UNITED STATES OF AMERICA DEPARTMENT 

OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

VIDEO TECHNOLOGY

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), 91.103(b)(2), 91.105, 91.109, 

91.119 (b) (c) (d), 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 A DJI PHANTOM QUADCOPTER, A DJI 

PHANTOM II VISION PLUS QUADCOPTER, A DJI INSPIRE-1 PRO QUADCOPTER UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on 12/16/2015

Video Technology

Randal Schildmeyer Owner/Founder

235 Boyson Rd. NE

Cedar Rapids, IA 52402

319 377-4542

rschildmeyer@mchsi.com

CDL Hazmet
2

GLOSSARY OF ABBREVIATIONS

AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

FLIR

GCS 

GPS 

LOL 

NAS

NOTAM 

PIC

Section 333 

SO

SOP 

UA 

UAS 

UAV 

VFR 

VLOS 

VMC 

VTOL

Above Ground Level 

Area of Interest

Air Traffic Control

Air Traffic Organization 

Aerial Vehicle

Code of Federal Regulations 

Certificate of Authorization Federal 

Aviation Administration Federal 

Aviation Regulation Ground Control 

Forward looking infrared Radiometer

Station

Global Positioning System 

Loss of Link

National Airspace System 

Notice to Airman

Pilot in Command

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

Observer

Standard Operating Procedures 

Unmanned Aircraft

Unmanned Aircraft System 

Unmanned Aerial Vehicle 

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions 

Vertical Takeoff and Landing
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SUMMARY

Video Technology seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.103(b)(2), 91.105, 91.109, 91.119 (b) (c) (d), 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 Video Technology to operate Unmanned Aircraft Systems, small 

(UASs) for the commercial purpose of conducting aerial video and photography of 

construction sites, real estate, sporting events, construction site, farm surveys, low-profile 

news events, landscape, inspections of equipment and power line systems using normal and 

FLIR cameras within the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Video Technology provides its clients with expertise and knowledge in advanced technologies 

and solutions to increase efficiency, productivity and effectiveness. Randal Schildmeyer, founder 

of Video Technology has had over 40-years’ experience in the television industry in all aspects of 

it video and photography, engineering, and has over 300 hours of flight time on various sizes of 

Unmanned Aerial Vehicles (UAV). The objective of Video Technology doing aerial video and 

photography operations is to provide high quality imaging for a variety of commercial, sports, 

public, residential, low priority news stories and governmental uses, specifically targeting the 

following:

 Construction sites before, during and after

 Events public and private

 Real-estate marketing

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

 Farm Land inspections

 DNR, County Parks projects and promotions

 Search and Rescue operations

 Commercial, Sports, low priority news production

 Power line inspections using FLIR cameras to inspect lines and insulators for heat and 

possible points of failure.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom II quadcopter, DJI Phantom II Vison + quadcopter and 

DJI Inspire quadcopter UAVs Video Technology seeks an exemption to operate UASs for 

compensation or hire within the NAS. The DJI Phantom II quadcopter, DJI Phantom II Vison+

quadcopter and DJI Inspire-1 pro quadcopter are vertical takeoff and landing (VTOL) Unmanned 

Aerial Vehicle (UAV) with a Ground Control Station (GCS) utilizing electronic tablet or laptop.

1. The DJI Phantom-II quadcopter has a maximum gross weight of approximately 3

pounds, while having a length of 17 inches width of 17 inches (propeller tip to propeller 

tip), height of 8 inches, and a maximum speed of approximately 30 knots The DJI 

Phantom quadcopter UAV is equipped with four main rotors; driven by a DJI 5200mAh 

LiPo Battery to power four electric motors and on board electronics. 

2. The DJI Phantom II vision + quadcopter has a maximum gross weight of approximately 

3 pounds, a length of 17 inches, width of 17 inches (propeller tip to propeller tip), height 
4

of 8-inches, and a maximum speed of approximately 30 knots. The DJI Phantom II 

Vision+ quadcopter is equipped with four main rotors; driven by a DJI 5200mAh LiPo 

Battery to power four electric motors and on board electronics.

3. The DJI Inspire-1 Pro quadcopter has a maximum gross weight of approximately 6.5

pounds, a length of 17.75 inches, width of 17.5 inches (propeller tip to propeller tip), 

height of 12-inches, and a maximum speed of approximately 42 knots., and the DJI 

Phantom II Vision+ quadcopter is equipped with four main rotors; driven by a DJI 

5700mAh LiPo-6S Battery to power four electric motors and on board electronics.

 The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and DJI Inspire-1 Pro

quadcopter UAVs that will be operated by Video Technology 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, Video Technology, 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the 

DJI Inspire-1 Pro quadcopter 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), 91.103(b)(2), 91.105(a), 91.109(a)1 &

(a)(2), 91.119 (b)(c)(d), 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, Video Technology operation of The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 Pro quadcopter UAVs 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, Video Technology 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.

Video Technology submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Video Technology 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 

Instruction Manuals). Furthermore, Video Technology will document and maintain all maintenance 

records for The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 Pro 

quadcopter UAVs.

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

privileges and limitations: Pilot in command, is requested by Video Technology to the extent 

necessary to allow a Pilot in Command (PIC) who is able to safely operate The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 Pro quadcopter UAVs in a manner 

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

appropriate distances from people, vessels, vehicles and structures.
5

Video Technology seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 Pro 

quadcopter UAVs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Video Technology submits that it will ensure that The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 Pro quadcopter are in an airworthy 

condition, prior to every flight, by determining that the UAVs are in compliance with the operating

documents (i.e., Monthly Maintenance Log, Instruction Manuals), and that the aircraft are in a 

condition for safe flight.

Video Technology also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire1 Pro quadcopter UAVs will not have a typical barometric altimeter onboard. However, altitude 

information of The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 Pro 

quadcopter UAVs will be provided to the PIC via Global Positioning System (GPS) equipment, and 

radio communications telemetry data link, which downlinks from the UAVs to the GCS for active 

monitoring of the flight path. This altitude information, combined with Video Technology’ operation 

of The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 Pro quadcopter

UAVs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.

Additionally, Video Technology seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Video Technology submits that 

safety will not be affected by operation of The DJI Phantom II quadcopter, DJI Phantom II Vision+

and the DJI Inspire-1 Pro quadcopter UAVs 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 25 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, Video Technology 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: Video Technology

Randal H Schildmeyer, owner/founder 

235 Boyson Rd N.E.

Cedar Rapids, IA 52402

321-228-7714

rschildmeyer@mchsi.com

B. The Specific Sections of 14 C.F.R. From Which Video Technology Seeks Exemption.

1. Video Technology 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
6

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

(a) The flight is only incidental to that business or employment; and

(b) The aircraft does not carry passengers or property for compensation or hire.

2. Video Technology 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. Video Technology Seeks Exemption From The Requirements Of Section 

91.103(b) (2).

Section 91.103 (b) (2) Pre-Flight action

(b) For any flight, runway lengths at airports of intended use, and the 

following takeoff and landing distance information:

(2) For civil aircraft other than those specified in paragraph (b)(1) of 

this section, other reliable information appropriate to the aircraft, 

relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and 

temperature.

4. Video Technology Seeks Exemption From The Requirements Of Section 

91.105.

Section 91.105 Flight crewmembers at stations.

(a) During takeoff and landing, and while in route, each required flight 

crewmember shall—

(1) Be at the crewmember station unless the absence is necessary 

to perform duties in connection with the operation of the 

aircraft or in connection with physiological needs; and

(2) Keep the safety belt fastened while at the crewmember 

station.

(b) Each required flight crewmember of a U.S.-registered civil aircraft 

shall, during takeoff and landing, keep his or her shoulder harness 

fastened while at his or her assigned duty station. This paragraph 

does not apply if—

(1) The seat at the crewmember's station is not equipped with a 

shoulder harness; or

(2) The crewmember would be unable to perform required duties 

with the shoulder harness fastened.
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5. Video Technology Seeks Exemption From The Requirements Of Section 

91.109.

Section 91.109 Flight instruction

Simulated instrument flight and certain flight tests.

(a) No person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. However, instrument flight instruction may 

be given in an airplane that is equipped with a single, functioning 

throw-over control wheel that controls the elevator and ailerons, in 

place of fixed, dual controls, when—

(1) The instructor has determined that the flight can be conducted 

safely; and

(2) The person manipulating the controls has at least a private 

pilot certificate with appropriate category and class ratings.

(b) An airplane equipped with a single, functioning throw-over control 

wheel that controls the elevator and ailerons, in place of fixed, dual 

controls may be used for flight instruction to conduct a flight review 

required by§ 61.56 of this chapter, or to obtain recent flight 

experience or an instrument proficiency check required by § 61.57

when—

(1) The airplane is equipped with operable rudder pedals at both 

pilot stations;

(2) The pilot manipulating the controls is qualified to serve and 

serves as pilot in command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in 

command of the airplane, meets the requirements of§ 

61.195(b), and has logged at least 25 hours of pilot-incommand flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the 

flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight 

unless—

(1) The other control seat is occupied by a safety pilot who 

possesses at least a private pilot certificate with category and 

class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side 

of the aircraft, or a competent observer in the aircraft 

adequately supplements the vision of the safety pilot; and 

(3) Except in the case of lighter-than-air aircraft, that aircraft is 

equipped with fully functioning dual controls. However, 

simulated instrument flight may be conducted in a singleengine airplane, equipped with a single, functioning, throw-
8

over control wheel, in place of fixed, dual controls of the 

elevator and ailerons, when—

(i) The safety pilot has determined that the flight can be 

conducted safely; and 

(ii) The person manipulating the controls has at least a private 

pilot certificate with appropriate category and class ratings. 

(d) No person may operate a civil aircraft that is being used for a flight 

test for an airline transport pilot certificate or a class or type rating on 

that certificate, or for apart 121 proficiency flight test, unless the pilot 

seated at the controls, other than the pilot being checked, is fully 

qualified to act as pilot in command of the aircraft. 

6. Video Technology Seeks Exemption From The Requirements Of Section 

91.119.

Section 91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 

1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those 

cases, the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure.

(d) [Helicopters, powered parachutes, and weight-shift-control aircraft. If 

the operation is conducted without hazard to persons or property on the 

surface—

(1) A helicopter may be operated at less than the minimums 

prescribed in paragraph (b) or (c) of this section, provided each 

person operating the helicopter complies with any routes or 

altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be 

operated at less than the minimums prescribed in paragraph 

(c) of this section.].

7. Video Technology 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 
9

flight level of that aircraft, as the case may be, by reference to an altimeter 

that is set, when operating--

(2) 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.

8. Video Technology 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

.
10

9. Video Technology 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[.]

10. Video Technology 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.

11. Video Technology 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
11

12. Video Technology 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.
12

(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 Video Technology Seeks And The Reason Video Technology Seeks 

The Relief.

1. Extent Of Relief Video Technology Seeks And The Reason Video Technology 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 UAVs 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, Video Technology submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ and the DJI Inspire-1 Pro quadcopter UAVs unless that PIC has met 

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

operate either The DJI Phantom II quadcopter, DJI Phantom II Vision+ and the DJI Inspire-1 

Pro quadcopter UAVs 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, Video Technology submits that all flights of The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ and the DJI Inspire-1 Pro quadcopter UAVs, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Video Technology business; and 

(2) will not carry passengers or property for compensation or hire.
13

2. Extent Of Relief Video Technology Seeks And The Reason Video Technology 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 Video Technology to determine The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ and the DJI Inspire-1 Pro quadcopter UAVs are in airworthy condition 

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

(i.e., the Video Technology Aerial Operations Manual, Flight log, Monthly Maintenance Log, 

and Instruction Manuals).

Video Technology seeks the requested relief because The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs do not require an 

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

Technology will ensure that the DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs are in airworthy condition based upon 

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

Manuals) 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 Video Technology Seeks And The Reason Video Technology Seeks 

Relief From Section 91.103(b) (2)

Relief from Section 91.103(b)-(2) Preflight action, is requested because Video Technology 

has no intention of flying the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs in or into a controlled air space such as an airport 

or no fly zone. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the 

DJI Inspire-1 Pro quadcopter are VTOL (Vertical Takeoff & Landing) UAVs that do not require 

the use or need of an airport. The DJI Phantom II quadcopter, DJI Phantom II Vision+ 

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs are not permitted to fly in controlled 

airspace. The manufacturer has programmed The DJI Phantom II quadcopter, DJI Phantom II 

Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs not to fly at some airports 

and control areas. Also the requirement for reliable aircraft performance base on values of 

airport elevation and runway slop, aircraft gross weight and wind and temperature is 

irrelevant to Video technology use of the DJI Phantom II quadcopter, DJI Phantom II Vision+ 

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs because they are not permitted to 

operate near airports but Video Technology would abide to weather conditions at the location 

the UAV is to used and not exceed the capabilities the DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAV’s set by the 

manufacturer. Video Technology will also monitor for NOTAMs using a UAV app on a mobile 

device

4. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks 

Relief From Section 91.105)

Relief from Section 91.105 Flight crewmembers at stations is requested because the DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter are UA (Unmanned Aircraft) and do not have crewmembers or work stations on 

board. Video Technology s seeks relief Section 91.105
14

5. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks 

Relief From Section 91.109)

Relief from Section 91.109 Flight Instruction because Section 91.109 references to 

equipment not on board the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs. The DJI Phantom II quadcopter, DJI Phantom II 

Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs falls under qualifications 

covered Section 333 and H.R. 658-62 Subtitle B Section 331, Section 332, Section 333, 

Section 334, Section 335, Section 336. Video Technology is seeking relief 61.113 which is 

associated with asking for relief from this Section 91.109.

6. Extent Of Relief Video Technology Seeks And The Reason Video Technology Seeks 

Relief From Section 91.119 (b) (c) (d)

Relief from Section 91.119 Minimum safe altitudes Video Technology will comply with the 

rules set in section 333 were the maximum altitude of 400-feet above terrain and line of sigh 

of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 

Pro quadcopter UAVs. Video Technology seeks relief form Section 91.119 which requires 

Minimum altitudes used by general manned aviation which exceeds the 400 foot limit above 

terrain that is allowed for The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs which these aircraft fall under in Section 333.

7. Extent Of Relief Video Technology Seeks And The Reason Video Technology 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs, which utilize a barometric pressure sensor, GPS equipment, 

and a radio communications telemetry datalink 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 UAVs operations be reported to air traffic control (ATC) in feet above 

ground level (AGL), Video Technology seeks the requested relief because The DJI Phantom 

II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs 

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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter` UAVs 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 UAVs on the heads-up 

display of the GCS.
15

8. Extent Of Relief Video Technology Seeks And The Reason Video Technology 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 The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs 

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

(VFR), for a total duration of 25 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5-minutes. Video Technology seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered The DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs will severely constrain the practicality 

of any aerial video or still photo flight operations that Video Technology proposes to conduct 

pursuant to this Petition.

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

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs 

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs operating documents, and Video Technology' proposed operating 

limitations, ensure that Video Technology will safely operate the battery powered The DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), with enough battery power to fly for a total duration of 25 minutes to 

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

least 5 minutes.

9. Extent Of Relief Video Technology Seeks And The Reason Video Technology 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, Video Technology requests relief from these 

Sections because The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and 

the DJI Inspire-1 Pro quadcopter UAVs do not require airworthiness certificates. As set forth 

more fully below, The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the 

DJI Inspire-1 Pro quadcopter UAVs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate.

Accordingly, Video Technology will use trained technicians to perform maintenance, 

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

practices prescribed in the UASs operating documents (i.e., the Video Technology Aerial

Operations Manual, Monthly Maintenance Log, and Instruction Manuals). Furthermore, Video 

Technology will document and maintain all maintenance records for The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs.
16

D. The Reasons Why Granting Video Technology 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 Video Technology to 

safely, efficiently, and economically perform aerial video and photography of construction 

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

Additionally, use of The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and 

the DJI Inspire-1 Pro quadcopter UAVs will decrease congestion of the NAS, reduce 

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

Technology' proposed operation of The DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs will be realized without implicating 

any privacy issues.`

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

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs 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 The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs 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 II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs 

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 II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs.

Conducting aerial acquisitions with The DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs, 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 II quadcopter, DJI Phantom II Vision+ quadcopter and 

the DJI Inspire-1 Pro quadcopter UAVs 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 II quadcopter, 

DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs, while 

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

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

engine.

By using The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs to perform aerial acquisitions, the substantial risk to life and 
17

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 II quadcopter, 

DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs (weighing 

approximately 3 pounds, 3 pounds, 6.5-pounds respectively, at their maximum gross weights 

with lengths of 17-inches, 17-inches and 17.75 inches respectively, widths of 17 inches, 

17inches and 17.75 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 II quadcopter, 

DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs Will Benefit 

the Economy.

In addition to being safe and efficient, The DJI Phantom II quadcopter, DJI Phantom II 

Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs are also an economical 

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

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs will allow United States based companies, like Video Technology, 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 The DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs, companies such as Video Technology, 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 II quadcopter, 

DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs, 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, Video Technology' proposed operation of The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs will not implicate 

any privacy issues. Specifically, The DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs will be operated only in compliance 

with operating documents (i.e., the Video Technology Aerial Operations Manual, Monthly 

Maintenance Log, and Instruction Manuals) which requires property owner involvement as 

well as local law enforcement notification, and in accordance with the Federal Aviation 
18

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 Video Technology Seeks Exemption.

1. Reasons Why the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the 

DJI Inspire-1 Pro quadcopter UAVs 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, Video Technology' operation of The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs 

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 UAVs to operate without airworthiness certification and 

sets forth requirements for considering whether a UAVs 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, Video Technology submits that The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs 

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

(a) the characteristics of The DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs; (b) the pilot certification 
19

requirement; and (c) the specific operating limitations.

a. The Specifications of the DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs Demonstrate Its Safe

Characteristics.

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs 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 technical specifications of the The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs are 

set forth by the Specifications and Data Sheet, attached hereto as Exhibit A,B

and C.

ii. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and 

the DJI Inspire-1 Pro quadcopter UAVs Autonomous Flight And 

Navigation Modes Enable The UAVs To Remain Within A Defined 

Operational Area.

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the 

DJI Inspire-1 Pro quadcopter UAVs may be operated in both manual and fully 

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

modes` of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs is provided at pages of the 

3DRobotics APM2.6 User Manual, attached hereto as Exhibit C.
20

iii. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs 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 II quadcopter, DJI Phantom 

II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs will 

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

DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs do not reacquire control link data from the 

GCS, the UAVs will assume that the Control Link is lost and the UAVs 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 The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs are set forth on pages of the 3DRobotics APM2.6 User 

Manual, attached hereto as Exhibit C.

iv. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs GCS and Its Operation.

A complete description of the operation and specifications of The DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs GCS and flight control software is provided 

at pages of the User Manual. User Manuals are attached hereto as Exhibits

C.

b. Flight Operations of the DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs1 UASs Are Limited to 

the Line Of Sight of a Certificated Pilot in Command with a Safety Observer.

Video Technology will only utilize certificated pilots to act as a pilot in 

command (PIC) of The DJI Phantom II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs. Additionally, a safety 

observer will assist all pilots during flight time.

c. Flights of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs Will Be Conducted Pursuant To 

Specific Operating Limitations.

In seeking this exemption, Video Technology proposes to commercially 

operate The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs 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: The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs Unmanned 

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

petition or a petition to amend this grant.
21

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

the purpose of aerial video and photography.

3. The UAVs may not be flown at an indicated airspeed exceeding 100 knots.

4. The UAVs 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 UAVs 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 

UAVs 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 UAVs 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 UAVs 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 UASs 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 UAVs that has undergone maintenance or alterations that affect the UAVs 

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.
22

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 UASs 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 UAVs to service.

15. Each UAVs 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 student pilot, private pilot certificate, or greater 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 UAVs in a manner 

consistent with how the UAVs 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 UAVs with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
23

19. UAVs 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 UAVs may not operate within 5 nautical miles of a 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 UAVs 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 UAVs 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 UAVs 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 UAVs must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.
24

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 UAV any time the UAV is operating. These 

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

upon request.

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

and activities at all times.

30. The UAVs 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 UAVs, 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.

Video Technology 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs unless that PIC has demonstrated, by meeting minimum flight-hour and

currency requirements, that the PIC is able to safely operate The DJI Phantom II quadcopter, 

DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter
25

UAVs in a manner consistent with the exemption, including evasive and emergency 

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

structures.

Considering Video Technology' 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 II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs, Video Technology submits that 

the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Video Technology' specific proposed flight

operations.

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

Video Technology will not allow any PIC to operate the DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or The DJI Phantom 

II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter

UAVs training and currency requirements, that the PIC is able to safely operate The DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs 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 UAVs rotorcraft pilot (with a minimum of 5 

hours of those hours as a UAVs 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 Video Technology' 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 UAVs 

rotorcraft pilot including at least 10 hours logged as a UAVs pilot with a multi-rotor UAVs. 

Prior to operations under Exemption No. 11062, the PIC must also have accumulated and 

logged a minimum of 5 hours as a UAVs pilot operating the same make and model of 

UAVs 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 UAVs rotorcraft time. In addition to the hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days 
26

(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 UAVs with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Video Technology will ensure safe operations by not allowing any PIC to 

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

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

able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

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

3. Reasons Why an Exemption from the Requirements of Section 91.7(a) Would Not 

Adversely Affect Safety.

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

prior to every flight, Video Technology will ensure that the DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs is in an 

airworthy condition based upon the UAV’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 UAVs, 

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 91.103(b) (2) Would Not 

Adversely Affect Safety.

Video Technology will not operate the DJI Phantom II quadcopter, DJI Phantom II Vision+ 

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs inside areas of controlled airspace 

at airports and any other controlled air space unless permission granted from authorized

person or persons. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UAVs are VTOL aircraft and do not require an airport 

or will operate at any airport facility therefore would not adversely affect safety at those 

facilities.

The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 

Pro quadcopter UAVs will be flown in conditions not to exceed manufactures 

recommended conditions for a safe flight and Video Technology will operate The DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs with the rules set in section 333.

5. Reasons Why an Exemption from the Requirements of Section 91.105 Would Not 

Adversely Affect Safety.

The equivalent level of safety established by Section 91.105 would be maintained because 

there are no crew on board the DJI Phantom II quadcopter, DJI Phantom II Vision+ 
27

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs

6. Reasons Why an Exemption from the Requirements of Section 91.109 Would Not 

Adversely Affect Safety.

Section 91.109 Would Not Adversely Affect Safety because of the equipment mentioned in 

Section 91.109 is for general aviation aircraft which is not on board or pertains to the DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs defined in Section 333.

Video Technology submits that the equivalent level of safety established by Section 91.109 

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

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter 

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

requirements, that the PIC is able to safely operate The DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter

Video Technology will not allow any PIC to operate the DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UAVs unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or The DJI Phantom 

II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter 

UAVs training and currency requirements, that the PIC is able to safely operate The DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter UAVs in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures

7. Reasons Why an Exemption from the Requirements of Section 91.119 Would Not 

Adversely Affect Safety.

Exemption Section 91.119 Would Not Adversely Affect Safety but improve it. This rule was 

written for general aviation aircraft to maintain altitude for safety of people in aircraft and 

property. The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UAVs do not qualify as general aviation but fall under the rules 

mentioned in Section 333, which require this type of aircraft to stay below the altitude 400-

feet above terrain and obstacles.

Maintaining this rule without exemption would require UAVs to occupy the same airspace 

as general aviation making this dangerous and in violation of Section 333 where UAV must 

stay below 400-feet above terrain and obstacles.

8. 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 II quadcopter, DJI Phantom II Vision+

quadcopter and the DJI Inspire-1 Pro quadcopter UAVs will be provided to the PIC via 

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

UAVs to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with Video Technology's operation of The DJI Phantom II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter

UAVs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 
28

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 UAVs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAV 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).

9. 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 UAS flight, a 

zero altitude initiation point is; (2) the limitations on the proposed flight operations; and (3) 

the location of the proposed flight operations. Accordingly, Video Technology will ensure 

that it will safely operate the battery powered UAS during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of 25 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes.

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

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter; 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 II quadcopter, DJI Phantom II 

Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UASs provide audible and visual 

warnings to the PIC at the GCS when the UASs experiences low battery voltage, the first 

warning occurring at approximately 25% remaining battery power, and at approximately 

10% remaining battery power 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).

10. 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, Video Technology 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 Video Technology 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 Video Technology Aerial 

Operations Manual, Monthly Maintenance Log, Inspire 1 Instruction Manual). Furthermore, 
29

Video Technology will document and maintain all maintenance records for the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs.

Since The DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter UASs will be inspected as prescribed by the operating 

documents, Video Technology 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 II 

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter User 

Manuals are attached hereto as Exhibit A,B and C; a copy of the DJI Phantom 2 Vision+

and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit D, E and F.

Likewise, the exemption sought will not adversely affect safety because Video Technology 

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

on the UAS using the methods, techniques, and practices prescribed by the operating 

documents.

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

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

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

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

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

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

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

are considered.

In consideration of Video Technology' proposed operating limitations, the operating 

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

UASs, Video Technology 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).

11. 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, Video Technology requests that the 

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

quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter

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. § 
30

21.16, for operation of the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter 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 Video Technology’s intended operation of The DJI 

Phantom II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro 

quadcopter 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 Video Technology Seeks Exemption:

Video Technology 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 Video Technology Seeks:

This exemption will permit Video Technology to commercially operate an Unmanned 

Aircraft System, small (UASs) 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 Video 

Technology' 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, Video Technology' 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, Video Technology will operate the DJI Phantom 2

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

the public, or otherwise pose a threat to national security.
31

CONCLUSION

As set forth herein, Video Technology 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 II quadcopter, DJI Phantom II Vision+ quadcopter and the DJI 

Inspire-1 Pro quadcopter 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 Video Technology to safely, efficiently, and economically operate the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs commercially within the NAS.

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

and Reform Act of 2012, Section 333, Video Technology 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), 91.103(b)(2), 91.105, 91.109, 91.119 (b) (c) (d), 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 Video Technology to operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States.

Video Technology will register the DJI Phantom II quadcopter, DJI Phantom II Vision+ quadcopter 

and the DJI Inspire-1 Pro quadcopter UASs as soon as the FAA completes the procedure 

needed to register and will place the necessary markings on the DJI Phantom II quadcopter, DJI 

Phantom II Vision+ quadcopter and the DJI Inspire-1 Pro quadcopter UASs.
32

Dated: March 29, 2015 

Respectfully submitted,

Randal Schildmeyer, Owner Video Technology

Video Technology 

Randal Schildmeyer

235 Boyson Rd. NE

Cedar Rapids, IA 52402

321-228-7714

rschildmeyer@mchsi.com

Appendices:

A – DJI Phantom II Specifications Data Sheet

B – DJI Phantom II Vision + quadcopter Specifications Data Sheet

C – DJI Inspire 1
29

APPENDIX – A

DJI Phantom II TECHNICAL SPECIFICATIONS

Video Technology only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. Our UASs utilizing 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 link d 

monitor (laptop/tablet devices)

1. DJI Phantom

1.1 General Features

1.1.1 Ready to Fly, Multifunctional Quad-rotor System

1.1.2 Customized H3-2D and H3-3D Gimbal Support

1.1.3 Precision Flight and Stable Hovering

1.1.4 25min Flight Time & Smart Battery

1.1.5 Auto Return-to-Home & Landing

1.1.6 Advanced Power Management

1.1.7 Intelligent Orientation Control (IOC)

1.1.8 Easy Battery Replacement

1.1.9 Self-tightening Propeller

1.1.10 Video Downlink Support

1.1.11 CAN-Bus Expansion Module

1.2 Aircraft

1.2.1 Weight (Battery & Propellers included) 1000g

1.2.2 Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

1.2.3 Max Yaw Angular Velocity 200°/s

1.2.4 Max Tilt Angle 35°

1.2.5 Max Ascent / Descent Speed

1.2.6 Ascent: 6m/s; Descent: 2m/s

1.2.7 Max Flight Speed

1.2.8 15m/s(Not Recommended)

1.2.9 Diagonal Length 350mm

1.2.10 Flight Time 25mins

1.2.11 Take-off Weight ≤1300g

1.2.12 Operating Temperature -10°C ~ 50°C

1.2.13 Supported Battery
29

1.3 DJI Smart Battery

1.3.1 DJI Smart Battery Type 3S LiPo

1.3.2 Capacity 5200mAh, 11.1V

1.3.3 Charging Environment Range to 40°C

1.3.4 Discharging Environment Range -20°C to 50°C

1.3.5 2.4GHz Remote Control

1.3.6 Operating Frequency 2.4GHz ISM

1.3.7 Communication Distance (open area)1000m

1.3.8 Receiver Sensitivity (1%PER) -97dBm

1.3.9 Working Current/Voltage 120 mA@3.7V

1.3.10 Built-in LiPo Battery Working Current/Capacity

1.3.11 3.7V, 2000mAh
31

APPENDIX – B

DJI Phantom II Vision + TECHNICAL SPECIFICATIONS

Video Technology only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. Our UASs utilizing 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 (laptop/tablet devices)

2. DJI Phantom II Vision + QUADCOPTER

1.4 Aircraft

2.1.1 Supported Battery I 5200mAh LiPo Battery

2.1.2 Weight (Battery & Propellers included) 1242g

2.1.3 Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

2.1.4 Max Yaw Angular Velocity 200°/s

2.1.5 Max Tiltable Angle 35°

2.1.6 Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s

2.1.7 Max Flight Speed 15m/s (Not Recommended)

2.1.8 Diagonal motor-motor distance 350mm

1.5 Camera

2.2.1 Operating Environment Temperature 0°C-40°C

2.2.2 Sensor size 1/2.3"

2.2.3 Effective Pixels 14 Megapixels

2.2.4 Resolution 4384×3288

2.2.5 HD Recording 1080p30 & 720p

2.2.6 Recording FOV 110° / 85°

2.2.7 Range Extender

2.2.8 Operating Frequency 2412-2462MHz

2.2.9 Communication Distance (open area) 500-700m

2.2.10 Transmitter Power 20dBm

2.2.11 Power Consumption 2W

2.3 Gimbal

2.3.1 Working Current Static : 750mA; Dynamic : 900mA

2.3.2 Control Accuracy ±0.03°

2.3.3 Controllable Range Pitch : -90°-0°

2.3.4 Maximum Angular Speed Pitch : 90°/s

2.4 Remote Control

2.4.1 Operating Frequency 5.728 GHz-5.85 GHz

2.4.2 Communication Distance (open area) CE Compliance: 400m; FCC 

Compliance: 800m
31

2.4.3 Receiver Sensitivity (1%PER) -93dBm

2.4.4 Transmitter Power CE Compliance: 25mW; FCC Compliance: 100mW

2.4.5 Working Voltage 120 mA@3.7V

2.4.6 Built-in LiPo Battery Working Current/Capacity 3.7V, 2000mAh

2.5 DJI VISION App

2.5.1 System Requirement Of Mobile Device S version 6.1 or above/ Android system 

version 4.0 or above

2.5.2 Mobile Device Support iOS recommended: iPhone 4s, iPhone 5, iPhone 5s, 

iPhone 6, iPhone 6 Plus, iPod touch 5 (available but not recommended: iPad 3, iPad 

4, iPad mini)

2.5.3 Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of similar 

configuration
31

APPENDIX – C

DJI Inspire-1 Pro quadcopter TECHNICAL SPECIFICATIONS

Video Technology only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. Our UASs utilizing 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 (laptop/tablet devices)

3. DJI Inspire 1 Pro QUADCOPTER

3.1 Aircraft

3.1.1 Model T600

3.1.2 Weight 2870 g (Battery and propellers included, Zenmuse X5 excluded)

3.1.3 3400 g (Battery, propellers and Zenmuse X5 included)

3.1.4 Max Takeoff Weight 3500 g

3.1.5 Hovering Accuracy (P Mode) Vertical: 0.5 m

3.1.6 Horizontal: 2.5 m

3.1.7 Max Angular Velocity Pitch: 300°/s

3.1.8 Yaw: 150°/s

3.1.9 Max Tilt Angle 35°

3.1.10 Max Ascent Speed5 m/s

3.1.11 Max Descent Speed 4 m/s

3.1.12 Max Speed 18 m/s (ATTI mode, no wind)

3.1.13 Max Service Ceiling Above Sea Level 4,500 m (Software altitude limit: 120 m 

above takeoff point)

3.1.14 Max Wind Speed Resistance 10 m/s

3.1.15 Max Flight Time Approxi. 15 minutes

3.1.16 Motor Model DJI 3510H

3.1.17 Propeller Model DJI 1345T

3.1.18 Indoor Hovering Enabled by default

3.1.19 Operating Temperature 14° to 104° F (-10° to 40° C)

3.1.20 Diagonal Distance 559 mm

3.2 Remote Controller

3.2.1 Name C1

3.2.2 Operating Frequency 922.7~927.7 MHz (Japan Only)

3.2.3 5.725~5.825 GHz

3.2.4 2.400~2.483 GHz

3.2.5 Max Transmitting Distance FCC Compliant: 3.1 miles (5 km); CE Compliant: 2.1 

miles (3.5 km)

3.2.6 (unobstructed, free of interference)

3.2.7 EIRP 10 dBm@900m MHz, 13 dBm@5.8 GHz, 20 dBm@2.4 GHz

3.2.8 Video Output PortsUSB, Mini HDMI

3.2.9 Power Supply Built-in battery

3.2.10 Charging DJI charger
31

3.2.11 Dual User Capability Host-and-Slave connection

3.2.12 Mobile Device Holder Tablet or Smart Phone

3.2.13 Max Mobile Device Width 170mm

3.2.14 Output Power 9 W

3.2.15 Operating Temperature 14° to 104° F (-10° to 40° C)

3.2.16 Storage Temperature Less than 3 months: -4° to 113° F (-20° to 45° C)

3.2.17 More than 3 months: 72° to 82° F (22° to 28° C)

3.2.18 Charging Temperature 32° to 104° F (0° to 40° C)

3.2.19 Battery 6000 mAh 2S LiPo

3.3 Battery (Standard)

3.3.1 Name Intelligent Flight Battery

3.3.2 Model TB47

3.3.3 Capacity 4500 mAh

3.3.4 Voltage 22.2 V

3.3.5 Battery Type LiPo 6S High voltage battery

3.3.6 Energy 99.9 Wh

3.3.7 Net Weight 570 g

3.3.8 Operating Temperature 14° to 104° F (-10° to 40° C)

3.3.9 Storage Temperature Less than 3 months: -4° to 113° F (-20° to 45° C)

3.3.10 More than 3 months: 72° to 82° F (22° to 28° C)

3.3.11 Charging Temperature 32° to 104° F (0° to 40° C)

3.3.12 Max Charging Power 180 W

3.4 Gimbal and Camera

3.4.1 General

01 Name Zenmuse X5

02 Dimensions 120 (W) x 135 (H) x 140 (D) mm

03 Weight 530 g (Including original lens, balancing ring, 

lens hood, Micro SD card)

04 Operating Temperature 32° to 104° F (0° to 40° C)

3.4.2 Camera

01 Lens Replaceable lens

02 M43 mount supporting auto-focus

03 Supported Lens DJI MFT 15mm f/1.7 ASPH

04 Panasonic Lumix G Leica DG Summilux 15mm f/1.7 ASPH

05 Olympus M.Zuiko Digital ED 12mm f/2.0

06 Olympus M.Zuiko 17mm f1.8 (Balancing ring will be available on 

the DJI Store soon)

07 Sensor Type 4/3 CMOS sensor

08 Effective Pixels 16 M

09 Max Resolution4608x3456

10 ISO Range 100-25600

11 Electronic Shutter Speed 8 s-1/8000 s

12 Field of View DJI MFT 15mm f/1.7 ASPH 72°

13 Still Photography ModesSingle shot

14 Burst shooting:3/5/7 frames

15 Auto Exposure Bracketing (AEB):3/5 bracketed frames at 0.7EV 
31

bias

16 Timelapse (3/5/7/10/20/30/60 sec)

17 Video Resolution UHD:4K (4096×2160) 24/25p, 4K 

(3840×2160) 24/25/30p,2.7K (2704×1520) 24/25/30p;

FHD:1920×1080 24/25/30/48/50/60p

18 Max Video Bitrate 60 Mbps

19 Supported File Systems FAT32 (≤ 32 GB), exFAT (> 32 GB)

20 Photo Formats JPEG, DNG (RAW)

21 Video Formats MP4/MOV (MPEG-4 AVC/H.264)

22 Supported Storage Devices Class 10 or UHS-1 or above 

Micro SD cards

23 Max capacity of 64 GB

3.4.3 Origin Lens

01 Name DJI MFT 15mm f/1.7 ASPH

02 Focal Length f=15 mm (35 mm format equivalent 30 mm)

03 Aperture Type 7 diaphragm blades/circular aperture diaphragm

04 Maximum Aperture F1.7

05 Minimum Aperture F16

06 Lens Construction 9 elements in 7 groups (3 aspherical 

lenses)

07 In Focus Distance 0.2 m to ∞ (from the focus distance 

reference line)

08 MountMicro Four Thirds Mount

09 Angle of View 72°

10 Max. Diameter Approx. 2.26 inches (57.5 mm)

11 Overall Length Approx. 1.42 inches (36 mm)

12 Weight Approx. 115 g

3.4.4 Gimbal

01 Angular Vibration Range±0.02°

02 MountDetachable

03 Controllable Range Pitch: -90° to +30° Pan ±320°

04 Max Controllable Speed Pitch: 120°/s Pan: 180°/s

3.4.5 Charger

01 Model A14-100P1A

02 Voltage 26.3 V

03 Rated Power 100 W

3.4.6 Battery (Optional)

01 Name Intelligent Flight Battery

02 Model TB48

03 Capacity 5700 mAh

04 Voltage 22.2 V

05 Battery Type 6S LiPo High voltage battery

06 Energy 129.96 Wh

07 Net Weight 670 g

08 Operating Temperature 14° to 104° F (-10° to 40° C)

09 Storage Temperature Less than 3 months: -4° to 113° F (-

20° to 45° C)

10 More than 3 months: 72° to 82° F (22° to 28° C)
31

11 Charging Temperature 32° to 104° F (0° to 40° C)

12 Max Charging Power 180 W

13 Max Flight Time Approx. 18 minutes

3.4.7 Battery (Standard)

01 Name Intelligent Flight Battery Model TB47

02 Capacity 4500 mAh

03 Voltage 22.2 V

04 Battery Type LiPo 6S High voltage battery

05 Energy 99.9 Wh

06 Net Weight 570 g

07 Operating Temperature 14° to 104° F (-10° to 40° C)

08 Storage Temperature Less than 3 months: -4° to 113° F (-

20° to 45° C)

09 More than 3 months: 72° to 82° F (22° to 28° C)

10 Charging Temperature 32° to 104° F (0° to 40° C)

11 Max Charging Power 180 W

3.4.8 Vision Positioning

01 Velocity Range < 8 m/s @altitude 6.56 feet (2 m)

02 Altitude Range 0.16 - 16.4 feet (5-500 cm)

03 Operating Environment Surfaces with clear patterns and 

adequate lighting (> 15 lux)

04 Operating Range < 9.84 feet (300 cm)

3.4.9 DJI GO App

01 Requirements iOS 8.0 (or later) and Android 4.1.2 (or later)

02 Supported Mobile Devices Compatible with iPhone 5s, 

iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad 

mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + 

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app 

is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

03 Compatible with Samsung tabs 705c, Samsung S6, Samsung 

S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, 

Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 

mini, SONY Z3,EXPERIA, MI 3, MI PAD, Smartisan T1. 

*Support for additional Android devices available as testing and 

development continues.