1

December 17, 2015 

Attn:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: Meredith N. Napoli, Owner/John Elkington Senior Manager dba. Front Page Productions, LLC.

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL 

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 2

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Meredith N. Napoli, Owner/John Elkington Senior Manager,

dba. Front Page Productions, LLC.

3743 Forest Park Pl. 

Land O ‘ lakes, Fl. 34639

813-918-3003

Frontpageproductions@gmail.com
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Table of Contents

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

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

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

BACKGROUND................................................................................................................... 4 

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

NAME AND ADDRESS OF PETITIONER.............................................................................. 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH FRONT PAGE PRODUCTION, LLC SEEKS 

EXEMPTION...................................................................................................................... 7 

THE EXTENT OF RELIEF FRONT PAGE PRODUCTION, LLC. SEEKS AND THE REASON FRONT PAGE 

PRODUCTION,LLC SEEKS THE RELIEF................................................................................ 10 

THE REASONS WHY GRANTING FRONT PAGE PRODUCTION, LLC ‘S REQUEST WOULD BE IN THE PUBLIC 

INTEREST ........................................................................................................................ 12 

THE REASONS WHY GRANTING THE EXEMPTION TO FRONT PAGE PRODUCTION, LLC WOULD NOT 

ADVERSELY AFFECT SAFETY........................................................................................... 14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER............................... 23

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT FRONT PAGE 

PRODUCTION, LLC’S REQUEST....................................................................................... 23

CONCLUSION................................................................................................................ 24

APPENDICES............................................................................................................................. 24
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GLOSSARY OF ABBREVIATIONS

AGL - Above Ground Level AOI Area of Interest

ATC - Air Traffic Control 

ATO- Air Traffic Organization

AV - Aerial Vehicle

CFR - Code of Federal Regulations

COA - Certificate of Authorization

FAA - Federal Aviation Administration

FAR - Federal Aviation Regulation 

GCS - Ground Control Station 

GPS - Global Positioning System 

LOL - Loss of Link 

NAS - National Airspace System 

NOTAM Notice to Airman 

PIC - Pilot In Command

SO - Safety Observer 

SOP - Standard Operating Procedures 

UA - Unmanned Aircraft

UAS - Unmanned Aircraft System 

VFR - Visual Flight Rules 

VLOS - Visual Line of Site 

VMC - Visual Meteorological Conditions 

VTOL - Vertical Takeoff and Landing
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SUMMARY

Meredith N. Napoli, Owner/John Elkington Senior Manager, dba. FRONT PAGE PRODUCTION, LLC 

hereafter referred to as FRONT PAGE PRODUCTION, LLC seeks exemption from the requirements of 14 

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b), to operate an Unmanned Aircraft System (DJI Phantom 2) pursuant to Section 333 of 

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

PRODUCTION, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography of construction sites, residential and commercial real estate, 

civil landscapes and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

FRONT PAGE PRODUCTION, LLC although a new established company its owner and staff has for over 

10 years provided their clients (which include private sector businesses and non-profits) with expertise 

and knowledge in video, advertising, public relations and training using advanced technologies and 

solutions. FRONT PAGE PRODUCTION, LLC has worked number of productions over the past 10 years in 

all types of locations with a perfect client and employee safety record. In the past we have supplied our 

client’s aerial video and photography. The objective of FRONT PAGE PRODUCTION, LLC and our 

Unmanned Aircraft System (DJI Phantom 2) aerial operations is to provide a more affordable, highquality production system for a variety of governmental, commercial, public, and residential uses, 

specifically targeting 

• Construction sites before and after 

• Appraisals 

• Real-estate marketing 

• Economic development 

• Civic landmarks 

• Special event coverage 

• Private training 

My staff has safely flown small RC electric quad-copters recreationally for approximately 2 years without 

incident. 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2, UAS FRONT PAGE PRODUCTION, LLC seeks an exemption to 

operate DJI Phantom 2 system for compensation or hire within the NAS. The DJI Phantom 2 is 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 has a maximum gross weight of 

approximately 2.6 lb. while having a diagonal dimension of 23.8”, a maximum speed of approximately 

16.4 fps and a maximum flying height of 400'. The DJI Phantom 2 is equipped with four main rotors; 
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driven by Lithium Polymer battery powered electric motors. The DJI Phantom 2 that will be operated by 

FRONT PAGE PRODUCTION, 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.

BASIS FOR PETITION

Petitioner, FRONT PAGE PRODUCTION, 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 2, 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, 91.151(b), 91.405(a), 

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

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

aircraft and its operation FRONT PAGE PRODUCTION, LLC operation of DJI Phantom 2 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, FRONT PAGE PRODUCTION, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that 

apply to aircraft with an airworthiness certificate. 

FRONT PAGE PRODUCTION, LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. FRONT PAGE PRODUCTION, 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 2 Instruction Manual). Furthermore, FRONT PAGE PRODUCTION, LLC will document and 

maintain all maintenance records for the DJI Phantom 2 UAS. 

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

limitations: Pilot in command, is requested by FRONT PAGE PRODUCTION, 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 or Drivers license , and who has demonstrated, by meeting minimum flight hour and 

currency requirements, that the PIC is able to safely operate the DJI Phantom UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

FRONT PAGE PRODUCTION, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 2 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. As such, FRONT PAGE PRODUCTION, LLC submits that they will ensure that the DJI 

Phantom 2 UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2

Instruction Manual), and that the aircraft are in a condition for safe flight. 
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FRONT PAGE PRODUCTION, LLC also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 2 UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Phantom 2 UAS 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 

The FRONT PAGE PRODUCTION, LLC ‘S operation of the DJI Phantom 2 UAS within visual line of sight, at 

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

Additionally, FRONT PAGE PRODUCTION, LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. FRONT PAGE PRODUCTION, LLC 

submits that safety will not be affected by operation of the DJI Phantom 2 UAS during daylight hours in 

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

for a total duration of approximately 23 minutes. Battery power indicators are also able to show exactly 

how much battery power is left, as well as how much time is needed to return safely back to point of 

take off.

In accordance with 14 C.F.R. § 11.81, FRONT PAGE PRODUCTION, 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: 

John Elkington

Senior Manager, dba. FRONT PAGE PRODUCTION, LLC 

3743 Forest Park Place

Land O’ Lakes, Fl. 34639

813-918-3003
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B. The Specific Sections Of 14 C.F.R. From Which FRONT PAGE PRODUCTION, 

LLC Seeks Exemption.

 1. FRONT PAGE PRODUCTIONS, 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. FRONT PAGE PRODUCTION, 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. FRONT PAGE PRODUCTION, LLC Seeks Exemption From The Requirements Of 

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

part: 

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

aircraft, as the case may be, by reference to an altimeter that is set, when operating—

 (1) Below 18,000 feet MSL, to—

 (i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

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

the current reported altimeter setting of an appropriate available station; or 

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

airport or an appropriate altimeter setting available before departure.
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4. FRONT PAGE PRODUCTION, LLC Seeks Exemption From The Requirements Of 

Section 91.151(b).

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

 (b), states the following: 

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

and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 20 minutes.

5. FRONT PAGE PRODUCTION, 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. FRONT PAGE PRODUCTION, LLC Seeks Exemption From The Requirements Of 

Section 91.407(a)(1) 

 Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)(1), states the following: (a) No person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless—

 (1) It has been approved for return to service by a person authorized under § 43.7 of this 

chapter[.]

7. FRONT PAGE PRODUCTIONS, LLC. Seeks Exemption From The Requirements 

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

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

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

within the preceding 12 calendar months, it has had –

 (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. 
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8. FRONT PAGE PRODUCTION, 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. 
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 (b) The owner or operator shall retain the following records for the periods prescribed:

 (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

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

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

the aircraft at the time the aircraft is sold. 

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

be retained until the defects are repaired and the aircraft is approved for return to service.

 C. The Extent Of Relief FRONT PAGE PRODUCTION, LLC Seeks And The Reason FRONT PAGE 

PRODUCTION, LLC Seeks The Relief. 

 1. Extent Of Relief FRONT PAGE PRODUCTION, LLC Seeks And The Reason FRONT PAGE 

PRODUCTION, 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 or drivers license, 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, FRONT PAGE PRODUCTION, LLC submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI Phantom 2 UAS unless that PIC has met 

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

either the DJI Phantom 2 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, FRONT PAGE PRODUCTION, LLC submits 

that all flights of the DJI Phantom 2 UAS, conducted by the PIC pursuant to the grant of this Petition: 

 (1) will be incidental to FRONT PAGE PRODUCTION, LLC business; and 

 (2) will not carry passengers or property for compensation or hire. 
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 2. Extent Of Relief FRONT PAGE PRODUCTION, LLC Seeks And The Reason FRONT PAGE 

PRODUCTION, 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 FRONT PAGE PRODUCTION, LLC to determine that the DJI Phantom 2 UAS are in airworthy 

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

(i.e., FRONT PAGE PRODUCTION, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 Instruction Manual). 

FRONT PAGE PRODUCTION, LLC seeks the requested relief because the DJI Phantom 2 UAS do not 

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

PAGE PRODUCTION, LLC will ensure that the DJI Phantom 2 UAS are in airworthy condition based upon 

its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2) prior 

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

conditions and limitations below. 

3. Extent Of Relief FRONT PAGE PRODUCTION, LLC Seeks And The Reason FRONT PAGE 

PRODUCTION, 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 2 UAS, 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), FRONT PAGE 

PRODUCTION, LLC seeks the requested relief because the DJI Phantom 2 UA’s altimeter may be set on 

the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each 

flight. 

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

the extent necessary to comply with the applicable conditions and limitations stated below. As more 

fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2 UAS are 

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

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

information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief FRONT PAGE PRODUCTION, LLC Seeks And The Reason FRONT PAGE 

PRODUCTION, LLC Seeks Relief From Section 91.151(b). 

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

the extent required to allow flights of the battery powered DJI Phantom 2 UAS during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 23 

minutes. FRONT PAGE PRODUCTION, LLC seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the 12 battery powered DJI Phantom 2 UAS will severely 

constrain the practicality of any aerial video or still photo flight operations that FRONT PAGE 

PRODUCTION, LLC proposes to conduct pursuant to this Petition. 

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

Phantom 2 operating documents, and The FRONT PAGE PRODUCTION, LLC’s proposed operating 

limitations, ensure that FRONT PAGE PRODUCTION, LLC will safely operate the battery powered DJI 
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Phantom 2 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 23 minutes. 

5. Extent Of Relief The FRONT PAGE PRODUCTION, LLC Seeks And The Reason FRONT PAGE 

PRODUCTION, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

And 91.417(a) & (b).

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

aircraft with an airworthiness certificate, FRONT PAGE PRODUCTION, LLC requests relief from these 

Sections because the DJI Phantom 2 UAS do not require airworthiness certificates. As set forth more 

fully below, the DJI Phantom 2 UAS meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, FRONT PAGE PRODUCTION, LLC, will use trained technicians to 

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

techniques, and practices prescribed in the UAS operating documents (i.e., FRONT PAGE PRODUCTION, 

LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Instruction Manual). 

Furthermore, FRONT PAGE PRODUCTION, LLC will document and maintain all maintenance records for 

the DJI Phantom 2 UAS. 

 D. The Reasons Why Granting FRONT PAGE PRODUCTION, LLC Request Would Be In The 

Public Interest;

 That Is, How It Would Benefit The Public As A Whole. Granting the present Petition will further the 

public interest by allowing FRONT PAGE PRODUCTION, LLC too safely, efficiently, and economically 

perform aerial video and photography of construction sites, real estate, events and civic landscape over 

certain areas of the United States. 

 Additionally, use of the DJI Phantom 2 UAS will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of FRONT PAGE PRODUCTION, 

LLC’s proposed operation of the DJI Phantom 2 UAS will be realized without implicating any privacy 

issues. 

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

 The DJI Phantom 2 UAS are battery powered and serve as a safe, efficient, and economical 

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

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

DJI Phantom 2 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

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

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

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 UAS do not 

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

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

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

 2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 UAS. 
13

 Conducting aerial acquisitions with the DJI Phantom 2 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 2 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 2 UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an 

internal combustion engine. 

 By using the DJI Phantom 2 UAS to perform aerial acquisitions, the substantial risk to life and property 

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

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

members located onboard the aircraft, the DJI Phantom 2 UAS (weighing approximately 2.6 pounds at 

their maximum gross weight with diagonal dimension of 23.8 inches, and with no fuel on board), has 

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

to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds 

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

 3. Performing Aerial Video and Photography Operations with The DJI Phantom 2 UAS Will 

Benefit The Economy.

 In addition to being safe and efficient, the DJI Phantom 2 UAS are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 UAS 

will allow United States based companies, like FRONT PAGE PRODUCTION, 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 2 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 2 UAS, 

companies such as FRONT PAGE PRODUCTION, 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 2 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, 

FRONT PAGE PRODUCTION, LLC’s proposed operation of the DJI Phantom 2 UAS will not implicate any 

privacy issues. Specifically, the DJI Phantom 2 UAS will be operated only in compliance with operating 

documents (i.e., FRONT PAGE PRODUCTION, LLC Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 2 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. 
14

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 FRONT PAGE PRODUCTIONS, LLC. 

Seeks Exemption.

 1. Reasons Why The DJI Phantom 2 UAS Meet The Conditions Of The FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft and its operation, FRONT PAGE PRODUCTION, LLC’s operation of the DJI Phantom 2

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 if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion of the 

plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this 

Act. 15 

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

the Secretary shall determine, at a minimum—

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

operational capability, proximity to airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace system or the public or pose a threat to 

national security; and 

 (2) Whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

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

unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall 

establish requirements for the safe operation of such aircraft systems in the national airspace system.

 In seeking this exemption, FRONT PAGE PRODUCTION, LLC submits that the DJI Phantom 2 UAS can 

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

the DJI Phantom 2 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

 a. The Specifications Of The DJI Phantom 2 UAS Demonstrate Its Safe Characteristics.

 The DJI Phantom 2 UAS does 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. 
15

i. Technical Specifications Of The DJI Phantom 2 UAS. The technical specifications of the DJI 

Phantom 2 UAS are set forth by the DJI Phantom 2 User Manual, attached hereto as 

Appendix A.

ii. The DJI Phantom 2 UAS Global Positioning Modes Enable The UAS To Remain Within A 

Defined Operational Area. The DJI Phantom 2 UAS may be operated in both manual and 

global positioning flight modes. A complete description of the flight and navigational 

modes of the DJI Phantom 2 UAS is provided at pages 11 of the DJI Phantom 2 User Manual 

attached hereto as Appendix A. 

iii. The DJI Phantom 2 UAS Are Designed For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI 

Phantom 2 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, 

the DJI Phantom 2 UAS does not reacquire control link data from the GCS, the UAS will 

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

mode) via GPS, and will descend to the takeoff position and shutdown. A complete 

description of the Failsafe Functions of the DJI Phantom 2 UAS are set forth at pages 32 

through 41 of the DJI Phantom 2 User Manual, attached hereto as Appendix A.

iv. The DJI Phantom 2 GCS And Its Operation.

a. A complete description of the operation and specifications of the DJI Phantom 2 GCS 

and flight control software is provided at pages 7 through 15 of the DJI Phantom 2 User 

Manual. DJI Phantom 2 User Manual is attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 2 UAS Is Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. FRONT PAGE PRODUCTION, LLC 

video production staff will be the only persons to act as a pilot in command (PIC) of the 

DJI Phantom 2 UAS. Additionally, a safety observer will assist him at all times during flight 

time. 

c. Flights Of DJI Phantom 2 UAS Will Be Conducted Pursuant To Specific Operating 

Limitations. In seeking this exemption, FRONT PAGE PRODUCTION, LLC proposes to 

commercially operate DJI Phantom 2 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 UAS weighing less than 55 

pounds maximum gross weight: DJI Phantom 2 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. 
16

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

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

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

permitted. 

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

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC 

must be able to communicate verbally at all times. Electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perform the functions prescribed in the operating documents. 

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

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments. 

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

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

exists between the conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions and limitations 

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

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

operator may update or revise its operating documents. It is the operator’s responsibility 

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

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

petitions for extension or amendment to the grant of exemption. If the operator 

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

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

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

arise regarding updates or revisions to the operating documents. 

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

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

UAS, the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations 

must be properly documented in the aircraft records. 

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

operation or flight characteristics, e.g. replacement of a flight critical 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. 
17

 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 UAS 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 

thirdclass medical certificate or drivers license. 

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

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

a manner consistent with how the UAS will be operated under the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner 

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s 

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

only be conducted during dedicated training sessions. During training, proficiency, and 

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

nonparticipants, and the PIC must operate the UA with appropriate distance from 

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

 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

All operations must be conducted under visual meteorological conditions (VMC). If flight 

at night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized. 

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

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

that airport’s management is obtained, and the operation is conducted in accordance 

with a NOTAM as required by the operator’s COA. The letter of agreement with the 

airport management must be made available to the Administrator upon request. 

 21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

 22. If the UA loses communications or loses its GPS signal, it must return to a 

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

accordance with the operating documents. 

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

in accordance with the operating documents. 
18

 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 a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately and/or; 

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

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

PIC has made a safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard, and; 

 c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a). 

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

permission from the land owner/controller or authorized representative. Permission 
19

from land owner/controller or authorized representative will be obtained for each flight 

to be conducted. 

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

boundaries of the operational area as defined by the applicable COA. must be reported 

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

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

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

Not Adversely Affect Safety.

 FRONT PAGE PRODUCTION, 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 2 UAS 

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

PIC is able to safely operate the DJI Phantom 2 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

 Considering FRONT PAGE PRODUCTIONS, LLC’s proposed area of operations, and the operating 

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

those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary 

to safely operate the DJI Phantom 2 UAS, FRONT PAGE PRODUCTIONS, LLC submits that the additional 

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

airmanship skills necessary for FRONT PAGE PRODUCTION, LLC’s specific proposed flight operations. 

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

circumstances similar, in all material respects, to those pSresented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11158, 11159, 11160, 11161). 

 FRONT PAGE PRODUCTION, LLC will not allow any PIC to operate the DJI Phantom 2 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 2 UAS training 

and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 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 21 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 Front 

Page Production’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: 
20

 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, page 15. 

 Accordingly, FRONT PAGE PRODUCTIONS, LLC., will ensure safe operations by not allowing 

any PIC to operate the DJI Phantom 2 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 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, FRONT PAGE PRODUCTIONS, LLC., will ensure that the DJI Phantom 2 UAS is in an airworthy 

condition based upon the UAS’s compliance with its operating documents and as stated in the 

conditions and limitations herein.

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

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

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

Adversely Affect Safety.

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

information of the DJI Phantom 2 UAS will be provided to the PIC via GPS equipment and a radio 

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

the flight path and altitude. This altitude information, combined with FRONT PAGE PRODUCTIONS, LLC.

operation of the DJI Phantom 2 UAS within visual line of sight, at or below 500 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. The altitude information will be generated by GPS 
21

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UAS at ground level. 

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

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

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety.

 A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of

 (1) the technical specifications of the DJI Phantom 2 UAS; 

 (2) the limitations on the proposed flight operations; and 

 (3) the location of the proposed flight operations. Accordingly, FRONT PAGE PRODUCTIONS, LLC.

will ensure that it will safely operate the battery powered DJI Phantom 2 UAS during daylight hours in 

VFR conditions, with enough battery power to fly for a total duration of 23 minutes. 

 Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 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 2 UAS provide audible and visual warnings to the PIC at the GCS when the 

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

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

level, the DJI Phantom 2 UAS will descend and land automatically. 

 Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the UAS 

are considered. Relief has been granted for manned aircraft to operate at less than the minimums 

prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has 

previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

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

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 

 6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

 In seeking this exemption, FRONT PAGE PRODUCTIONS, 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because FRONT PAGE 

PRODUCTIONS, 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., FRONT PAGE PRODUCTIONS, LLC. Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 2 Instruction Manual). Furthermore, FRONT PAGE PRODUCTIONS, LLC will document 

and maintain all maintenance records for the DJI Phantom 2 UAS. 
22

 Since the DJI Phantom 2 UAS will be inspected as prescribed by the operating documents, FRONT 

PAGE PRODUCTIONS, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 User Manuals are attached hereto as 

Appendix A and B; a copy of the DJI Phantom 2 UAS Maintenance LOG is attached hereto as Appendix C. 

 Likewise, the exemption sought will not adversely affect safety because FRONT PAGE PRODUCTIONS, 

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 2 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)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered. 

 In consideration of FRONT PAGE PRODUCTIONS, LLC’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 UAS, FRONT PAGE PRODUCTIONS, LLC.

submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

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

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

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 

entitled Special Conditions,

 FRONT PAGE PRODUCTIONS, LLC. requests that the FAA prescribe special conditions for the 

intended operation of the DJI Phantom 2 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 §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAS 

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

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

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

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

in accordance with any requirements that must be established for the safe operation of the UAS in the 

NAS. 

 Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the DJI Phantom 2 UAS, 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 
23

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

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

finds necessary to establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16.

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

special conditions for Leading Edge’s intended operation of the DJI Phantom 2 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 25 61.113(a) & (b), 91.7(a), 91.121, 

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

 • A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

FRONT PAGE PRODUCTIONS, LLC. Seeks Exemption:

 FRONT PAGE PRODUCTIONS, LLC. seeks exemption from the requirements of 14 C.F.R Sections 

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

(b). 

 A Brief Description Of The Nature Of The Exemption FRONT PAGE PRODUCTIONS, LLC. Seeks:

 This exemption will permit FRONT PAGE PRODUCTIONS, 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. 

 • Any Additional Information, Views, Or Arguments Available To Support The FRONT PAGE 

PRODUCTIONS, 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, FRONT PAGE PRODUCTIONS, 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 poses a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification. As discussed in detail above, 

FRONT PAGE PRODUCTIONS, LLC.will operate the DJI Phantom 2 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. 
24

CONCLUSION

As set forth herein, FRONT PAGE PRODUCTIONS, 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 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 of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing 

FRONT PAGE PRODUCTIONS, LLC. to safely, efficiently, and economically operate the DJI Phantom 2 UAS 

commercially within the NAS. 

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

Reform Act of 2012, Section 333, FRONT PAGE PRODUCTIONS, 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and 

permit Leading Edge to operate the DJI Phantom 2 UAS commercially for the purpose of conducting 

aerial video and photography over certain areas of the United States. 

Dated: December 17, 2015 

Respectfully submitted, 

Meredith N. Napoli, Owner/John Elkington, Senior Manager,

dba. FRONT PAGE PRODUCTIONS, LLC.

3743 Forest Park Place

Land O’Lakes, Fl. 34639

813-918-3003

Appendices: 

A – Link to DJI Phantom 2 Manual: Click on link below 

http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf