Petition for Exemption 14 CFR § 11.81

Unmanned Aircraft Systems: DJI Phantom 3

Summary: 

Soleil Multimedia Productions LLC. seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 

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

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

Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Soleil Multimedia Productions 

LLC to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of 

construction sites, real estate, and landscape over certain areas of 

the United States. The industries I serve are Real Estate, Solar, Flyfishing. My company will create local jobs. I have over 8 years 

experience providing video and photography services professionally 

and have flown recreationally for 3 years. My goal is to fly the DJI 

Phantom 3 to provide marketing collateral to my clients. I am seeing 

an exemption to operate DJI systems for compensation.

Contact Information

Soleil Multimedia Productions, LLC.

Jared Sabater

87 Hill Creek Blvd

Chapel Hill, N.C. 27516

206-265-1420

jared@soleilmultimedia.com

www.soleilmultimedia.com
The specific section or sections of 14 CFR from which you seek 

an exemption;

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),

The extent of relief you seek and the reason you seek the relief;

Relief from Section 61.113(a) and (b) entitled: I am submitting that 

an equivalent level of safety will be maintained because no PIC will 

be allowed to operate the UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able 

to safely operate the DJI Inspire 1 UAS in a manner consistent with 

the operations specifications as described in this exemption, including 

evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Relief from Section 91.7(a) Civil Aircraft Airworthiness: I will ensure 

that the UAS is in airworthy condition based upon its compliance with 

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

Inspire 1 Instruction Manual) prior to every flight, and further, 

determine that the aircraft is in condition for safe flight 

Relief from Section 91.121 ((Altimeter Settings): As more fully set 

forth herein, an equivalent level of safety will be maintained since the 

DJI Inspire 1 UA is equipped with a barometric pressure sensor and 

GPS equipment, which automatically ensures that a ground level 

pressure setting will be established prior to each flight, and provides 

the PIC with altitude information of the UA on the heads-up display of 

the GCS. 

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

VFR conditions,:

The UAS is battery powered. Each battery last apx 15 minutes.
Relief from 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, Dragonfly Live LLC requests relief from these Sections 

because UAS does not require airworthiness 

certificates. As set forth more fully below, the UAS meets the 

conditions of 

FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, 

Soleil Multimedia Productions LLC 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., Monthly Maintenance Log, and DJI 

Phantom 3). 

Soleil Multimedia Productions LLC will document and maintain all 

maintenance records for the DJI Phantom 3 

How your request would benefit the public as a whole;

This petitions will allow Soleil Multimedia Productions, LLC to safely, 

efficiently, and economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of 

the United States. Conducting aerial acquisitions with the DJI 

Phantom 3 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 3 UAS produces 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. DJI Phantom 3 UA, 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 DJI Phantom 3 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 or completely eliminated. Aside from the 

lack of flight crew members located onboard the aircraft, the DJI 

Phantom 3 UA (weighing approximately 2 pounds 11 ounces, at its 

maximum gross weight with a length of 16 inches, widths of 16 

inches, and with no fuel on board), has 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 

Reasons why the exemption would not adversely affect safety, 

or how the exemption would provide a level of safety at least 

equal to the existing rule;

- The UA will be operated at an altitude of no more than 400 feet 

above ground level 

-When the Control Link is lost, the DJI Phantom 3 UA will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 3 UA does 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. 

- Soleil Multimedia Productions LLC 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 Inspire 1 UAS. Additionally, a 

safety observer will assist all pilots during flight time. 

- The DJI Phantom 3 weighs less than 5 pounds

- I only plan to fly to conduct operations of aerial video and 

photography

- I will not exceed 20 knots

- I will only operate the DJI Phantom 3 with in a visual line of sight at 

all times

-I will utilize a safety observer at all times

- I will have all operating documents accessible and available upon 

request

- Prior to each flight the PIC must pre-flight inspection the UAS to 

ensure that it is in a condition for safe flight. 

- We will not fly during the night time
- we will not operate with in 5 nautical miles of an airport

- no PIC will be allowed to operate the DJI Phantom 3 UAS unless 

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

currency requirements, that the PIC is able to safely operate the the 

DJI Phantom 3 UAS in a manner consistent with the exemption 

A summary we can publish in the Federal stating—

Soleil Multimedia Productions LLC. seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 

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

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

Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Soleil Multimedia Productions 

LLC to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of 

construction sites, real estate, and landscape over certain areas of 

the United States. The industries I serve are Real Estate, Solar, Flyfishing. My company will create local jobs. I have over 8 years 

experience providing video and photography services professionally 

and have flown recreationally for 3 years. My goal is to fly the DJI 

Phantom 3 to provide marketing collateral to my clients. I am seeing 

an exemption to operate DJI systems for compensation.