HorizonRPV Request for Relief Page 1

PETITION FOR EXEMPTION OF:

HorizonRPV

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTION,

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

OPERATION OF DJI PHANTOM 2 AND DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Created by Douglas Goodwin

HorizonRPV

475 Dale Ave

Escondido, CA 92026

Email: Douglas.Goodwin@HorizonRPV.com
HorizonRPV Request for Relief Page 2

TABLE OF CONTENTS Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 5

BASIS FOR PETITION 6

NAME AND ADDRESS OF PETITIONER 9

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH HORIZONRPV

SEEKS EXEMPTION 9

THE EXTENT OF RELIEF HORIZONRPV SEEKS AND THE REASON

HORIZONRPV SEEKS THE RELIEF 13

THE REASONS WHY GRANTING HORIZONRPV’S REQUEST WOULD

BE IN THE PUBLIC INTEREST 16

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY 20

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. 31

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT HORIZONRPV’ REQUEST 32

CONCLUSION 33

APPENDICES 35
HorizonRPV Request for Relief Page 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

HAE Height Above Ellipsoid

ISR Intelligence Surveillance Reconnaissance

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

SAR Search and Rescue

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
HorizonRPV Request for Relief Page 4

SUMMARY

Douglas Goodwin and his wholly-owned Imagery company, HorizonRPV

(hereafter “HorizonRPV”), seek exemption from the requirements of 14

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

& (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA). 

This exemption will permit HorizonRPV to operate Unmanned Aircraft Systems (UAS) for the commercial 

purpose of conducting UAS aerial training, Full Motion Video (FMV), Sensory and Imagery collection of 

construction sites, Infrastructure Inspection, real estate,

Closed special events, film sets, and landscape over certain areas of the United States until such time as new 

regulations governing Light UAS are in effect and there has been sufficient time to obtain the necessary 

certifications.

INTRODUCTION AND INTERESTS OF THE PETITIONER

HorizonRPV provides its clients with Full Motion Video (FMV) and high-quality digital imagery content for 

use in their commercial, personal, and nonprofit multimedia projects. 

Douglas Goodwin, the sole owner of HorizonRPV, has been a certificated airman since 1998 and is a Multiengine Commercial pilot and Certified Flight Instructor.

He has over 10 years of Unmanned Aerial System (UAS) experience and has deployed with Military and 

Civilian UAS systems. As a hobbyist he is the organizer for a large Multicopter group in San Diego and has 

provided demonstrations at several Science Technology Engineering And Math (STEAM) events. The first 6 

months of 2015 were engaged in teaching ISR operations and Ground Station Maintenance for the Iraqi Air 

Force manned reconnaissance system.

The objective of HorizonRPV’s operations is to provide training on its listed Unmanned Aerial Systems, high 

quality imaging for a variety of commercial, public, and residential uses, specifically targeting: 

● Flight Training

● Aerial safety inspections

● Infrastructure monitoring

● Emergency response 

● Aerial event filming

● Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

An exemption to operate three Unmanned Aircraft Systems for compensation or hire within the NAS:

1. DJI Phantom 2 : vertical takeoff and landing (VTOL) Unmanned Aircraft

2. DJI Inspire 1: vertical takeoff and landing (VTOL) Unmanned Aircraft.
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Each system uses a hand controller alone or in conjunction with a Ground Control Stations (GCS) utilizing 

computers, electronic tablets or smart phone systems.

1. The DJI Phantom 2 has a maximum gross weight of approximately 2 pounds 11 ounces, while having a 

length of 16 inches width of 16 inches, height of 11.9 inches, and a maximum true airspeed of 

approximately 29 knots. Four (4) rotors provide lift and steering.

2. The DJI Inspire 1 has a maximum gross weight of approximately 5 pounds 4 ounces, while having a 

length of 17.2 inches, width of 17.8 inches, and a maximum true speed of 42 knots. Four (4) rotors 

provide lift and steering.

3. The Mapper has a max gross weight of approximately 4 pounds with a length of 36inches and a 50inch 

wing span, and a maximum true speed of 50knots. It is in the form of a traditional aircraft with a single 

propeller and control surfaces on fixed wings.

4. All three Aircraft are driven by Lithium Polymer battery powered electric motors.

5. The Aircraft that will be operated by HorizonRPV 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.
HorizonRPV Request for Relief Page 6

BASIS FOR PETITION

Petitioner, HorizonRPV Incorporated, pursuant to the provisions of the Federal

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

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

petitions the Administrator to commercially operate the DJI Phantom 2 UAS, DJI Inspire 1 UAS in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a),

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

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

its operation, HorizonRPV’ operation of DJI Phantom 2 UAS and DJI Inspire 1 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, HorizonRPV 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. HorizonRPV submits that the requested relief is proper since an equivalent level of 

safety will be ensured. 

HorizonRPV will use experienced personnel or technicians to perform maintenance, alterations, or preventive 

maintenance on the Aircraft using the methods, techniques, and practices prescribed in the operating documents 

(i.e., DJI Phantom 2 User Manual, DJI Inspire 1 User Manual, Phantom 2 Pilot Training Guide, DJI Inspire 1 

User Manual, DJI Inspire 1 Maintenance Manual, and DJI Inspire 1 Safety Guidelines). Furthermore, 

HorizonRPV will document and maintain all maintenance records for the Aircraft.

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

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

necessary to allow a Pilot in Command (PIC) who is a holder of a private pilot certificate

and who has demonstrated, by meeting minimum flight hour and currency requirements, that the PIC is able to 

safely operate the DJI Phantom 2 UAS or DJI Inspire 1UAS in a manner consistent with this exemption, 

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

vehicles and structures and adherence to requirements of operating in the National Airspace system.

HorizonRPV seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 2 UAS, DJI Inspire 1 UAS do not require an airworthiness certificate 

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

As such, HorizonRPV submits that it will ensure that the Aircraft are in an airworthy condition, prior to every 

flight, by determining that the Aircraft are in compliance with the operating documents (i.e., User Manuals, 

Maintenance Manuals, and Safety Guidelines issued by DJI), and that the Aircraft are in a condition for safe 

flight.

HorizonRPV also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as 

the Aircraft will not have a typical barometric altimeter onboard. 
HorizonRPV Request for Relief Page 7

However, altitude information of the Aircraft will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the UAS to the GCS for active 

monitoring of the flight path. This altitude information, combined with HorizonRPV’s operation of the Aircraft 

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, HorizonRPV seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. HorizonRPV submits

that safety will not be affected by operation of the Aircraft during daylight hours in visual

meteorological conditions (VMC) under visual flight rules (VFR), The Phantom 2 and Inspire 1 will be 

operated with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of 

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

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

Douglas Goodwin

475 Dale Ave

Escondido, CA 92026

Douglas.Goodwin@HorizonRPV.com

B. The Specific Sections Of 14 C.F.R. From Which HorizonRPV Seeks Exemption.

1. HorizonRPV Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, for 

compensation or hire, act as PIC of an aircraft.

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

any business or employment if—

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

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

2. HorizonRPV 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. HorizonRPV Exemption From The Requirements Of Section 91.121.

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

part:

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

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

operating--

(1) Below 18,000 feet MSL, to--

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

within 100 nautical miles of the aircraft;
HorizonRPV Request for Relief Page 8

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

this section, the current reported altimeter setting of an appropriate

available station; or

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

departure airport or an appropriate altimeter setting available before departure.

4. HorizonRPV Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states 

the following:

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

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

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

5. HorizonRPV Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.]

6. HorizonRPV From The Requirements Of Section 91.407(a)(1)

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

alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

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

chapter[.]

7. HorizonRPV Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2).

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

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

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of this

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. HorizonRPV 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
HorizonRPV Request for Relief Page 9

records of the 100-hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and

each engine, propeller, rotor, and appliance of an aircraft. The records must

include--

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and

each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

a. 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.

b. 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.

c. 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.

The Extent of Relief HorizonRPV Seeks And The Reason HorizonRPV Seeks The 

Relief

1) HorizonRPV Seeks The 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 either holding a

private pilot or higher level certificate, as well as a current and valid airman medical
HorizonRPV Request for Relief Page 10

certificate, and who has met certain flight-hour and currency requirements to conduct the 

proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that

business or employment; and (2) The aircraft does not carry passengers or property for

compensation or hire.

As set forth more fully below, HorizonRPV submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the Aircraft unless that PIC 

possesses at least a private pilot certificate and has met certain flight-hour and

currency requirements, demonstrating that the PIC is able to safely operate the Aircraft 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, HorizonRPV submits that all flights of the Aircraft, conducted by the

PIC pursuant to the grant of this Petition: (1) will be incidental to HorizonRPV business;

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

2) Extent Of Relief HorizonRPV Seeks And The HorizonRPV 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 HorizonRPV to determine that the Aircraft are in

airworthy condition prior to every flight by ensuring that the UAS is in

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

Phantom 2 Instruction Manual, DJI Inspire 1 User Manual, DJI Inspire

1 Maintenance Manual, and DJI Inspire 1 Safety Guidelines). 

HorizonRPV seeks the requested relief because the Aircraft do not require an

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

HorizonRPV will ensure that the Aircraft are in airworthy condition based upon its

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

Instruction Manual, DJI Inspire 1 User Manual, DJI Inspire 1 Maintenance

Manual, and DJI Inspire 1 Safety Guidelines, 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 HorizonRPV Seeks And The Reason HorizonRPV Seeks

Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of the Aircraft, which utilize a barometric pressure sensor, GPS

equipment, and a radio communications telemetry data link to downlink altitude

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

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

control (ATC) in feet above ground level (AGL), HorizonRPV seeks the requested relief because 

the Aircraft’s altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.
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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 Aircraft are equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be established 

prior to each flight, and provides the PIC with altitude information of the UA n the heads-up 

display of the GCS.

4) Extent Of Relief HorizonRPV 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

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

flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, 

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

HorizonRPV seeks the requested relief because without an exemption from Section 91.151(b), 

the flight time duration of the battery powered Aircraft

will severely constrain the practicality of any aerial video or still photo flight operations

that HorizonRPV proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Aircraft,

the operating documents of the Aircraft, and HorizonRPV’s proposed operating

limitations, ensure that HorizonRPV will safely operate the battery powered Aircraft

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

(VFR), with enough battery power to fly for a total duration of 13.5 minutes to the first

point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes.

5) Extent Of Relief HorizonRPV Seeks And The Reason HorizonRPV 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, HorizonRPV requests relief from

these Sections because the DJI Phantom 2 UAS, DJI Inspire 1 UAS do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 2 UAS, DJI Inspire 1 UAS meets the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, HorizonRPV will use trained technicians to perform maintenance, alterations, or 

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

the UAS operating documents (i.e., DJI Phantom 2 User Manual, DJI Inspire 1 User Manual, 

Phantom 2 Pilot Training Guide, DJI Inspire 1 User Manual, DJI Inspire 1 Maintenance Manual, 

DJI Inspire 1 Safety Guidelines. Furthermore, HorizonRPV will document and maintain all 

maintenance records for the Aircraft.
HorizonRPV Request for Relief Page 12

D. The Reasons Why Granting HorizonRPV 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 HorizonRPV to safely, efficiently, and 

economically perform aerial video and photography of client sites, events, and landscape over certain areas of 

the United States. Additionally, use of the Aircraft will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of HorizonRPV’s proposed operation of the 

Aircraft will be realized without implicating

any privacy issues.

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

The Aircraft 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 petitioner’s UAS’s 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. HorizonRPV has in the past used manned

helicopters and fixed-wing aircraft to accomplish some of the same videography

assignments.

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 Aircraft do not 

require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial video and photography missions would result in fewer aircraft

that must be handled by air traffic control during the ground, takeoff, departure, arrival,

and landing phases of flight operations.

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

Phantom 2 UAS.

Conducting aerial acquisitions with the UAS Aircraft, 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 petitioner’s UAS’ will 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 petitioners’ UAS’s, while reducing the carbon footprint of aerial acquisitions, also

eliminate noise pollution, as the UAs are propelled by battery powered electric motors,

rather than an internal combustion engine.

By using UAS’s to perform aerial acquisitions, the substantial risk to life and property in the air and on 

the ground, which is usually associated with traditional manned aircraft flight operations, will be 

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

onboard the aircraft, the DJI Phantom 2 and DJI

Inspire 1 UAS’s (weighing approximately 2 pounds 11 ounces and 7 pounds 4 ounces

respectively, at their maximum gross weights with lengths of 16 inches and 17.5 inches

respectively, widths of 16 inches and 17.7 inches respectively, and with no liquid fuel on
HorizonRPV Request for Relief Page 13

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 UAS’s Will Benefit The Economy.

In addition to being safe and efficient, the petitioner’s UAS’s are also an

economical alternative to using manned aircraft to conduct similar aerial operations. As

such, operation of the UAS’s such as the Petitioners’ Aircraft will allow United States

based companies, like HorizonRPV, 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 Aircraft 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 UAS’s such as the petitioner’s Aircraft, companies such as

HorizonRPV, 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 UAS’s, 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, HorizonRPV proposed operation of the Aircraft will not implicate any privacy

issues. Specifically, the Aircraft will be operated only in compliance with operating

documents (i.e., HorizonRPV Aerial Operations Policies, Monthly Maintenance Log, and

DJI Phantom 2 Instruction Manual) which requires property owner involvement as

well as local law enforcement notification where required, and in accordance with the

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

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

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

Provided By The Rule From Which HorizonRPV Seeks Exemption.

1) Reasons Why Petitioner’s UAS Meets 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, HorizonRPV operation of the Aircraft meets the conditions 

of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness

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

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

Specifically, FMRA Section 333 states the following, in part:
HorizonRPV Request for Relief Page 14

(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, HorizonRPV submits that the Aircraft can operate

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

characteristics of the DJI Phantom 2 UAS and DJI Inspire 1 UAS; (b) the pilot

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

2. The Specifications Of The DJI Phantom 2 UAS, the DJI Inspire 1 UAS Demonstrate Their 

Safe Characteristics.

The DJI Phantom 2 UAS,DJI Inspire 1 UAS do not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability.

3. Technical Specifications Of the Aircraft.

The technical specifications of the Petitioner’s aircraft are set forth by the

DJI Phantom 2 Specifications and Data Sheet and the DJI Inspire 1 Specifications and Data Sheet, 

attached hereto as Exhibits A-1, A-2.

4. The DJI Phantom 2 UAS, DJI Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational Area.

The DJI Phantom 2 UAS, DJI Inspire 1 UAS may be operated in manual or fully autonomous flight 

mode.

● A complete description of the flight and navigational modes of the DJI

Phantom 2 UAS is provided in the attached DJI Phantom 2

User Manual, attached hereto as Exhibit B-1.

● A complete description of the flight and navigational modes of the DJI
HorizonRPV Request for Relief Page 15

Inspire 1 UAS is provided in the attached DJI Inspire 1 User Manual,attached hereto as Exhibit 

B-2.

5. The DJI Phantom 2 UAS and DJI Inspire 1 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, both the DJI Phantom 2 UA and DJI

Inspire 1 will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 

2 UA does not reacquire control link data from the GCS, the UA will assume that the Control Link is 

lost and the UA will return to the home position (i.e.,failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown.

● A complete description of the Failsafe Functions of the DJI Phantom 2 UAS is set forth in 

the DJI Phantom 2 User Manual, attached hereto as Exhibit B-1.

● A complete description of the Failsafe Functions of the Failsafe Functions of the DJI Inspire 

1 UAS is set forth in the DJI Inspire 1 User Manual, attached hereto as Exhibit B-2.

6. The DJI Phantom 2 GCS and Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2

GCS and flight control software is provided in the DJI Phantom 2 User Manual. DJI Phantom 2 User 

Manual is attached hereto as Exhibit B-1.

7. The DJI Inspire 1 GCS and Its Operation.

A complete description of the operation and specifications of the DJI Inspire 1

GCS and flight control software is provided in the DJI Inspire 1User Manual the User Manual is 

attached hereto as Exhibit B-2.

E. HorizonRPV will require certification and substantial experience of its pilots.

1. HorizonRPV will require certification and substantial experience of its pilots.

HorizonRPV will only utilize certificated pilots or approved pilots with at least

private pilot certification and a minimum of 25 hours of total time as operator of a UAS

rotorcraft and 5 in the make and model being flown to act as a pilot in command (PIC) of

the DJI Phantom 2 UAS and DJI Inspire 1 UAS.

2. Flights Of DJI Phantom 2 and DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, proposes to commercially operate DJI Phantom 2, DJI Inspire 1 UAS for the 

special purpose of conducting aerial video and photography over certain areas of United States, pursuant 

to the following specific operating limitations, which are wholly adherent to the limitations set forth in 

the FAA’s Proposed Part 107 contained in the Notice of Proposed Rulemaking under Docket FAA2015-0150 and dated February 15, 2015:

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

aircraft described in the operating documents, rotorcraft UASs weighing less

than 55 pounds maximum gross weight: DJI Phantom 2 and DJI Inspire 1 UAS,

or successor versions of the same aircraft (e.g. DJI Phantom 3).

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

for the purpose of aerial video and photography.

3. The UAS must be operated at all times within visual line of sight (VLOS) of
HorizonRPV Request for Relief Page 16

the operator or visual observer.

4. At all times the UAS must remain close enough to the operator for the operator

to be capable of seeing the Aircraft with vision unaided by any device other

than corrective lenses.

5. Aircraft over 4.4 pounds may not operate over any persons not directly

involved in the operation.

6. Daylight-only operations (official sunrise to official sunset, local time)

7. Must yield right-of-way to other aircraft, manned or unmanned.

8. May use visual observer (VO), but not required.

9. First-person view camera cannot satisfy “see-and-avoid” requirement but can

be used as long as requirement is satisfied in other ways.

10. Maximum airspeed of 42 knots.

11. Maximum altitude of 500 feet AGL.

12. Minimum weather visibility of 3 miles from control station.

13. No operations in Class A airspace.

14. Operations in Class B, C, D and E airspace allowed with required ATC permission.

15. Operations in Class G airspace allowed without ATC permission.

16. No person may act as an operator or VO for more than one unmanned aircraft

operation at one time.

17. No operations from a moving vehicle or aircraft, other than watercraft on water.

18. No reckless or careless operations.

19. Requires preflight inspection by the operator.

20. PIC may not operate the Aircraft if he or she knows or has reason to know of

any physical or mental condition that would interfere with the safe operation of a small UAS.

21. Aircraft registration and markings required.

2. Reasons Why an Exemption from the Requirements of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety.

HorizonRPV 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 Aircraft unless that PIC has 

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

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

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

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

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

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 

11161).

HorizonRPV will not allow any PIC to operate the Aircraft unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the UAS’s training and currency requirements, that the PIC is able to 

safely operate the Aircraft in a manner consistent with this exemption, including evasive and emergency 

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

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 

hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the exemption). In addition to the 
HorizonRPV Request for Relief Page 17

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 HorizonRPV’ proposed 

operations. The Administrator has held that prior documented flight experience that was obtained in compliance 

with applicable regulations would ensure safe operations, stating as follows:

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

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

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

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

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

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

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

exemption. 

For clarification, the FAA considers these minimum hour requirements to be inclusive rather than 

additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

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

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

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

safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight 

experience that was obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under the grant of 

exemption to accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 

91.119.

Exemption No. 11138 at page 15.

Accordingly, HorizonRPV will ensure safe operations by not allowing any PIC to operate the Aircraft unless 

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

safely operate the Aircraft 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, 

HorizonRPV will ensure that the Aircraft are in an airworthy condition based upon the UAS’s compliance with 

their operating documents and as stated in the conditions and limitations herein.

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

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

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).
HorizonRPV Request for Relief Page 18

4. Reasons Why an Exemption from the Requirements of Section 91.121 Would Not Adversely Affect 

Safety.

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

of the Aircraft will be provided to the PIC via GPS equipment and a radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with HorizonRPV’s operation of the Aircraft within visual line of sight, at or below 500 

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated 

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

automatically established by the UASs at ground level.

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

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

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161).

5. Reasons Why An Exemption from the Requirements of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) 

as a result of:

(1) the technical specifications of the DJI Phantom 2 and DJI Inspire 1

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

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

operate the battery powered Aircraft during daylight hours in VFR conditions, with enough battery power to fly 

for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.5 minutes for the multicopters and 45 minutes / 5minutes for the Mapper UAS.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 UAS; the limitations on the 

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

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

and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning 

occurring at approximately 30% remaining battery power, and again at approximately 10% remaining battery 

power. At the critically low battery level, the Aircraft will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151establish that safety is not 

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

Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, 

including Exemption Nos. 2689, 5745, and 10650. 

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

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161).

6. Reasons Why an Exemption from the Requirements of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

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

In seeking this exemption, HorizonRPV 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), 
HorizonRPV Request for Relief Page 19

and 91.417(a) & (b) will be met because HorizonRPV will use DJI trained technicians to perform maintenance, 

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

the operating documents (i.e., Monthly Maintenance Log, DJI Phantom 2 Instruction Manual, DJI Inspire 1 

User Guide, and DJI Inspire 1 Maintenance Manual.

Furthermore, HorizonRPV will document and maintain all maintenance records for the Aircraft.

Since the Aircraft will be inspected as prescribed by the operating documents, HorizonRPV 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 UAS User Manuals are attached hereto as Exhibit B; a copy of the DJI Phantom 

UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because HorizonRPV will use trained 

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

techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 

91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 UAS will be performed by trained 

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

Significantly, previous exemptions granted by the FAA concerning Sections

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

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of HorizonRPV proposed operating limitations, the operating documents, and the technical 

aspects of the DJI Phantom 2 UAS, the DJI Inspire 1 UAS, HorizonRPV submits that safety will not be 

adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b).

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

those presented herein (e.g.Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, HorizonRPV requests that

the FAA prescribe special conditions for the intended operation of the DJI Phantom 2

Vision+ and DJI Inspire 1 UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

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

(b). Such special conditions will permit safe operation of the UAs for the limited purpose of conducting aerial 

video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established for the safe operation 

of the UAS in the NAS.

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

§ 21.16, for operation of the DJI Phantom 2 or DJI Inspire 1 UAS, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate

safety standards, due to the novel or unusual design features of the aircraft. Section
HorizonRPV Request for Relief Page 20

21.16, entitled Special Conditions, states the following:

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

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

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

propeller, he prescribes special conditions and amendments thereto for the product.

The special conditions are issued in accordance with Part 11 of this chapter and

contain such safety standards for the aircraft, aircraft engine or propeller as the

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

the regulations. See 14 C.F.R. § 21.16.

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

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

Phantom 2 UAS, which contain such safety standards that the Administrator finds

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

C.F.R Sections 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 HorizonRPV Seeks Exemption:

HorizonRPV Incorporated 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 HorizonRPV Seeks:

This exemption will permit HorizonRPV to commercially operate an Unmanned Aircraft System (UAS) for the 

purpose of conducting aerial videoand photography over certain areas of the United States.

G. Any Additional Information, Views, or Arguments Available To Support HorizonRPV’ 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, HorizonRPV’ 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, HorizonRPV will operate the Aircraft safely in the NAS, without creating a hazard 

to users of the NAS, or the public, or otherwise pose a threat to national security.
HorizonRPV Request for Relief Page 21

CONCLUSION

As set forth herein, HorizonRPV seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of 

the DJI Phantom 2, DJI Inspire 1 UAS commercially, without an airworthiness certificate, for the limited 

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

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

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

HorizonRPV to safely, efficiently, and economically operate the DJI Phantom 2.DJI Inspire 1 UAS’s 

commercially within the NAS.

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

Act of 2012, Section 333, HorizonRPV respectfully requests that the Administrator grant this Petition for an 

exemption from the requirements of 14C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1),91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit HorizonRPV to operate the DJI Phantom 2 

UAS and DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

Respectfully submitted,

Douglas Goodwin

Douglas Goodwin

President

HorizonRPV

475 Dale Ave

Escondido, CA 92026

Douglas.Goodwin@HorizonRPV.com
HorizonRPV Request for Relief Page 22

APPENDICES:

A-1 – DJI Phantom 2 Specifications Data Sheet 

A-2 – DJI Inspire 1 Specifications

B-1 – DJI Phantom 2 User Manual (Selections pertaining to Flight Operations

B-2 – DJI Inspire 1 User Manual (Selections pertaining to Flight Operations)

C – UAS Maintenance LOG

*The above files are too large for addition to the Petition provided are the below links

A-1 – LINK DJI Phantom 2 Specifications Data Sheet

http://www.dji.com/product/Phantom-2/spec

A-2 – LINK DJI Inspire 1 Specifications

http://www.dji.com/product/inspire-1/spec

B-1 – LINK DJI Phantom 2 User Manual (Selections pertaining to Flight Operations

http://www.dji.com/product/phantom-2/download

B-2 – LINK DJI Inspire 1 User Manual (Selections pertaining to Flight Operations)

http://www.dji.com/product/inspire-1/download