UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No.___________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Philip Jordan 

Design LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 

3 UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

<PUBLIC LAW 112-95) 

Submitted on October 21, 2015 

Philip Jordan Design LLC

1285 S. Gilbert St

Castle Rock, CO 80104

GLOSSARY OF ABBREVIATIONS 

AGL AOI ATC ATO AV CFR COA FAA FAR GCS GPS LOL NAS 

NOTAM PIC 

Section 333 

SO SOP UA UAS VFR VLOS 

VMC 

VTOL 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations Certificate of Authorization Federal 

Aviation Administration Federal Aviation Regulation Ground 

Control Station 

Global Positioning System

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

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

Safety Observer 

Standard Operating Procedures 
Unmanned Aircraft Unmanned Aircraft System Visual 

Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

SUMMARY 

Philip Jordan Design LLC seeks exemption from the requirements of 14C.F.R §§ 61.113(a) 

& (b), 91.7(a), 91.121, 91.lSl(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a) (2), and 91.417(a) & 

(b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (FMRA). This exemption will permit Philip Jordan Design LLC to operate 

an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and 

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

States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Philip Jordan Design LLC provides his clients with expertise and knowledge in 

advanced technologies and solutions to increase efficiency, productivity and effectiveness 

through graphic and digital art. Philip Jordan Design LLC has over 6 years of recreational/

hobby experience and aerial video and photography. Philip Jordan Design LLC and its aerial 

operations is to provide high quality imaging for a variety of commercial, public, and 

residential uses, specifically targeting: 

• Construction sites before, during and after 

• Appraisals 

• Real-estate marketing 

• Aerial acquisitions used for inspections of public and private structures. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 UAS

Philip Jordan Design LLC seeks an exemption to operate DJI systems for compensation 

or hire within the NAS. The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet, laptop or smart phone 

systems. The The DJI Phantom 3 has a maximum gross weight of 1280 g, a diagonal size of 590 

mm including propellers, with a maxiumum speed of approximately 16 m/s. The DJI Phantom 3 

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

motors. 

BASIS FOR PETITION 

Petitioner, Philip Jordan Design LLC, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Phantom 3 UAS in the National 
Airspace System (NAS), and for an exemption from the Requirements of 14 C.F.R §§ 

61.113(a) & (b), 91.7(a), 91.121, 91. lSl(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), 

and 91.417(a) & (b). 

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

with the unmanned aircraft and its operation, Philip Jordan Design LLCs operation of DJI 

Phantom 3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an 

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

Accordingly, Philip Jordan Design LLC requests relief from Sections 91.405(a), 91.407(a)

(l), 91.409(a)(l ) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

Philip Jordan Design LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Philip Jordan Design LLC will use experienced 

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

the UAS using the methods, techniques, and practices prescribed in the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). 

Furthermore, Philip Jordan Design LLC will document and maintain all maintenance records 

for the DJI Phantom 3 UAS. 

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

privileges and limitations: Pilot in command, is requested by Philip Jordan Design LLC to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

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

Phantom 3 UAS in a manner consistent with this exemption,including evasive and emergency 

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

Philip Jordan Design LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the DJI Phantom 3 UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Philip Jordan Design LLC submits that he will ensure that the DJI 

Phantom 3 UAS are in an airworthy condition, prior to every flight, by determining that the UASs are in 

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

Manual), and that the aircraft is in a condition for safe flight. 

Philip Jordan Design LLC also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3UA will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Phantom 3UA will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with 

Philip Jordan Design LLC’s operation of the DJI Phantom 3 UAS within visual line of sight, at or below 

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

Additionally, Philip Jordan Design LLC seeks an exemption from the requirements of Section 

91.15l(b), entitled Fuel requirements for flight in VFR conditions. Philip Jordan Design LLC submits 

that safety will not be affected by operation of the DJI Phantom 3 UAS during daylight hours invisual 

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a 

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

normal cruising speed, to fly after that for at least 4.5 minutes. 
In accordance with 14 C.F.R. § 11.81, Philip Jordan Design LLC provides 

the following information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

Philip Jordan Design LLC 

1285 S. Gilbert St. 

Castle Rock, CO 80104 

507-438-2334 

Email: create@philipjordandesign.com

B. The Specific Sections Of 14 C.F.R. From Which Philip Jordan Design LLC Seeks 

Exemption. 

1. Philip Jordan Design LLC 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. Philip Jordan Design LLC 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. Philip Jordan Design LLC Seeks Exemption From The Requirements Of 

Section 91.121. 

Section91.121,entitled Altimeter settings,subsection(a),statesthefollowing, 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 18,000feet MSL, to--
! ! (i) The current reported altimeter setting of a station along the route and within 100 

! ! nautical miles ofthe aircraft; 

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

! ! this section,the current reported altimeter settingofanappropriate 

! ! 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. Philip Jordan Design LLC Seeks Exemption From The Requirements Of 

Section 91.151(b). 

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

(b),statesthe 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. Philip Jordan Design LLC 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. Philip Jordan Design LLC Seeks Exemption From The Requirements Of 

Section 91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l), 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. Philip Jordan Design LLC Seeks Exemption From The Requirements Of 

Sections 91.409(a)(l) 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 -- 

(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. Philip Jordan Design LLC 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. 

(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)( l) of this section shall be retained 

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

is performed. 

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

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

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

43.11 of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

C. The Extent Of Relief Philip Jordan Design LLC Seeks And The Reason Philip Jordan Design 

LLC Seeks The Relief. 

1. Extent Of Relief Philip Jordan Design LLC Seeks And The Reason Philip 

Jordan Design LLC .

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, Philip Jordan Design LLC submits that an equivalent level 

of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS 

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

PIC is able to safely operate the DJI Phantom 3 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, Philip Jordan Design LLC submits that all flights of the DJI Phantom 3 UAS, 

conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to Philip Jordan Design LLC's business; and (2) will not carry passengers 

or property for compensation or hire. 

2. Extent Of Relief Philip Jordan Design LLC Seeks And The Reason Philip 

Jordan Design LLC 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 Philip Jordan Design LLC to determine that the DJI Phantom 3 

UAS 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 3 Instruction Manual). 

Philip Jordan Design LLC seeks the requested relief because the DJI

Phantom 3 UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, Philip Jordan Design LLC will ensure that the DJI 

Phantom 3 UAS is in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 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 Of Relief Philip Jordan Design LLC Seeks And The Reason 

Philip Jordan Design LLC 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 3 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), Philip Jordan Design LLC 

seeks the requested relief because the DJI Phantom 3 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 be maintained since 

the DJI Phantom 3 UA is 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 Philip Jordan Design LLC Seeks And The Reason Philip Jordan 

Design LLC Seeks Relief From Section 91.lSl(b). 

Relief from Section 91.15l(b) entitled Fuel requirements for flight in VFR conditions, 

is requested to the extent required to allow flights of the battery powered DJI Phantom 3 

UA during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, 
assuming normal cruising speed, to fly after that for at least 4.5 minutes. Philip Jordan 

Design LLC seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 3 UA will severely 

constrain the practicality of any aerial video or still photo flight operations that Philip Jordan 

Design LLC proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS 

operating documents, and Philip Jordan Design LLC's proposed operating limitations, ensure that 

Philip Jordan Design LLC will safely operate the battery powered DJI Phantom 3 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 And The Philip Jordan Design LLC Seeks Relief 

From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & 

(b). 

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

only apply to aircraft with an airworthiness certificate, Philip Jordan Design LLC requests relief 

from these Sections because the DJI Phantom 3 UAS do not require airworthiness certificates. 

As set forth more fully below, the DJI Phantom 3 UAS meet the conditions of FMRA Section 333 

for operation without an airworthiness certificate. Accordingly, Philip Jordan Design LLC to 

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

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

Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, Philip Jordan Design 

LLC will document and maintain all maintenance records for the DJI Phantom 3 UAS. 

D. The Reasons Why Granting Philip Jordan Design LLC Request Would Be In The 

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

Granting the present Petition will further the public interest by allowing Philip Jordan 

Design LLC to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 3UAS will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Philip 

Jordan Design LLC's proposed operation of the DJI Phantom 3 UAS will be realized without 

implicating any privacy issues. 

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

The DJI Phantom 3 UA is battery powered and serve as a safe, efficient, and economical 

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

the amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing 

the use of a DJI Phantom 3 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 3 UAS's 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 3 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 UAS, 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 3 UAS 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 3 UA, 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 theDJI Phantom 3UAS 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 on board the aircraft, the DJI Phantom 3 UA (weighing 

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at its 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 3 

UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 UAS is also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the 

DJI Phantom 3 UAS will allow United States based companies, like Philip Jordan Design LLC, 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 3 UAS 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 3 UAS, companies such as Philip Jordan Design LLC, 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 3 UAS, 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, Philip Jordan Design LLC's proposed operation of the DJI Phantom 3 UAS will not 

implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in 

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

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. 

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

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

By The Rule From Which Philip Jordan Design LLC Seeks Exemption. 

1. Reasons Why DJI Phantom 3 UA 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, Philip Jordan Design LLC operation of the 

DJI Phantom 3 UAS 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 i f certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan 

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

section 334 of this Act. 

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

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

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

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

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

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

a threat to national security; and 

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

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--lf 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, Philip Jordan Design LLC submits that the DJI Phantom 3 UAS 

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

characteristics of the DJI Phantom 3

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

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe 

! ! Characteristics. 

The DJI Phantom 3 UAS 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 3 UAS. 

The technical specifications of the DJI Phantom 3 UAS is set forth by the DJI Phantom 

3 Specifications and Data Sheet, attached hereto as Exhibit A. 

ii The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational Area. 

The DJI Phantom 3 UAS may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the DJI Phantom 3 UAS 

is provided at pages 12-16 and 45-50 of the DJI Phantom 3 User Manuals, attached hereto as 

Exhibit B. 

iii.The DJI Phantom 3UAS is 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 3 UAS will remain stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS do not reacquire control 

link data from the GCS, the UA will assume that the Control Link is lost and the UA 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 3 UAS is set forth 

at pages 13 through 15 of the DJI Phantom 3 User Manual, attached hereto as Exhibit B. 

iv. The DJI Phantom 3 GCS And its Operation. 

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

and flight control software is provided at pages 40 through 47 of the DJI Phantom 

3 User Manual. DJI Phantom 3 User Manuals are attached hereto as Exhibits B. 

b. Flight Operations Of DJI Phantom 3 UAS Are Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer. 
Philip Jordan Design LLC 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 

3 UAS. Additionally, a safety observer will assist all pilots during flight time. 

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To 

! ! Specific Operating Limitations. 

In seeking this exemption, Philip Jordan Design LLC proposes to commercially 

operate DJI Phantom 3 UAS 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 3

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 400 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. 

S. 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 exemptionand the 
procedures outlined in the operating documents, the conditions and limitations contained 

in the grant of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. The operator 

may update or revise its operating documents. It is the operator's responsibility to track 

such revisions and present updated and revised documents to the Administrator upon 

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

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

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

then the operator must petition for amendment to its grant of exemption. The FAA's UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents. 

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

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft 

is prohibited from operating until the necessary maintenance has been performed and the UAS 

is found to be in a condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly documented in the aircraft 

records. 

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

flight characteristics, e.g. replacement of a flight critical 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.Sl(b). Flights for the purposes of training the operator's PICs are permitted under 

the terms of the exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all 

persons not essential for flight operations are considered nonparticipants, and the PIC must 

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

91.119. 

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

19.1. 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 pre-determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents. 

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

accordance with the operating documents. 

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

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

intended landing point and land the UA with 25% battery power remaining. 

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

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

will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in 

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

altitude level and potential transponder requirements. 

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

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings 

in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

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

of the UA must comply with the Federal Communications Commission (FCC) or other 

appropriate government oversight agency requirements. 

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

at the Ground Control Station of the UAS any time the UAS is operating. These documents 
must be made available to the Administrator or any law enforcement official upon request. 

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

activities at all times. 

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

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 asituation 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 FAA1s 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. 

Philip Jordan Design LLC 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 3 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 3 UAS in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering Philip Jordan Design LLC 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 3 UAS, 

Philip Jordan Design LLC submits that the additional manned airmanship experience of a 
commercially certificated pilot would not correlate to the airmanship skills necessary for 

Philip Jordan Design LLC’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.l 13(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). 

Philip Jordan Design LLC will not allow any PIC to operate the DJI Phantom 3 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI 

Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the 

DJI Phantom 3 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 Philip Jordan Design LLC's proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

ensure safe operations, stating as follows: 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

distances in accordance with 14 C.F.R 91.119. 
Exemption No. 11138 at page 15. 

Accordingly, Philip Jordan Design LLC will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 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, Philip Jordan Design LLC will ensure that the DJI Phantom 3 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 3 UA will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the UA to the 

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

Philip Jordan Design LLC's operation of the DJI Phantom 3 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 (l) the technical specifications of the DJI

Phantom 3 UASs; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, Philip Jordan Design LLC will ensure that it 

will safely operate the battery powered DJI Phantom 3 UA 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 3 UAS; 

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 3 UAS provide audible and visual warnings to the PIC 

at the GCS when the UA 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 3 UASs will descend and 

land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at 

less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

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

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely 

Affect Safety. 

In seeking this exemption, Philip Jordan Design LLC 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)(l), 91.409(a)( l) & (a)(2), and 91.417(a) & (b) will be met because 

Philip Jordan Design LLC will use trained technicians to perform maintenance, alterations, or 

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

the operating documents (i.e., the Monthly Maintenance Log, and DJI Phantom 3 Instruction 

Manual). Furthermore, Philip Jordan Design LLC will document and maintain all maintenance 

records for the DJI Phantom 3UAS. 

Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating 

documents, Philip Jordan Design LLC will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)( l), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manual is 

attached hereto as Exhibit B; a copy of the DJI Phantom 3 UAS Maintenance LOG 

is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Philip Jordan 

Design LLC 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 3 UAS 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)(l ), 91.409(a)(l) & (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 Philip Jordan Design LLC's proposed operating limitations, 

the 

operating documents, and the technical aspects of the DJI Phantom 3 UAS, Philip Jordan 

Design LLC submits that safety will not be adversely affected by granting exemption from 14 

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

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

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Philip Jordan Design LLC requests that 

the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, 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.l 13(a) & (b), 

91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (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 3 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 3 UAS, 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, 91.15l(b), 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 
From Which Philip Jordan Design LLC Seeks 

Exemption: 

Philip Jordan Design LLC seeks exemption from the requirements of 14 C.F.R 

Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

(a)(2}, and 91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Philip Jordan Design LLC 

Seeks: 

This exemption will permit Philip Jordan Design LLC to commercially operate 

an 

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

photography over certain areas of the United States. 

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

Philip Jordan Design LLC'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, Philip Jordan Design LLC'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, Philip Jordan Design LLC will operate the DJI 

Phantom 3 UAS 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, Philip Jordan Design LLC seeks an exemption pursuant to 

14 

C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the DJI Phantom 3 UAS 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 ofthe FAA Modernization and 

Reform Act of 2012, while also advancing the interests ofthe public, by allowing Philip 

Jordan Design LLC to safely, efficiently, and economically operate the DJI Phantom 3 UAS 

commercially within the NAS. 
WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of2012, Section 333, Philip Jordan Design LLC 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)(l), 91.409(a)(l) & (a)

(2), and 91.417(a) & (b), and permit Philip Jordan Design LLC to operate the DJI Phantom 3 

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

areas of the United States. 

Dated: October 21st 2015 

Respectfully submitted, 

Philip Jordan Design 

LLC
Philip Jordan Design LLC 

1285 S. Gilbert St.

Castle Rock, CO

80104 

507-438-2334 

Email: create@philipjordandesign.com

Appendices: 

A -DJI Phantom 3 Specifications Data Sheet 

B -DJI Phantom 3Manufacturer's User Manual 

C -Monthly Maintenance Log 

APPENDIX-A 

 DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

Philip Jordan Design LLC only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DGI UASs are loaded with ground breaking software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight 

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

distance. In addition, DJI software provides real-time altitude and location information to 

the PIC via the linked monitor (smart phone/tablet devices) 

2.2 DJI Phantom 3 

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: 300 /s; Yaw; 150 ̊/s 

2.2.1.5 Max Tilt Angle - 35 ̊

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 18 minutes 

2.2.1.12 Motor Model - DJI 3510 

2.2.1.13 Propeller Model - DJI 1345 

2.2.1.14 Operating Temperature Range - 14̊F to 104̊ F (-10̊ C to 40̊C) 

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 - + 0.03 ̊

 2.2.2.5 Mounting - Detachable 

 2.2.2.6 Controllable Range - Pitch; -90̊ to +30̊; Pan: +320 ̊

 2.2.2.7 Mechanical Range - Pitch; -125̊ to 45̊; Pan: + 330̊
 2.2.2.8 Max Controllable Speed - Pitch: 120̊ /s; Pan: 180̊ /s 

2.2.3.1 Camera 

2.2.3.1 Name - X3 

2.2.3.2 Model - FC350 

2.2.3.3 Total Pixels - 12.76M 

2.2.3.4 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 - 94° 

2.2.3.8 CMOS -SonyEXMOR 1 .3" /2 

2.2.3.9 HD Video Recording - UHD(4K): 4096x2160p24/2S, 

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

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

2.2.3.10 Operating Temperature Range - 32°F - 104°F (o0c - 40°C) 

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 - 14°F to 104°F (-10°c to 40°C) 

2.2.4.6 Battery - 600mAh Li-ion 2S 

APPENDIX -B 

DJI Phantom 3 Manufacturer's User Manual 

APPENDIX -C 

 MONTHLY MAINTENANCE

Inspection Date Aircraft Repairs Needed Repaired (Y/N)