UNITED STATES OF AMERICA

DEPARTEMNT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ROXSOL, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 14 CFR PART 21, 45.23(b), 61.113 (a) & (b), 91.7 (a), 91.9 (b)(2)

91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a) & (b), 91.405 (a), 401 (a)(1), 409(a)(2),

And 417 (a)&(b) CONCERNING COMMERCIAL OPERATION OF THE

DJI PHANTOM 2 VISION+, DJI PHANTOM 3, AND DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on January 12th, 2016

Roxsol, LLC

Kyle Baldwin

2950 Dresden Rd.

Zanesville, Ohio 43701

Ph: 740-704-1879
January 12th, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

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

Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b);

91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & (b);91.405

(a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Sir or Madam,

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

Act) and 14 C.F.R. Part 11, Roxsol, LLC, operator of Small Unmanned Aircraft

Systems (“UAS”) equipped to offer on-demand commercial UAS operations for a host

of industries and applications. 

These include:

• Aerial surveying and mapping

• Construction site inspection and monitoring

• Public Safety Support Operations

• Building/Structure Inspection

• Utility-power generation system inspections and patrolling

• Pipeline inspection and patrolling

• Mining progression

• Precision agriculture

• Wildlife and forestry monitoring

Roxsol, LLC hereby applies for an exemption from the listed Federal Aviation

Regulations (“FARs”) to allow commercial operation of its UAS, so long as such 

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

established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of 

small, unmanned and relatively inexpensive UAS under controlled conditions in 

airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would

provide safety enhancements to the already safe operations using conventional aircraft.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements

for the safe operation of such aircraft systems in the national airspace system” Section

333(c) of the Reform Act.
The name and address of the petitioner is:

Roxsol, LLC

Attn: Kyle Baldwin

2950 Dresden Rd.

Zanesville, Ohio 43701

Ph: 740-704-1879

Email: kylebaldwin@roxsol.com

Website: www.roxsol.com

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)

14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of

Transportation to consider whether certain unmanned aircraft systems may operate

safely in the national airspace system (NAS) before completion of the rulemaking

required under Section 332 of the Reform Act. In making this determination, the

Secretary is required to determine which types of UAS’s do not create a hazard to users

of the NAS or the public or pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability

• Operation of the UAS in close proximity to airports and populated areas

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system.” Id.

§333(c) (emphasis added) 
Applicant interprets this provision to place the duty on the Administrator to not only

process applications for exemptions under section 333, but for the Administrator to craft

conditions for the safe operation of the UAS, if it should be determined that the

conditions set forth herein do not fulfill the statutory requirements for approval.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority by its terms includes exempting civil aircraft, as the term is

defined under §40101 of the Act that includes UAS, from the requirement that all civil

aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of 

this title if the Administrator finds the exemption in the public interest. 49 U.S.C. 

§44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

Roxsol, LLC UAS are rotorcraft, weighing 55 or fewer lbs. including payload.

They operate, under normal conditions at a speed of no more than 50 knots and have 

the capability to hover, and move in the vertical and horizontal plane simultaneously. 

They will operate only in line of sight and will operate only within a sterile area. Such

operations will insure that the UAS will “not create a hazard to users of the national

airspace system or the public.” Specific operational UAS are the DJI Phantom 2 

Vision+, DJI Phantom 3, and DJI Inspire 1. The DJI Phantom 2 Vision+, DJI Phantom 3, 

and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The 

DJI Phantom 2 Vision+ and Phantom 3 have a maximum gross weight of approximately 

2 pounds 11 ounces, while having a length of 16 inches, width of 16 inches, height of 8 

inches, and maximum speed of approximately 29 knots. 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 Phantom 2 Vision+, Phantom 3, and the DJI Inspire 1 UAs are equipped with four 

main rotors; driven by Lithium Polymer battery powered electric motors. The DJI 

Phantom 2 Vision+, Phantom 3, and DJI Inspire 1 UAs that will be operated by Roxsol, 

LLC 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.

Reform Act Section 333 (b).

Given the small size of the UAS involved and the restricted sterile environment within

which they will operate, the applicant falls squarely within that zone of safety (an

equivalent level of safety) in which Congress envisioned that the FAA must, by

exemption, allow commercial operations of UAS to commence immediately. Also due to

the size of the UAS and the restricted areas in which the relevant UAS will operate,

approval of the application presents no national security issue. Given the clear direction

in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as
amended; the strong equivalent level of safety surrounding the proposed operations, 

and the significant public benefit, including enhanced safety, reduction in environmental

impacts, including reduced emissions associated with allowing UAS, the grant of the

requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that

have the characteristics and that operate with the limitations listed herein. These

limitations provide for at least an equivalent or even higher level of safety to operations

under the current regulatory structure because the proposed operations represent a

safety enhancement to the already safe operations conducted with conventional aircraft.

These limitations and conditions to which Roxsol, LLC agrees to be bound when

conducting commercial operations under an FAA issued exemption include:

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 45 minutes. Flights will be

terminated at 25% battery power reserve should that occur prior to the 45 minute 

limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than

 200 feet above an elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer,

 and/or the Camera Operator.

6. UAS pilot will be an FAA licensed airman with at least a private pilot’s certificate

7. UAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the

UAS Pilot, who possess the necessary PIC qualifications, is also present (i.e. the 

Visual Observer), that person can also be designated as the PIC.

8. The UAS will only operate within a confined “Sterile Area” of the flight operations 

area.

9. A briefing will be conducted in regard to the planned UAS operations prior to each

 day’s activities. It will be mandatory that all personnel who will be performing duties

 within the boundaries of the safety perimeter be present for this briefing.

10. The operator will obtain the consent of all persons involved and ensure that only

 consenting persons will be allowed within 100 feet of the flight operation, and this 

radius may be reduced to 30 feet based upon an equivalent level of safety determination.

11. Pilot and observer will have been trained in operation of UAS generally and received

 up-to-date information on the particular UAS to be operated.

12. Observer and pilot will at all times be able to communicate by voice and/or text.

13. Written and/or oral permission from the relevant property holders will be obtained.
14. All required permissions and permits will be obtained from territorial, state, county or

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

 governmental agencies.

15. If the UAS loses communications or loses its GPS signal, the UAS will have

 capability to return to a pre-determined location within the Security Perimeter and 

land.

16. The UAS will have the capability to abort a flight in case of unpredicted obstacles 

or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). Given

the size and limited operating area associated with the aircraft to be utilized by the

Applicant, an exemption from Part 21 Subpart H meets the requirements of an

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal

Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon

consideration of the size, weight, speed, operational capability, and proximity to airports

and populated areas of the particular UAS. In all cases, an analysis of these criteria

demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an 

airworthiness certificate without the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and

operates exclusively within a secured area as set out in the Manual. Unlike other civil

aircraft, operations under this exemption will be tightly controlled and monitored by both

the operator, pursuant to the Manual’s requirements, and under the requirements and in

compliance with local public safety requirements, to provide security for the area of

operation as is now done with conventional filming. The FAA will have advance notice of

all operations. These safety enhancements, which already apply to civil aircraft 

operated in connection with motion picture and television production, provide a greater 

degree of safety to the public and property owners than conventional operations 

conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. 

Lastly, application of these same criteria demonstrates that there is no credible threat to 

national security posed by the UAS, due to its size, speed of operation, location of 

operation, lack of explosive materials or flammable liquid fuels, and inability to carry a 

substantial external load. The FAA has issued the following exemptions to this 

regulation Exemptions Nos. 11251.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light-sport category aircraft or experimental or
provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or

"provisional," as applicable.

Even though the UAS will have no airworthiness certificate, an exemption may be

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which

the word “Experimental” can be placed. Given the size of the sUAV, two-inch lettering

will be impossible. The word “Experimental” will be placed on the fuselage in 

compliance with §45.29 (f). The equivalent level of safety will be provided by having the 

UAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and 

others working with the UAV will see the identification of the UAS as “Experimental.”

The FAA has issued the following exemptions to this regulation to Exemptions, but not 

limited to, Nos. 10700, 8738,10167 and 10167A, 11256, 11251.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in

Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the

UAS will not carry a pilot or passengers, the proposed operations can achieve the

equivalent level of safety of current operations by requiring the PIC operating the aircraft

to have a private pilot’s license rather than a commercial pilot’s license to operate this

small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS

is remotely controlled with no living thing on board. The area of operation is controlled

and restricted, and all flights are planned and coordinated in advance. The level of 

safety provided by the requirements included in the Manual exceeds that provided by a 

single individual holding a commercial pilot’s certificate operating a conventional aircraft. 

The risks associated with the operation of the sUAS are so diminished from the level of 

risk associated with commercial operations contemplated by Part 61 when drafted, that

allowing operations of the UAS as requested with a private pilot as the PIC exceeds the

present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy condition. As there will be no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. Given the size of the aircraft and the requirements contained in the

Manual for maintenance and use of safety check lists prior to each flight, as set forth in

Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this

chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft

Flight Manual, approved manual material, markings, and placards, or any combination
thereof. The UAS, given its size and configuration has no ability or place to carry such 

a flight manual on the aircraft, not only because there is no pilot on board, but because 

there is no room or capacity to carry such an item on the aircraft. The equivalent level 

of safety will be maintained by keeping the flight manual at the ground control point 

where the pilot flying the UAS will have immediate access to it. The FAA has issued the 

following exemptions to this regulation, but not limited to: Exemption Nos. 8607, 8737, 

8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700,11251, and 

11256.

14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided

for the aircraft an exemption will be needed. The PIC will take all actions including

reviewing weather, flight battery requirements, landing and takeoff distances and aircraft

performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned

free balloon) that is being used for flight instruction unless that aircraft has fully

functioning dual controls. UASs and remotely piloted aircraft, by their design do not 

have fully functional dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft via radio communications. The FAA has 

approved exemptions for flight training without fully functional dual controls for a number 

of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 

9862A. The equivalent level of safety is provided for by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 

(d) allows helicopters to be operated at less than the minimums prescribed, provided 

the person operating the helicopter complies with any route or altitudes prescribed for

helicopters by the FAA. As this exemption is for a UAS that is a helicopter and the

exemption requests authority to operate at altitudes up to 400 AGL, or not more than

200 above an elevated platform from which filming is planned, an exemption may be

needed to allow such operations. As set forth herein, except for the limited conditions

stated in the Manual, the UAS will never operate at higher than 400 AGL. It will however

be operated in a restricted area with security perimeter, where buildings and people will

not be exposed to operations without their pre-obtained consent. The equivalent level of

safety will be achieved given the size, weight, and speed of the UAS as well as the

location where it is operated. No flight will be taken without the required permission of

the property owner or local officials. Because of the advance notice to the property

owner and participants in the aerial activity, all affected individuals will be aware of the

planned flight operations. Compared to flight operations with aircraft or rotorcraft

weighting far more than the maximum 55lbs. proposed herein and the lack of flammable
fuel, any risk associated with these operations is far less than those presently presented

with conventional aircraft operating at or below 500 AGL other industries. In addition, 

the low-altitude operations of the UAS will ensure separation between these small-UAS

operations and the operations of conventional aircraft that must comply with Section

91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set “...to the elevation of the departure airport or an

appropriate altimeter setting available before departure.” As the UAS may not have a

barometric altimeter, but instead a GPS altitude read out, an exemption may be needed.

An equivalent level of safety will be achieved by the operator, pursuant to the Manual

and Safety Check list, confirming the altitude of the launch site shown on the GPS

altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes.” The battery powering the UAS provides approximately 

30-50 minutes of powered flight. To meet the 30-minute reserve requirement in 14 CFR

§91.151, UAS flights would be limited to approximately 20 minutes in length. Given the 

limitations on the UAS’s proposed flight area and the location of its proposed operations 

within a predetermined area, a longer time frame for flight in daylight or night VFR 

conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly

controlled area where only people and property owners or official representatives who

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not

engender the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the small UAS. Additionally, limiting UAS flights to 20 minutes would

greatly reduce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to

45 minutes or 25% of battery power whichever happens first. This restriction would be

more than adequate to return the UAS to its planned landing zone from anywhere in its

limited operating area.

Similar exemptions have been granted to other operations, including Exemptions 

2689F,5745, 10673, 10808, and 11251.
14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has

within it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard

pilot. As such, there is no ability or place to carry certification and registration 

documents or to display them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the UAS will have immediate access to them, to the

extent they are applicable to the UAS. The FAA has issued numerous exemptions to

this regulation. A representative sample of other exceptions includes Exemption Nos.

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11251, and 11256.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft 

in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness

certificate, these sections will not apply to the applicant. The operator pursuant to the

flight manual and operating handbook will accomplish maintenance. An equivalent level

of safety will be achieved because these small UASs are very limited in size and will

carry a small payload and operate only in restricted areas for limited periods of time. If

mechanical issues arise the UAS can land immediately and will be operating from no

higher than 400 feet AGL. As provided in the Manual, the operator will ensure that the

UAS is in working order prior to initiating flight, perform required maintenance, and keep

a log of any maintenance performed. Moreover, the operator is the person most familiar

with the aircraft and best suited to maintain the aircraft in an airworthy condition to

provide the equivalent level of safety.

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

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

Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 

91.9(b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a);

91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate 

commercially a small unmanned vehicle (55lbs or less).

Approval of exemptions allowing commercial operations of UAS, will enhance safety

by reducing risk. Conventional operations, using jet or piston power aircraft, operate at

extremely low altitudes just feet from the subjects being filmed and in extreme proximity

to people and structures and present the risks associated with vehicles that weigh in the

neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. Such aircraft

must fly to and from the operational location. In contrast, a UAS weighing fewer than 55

lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass

and lack of combustible fuel carried on board. The UAS is carried to the operation site

and not flown. The UAS will carry no passengers or crew and, therefore, will not expose

them to the risks associated with manned aircraft flights.

The operation of small UAS, weighing less than 55 lbs., conducted in the strict

conditions outlined above, will provide an equivalent level of safety supporting the grant

of the exemptions requested herein, including exempting the applicant from the

requirements of Part 21 and allowing commercial operations. These lightweight aircraft

operate at slow speeds, close to the ground, and in a sterile environment and, as a

result, are far safer than conventional operations conducted with turbine helicopters

operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner’s

prior consent and knowledge. Filming will be of people who have also consented to

being filmed or otherwise have agreed to be in the area where filming will take place.

The grant of this exemption request will provide improved safety in both day and night

operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 

2012- -size, weight, speed, operating capabilities, proximity to airports and populated 

areas and operation within visual line of sight and national security – provide more than

adequate justification for the grant of the requested exemptions allowing commercial

operation of applicant’s UAS. It is of note that certain public safety operations may 

involve advanced monitoring technology such as Infrared, Night Vision, etc. These 

specific operations will be governed pursuant to all applicable Local, State, and Federal 

laws regarding search and seizure including court approval of said operations via

search warrant.
Conclusion

As set forth herein, Roxsol, LLC 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+, DJI Phantom 3, and DJI Inspire 1 

UAS commercially, without an airworthiness certificate, for the limited purpose of 

conducting the aforementioned on-demand commercial UAS operations that include:

• Aerial surveying and mapping

• Construction site inspection and monitoring

• Public Safety Support Operations

• Building/Structure Inspection

• Utility-power generation system inspections and patrolling

• Pipeline inspection and patrolling

• Mining progression

• Precision agriculture

• Wildlife and forestry monitoring

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 Roxsol, LLC to safely, efficiently, and economically 

operate UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, section 333, Roxsol, LLC respectfully

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

requirements of 14 C.F.R Sections 45.23(b); Part 21; 61.113(a) & (b), 91.7(a); 91.9(b); 

91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a); 91.405(a), 91.407(a)(1); 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Roxsol, LLC to operate the DJI 

Phantom 2 Vision+, DJI Phantom 3, and the DJI Inspire 1 commercially in the United 

States.

Respectfully Submitted,

Roxsol, LLC

Kyle Baldwin

2950 Dresden Rd.

Zanesville, Ohio 43701

740-704-1879

kylebaldwin@roxsol.com

Appendices:

A – DJI Phantom 2 Vision+/Phantom 3 – Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet

C – Link to DJI Phantom 2 Vision+ Manufacturer’s User Manual

D – Link to DJI Inspire 1 Manufacturer’s User Manual

APPENDIX – A
DJI PHANTOM 2 VISION+/PHANTOM 3 TECHNICAL SPECIFICATIONS

Roxsol, LLC only utilizes safe and reliable UAS. DJI is an industry leader in small

UAS production. DJI UAS 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 realtime altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices)

1.1 DJI Phantom 2 Vision+/Phantom 3.

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 3501.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED).

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s.

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x32884.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Roxsol, LLC only utilizes safe and reliable UAS. DJI is an industry leader in small

UAS production. DJI UAS 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)

2.2 DJI Inspire 1.

2.2.1 Aircraft

2.2.1.1 Model – T600

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

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

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

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s

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

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 20 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 2.2.1.15

Dimensions – 17 1/4” x 17 3/4” x 12”

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

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

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

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable

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

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

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

2.2.3 Camera

2.2.3.1 Name – X3

2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M2.2.3.4 Effective Pixels – 12.4M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25,

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD:

1280x720p24/25/30/48/50/60

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

2.2.4 Transmitter

2.2.4.1 Name – C1

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

2.2.4.3 Communicating Distance (unobstructed) – 2000m
2.2.4.4 Output Power – 9W

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

2.2.4.6 Battery – 600mAh LiPo 2S

APPENDIX – C

DJI Phantom 2 Vision+ Manufacturer’s User Manual

http://download.djiinnovations.

com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_M

anual_v1.8_en.pdf

APPENDIX – D

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.

com/downloads/inspire_1/en/Inspire_1_User_