The sUAS

The Petitioner currently operates one model of aircraft: the DJI Phantom 3 

Professional. The market for aerial imagery is rapidly evolving, and there are 

market forces which pressure vendors to constantly upgrade equipment. These

facts, combined with the length of time it takes to receive a grant of exemption, 

may make it difficult to operate in the market with current equipment: by the time 

the exemption for the specific aircraft is granted, those aircraft may very likely be 

outdated and/or obsolete. Therefore, The Petitioner requests that any exemption 

granted extend not only to aircraft currently owned by The Petitioner, but also to 

any future sUASs owned by The Petitioner that meet the following criteria:

1. The sUAS is manufactured by DJI.

2. The sUAS weighs no more than 10 lbs. at takeoff.

3. The sUAS has GPS capability which aids its flight.

or

1. The sUAS has already been approved for commercial use by a published FAA 

Grant of Exemption. E.g. the SenseFly eBee permitted in Exemption No. 11136,

Advanced Aviation Solutions.

Without abandoning the above request, The Petitioner explicitly requests the 

exemption allow the operation of the DJI Phantom 3 Professional. This

sUAS is battery-operated multirotor aircraft weighing less than 10 lbs.

Respectively, the sUAS employed by The Petitioner has the following

specifications:

Airframe: DJI Phantom 3

Flight Control System: The built-in flight control system contains the MC (main

controller), GPS + GLONASS processor, IMU (inertial measurement unit) and

compass. The MC is the brains of the system, receiving thousands of bits of data

each second and translating that data for optimal flight stability. The GPS

processor now includes the capability to receive signals from the Russian-built

GLONASS satellites, which improves positioning accuracy and quicker satellite

acquisition. The IMU contains a 6-axis gyroscope as well as an accelerometer.

Max takeoff weight: 2.9 lbs.

Max flight speed: 31 knots

Max ascent/descent speed: 16.4 ft/sec; 9.8 ft/sec

Battery type: PH3-4480 mAh-15.2V

The Phantom 3 Professional has a sophisticated failsafe function. The Phantom 

3 Professional continuously estimates the amount of battery power required to fly 

the aircraft back to the Home Point. Once this level of battery power is reached, a 

message will appear within the flight control program alerting the operator. The 

Petitioner will always attempt to return the aircraft to the Home Point when this 
message appears. If no action is taken, the aircraft will automatically fly up to a 

pre-set altitude, then fly to the Home Point and land (this is the return-to-home 

function or RTH). Additionally, the flight software will automatically conduct an 

RTH if the signal from the remote controller is lost for more than three seconds. 

Before each flight, the operator will inspect the area where the flight will take 

place and note the tallest obstruction. The operator will then set the failsafe 

altitude to a height greater than the tallest object in the area.

This sUAS has a limited range due to the physical limitations of the transmissions 

from the remote controller. In field conditions, this limited range is generally not 

greater than 1,000-1,200 meters or roughly 3,300-3,900 feet. The sUAS has the 

capability for a maximum altitude to be set prior to each flight. This is a separate 

setting from the maximum altitudes which are unchangeable and are set by the 

manufacturer from the factory. Using GPS data to determine altitude, the sUAS

will not violate either of these altitude limit parameters. The Phantom 3 

Professional sUAS has the ability to conduct a pre-programmed, automated

flight pattern from takeoff to landing. The aircraft will take off from a designated 

point and fly in a straight line to various waypoints in sequence. It is this 

automated flight function which allows the sUAS to take geo-referenced 

photographs for survey-grade photogrammetry and other analytics.