July 24, 2015

Exemption No. 12145

Regulatory Docket No. FAA–2015-1464

Mr. Joseph Gardner Price, Esq.

Counsel for Mobile Tint Inc dba Diversified Drone

Corbett Price Law

612 Spruce Street

Scranton, PA 18503

Dear Mr. Price:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 1, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Mobile Tint Inc dba Diversified Drone (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial video and photography of construction sites, real estate, special events, film 

sets, and landscape.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+.

In accordance with the statutory criteria provided in Section 333 of Public Law 112−95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 
2

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 

finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Diversified Drone is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Conditions and Limitations

In this grant of exemption, Diversified Drone is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA 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 or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO 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 VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 
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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 or any law enforcement official upon request. The 

operator must also present updated and revised documents if it petitions for extension 

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

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

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

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

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

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

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

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 
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operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

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

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

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 
6

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

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

that nonparticipating persons remain under such protection. If a situation arises 

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

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.
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29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
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This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
VIA First Class US Mail 

CORBETT PRICE LAW. 

612 SPRUCE STREET 

SCRANTON, PA 18503 

J oeprice@CorbettPricelaw.com 

570-955-7418 

United States Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

West Building Ground Floor Room W12-140 

Washington, DC 20590 

April1, 2015 

RE: Exemption Request Pursuant to Section 333 of the FAA Reform Act of 

Dear Sir or Madam: 

We represent Mobile Tint Inc., a Pennsylvania Close Corporation doing business as 

Diversified Drone ("Diversified Drone"). We are writing pursuant to the FAA 

Modernization and Reform Act of 2012 and the procedures contained in 14 C.F .R 11, to 

request that Diversified Drone, an owner and operator of Small Unmanned Aircraft Systems, 

be exempted from the Federal Aviation Regulations listed below so that Diversified Drone 

may operate its small, lightweight Unmanned Aircraft Systems ("UAS") commercially in 

airspace regulated by the Federal Aviation Administration ("FAA"). 

Through its founder and owner Matthew Sandherr, Diversified Drone hopes to bring 

new life to the business community of his hometown, Tunkhannock, P A. Specifically, Mr. 

Sandherr is seeking this exemption to use his UAS to assist his wife, Kimberly Sandherr's Real 

Estate business. Mrs. Sandherr is an Associate Real Estate Broker with Century 21 Sherlock 

Homes, Inc. with a place of business at 302 W. Tioga Strret, Tunkhannock, PA 18657. 

Mr. Sandherr is on the verge of obtaining his Private Pilot License and is currendy 

certified to make solo flights. Mr. Sanherr has obtained from the United states Department of 

Transportation his Airman's Medical Certificate Third Class and his Student Pilot Certificate; 

attached as Appendices D and E are Mr. Sandherr's flight logs and current Airman's Medical 

Certificate. 
Over the past year and a half, Mr. Sandherr has logged hundreds of flight hours with 

his DJI Phantom II UAS, always ensuring that flights are conducted in a safe manner and in 

accordance with the FAA guidelines. To this date, Diversified Drone has refused a multitude 

of advances made by area businesses and individuals alike to use their aerial imagery 

capabilities for commercial purposes. 

Based primarily in rural Tunkhannock, Pennsylvania, Diversified Drone now seeks 

permission for its owner and soon-to-be Certified Pilot Matthew Sandherr fly its UAS 

commercially in the United States to capture aerial imagery for local Northeastern 

Pennsylvania Businesses and First Responders. Northeastern Pennsylvania is in dire need of 

an influx of business. Diversified Drone seeks to use its expertise in the area of aerial imagery 

capturing to bring this much needed new business to the local area. Granting Diversified 

Drone's exemption will be granting Northeastern Pennsylvania the right to believe that 

there is hope on the horizon in the form of a modernization of business practices. 

2 

Respectfully Submitted, 

Joseph Gardner Price, Esq. 

Corbett Price Law 

612 Spruce St. 

Scranton, P A 18503 

Attorney ID 317300 
UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _____ _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

MOBILE TINT INC. d/b/a DIVERSIFIED DRONE 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

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

OPERATION OF DJI PHANTOM 2 VISION+ UNMANNED AIRCRAFT 

SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on Aprill, 2015 

3 
TABLE OF CONTENTS 

Page 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER ............................................................. ? 

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

DRONE SEEKS EXEMPTION ............................................................ : .... 8 

THE EXTENT OF RELIEF DIVERSIFIED DRONE SEEKS AND THE REASON 

DIVERSIFIED DRONE SEEKS THE RELIEF ......................... 11 

THE REASONS WHY GRANTING DIVERSIFIED DRONE'S REQUEST 

WOULD BE IN THE PUBLIC INTEREST ......................................................... 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

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

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

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT DIVERSIFIED DRONE'S REQUEST ......... 34 

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

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

4 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofF ederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss ofLink 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) Section 333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

5 
SUMMARY 

Mobile Tint Inc., a Pennsylvania Close Corporation d/b/a Diversified Drone 

("Diversified Drone") seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

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

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

FAA Modernization and Reform Act of2012 (FMRA). This exemption will permit 

Diversified Drone to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, 

special events, film sets, and landscape over certain areas of the United States. Diversified 

Drone is in the process of reserving anN number with the FAA to ensure that all 

registration requirements will be met if an exemption is granted. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Matthew Sandherr of Tunkhannock, Pennsylvania is the founder and owner of 

Diversified Drone. Over the past year and a half, Diversified Drone has logged hundreds 

of hours flying its DJI Phantom II UAS with the main focus always being on the safety of 

those on the ground and in the air alike. Based in Tunkhannock, Pennsylvania, Diversified 

Drone now seeks to use their experience in the area ofUAS aerial image capturing to 

bolster the stagnant economic climate that exists in Northeastern Pennsylvania. The 

objective of Diversified Drone is to provide Kimberly Sandherr Real Estate with aerial 

imagery to assist in the marketing of real estate properties. 

6 
BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 2 Vision+ UAS 

Diversified Drone seeks an exemption to operate DJI systems for commercial 

purposes or hire within the NAS. The DJI Phantom 2 Vision+ are vertical takeoff and 

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

electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a maximum 

gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches 

width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. 

The DJI Phantom 2 Vision+ are equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. 

The DJI Phantom 2 Vision+ UAS that will be operated by soon-to-be Pilot 

Matthew Sandherr. Diversified Drone is in the process of obtaining aN Number from the 

FAA so that its aircraft 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.P.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Diversified Drone, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.P.R.§ 11.61) and the FAA Modernization and Reform Act of2012 

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

petitions the Administrator to commercially operate the DJI Phantom 2 Vision+ 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)(l), 91.409(a)(l) & 

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

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

with the unmanned aircraft and its operation, Diversified Drone's operation ofDJI 

Phantom 2 Vision+ UAS meets the conditions ofFMRA Section 333 and therefore, will 

not require an airworthiness certificate in accordance with 14 C.F .R. Part 21, Subpart H. 

Accordingly, Diversified Drone requests relief from Sections 91.405(a), 

91.407(a)(l), 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. 

Diversified Drone submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Diversified Drone will use experienced personnel or 

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

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

Monthly Maintenance Log, and DJI Phantom 2 Vision+). Furthermore, Diversified Drone 

will document and maintain all maintenance records for the DJI Phantom 2 Vision+ UAS. 

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

privileges and limitations: Pilot in command, is requested by Diversified Drone to the 

extent necessary to allow a Pilot in Command (PIC) who has demonstrated that the PIC is 

able to safely operate the DJI Phantom 2 Vision+ UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. An individual will ensure that the 

UAS remain in direct live-of-sight at all times that the PIC is flying the UAS. 

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

airworthiness, because the DJI Phantom 2 Vision+ UAS do not require an airworthiness 

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

8 
submits that it will ensure that the DJI Phantom 2 Vision+ and are in an airworthy 

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

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+), and 

that the aircraft are in a condition for safe flight. 

Diversified Drone also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+ 

will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

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

monitoring of the flight path. This altitude information, combined with Diversified Drone's 

operation ofthe DJI Phantom 2 Vision+ UAS within visual line of sight, at or below 500 

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

Additionally, Diversified Drone seeks an exemption from the requirements of 

Section 91.151 (b), entitled Fuel requirements for flight in VFR conditions. Diversified 

Drone submits that safety will not be affected by operation of the DJI Phantom 2 Vision+ 

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

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

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

for at least 4.5 minutes. 

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

9 
Mobile Tint Inc. d/b/a Diversified Drone 

6 Elizabeth Drive 

Tunkhannock, P A 18 

Tel: (570) 815-6158 

Email: MobileTintlnc@Gmail.com 

B. The Specific Sections Of 14 C.F.R. From Which Diversified Drone Seeks 

Exemption. 

1. Diversified Drone 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. Diversified Drone 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. Diversified Drone Seeks Exemption From The Requirements Of Section 

91.121. 

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

part: 

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

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

when operating--

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

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

within 1 00 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. Diversified Drone Seeks Exemption From The Requirements Of Section 

91.151(b). 

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

(b), states the following: 

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

(considering wind and forecast weather conditions) there is enough fuel to fly 

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

fly after that for at least 20 minutes. 

5. Diversified Drone Seeks Exemption From The Requirement Of Section 

91.405(a). 

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

Each owner or operator of an aircraft-

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

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

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

6. Diversified Drone Seeks Exemption From The Requirements Of Section 

91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l), states the following: 

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

maintenance, rebuilding, or alteration unless--

11 
(1) It has been approved for return to service by a person authorized under § 

43.7 ofthis chapter[.] 

7. Diversified Drone Seeks Exemption From The Requirements O_f Sections 

91.409(a)(l) And 91.409(a)(2). 

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

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

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

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

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

chapter; or 

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

with part 21 of this chapter. 

8. Diversified Drone 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: 

12 
(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 ofthe forms prescribed by§ 43.9(d) ofthis chapter for each · 

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

propellers, and appliances. 

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

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

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

work is performed. 

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

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

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

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Diversified Drone Seeks And The Reason Diversified Drone 

Seeks The Relief. 

1. Extent Of Relief Diversified Drone Seeks And The Reason Diversified 

Drone Seeks Relief From Section 61.113(a) And (b). 

13 
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 to 

conduct the proposed U AS 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, Diversified Drone submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 

Vision+ UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate the DJI Phantom 2 Vision+ UAS in a 

manner consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Further, Diversified Drone submits that all flights of the DJI Phantom 2 Vision+ 

UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to 

Diversified Drone's business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Diversified Drone Seeks And The Reason Diversified 

Drone 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 Diversified Drone to determine that the DJI Phantom 2 Vision+ 

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

14 
compliance with the operating documents (i.e., the Diversified Drone Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+). 

Diversified Drone seeks the requested relief because the DJI Phantom 2 Vision+ 

UAS does not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, 

Subpart H. Therefore, Diversified Drone will ensure that the DJI Phantom 2 Vision+ UAS 

are in airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual) prior to every 

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

conditions and limitations below. 

3. Extent Of Relief Diversified Drone Seeks And The Reason Diversified 

Drone Seeks Relief From Section 91.121. 

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

flight operations of the DJI Phantom 2 Vision+ UAS, which utilize a barometric pressure 

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

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

FAA requires that any altitude information concerning U AS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Diversified Drone seeks the 

requested relief because the DJI Phantom 2 Vision+ altimeter may be set on the ground to 

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

flight. 

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

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

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

be maintained since the DJI Phantom 2 Vision+ UAS are equipped with a barometric 

15 
pressure sensor and GPS equipment, which automatically ensures that a ground level 

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

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

4. Extent Of Relief Diversified Drone Seeks And The Reason Diversified 

Drone Seeks Relief From Section 91.151(b). 

Relief from Section 91.151 (b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Phantom 2 Vision+ UAS during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first 

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

4.5 minutes. Diversified Drone seeks the requested relief because without an exemption 

from Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 2 

Vision+ UAS will severely constrain the practicality of any aerial video or still photo flight 

operations that Diversified Drone proposes to conduct pursuant to this Petition. 

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

Vision+ UAS, the DJI Phantom 2 Vision+ operating documents, and Diversified Drone's 

proposed operating limitations, ensure that Diversified Drone will safely operate the 

battery powered DJI Phantom 2 Vision+ 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 Diversified Drone Seeks And The Reason Diversified 

Drone Seeks Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

(a)(2), And 91.417(a) & (b). 

16 
Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, Diversified Drone requests relief 

from these Sections because the DJI Phantom 2 Vision+ UAS do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 2 Vision+ UAS meet the 

conditions ofFMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Diversified Drone will use trained technicians to perform maintenance, 

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

practices prescribed in the UAS operating documents (i.e., the Diversified Drone Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction 

Manual). Furthermore, Diversified Drone will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+ UAS. 

D. The Reasons Why Granting Diversified Drone's Request Would Be In The Public 

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

Granting the present Petition will further the public interest by allowing Diversified 

Drone to safely, efficiently, and economically perform aerial video and photography of of 

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

Additionally, use of the DJI Phantom 2 Vision+ UAS will decrease congestion of 

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

benefits of Diversified Drone's proposed operation of the DJI Phantom 2 Vision+ UAS 

will be realized without implicating any privacy issues. 

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

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

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, 

17 
an exemption allowing the use of a DJI Phantom 2 Vision+ UAS would reduce the amount 

of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety 

oflife and property in the air and on the ground. 

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

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

DJI Phantom 2 Vision+ UAS do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 

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

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

Phantom 2 Vision+ UAS. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and 

noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ UAS 

produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The DJI Phantom 2 Vision+ UAS, while reducing the carbon footprint 

of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 2 Vision+ UAS to perform aerial acquisitions, the 

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

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

18 
or completely eliminated. Aside from the lack of flight crew members located onboard the 

aircraft, the DJI Phantom 2 Vision+ (weighing approximately 2 pounds 11 ounces and 6 

pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches 

and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no 

fuel on board), has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar 

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 

feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 2 Vision+ UAS Will Benefit The Economy. 

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

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

such, operation ofthe DJI Phantom 2 Vision+ UAS will allow United States based 

companies, like Diversified Drone, to remain competitive and contribute to growth of the 

U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI Phantom 2 Vision+ UAS is one 

such technology that not only allows companies greater operational flexibility compared to 

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

traditional manned aircraft. 

By operating the DJI Phantom 2 Vision+ UAS, companies such as Diversified 

Drone, 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. 

19 
economy. Improved financial performance of U.S. companies, through commercial use of 

the DJI Phantom 2 Vision+ UAS, provides a stable workforce that increases consumer 

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

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

abroad. 

4. There Are No Privacy Issues. 

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

decades, Diversified Drone's proposed operation of the DJI Phantom 2 Vision+ UAS will 

not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ UAS will be 

operated only in compliance with operating documents (i.e., the Diversified Drone Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction 

Manual) which requires property owner involvement as well as local law enforcement 

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

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

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

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

Provided By The Rule From Which Diversified Drone Seeks Exemption. 

1. Reasons Why The DJI Phantom 2 Vision+ UAS Meet The Conditions Of 

The FAA Modernization and Reform Act of2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, Diversified Drone's operation of the DJI 

Phantom 2 Vision+ UAS meet the conditions ofFMRA 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 U AS will create a 

20 
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.--Jfthe 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, Diversified Drone submits that the DJI Phantom 2 

Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics ofthe DJI Phantom 2 Vision+ UAS; (b) the 

specific operating limitations. 

a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate Its 

Safe Characteristics. 

The DJI Phantom 2 Vision+ 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. 

21 
i. Technical Specifications Of The DJI Phantom 2 Vision+ UAS. 

The technical specifications ofthe DJI Phantom 2 Vision+ UAS are set forth by the 

DJI Phantom 2 Vision+ Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area. 

The DJI Phantom 2 Vision+ U AS may be operated in both manual and fully 

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

the DJI Phantom 2 Vision+ UAS is provided at pages 25-35 of the DJI Phantom 2 Vision+ 

User Manual, attached hereto as Exhibit B. 

iii. The DJI Phantom 2 Vision+ UAS Are Designed For Automatic 

Return To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 2 Vision+ UAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ 

do not reacquire control link data from the GCS, the UAs will assume that the Control 

Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and 

will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions ofthe DJI Phantom 2 Vision+ 

UAS are set forth at pages 13 through 15 of the DJI Phantom 2 Vision+ attached hereto as 

Exhibit B. 

iv. The DJI Phantom 2 Vision+ GCS And Its Operation. 

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

Vision+ GCS and flight control software is provided at pages 32 through 43 ofthe DJI 

Phantom 2 Vision+ User Manual 

22 
b. Flight Operations Of DJI Phantom 2 Vision+ Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer. 

Diversified Drone will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 

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

c. Flights Of DJI Phantom 2 Vision+ UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, Diversified Drone proposes to commercially operate DJI 

Phantom 2 Vision+ UAS for the special purpose of conducting aerial video and 

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

operating limitations: 

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

aircraft described in the operating documents, rotorcraft UAS weighing less than 

55 pounds maximum gross weight: DJI Phantom 2 Vision+ Unmanned Aircraft 

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

a petition to amend this grant. 

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

for the purpose of aerial video and photography. 

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

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

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

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

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC's FAA-issued airman 

medical certificate. 

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

permitted. 

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

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

23 
designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

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

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

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

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator's responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

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

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

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

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

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

questions arise regarding updates or revisions to the operating documents. 

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

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

safe operation of the UAS, the aircraft is prohibited from operating until the 

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

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

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

11. Any U AS that has undergone maintenance or alterations that affect the U AS 

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

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

functional test flight must make an entry in the aircraft records. 

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

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

relevant sections of the operating documents. 

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

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

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

24 
of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

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

Safety Bulletins. 

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

corrective action taken against discrepancies discovered between inspections. 

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

third- class medical certificate. 

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

operator's qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F .R. 

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

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

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

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

91.119. 

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

1.1. All operations must be conducted under visual meteorological conditions 

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

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

rules (SVFR) are not authorized. 

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

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

agreement with that airport's management is obtained, and the operation is 

conducted in accordance with a NOT AM as required by the operator's COA. 

The letter of agreement with the airport management must be made available to 

the Administrator upon request. 

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

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

PIC. 

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

in accordance with the operating documents. 

25 
23. The PIC must abort the flight in the event ofunpredicted obstacles or 

emergencies in accordance with the operating documents. 

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

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

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

remammg. 

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 (NOT AM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

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

altitude level and potential transponder requirements. 

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

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

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

Subpart C. Markings must be as large as practicable. 

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

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

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

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

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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

operations and activities at all times. 

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

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

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

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

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

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

26 
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: \V\N-w.ntsb.gov. 

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

And (b) Would Not Adversely Affect Safety. 

Diversified Drone submits that the equivalent level of safety established by Section 

61.113 (a) and (b) will be maintained because no PIC will be allowed to operate the DJI 

Phantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 

Vision+ UAS in a manner consistent with the exemption, including evasive and emergency 

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

structures. 

Considering Diversified Drone's proposed area of operations, and the operating 

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

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+, Diversified 

Drone submits that the additional manned airmanship experience of a commercially 

27 
certificated pilot would not correlate to the airmanship skills necessary for Diversified 

Drone's specific proposed flight operations. 

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

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

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

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

Diversified Drone will not allow any PIC to operate the DJI Phantom 2 Vision+ 

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

the DJI Phantom 2 Vision+ that the PIC is able to safely operate the DJI Phantom 2 

Vision+ UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

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

with 14 C.P.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 U AS 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 Diversified Drone's proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

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

28 
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 U AS 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 total25 hours ofUAS 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, Diversified Drone will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 2 Vision+ 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+ 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, Diversified Drone will ensure that the DJI Phantom 2 

Vision+ UAS is in an airworthy condition based upon the UAS's compliance with its 

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

29 
Additionally, the FAA has previously granted relieffrom Section 91.7(a) specific 

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

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

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

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

Would Not Adversely Affect Safety. 

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

because the altitude information ofthe DJI Phantom 2 Vision+ UAS will be provided to 

the PIC via GPS equipment and a radio communications telemetry data link, which 

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

This altitude information, combined with Diversified Drone's operation of the DJI 

Phantom 2 Vision+ UAS within visual line of sight, at or below 500 feet AGL, will ensure 

a level of safety equivalent to Section 91.121. The altitude information will be generated 

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

initiation point is automatically established by the UAS at ground level. 

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

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

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

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

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

Would Not Adversely Affect Safety. 

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

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

Phantom 2 Vision+ UAS; (2) the limitations on the proposed flight operations; and (3) the 

location ofthe proposed flight operations. Accordingly, Diversified Drone will ensure that 

30 
it will safely operate the battery powered DJI Phantom 2 Vision+ UAS during daylight 

hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 

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

after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 

Vision+ UAS; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 C.F .R. 

Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ UAS 

provide audible and visual warnings to the PIC at the GCS when the UAs experiences low 

battery voltage, the first warning occurring at approximately 33% remaining battery power, 

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

level, the DJI Phantom Vision+ 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. Reliefhas 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 U AS, in circumstances similar, in all material respects, to 

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

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

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

31 
In seeking this exemption, Diversified Drone submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met 

because Diversified Drone will use trained technicians to perform maintenance, alterations, 

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

prescribed in the operating documents (i.e., the Diversified Drone Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ nstruction Manual). 

Furthermore, Diversified Drone will document and maintain all maintenance records for 

the DJI Phantom 2 Vision+ 1 UAS. 

Since the DJI Phantom 2 Vision+ UAS will be inspected as prescribed by the 

operating documents, Diversified Drone will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe DJI 

Phantom 2 Vision+ User Manuals are attached hereto as Exhibit B; a copy ofthe DJI 

Phantom 2 Vision+ Maintenance LOG is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Diversified 

Drone 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 ofthe 

DJI Phantom 2 Vision+ UAS will be performed by trained technicians. Maintenance will 

be documented and maintained utilizing the monthly maintenance log. 

32 
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 

U AS are considered. 

In consideration of Diversified Drone's proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2 Vision+ UAS, 

Diversified Drone submits that safety will not be adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2), and 91.417(a) 

and (b). The FAA has previously granted relief specific to UAS in circumstances similar, 

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

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

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

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

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 

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

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

Vision+ 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)(l) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAs for the limited purpose of conducting aerial video and photography 

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

forth the requirements for considering whether a UAS will create a hazard to users of the 

33 
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 ofthe DJI Phantom 2 Vision+ UAS, since the airworthiness 

regulations of 14 C.F .R. Part 21 do not contain adequate or appropriate safety standards, 

due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special 

Conditions, states the following: 

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

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

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

propeller, he prescribes special conditions and 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 Vision+ 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). 

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

From Which Diversified Drone Seeks Exemption: 

Diversified Drone seeks exemptionfrom 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). 

34 
A Brief Description Of The Nature Of The Exemption Diversified Drone 

Seeks: 

This exemption will permit Diversified Drone to commercially operate an 

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

photography over certain areas of the United States. 

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

Diversified Drone's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Diversified Drone's request for exemption 

may be granted pursuant to the authority ofFMRA 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, Diversified Drone will operate the DJI Phantom 2 

Vision+ UAS safely in the NAS, without creating a hazard to users of the NAS, or the 

public, or otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, Diversified Drone seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), 

which will permit safe operation of the DJI Phantom 2 Vision+ UAS commercially, 

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

35 
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 of2012, while also advancing the interests of the public, by allowing 

Diversified Drone to safely, efficiently, and economically operate the DJI Phantom 2 

Vision+ UAS commercially within the NAS. 

More importantly, granting Diversified Drone this exemption will allow for 

Scranton and the rest of Northeastern Pennsylvania to advance its economy and provide a 

new and refreshing business to the area. Granting Diversified Drone's exemption will be 

granting Northeastern Pennsylvania the right to believe that there is hope on the horizon in 

the form of a modernization of business practices. 

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

Modernization and Reform Act of2012, Section 333, Diversified Drone respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

Phantom 2 Vision+ UAS commercially for the purpose of conducting aerial video and 

photography over certain areas ofthe United States. 

Matthew Sandherr 

Mobile Tint Inc. d/b/a Diversified Drone 

6 Elizabeth Drive 

Tunkhannock, P A 18 

Tel: (570) 815-6158 

Email: MobileTintinc@Gmail.com 

36