas of the United States.

Dated: June 4, 2015

Respectfully submitted,

Lee M. Woodworth
24

LEE M. WOODWOTH – PETITION FOR EXEMPTION

APPENDICES 

A – DJI Phantom 2 Vision+ Manufacturer’s User Manual

B– DJI Inspire 1 Manufacturer’s User Manual