UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Vincent Urgo 

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)(1),

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 3 PROFESSIONAL AND DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on October 10th, 2015

Vincent Urgo

Urgonomic Enterprises, LLC.

518 North 18th Ave.

Bozeman, MT 59715

(406) 600-2693
TABLE OF CONTENTS

Page

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER.............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VINCENTURGO/

URGONOMIC ENTERPRISES, LLC. SEEKS 

EXEMPTION.................................................................8

THE EXTENT OF RELIEF VINCENTURGO/URGONOMIC ENTERPRISES, LLC. 

SEEKS AND THE REASON MORTENSEN PHOTOGRAPHY SEEKS THE 

RELIEF.........................11

THE REASONS WHY GRANTING VINCENTURGO/URGONOMIC 

ENTERPRISES, LLC’S REQUEST WOULD BE IN THE PUBLIC 

INTEREST

.........................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY..........................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT VINCENTURGO/URGONOMIC 

ENTERPRISES, LLC’S REQUEST.........34

CONCLUSION....................................................................................................................35

APPENDICES........................................................................................37
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

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

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
SUMMARY

Vincent Urgo 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 pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Vincent Urgo/

Urgonomic Enterprises, 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

Vincent Urgo provides its clients with aerial photo and video. Vincent Vincent Urgo has 

over 15 years of professional video and photography and is recognized as an expert in digital 

media. I have over 3 years professional experience in all aspects of aerial video and 

photography. The objective of Vincent Urgo aerial video and photography operations is to 

provide high quality imaging for a variety of commercial, public, and residential uses, 

specifically targeting:

• Aerial event filming and photography

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

• Real Estate Photography.

• Promotional videos for businesses, non-profits & government agencies
BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs

Vincent Urgo seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 3 Professional and DJI Inspire 1 are vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The DJI Phantom 3

Professional has a maximum gross weight of approximately 2 pounds 11 ounces, while having a 

length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of 

approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, 

a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a

maximum speed of approximately 42 knots. The DJI Phantom 3 Professional and DJI 

Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

The DJI Phantom 3 Professional and DJI Inspire 1 UAs that will be operated by 

Vincent Urgo 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, Vincent Urgo, 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 Professional, DJI
Inspire 1 UASs 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, Vincent Urgo’s operation of DJI Phantom 3 

Professional and DJI Inspire 1 UASs 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, Vincent Urgo 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 only apply to aircraft with an airworthiness certificate.

Vincent Urgo submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Vincent Urgo will use experienced personnel or technicians to perform 

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

and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI 

Phantom 3 Professional and DJI Inspire 1 Instruction Manual). Furthermore, Vincent Urgo will 

document and maintain all maintenance records for the DJI Phantom 3 Professional and DJI 

Inspire 1

UASs.

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

privileges and limitations: Pilot in command, is requested by Vincent Urgo 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 Professional and DJI Inspire 1 UASs in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Vincent Urgo seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3 Professional and DJI Inspire 1 UASs do not require an 

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

Urgo submits that he will ensure that the DJI Phantom 3

Professional and DJI Inspire 1UASs 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, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual), and 

that the aircraft are in a condition for safe flight.

Vincent Urgo also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional and DJI Inspire 1

UAs will not have a typical barometric altimeter onboard. However, altitude information of 

the DJI Phantom 3 Professional and DJI Inspire 1UAs 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 Vincent Urgo’s operation of the DJI

Phantom 3 Professional and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet 

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

Additionally, Vincent Urgo’s seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Vincent Urgo submits 

that safety will not be affected by operation of the DJI Phantom 3

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

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

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, Vincent Urgo provides the following information in 

support of its petition for exemption:

A. Name And Address Of The Petitioner.

Vincent Urgo

Urgonomic Enterprises, LLC.

518 North 18th Ave.

Bozeman, MT 59715

(406) 600-2693

B. The Specific Sections Of 14 C.F.R. From Which Vincent Urgo Seeks

Exemption.

1. Vincent Urgo 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. Vincent Urgo 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. Vincent Urgo 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.

4. Vincent Urgo 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. Vincent Urgo 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. Vincent Urgo 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. Vincent Urgo 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.

8. Vincent Urgo 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)(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 Vincent Urgo Seeks And The Reason Mortensen

Photography Seeks The Relief.

1. Extent Of Relief Vincent Urgo Seeks And The Reason Mortensen

Photography 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, Vincent Urgo submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional 

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

requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 3 

Professional or DJI Inspire 1 UAS in a manner consistent with the operations specifications as 

described in this exemption, including evasive and emergency
maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and 

structures.

Further, Vincent Urgo submits that all flights of the DJI Phantom 3

Professional and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to Vincent Urgo’s business; and (2) will not carry passengers or property 

for compensation or hire.

2. Extent Of Relief Vincent Urgo Seeks And The Reason Vincent Urgo 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 Vincent Urgo to determine that the DJI Phantom 3

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

that the UAS is in compliance with the operating documents (i.e., the Vincent Urgo Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3

Professional and DJI Inspire 1 Instruction Manual).

Vincent Urgo seeks the requested relief because the DJI Phantom 3

Professional and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, Vincent Urgo will ensure that the DJI Phantom 3 

Professional and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with 

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

DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the aircraft 

are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Vincent Urgo Seeks And The Reason Vincent Urgo 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 Professional and DJI Inspire 1 UASs, which utilize a 

barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to 

downlink altitude information from the UA to the PIC at the ground control station (GCS). Since 

the FAA requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Vincent Urgo seeks the requested relief 

because the DJI Phantom 3 Professional and DJI Inspire 1 UA’s altimeter may be set on the 

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

flight.

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

91.121 is sought to the extent necessary to comply with the applicable conditions and 

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

maintained since the DJI Phantom 3 Professional and DJI Inspire 1 UAs are equipped with a 

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

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

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

4. Extent Of Relief Vincent Urgo Seeks And The Reason Mortensen

Photography 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 3 

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

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

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

after that for at least 4.5 minutes. Vincent Urgo seeks the requested relief
because without an exemption from Section 91.151(b), the flight time duration of the battery 

powered DJI Phantom 3 Professional and DJI Inspire 1 UAs will severely constrain the 

practicality of any aerial video or still photo flight operations that Vincent Urgo proposes to 

conduct pursuant to this Petition.

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

Professional and DJI Inspire 1 UASs, the DJI Phantom 3 Professional and DJI Inspire 1 operating 

documents, and Vincent Urgo proposed operating limitations, ensure that Vincent Urgo will 

safely operate the battery powered DJI Phantom 3

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

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

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

after that for at least 4.5 minutes.

5. Extent Of Relief Vincent Urgo Seeks And The Reason Mortensen

Photography 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, Vincent Urgo requests relief from these 

Sections because the DJI Phantom 3 Professional and DJI Inspire 1 UASs do not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 3

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

without an airworthiness certificate. Accordingly, Vincent Urgo will use trained technicians to 

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

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

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI 

Inspire 1 Instruction Manual).
Furthermore, Vincent Urgo will document and maintain all maintenance records for the DJI 

Phantom 3 Professional and DJI Inspire 1 UASs.

D. The Reasons Why Vincent Urgo Photography’s 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 Vincent Urgo 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 3 Professional and DJI Inspire 1 UASs will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of Vincent Urgo’s proposed operation of the DJI Phantom 3 

Professional and DJI Inspire 1 UASs will be realized without implicating any privacy issues.

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

The DJI Phantom 3 Professional and DJI Inspire 1 UAs are battery powered and 

serve as a safe, efficient, and economical alternative to the manned aircraft traditionally 

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

perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3

Professional or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, 

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

on the ground.

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

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

Phantom 3 Professional and DJI Inspire 1 UAs do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography
missions would result in fewer aircraft that must be handled by air traffic control during the 

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

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

Phantom 3 Professional and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 3 Professional and DJI Inspire

1 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the 

levels of air and noise pollution generated during traditional aerial video and still photography 

flight operations. By using battery power and electric motors, the DJI Phantom 3 Professional 

and DJI Inspire 1 UASs produce no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 gallons 

per hour of leaded aviation fuel. The DJI Phantom 3 Professional and DJI Inspire 1 UAs, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs 

are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 Professional and DJI Inspire 1 UASs to perform aerial 

acquisitions, the substantial risk to life and property in the air and on the ground, which is 

usually associated with traditional manned aircraft flight operations, will be substantially 

reduced or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Phantom 3 Professional and DJI Inspire 1 UAs (weighing approximately 2 

pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with 

lengths of 16 inches and 17.3 inches respectively, widths of

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

collateral damage to life and property on the ground, and in the air, compared
to the manned aircraft that typically conduct similar operations (weighing approximately

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

capacity of 180 gallons).

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

Professional and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional and DJI Inspire 1 

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

operations. As such, operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will 

allow United States based companies, like Vincent Urgo, 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 Professional and DJI Inspire 

1 UASs is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft.

By operating the DJI Phantom 3 Professional and DJI Inspire 1 UASs, companies such 

as Vincent Urgo, 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 Professional and DJI Inspire 1 UASs, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United States and 

abroad.
4. There Are No Privacy Issues.

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

Vincent Urgo’s proposed operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs 

will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the Vincent 

Urgo Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and 

DJI Inspire 1 Instruction Manual) which requires property owner involvement as well as local 

law enforcement notification, and in accordance with the Federal Aviation Regulations, including 

the minimum altitude requirements of 14 C.F.R. § 91.119.

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 Vincent Urgo Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional and DJI Inspire 1 UAs Meet The 

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

333.

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

the unmanned aircraft and its operation, Vincent Urgo’s operation of the

DJI Phantom 3 Professional and DJI Inspire 1 UASs meet the conditions of FMRA Section

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a hazard 

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

FMRA Section 333 states the following, in part:
(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan

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

section 334 of this Act.

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

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

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

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

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

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

threat to national security; and

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

certification under section 44704 of title 49, United States Code, is required 

for the operation of unmanned aircraft systems identified under paragraph 

(1).

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

certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such 

aircraft systems in the national airspace system.

In seeking this exemption, Vincent Urgo submits that the DJI Phantom 3

Professional and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 

333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Professional and DJI Inspire 1

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 3 Professional and DJI Inspire 1 UASs do not create a hazard to users 

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

weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 Professional and DJI 

Inspire 1 UASs.
The technical specifications of the DJI Phantom 3 Professional and DJI Inspire 1

UASs are set forth by the DJI Phantom 3 Professional and DJI Inspire 1 Specifications and

Data Sheet, attached hereto as Exhibit A and B.

ii. The DJI Phantom 3 Professional and DJI Inspire 1 UASs 

Autonomous Flight And Navigation Modes Enable The UASs To 

Remain Within A Defined Operational Area.

The DJI Phantom 3 Professional and DJI Inspire 1 UASs may be operated in both 

manual and fully autonomous flight modes. A complete description of the flight and navigational 

modes of the DJI Phantom 3 Professional and DJI Inspire 1 UASs is provided at pages 25-35 of 

the DJI Phantom 3 Professional and pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, 

attached hereto as Exhibit C and D.

iii. The DJI Phantom 3 Professional and DJI Inspire 1 UASs Are Designed 

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

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 Professional and DJI Inspire 1

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

3 Professional and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs 

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

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

A complete description of the Failsafe Functions of the DJI Phantom 3 Professional

UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the 

DJI Phantom 3 Professional and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and 

D.

iv. The DJI Phantom 3 Professional and DJI Inspire 1 GCS And Its

Operation

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

Professional and DJI Inspire 1 GCS and flight control software is provided at pages 32 through 

43 of the DJI Phantom 3 Professional User Manual and pages 40 through 47 of the DJI Inspire 1 

User Manual. DJI Phantom 3 Professional and DJI Inspire 1 User Manuals

are attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 3 Professional and DJI Inspire 1

UASs Are Limited To The Line Of Sight Of A Certificated Pilot in

Command With A Safety Observer.

Vincent Urgo 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 Professional and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots 

during flight time.

c. Flights Of DJI Phantom 3 Professional and DJI Inspire 1 UASs Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Vincent Urgo proposes to commercially operate DJI 

Phantom 3 Professional and DJI Inspire 1 UASs for the special purpose of conducting aerial 

video and photography over certain areas of United States, pursuant to the following specific 

operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 

pounds maximum gross weight: DJI Phantom 3 Professional and DJI Inspire 1

Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this grant.

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

the purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operating
documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL.

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

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

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

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

permitted.

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

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

PIC must be able to communicate verbally at all times. Electronic messaging or 

texting is not permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the flight. The 

PIC must ensure that the SO can perform the

functions prescribed in the operating documents.

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

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

permitted to operate the camera or other instruments.

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

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

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

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

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

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to the 

grant of exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted the exemption, then the operator must 

petition for amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or revisions to the 

operating documents.

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

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

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

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

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

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

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

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

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

flight must make an entry in the aircraft records.

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

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

relevant sections of the operating documents.

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

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

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

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, 

and the signature of the authorized person returning the UAS to service.

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

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

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

third- class medical certificate.

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

qualification criteria and demonstrates the ability to safely operate the UAS in a 

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

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures. PIC qualification flight hours must be 

logged in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are

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

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

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

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

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

91.119.

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

1.1. All operations must be conducted under visual meteorological conditions

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

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

(SVFR) are not authorized.
20. The UA may not operate within 5 nautical miles of an airport reference point as 

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

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

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

agreement with the airport management must be made available to the Administrator 

upon request.

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

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

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

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

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

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

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. All operations shall be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements.

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

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable.

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

control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requirements.

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

to the PIC at the Ground Control Station of the UAS any time the UAS is 

operating. These documents must be made available to the Administrator or any 

law enforcement official upon request.

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

operations and activities at all times.
30. The UAS may not be operated by the PIC from any moving device or vehicle.

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

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or;

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

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

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

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

c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a).

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

permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

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

must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov.

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

(b) Would Not Adversely Affect Safety.

Vincent Urgo 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 

Professional and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 

Professional or DJI Inspire 1 UAS in a manner consistent with
the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Considering Vincent Urgo’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 3

Professional or DJI Inspire 1 UAS, Vincent Urgo submits that the additional manned 

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

airmanship skills necessary for Vincent Urgo’s specific proposed flight operations.

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

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

Vincent Urgo will not allow any PIC to operate the DJI Phantom 3

Professional or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the DJI Phantom 3 Professional or DJI Inspire 1 UAS training and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 3

Professional or DJI Inspire 1 UAS in a manner consistent with this exemption, including 

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

vehicles and structures.

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

14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a
minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS 

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

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

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

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

safety during Vincent Urgo’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, Vincent Urgo will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the
PIC is able to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner 

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

appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety.

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

because prior to every flight, Vincent Urgo will ensure that the DJI Phantom 3

Professional or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations 

herein.

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

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

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

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

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

the altitude information of the DJI Phantom 3 Professional and DJI Inspire 1 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 Vincent Urgo’s operation of the DJI Phantom 3 Professional 

and DJI Inspire 1 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 equipment installed onboard the aircraft.
Prior to each flight, a zero altitude initiation point is automatically established by the UASs at 

ground level.

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

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

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

Would Not Adversely Affect Safety.

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

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 

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

(3) the location of the proposed flight operations. Accordingly, Vincent Urgo will ensure that it 

will safely operate the battery powered DJI Phantom 3

Professional and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

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

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3

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

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

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

Phantom 3 Professional and DJI Inspire 1 UASs provide audible and visual warnings to the PIC 

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

approximately 33% remaining battery power, and again at approximately 10%
remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and

DJI Inspire 1 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

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

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

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

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

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

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

11157, 11158, 11159, 11160, 11161).

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, Vincent Urgo 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 Vincent Urgo 

will use trained technicians to perform maintenance, alterations, or preventive maintenance on the 

UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., 

the Vincent Urgo Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3

Professional and DJI Inspire 1 Instruction Manual). Furthermore, Vincent Urgo will document 

and maintain all maintenance records for the DJI Phantom 3 Professional and DJI Inspire 1 

UASs.
Since the DJI Phantom 3 Professional and DJI Inspire 1 UASs will be inspected as 

prescribed by the operating documents, Vincent Urgo 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 3 Professional and DJI Inspire 1 User Manuals are 

attached hereto as Exhibit C and D; a copy of the DJI Phantom 3 Professional and DJI Inspire 1 

UAS Maintenance LOG is attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because Vincent Urgo 

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 Professional and DJI Inspire 1 UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

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

adversely affected when the technical characteristics and operating limitations of the UAS are 

considered.

In consideration of Vincent Urgo’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, 

Vincent Urgo 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, Vincent Urgo requests that the FAA 

prescribe special conditions for the intended operation of the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that

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

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such 

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

aerial video and photography over certain areas of the United States for compensation or hire. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification in 

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

the NAS.

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

§ 21.16, for operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate
safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following:

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

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

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

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the

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

regulations.

See 14 C.F.R. § 21.16.

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

prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 3 

Professional and DJI Inspire 1 UASs, which contain such safety standards that the Administrator 

finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R Sections 61.113(a) & (b),

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

F. A Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Vincent Urgo Seeks Exemption:

Vincent Urgo 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 Mortensen

Photography Seeks:

This exemption will permit Vincent Urgo 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

Vincent Urgo’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, Vincent Urgo’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, Vincent Urgo will operate the DJI Phantom

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

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

CONCLUSION

As set forth herein, Vincent Urgo 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 3 Professional and DJI Inspire 1 UASs 

commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

video and photography over certain areas of the United States. By granting this Petition, the 

FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing Vincent Urgo 

to safely, efficiently, and economically operate the DJI Phantom 3 Professional and DJI Inspire 1 

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

Modernization and Reform Act of 2012, Section 333, Vincent Urgo 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 3 Professional and DJI Inspire 1 UASs commercially for the purpose of conducting 

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

Dated: July 8, 2015

Respectfully submitted, 

Vincent Urgo

Urgonomic, LLC.

518 North 18th Ave. 

Bozeman, MT 59715

Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet

C – DJI Phantom 3 Professional Manufacturer’s User Manual

D – DJI Inspire 1 Manufacturer’s User Manual

E – Monthly Maintenance Log
APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

Vincent Urgo only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI 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)

1.1 DJI Phantom 3 Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2.82lbs (1280g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .5m; Horizontal: 1.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 5m/s

1.1.1.7 Max Descent Speed – 3m/s

1.1.1.8 Max Flight Speed – 16m/s (NOT RECOMMENDED)

1.1.2 Gimbal

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

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender
1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Vincent Urgo only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI 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##DJIInspire##1

2.2.1 #Aircraft

2.2.1.1 #Model# –T600

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

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

2.2.1.4 #MaxAngularVelocity–Pitch:####3000/s;####Yaw:###1500/s

2.2.1.5 #MaxTiltAngleX350

2.2.1.6 #MaxAscentSpeed–5m/s

2.2.1.7 #Max DescentSpeed##–4m/s

2.2.1.8 #Max Speed##–22m/s(ATTImode,nowind–NOT#

RECOMMENDED)

2.2.1.9 #MaxFlightAltitude–4500m

2.2.1.10 #Max Wind##Resistance##–10m/s

2.2.1.11 #MaxFlightTime–Approximately18minutes

2.2.1.12# Motor#Model–DJI3510

2.2.1.13# Propeller#Model–DJI1345

2.2.1.14 #OperatingTemperatureRange–140F#to#1040F#(X100C#to#400C)

2.2.1.15 #Dimensions–17##1⁄4”x17##3⁄4”x12”

2.2.2 #Gimbal

2.2.2.1 #Model# –ZENMUSEX3

2.2.2.2 #OutputPower(withcamera)–Static:####9W;###In###Motion:###11W

2.2.2.3# Operating##Current–Static:####750mA; InMotion:900mA

2.2.2.4 #AngularVibrationRangeX±0.030
2.2.2.5# Mounting##–Detachable

2.2.2.6# Controllable#Range##–Pitch:##X900to#+300;#Pan:#±3200

2.2.2.7# MechanicalRange##–Pitch:##X1250to#450;#Pan:#±3300

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

2.2.3 #Camera

2.2.3.1 #Name–X3

2.2.3.2 #Model# –FC350

2.2.3.3 #Total Pixels#–12.76M

2.2.3.4# Effective##Pixels#–12.4M

2.2.3.5 #ImageMaxSize–4000x3000

2.2.3.6 #ISO Range##–100X3200

2.2.3.7# Field#of#ViewX940

2.2.3.8# CMOS#–Sony####EXMOR# #1/2.3”

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

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

HD:# 1280x720p24/25/30/48/50/60

2.2.3.10 #OperatingTemperatureRangeX320F#X1040F#(00C#X400C)

2.2.4 #Transmitter

2.2.4.1 #Name–C1

2.2.4.2# Operating##Frequency–5.728X5.850GHz;###2.400X2.483GHz

2.2.4.3 #CommunicatingDistance(unobstructed)–2000m

2.2.4.4 #Output# Power#–9W

2.2.4.5 #OperatingTemperatureRangeX140F#to#1040F#(X100C#to#400C)

2.2.4.6# Battery##–600mAhLiPo2S

APPENDIX – C

DJI Phantom 3 Professional Manufacturer’s User Manual

A link may be found at:

http://download.dji- innovations.com/downloads/phantom_3/en/

Phantom_3_Professional_User_Manual_v1.2_ en.pdf
APPENDIX – D

DJI Inspire 1 Manufacturer’s User Manual

A link may be found at:

http://download.dji- innovations.com/downloads/inspire_1/en/

Inspire_1_User_Manual_v1.2_en.pdf

APPENDIX – E

MONTHLY$MAINTENANCE

$LOG month: (year:

UAS$#:$ Date(Issue(

Discovered

Date(Issue(

Addressed

Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:(((

Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: