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FROM: 

Joseph T. Mutchler

Nighthawk Aerial Photography LLC.

2512 Shiloh Rd.

Billings, Montana

Tel: 406-702-6658

Email: joseph.t.mutchler@gmail.com

TO: 

DOCKET OPERATIONS 

ROOM W12-140 OF THE WEST BUILDING 

GROUND FLOOR 

1200 NEW JERSEY AVENUE, SE. 

WASHINGTON, DC, 20590 

Regulatory Docket No._____________

PETITION FOR EXEMPTION OF:

Nighthawk Aerial Photography

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONS

PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 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+, DJI PHANTOM 3 PROFESSIONAL AND DJI 

INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

 

Submitted on September 7th, 2015
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TABLE OF CONTENTS

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

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

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

BACKGROUND.......................................................................................................5

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

NAME AND ADDRESS OF PETITIONER............................................................7 

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

AERIAL PHOTOGRAPHY SEEKS EXEMPTION................................................7

THE EXTENT OF RELIEF NIGHTHAWK AERIAL PHOTOGRAPHY SEEKS 

AND THE REASON NIGHTHAWK AERIAL PHOTOGRAPHY SEEKS THE 

RELIEF...............................................................................................11 

THE REASONS WHY GRANTING NIGHTHAWK AERIAL PHOTOGRAPHY

REQUEST 

WOULD BE IN THE PUBLIC INTEREST ..........................................................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.........................................................................15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.....25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

CONCLUSION.......................................................................................................25
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing
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SUMMARY

Nighthawk Aerial Photography, LCC (Joseph T. Mutchler) seeks exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 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 Nighthawk Aerial Photography to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of Real 

Estate Properties (for homeowners, realtors, home builders, home contractors and / or home 

inspectors for real estate marketing and inspection of home exteriors) as well as filming of 

special event, film sets, scripted and unscripted television sets and landscape, conducting power 

line inspection, aerial mapping, UAS operational training, surveying and search and rescue over 

certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Nighthawk Aerial Photography is a production company based in Montana specializing in real 

estate videography, photography, music video production, special event production and film and 

television production. The principals of Nighthawk Aerial Photography, LLC have been in the 

video and entertainment production business for over five years; special events, aerial mapping, 

power line inspection and search and rescue. Nighthawk Aerial Photography’s objective is to 

conduct aerial photography and videography in order to provide high quality digital imaging and 

video content to its clients, in particular to homeowners, real estate agents, realtors, home 

builders, home contractors, and/or home inspectors for real estate marketing and inspections of 

home exteriors as well as filming of special events, film sets, scripted and unscripted television 

sets and landscape, conducting power line inspection, aerial mapping, UAS operational training,

surveying and search and rescue utilizing DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1, and E-Flight Apprentice S 15e UAS. More specifically, Nighthawk Aerial 

Photography aerial video and photography operations will serve in the following areas: 

• Aerial photography of houses / residential and commercial buildings and power lines 

• UAS Operational Training

• Aerial event photography/cinematography/livestock/crop observation management

• Aerial event filming 

• Aerial Film & Television production

• Aerial search and rescue training and safety inspections 

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

The proposed aerial filming will be conducted over private property with controlled access in the

NAS and with the knowledge and permit of the private property’s owner.
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Unmanned Aircraft Systems: DJI Phantom 2 Vision+, Phantom 3 Professional, DJI 

Inspire 1, and E-Flight Apprentice S 15e UAS

Nighthawk Aerial Photography seeks an exemption to operate DJI systems DRONES for

compensation or hire within the NAS. The DJI Phantom 2 Vision+, DJI Phantom 3

Professional, and DJI Inspire 1 are vertical takeoff and landing (VTOL) Unmanned

Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart

phone systems. The DJI Phantom 2+ and DJI Phantom 3 Professional have 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 Inspire 1 has a maximum gross weight of approximately 6 pounds 8 ounces, 

while having a length of 17 inches, width of 18 inches, height of 12 inches, and a 

maximum speed of approximately 43 knots. The DJI Phantom 2 Vision+, DJI Phantom 3

Professional, and DJI Inspire 1 UAS are equipped with four main rotors; driven by

Lithium Polymer battery powered electric motors. The E-Flight Apprentice S 15e is 

equipped with a single battery powered electric motor.

The DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS that will be operated by Nighthawk Aerial Photography (trained

professional), will be registered in accordance with 49 U.S.C. 44103, Registration of

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with

14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Nighthawk Aerial Photography, pursuant to the provisions of the Federal

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

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

petitions the Administrator to commercially operate the DJI Phantom 2 Vision+, DJI

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS in the National

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

61.113(a) & (b), 91.109, 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).
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In consideration of the speed, weight, size, and limited operating area associated with the 

unmanned aircraft and its operation, Nighthawk Aerial Photography operation of DJI Phantom 2 

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS meets 

the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Nighthawk Aerial Photography

requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b), as these sections set forth requirements for maintenance that only apply to aircraft with an 

airworthiness certificate. Nighthawk Aerial Photography submits that the requested relief is 

proper since an equivalent level of safety will be ensured. Nighthawk Aerial Photography will 

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

maintenance on the UAS’s using the methods, techniques, and practices prescribed in the 

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

3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e Instruction Manual). Furthermore, 

Nighthawk Aerial Photography will document and maintain all maintenance records for the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e

UAS. 

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

and limitations: Pilot In Command, is requested by Nighthawk Aerial Photography to the extent 

necessary to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate, and who 

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

able to safely operate the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS in a manner consistent with this exemption, including 

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

vehicles and structures.

Nighthawk Aerial Photography seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Nighthawk Aerial Photography submits that it will 

ensure that the Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS are in an airworthy condition, prior to every flight, by determining that 

the UAS’s are in compliance with the operating documents (i.e., Monthly Maintenance Log, 

and DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e Instruction Manual), and that the aircraft are in a condition for safe flight. 

Nighthawk Aerial Photography also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+, DJI Phantom 3 Professional,

DJI Inspire 1, and E-Flight Apprentice S 15e UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Phantom 2 Vision+, DJI Phantom 3 
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Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS 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 Nighthawk Aerial Photography’s operation of the DJI Phantom 2 

Vision+, DJI Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS within 

visual line of sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, Nighthawk Aerial Photography seeks an exemption from the requirements of 

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

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

DJI Phantom 3 Professional, and DJI Inspire 1 UAS 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, Nighthawk Aerial Photography 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: 

Joseph T. Mutchler

Nighthawk Aerial Photography LLC

2512 Shiloh Rd.

Billings, Montana

Tel: 406-702-6658

Email: joseph.t.mutchler@gmail.com

B. The Specific Sections of 14 C.F.R. From Which Nighthawk Aerial Photography Seeks

Exemption. 

1. Nighthawk Aerial Photography 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.
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2. Nighthawk Aerial Photography 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. Nighthawk Aerial Photography 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--

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

 (i) The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft; 

 (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. Nighthawk Aerial Photography 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. Nighthawk Aerial Photography 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. Nighthawk Aerial Photography Seeks Exemption from the Requirements of Section

91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter [.]
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7. Nighthawk Aerial Photography Seeks Exemption from the Requirements of Sections 

91.409(a)(1) and 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states the 

following: 

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

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

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

approved for return to service by a person authorized by § 43.7 of this chapter; or 

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

part 21 of this chapter.

8. Nighthawk Aerial Photography Seeks Exemption from the Requirements of Sections 

91.417(a) and 91.417(b).Section 91.417, entitled Maintenance records, subsections (a) and (b), 

state the following: 

 (a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section: 

 (1) Records of the maintenance, preventive maintenance, and alteration and records 

of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an 

aircraft. The records must include--

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

performed; and 

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

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

return to service. 

 (2) Records containing the following information: 

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

rotor. 

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

rotor, and appliance. 

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

required to be overhauled on a specified time basis. 

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

Inspection, required by the inspection program under which the aircraft and its appliances are 

maintained. 

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

directives including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date when the 

next action is required.
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 (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major 

alteration to the airframe and currently installed engines, rotors, propellers, and appliances. 

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

prescribed: 

 (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 Nighthawk Aerial Photography Seeks and the Reason Nighthawk Aerial 

Photography Seeks the Relief. 

 1. Extent of Relief Nighthawk Aerial Photography Seeks and the Reason 

Nighthawk Aerial Photography Seeks Relief from Section 61.113(a) And (b). Relief from 

Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is 

requested to the extent necessary to allow a PIC holding a Supplemental Pilot Certificate, as well 

as a current and valid airman medical certificate, and who has met certain flight-hour and 

currency requirements, to conduct the proposed UAS flight operations for compensation or hire. 

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

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any

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

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

As set forth more fully below, Nighthawk Aerial Photography submits that an equivalent level of 

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

Phantom 3 Professional, and DJI Inspire 1 UAS unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate either the DJI 

Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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, Nighthawk Aerial Photography submits that all 

flights of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to Nighthawk Aerial Photography business; and (2) will not carry passengers or 

property for compensation or hire.
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Nighthawk Aerial Photography believes that though UAS are not traditional aircrafts, a PIC 

operating the UA must have knowledge of Airman Rules, basic Airspace and comply with all the 

rules proposed by the FAA. However, considering the fact that a UA is almost like a toy, 

weighing less than a skinny person, the PIC may be except from obtaining a Private Pilot 

Certificate, a Sports Certificate, and a Recreational Certificate considering these certificates 

require flight hours of several thousand tons weighing aircrafts. The operation of UAS by

Nighthawk Aerial Photography is strictly for entertainment / informational purposes, thus the 

operators of the UAS have a career and / or freelance employment as a Camera Operator and 

Cinematographer and will be not be entertaining a career as a pilot. Lastly, Nighthawk Aerial 

Photography PICs will operate the UAS no higher than 200 feet, consequently causing no danger 

do any other aircraft in the NAS. However, Nighthawk Aerial Photography Proposes PIC 

Certification as a Supplemental pilot and a minimum requirement of successfully completed 

private pilot ground school. Additionally, supplemental pilots without a current FAA private 

pilot certificate must have successfully passed the private pilot, commercial pilot, or airline 

transport pilot knowledge test within the past 24 calendar months.

 2. Extent of Relief Nighthawk Aerial Photography Seeks and the Reason UAV Aerial 

Video 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 Nighthawk Aerial Photography to 

determine that the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS are in airworthy condition prior to every flight by ensuring that the UAS 

is in compliance with the operating documents (i.e., the Nighthawk Aerial Photography Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e Instruction Manual). Nighthawk 

Aerial Photography seeks the requested relief because the DJI Phantom 2 Vision+, Phantom 3 

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS do not require an airworthiness 

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

Photography will ensure that the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI 

Inspire 1, and E-Flight Apprentice S 15e UAS are in airworthy condition based upon its 

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

Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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 Nighthawk Aerial Photography Seeks and the Reason 

Nighthawk Aerial Photography 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+, Phantom 3 Professional UAS, DJI Inspire 1, and E-Flight Apprentice S 15e 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 
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(GCS). Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control (ATC) in feet above ground level (AGL), Nighthawk Aerial 

Photography seeks the requested relief because the DJI Phantom 2 Vision+, Phantom 3 

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS’s 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+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e

UAS are equipped with a barometric pressure sensor and GPS equipment, which automatically 

ensures that a ground level pressure setting will be established prior to each flight, and provides 

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

 

 4. Extent of Relief Nighthawk Aerial Photography Seeks and the Reason Nighthawk 

Aerial Photography 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+, Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e 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. 

Nighthawk Aerial Photography 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+, 

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS will severely 

constrain the practicality of any aerial video or still photo flight operations that Nighthawk Aerial 

Photography proposes to conduct pursuant to this Petition. Significantly, as set forth below, the 

technical specifications of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS operating documents, and Nighthawk Aerial Photography

proposed operating limitations, ensure that Nighthawk Aerial Photography will safely operate the 

battery powered DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS 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 Nighthawk Aerial Photography Seeks and the Reason Nighthawk 

Aerial Photography Seeks Relief from Section 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

and 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b) Only apply to aircraft with an airworthiness certificate, Nighthawk Aerial Photography

requests relief from these Sections because the DJI Phantom 2 Vision +, Phantom 3
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Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 2 Vision+, Phantom 3 Professional, 

DJI Inspire 1, and E-Flight Apprentice S 15e UAS meet the conditions of FMRA Section 333

for operation without an airworthiness certificate. Accordingly, Nighthawk Aerial Photography

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 Nighthawk Aerial Photography Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and EFlight Apprentice S 15e Instruction Manual). Furthermore, Nighthawk Aerial Photography will

document and maintain all maintenance records for the DJI Phantom 2 Vision+, Phantom 3

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS.

D. The Reasons Why Granting Nighthawk Aerial Photography 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 Nighthawk Aerial 

Photography too safely, efficiently, and economically perform aerial video and photography

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

Additionally, use of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS will decrease congestion of the NAS, reduce pollution,

and provide significant benefits to the economy. Notably, the benefits of Nighthawk Aerial 

Photography’s proposed operation of the DJI Phantom 2 Vision+, DJI Phantom 3, DJI

Inspire 1, and E-Flight Apprentice S 15e 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+, Phantom 3 Professional, and DJI Inspire 1 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, an exemption allowing the use of a DJI Phantom 2 Vision+, Phantom 3

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS would reduce the amount of

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

and property in the air and on the ground.

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

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 2

Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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
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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+,

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS. Conducting

aerial acquisitions with the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e 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+, Phantom 3 Professional, DJI Inspire 1, and EFlight Apprentice S 15e 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+,

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e 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 2 Vision+, Phantom 3

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS (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+,

Phantom 3 Professional, and DJI Inspire 1 UAS Will Benefit the Economy. In addition to

being safe and efficient, the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS is also an economical alternative to using manned

aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2

Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS will 

allow United States based companies, like Nighthawk Aerial Photography, 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
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alternative technology in order to remain competitive. Operating the battery powered DJI

Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e

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+, Phantom 3

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS, companies such as

Nighthawk Aerial Photography, can remain competitive and profitable, and therefore,

provide greater job stability to employees and contractors, which will ultimately contribute

to growth of the U.S. economy. Improved financial performance of U.S. companies, 

through commercial use of the DJI Phantom 2 Vision +, Phantom 3 Professional, DJI 

Inspire 1, and E-Flight Apprentice S 15e 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,

Nighthawk Aerial Photography proposed operation of the DJI Phantom 2 Vision+, Phantom 3

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS will not implicate any privacy

issues. Specifically, the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and EFlight Apprentice S 15e UAS will be operated only in compliance with operating documents (i.e.,

the Nighthawk Aerial Photography Aerial Operations Manual, Monthly Maintenance Log, and

DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e

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 Nighthawk Aerial Photography Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+, Phantom 3 Professional, and DJI Inspire 1 UAS

Meet The Conditions o f The FAA Modernization and Reform Act of 2012 (FMRA) Section

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

unmanned aircraft and its operation, Nighthawk Aerial Photography operation of the DJI

Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e

UAS meet the conditions of FMRA Section 333, and will not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority for

a UAS to operate without airworthiness certification and sets forth requirements for considering
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whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a

threat to national security.

Specifically, FMRA Section 333 states the following, in part:

(a) In General.—Not withstanding 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 rule-making required by section 332 of this Act or the guidance

required by section 334 of this Act.

(b)Assessment of Unmanned Aircraft Systems.--In making the determination under

subsection (a), the Secretary shall determine, at a minimum--

 1. Which types of unmanned aircraft systems, if any, as a result of their size, weight,

speed, operational capability, proximity to airports and populated areas, and operation within

visual line of sight do not create a hazard to users of the national airspace system or the public

or pose a threat to national security; and

 2. Whether a certificate of waiver, certificate of authorization, or airworthiness

certification under section 44704 of title 49, United States Code, is required for the operation of

unmanned aircraft systems identified under paragraph (1).

(c)Requirements for Safe Operation.--If the Secretary determines under this section that

certain unmanned aircraft systems may operate safely in the national airspace system, the

Secretary shall establish requirements for the safe operation of such aircraft systems in the

national airspace system. In seeking this exemption, Nighthawk Aerial Photography submits

that the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: 

(a) The characteristics of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI 

Inspire 1, and E-Flight Apprentice S 15e UAS;

 (b) The pilot certification requirement; and

 (c) The specific operating limitations.

a. The Specifications of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 

15e UAS does 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.
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 1. Technical Specifications of the DJI Phantom 2 Vision+, Phantom 3 Professional,

DJI Inspire 1, and E-Flight Apprentice S 15e UAS. The technical specifications of the DJI

Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e

UAS is set forth by the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and 

E-Flight Apprentice S 15e Specifications and Data Sheet, attached here to as Exhibit A.

 2. The DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS Autonomous Flight and Navigation Modes Enable the UAS to Remain

Within a Defined Operational Area. The DJI Phantom 2 Vision+, Phantom 3 Professional, and 

DJI Inspire 1 UAS 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+,

Phantom 3 Professional, and DJI Inspire 1 UAS is provided at pages 25-35 of the DJI Phantom

2 Vision+, User Manual, attached hereto as Exhibit B & D (Phantom 3 User Manual will be

available after May 15, 2015; however, is very similar to DJI Phantom 2 Vision+ User Manual).

 3. The DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e 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+

UA will remains stationary, in flight, for 3 seconds or more. If, after 3 seconds, DJI Phantom 2 

Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS does not

reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the

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

position and shutdown. A complete description of the Failsafe Functions of the DJI Phantom 2 

Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS are set forth at

27 through 29 of the DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual, attached

hereto as B & D.

 4. The DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS GCS and its Operation. A complete description of the operation and

specifications of DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS GCS and flight control software is provided at pages 32 through 43 of the

DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual. DJI Phantom 2 Vision+ User

Manual is attached hereto as Exhibit B & D.

b. Flight Operations Of DJI Phantom 2 Vision+, Phantom 3 Professional UAS Are Limited

To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Nighthawk Aerial Photography 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+, 

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS. Additionally, a safety

observer will assist all pilots during flight time.
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c. Flights Of DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, proposes to commercially operate DJI Phantom 2 Vision+, Phantom 3 

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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 UASs weighing less than 55 pounds maximum

gross weight: DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e Unmanned Aircraft System. 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 for homeowners, Realtors, home builders, contractors, home 

 inspectors for use in real estate marketing and real estate inspections. Additionally, aerial video 

 and photography may be conducted on occasional basis for film and television sets, special 

 events and landscape photography, conducting power line inspection, aerial mapping, surveying 

 as deemed necessary. 

 3. The UAS may not be flown at an indicated airspeed exceeding 43 knots (15 m/s). 

4. The UAS must be operated at an altitude of no more than 200 (500 per the User Manual) 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 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.
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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 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. 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 
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replacement/overhaul component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the authorized person 

returning the 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 of the corrective action taken 

against discrepancies discovered between inspections.

17. The PIC must possess at least a Supplemental Pilot certificate and at least a current thirdclass medical certificate. Supplemental pilots must have, at a minimum, successfully completed 

private pilot ground school. Additionally, supplemental pilots without a current FAA private 

pilot certificate must have successfully passed the private pilot, commercial pilot, or airline 

transport pilot knowledge test within the past 24 calendar months.

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). If flight at night is 

required, a special request will be made at the FAA office closest to proposed area of operations. 

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

20. The 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 NOTAM as 

required by the operator’s COA. The letter of agreement with the airport management must be 

made available to the Administrator upon request.

21. The 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.
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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.

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

accordance with the operating documents.

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

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. All operations shall be 

conducted in accordance with airspace requirements in the ATO issued COA including class of 

airspace, altitude level and potential transponder requirements.

26. All aircraft operated in accordance with this 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 UAS 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 
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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; 

 b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of 

such vessels, vehicles or structures has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and determined that it does not present 

an undue hazard, and; 

 c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an 

undue hazard to those persons per § 91.119(a).

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

from the land owner/controller or authorized representative. Permission from land

owner/controller or authorized representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

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

Not Adversely Affect Safety. 

Nighthawk Aerial Photography 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+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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+, Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS in a manner consistent with the exemption, including 

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

vehicles and structures.

Considering Nighthawk Aerial Photography 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+, Phantom 3 

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS, Nighthawk Aerial Photography

submits that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for Nighthawk Aerial Photography

specific proposed flight operations.
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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). 

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, Nighthawk Aerial Photography will ensure that the DJI Phantom 2 Vision+, 

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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. Additionally, the FAA has previously granted relief from 

Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those

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

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

11161).

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

Adversely Affect Safety. 

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

altitude information of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and 

E-Flight Apprentice S 15e 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 Nighthawk 

Aerial Photography’s operation of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI 

Inspire 1, and E-Flight Apprentice S 15e 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 UASs at ground level. The FAA has 

previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all 

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

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

11160, 11161).

5. Reasons Why an Exemption from the Requirements of Section 91.151(b) Would Not 

Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 Vision+, 

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS; (2) the limitations 
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on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, Nighthawk Aerial Photography will ensure that it will safely operate the battery

powered DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e 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+, Phantom 3 Professional, DJI Inspire 

1, and E-Flight Apprentice S 15e 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+, 

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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+, 

Phantom 3 Professional, and DJI Inspire 1 UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151establish that 

safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

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

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

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

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

 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, Nighthawk Aerial Photography submits that the equivalent level of 

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

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because 

Nighthawk Aerial Photography 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 Nighthawk Aerial Photography Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, 

and E-Flight Apprentice S 15e UAS Instruction Manual). Furthermore, Nighthawk Aerial 

Photography will document and maintain all maintenance records for DJI Phantom 2 Vision+, 

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS. Since the DJI 

Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS

will be inspected as prescribed by the operating documents, Nighthawk Aerial Photography will 

maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B 
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& D; a copy of DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS Maintenance LOG is attached hereto as Exhibit C. Likewise, the 

exemption sought will not adversely affect safety because Nighthawk Aerial Photography will 

use trained technicians to perform maintenance, alterations or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed by the operating documents. 

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

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 

Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS will be 

performed by trained technicians. Maintenance will be documented and maintained utilizing the 

monthly maintenance log. Significantly, previous exemptions granted by the FAA concerning 

Sections 

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

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

considered. In consideration of Nighthawk Aerial Photography proposed operating limitations, 

the operating documents, and the technical aspects of the DJI Phantom 2 Vision+, Phantom 3 

Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS, Nighthawk Aerial Photography

submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously 

granted relief specific to UAS in circumstances similar, in all material respects, to those 

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

11109, 11110, 11112, 11136, 11138, 11150,11153, 11156, 11157, 11158, 11159, 11160, 11161). 

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

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

and 14 C.F.R. § 21.16 entitled Special Conditions, Nighthawk Aerial Photography requests that 

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

Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e UAS, which contain such 

safety standards that the Administrator finds necessary to establish a level of safety equivalent to 

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 

91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such 

special conditions will permit safe operation of the UAS for the limited purpose of conducting 

aerial video and photography over certain areas of the United States for compensation or hire. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

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

further, provides the authority for such UAS to operate without airworthiness certification in 

accordance with any requirements that must be established for the safe operation of the UAS in 

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

21.16, for operation of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and 

E-Flight Apprentice S 15e 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 
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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 Nighthawk 

Aerial Photography’s intended operation of the DJI Phantom 2 Vision+, Phantom 3 Professional, 

DJI Inspire 1, and E-Flight Apprentice S 15e UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

8. A Summary That Can Be published In the Federal Register, stating: The Rules from which 

 Nighthawk Aerial Photography Seeks Exemption: 

Nighthawk Aerial Photography seeks exemption from the requirements of 14 C.F.R Sections

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

91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption Nighthawk Aerial Photography Seeks: 

This exemption will permit Nighthawk Aerial Photography to commercially operate an 

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

over certain areas of the United States. 

9. Any Additional Information, Views, Or Arguments Available To Support UAV Aerial 

Video 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, Nighthawk Aerial Photography request for exemption may

be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

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

further, provides the authority for such UAS to operate without airworthiness certification. As 

discussed in detail above, Nighthawk Aerial Photography will operate the DJI Phantom 2 

Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight Apprentice S 15e 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.
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CONCLUSION 

As set forth herein, Nighthawk Aerial Photography seeks an exemption pursuant to 14 C.F.R. § 

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

permit safe operation of the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and 

E-Flight Apprentice S 15e UAS commercially, without an airworthiness certificate, for the 

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

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 

of the public, by allowing Nighthawk Aerial Photography to safely, efficiently, and economically 

operate the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and E-Flight 

Apprentice S 15e UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Nighthawk Aerial Photography

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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Nighthawk Aerial 

Photography to operate the DJI Phantom 2 Vision+, Phantom 3 Professional, DJI Inspire 1, and 

E-Flight Apprentice S 15e UAS commercially for the purpose of conducting aerial video and 

photography of Real Estate Properties (for homeowners, realtors, home builders, home 

contractors and / or home inspectors for real estate marketing and inspection of home exteriors) 

as well as filming of special events, film sets, scripted and unscripted television sets and

landscape as well as conducting power line inspection, aerial mapping, surveying and search and 

rescue over certain areas of the United States.

Dated: September 22, 2015 

Respectfully submitted by, 

Joseph T. Mutchler

Douglas M. Forest

Nighthawk Aerial Photography LLC

2512 Shiloh Rd.

Billings, Montana

Tel: 406-702-6658

Email: joseph.t.mutchler@gmail.com
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Appendixes: 

A – DJI Phantom 2 Vision+ Specifications Data Sheet 

B – DJI Phantom 2 Vision+ Manufacturer’s User Manual 

C – DJI Phantom 3 Professional Specifications Data Sheet 

D – DJI Phantom 3 Manufacturer’s User Manual 

E – DJI Inspire 1 Specifications Data Sheet

F – DJI Inspire 1 Manufacturer’s User Manual

G – E-Flite Apprentice S 15e Specifications Data Sheet

H – E-Flite Apprentice S 15e Manufactures User Manual
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APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

Nighthawk Aerial Photography only utilizes safe and reliable UASs. DJI is an industry leader in 

small UAS production. DJI UASs are loaded with ground breaking software enabling the user to 

set parameters which will not allow flight into controlled airspace. Parameters can also be set to 

limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and location 

information to the PIC via the linked monitor (smart phone/tablet devices)

DJI Phantom 2 Vision+

Supported Battery

DJI 5200mAH LiPo Battery

Weight (Battery & Propellers Included)

2lbs 11.810oz (1242g)

Hover Accuracy (Ready to Fly)

Vertical: .8m; Horizontal: 2.5m

Max Yaw Angular Velocity

2000/s

Max Tilt Angel

350

Max Ascent Speed

6m/s

Max Descent Speed

2m/s

Max Flight Speed

15m/s (NOT RECOMMENDED)

Gimbal

Working Current

Static: 750mA; Dynamic: 900mA

Control Accuracy

±0.030
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Controllable Range

Pitch: -900 - 00

Maximum Angular Speed

Pitch: 900/s

Camera

Operating Temperature Range

320F - 1040F (00C - 400C)

Sensor Size

1/2.3”

Effective Pixels

14M UAV Page 37

Resolution

4384x3288

HD Video Recording

1080p30 & 720p

Recording Field of View

1100/850

Operating Frequency

5.728GHz – 5.85GHz

Communication Distance (unobstructed)

FCC Compliance: 800m

Receiver Sensitivity (1%PER) - -93dBm

Transmitter Power – FCC Compliance: 100mW

Working Voltage

120mA@3.7V

Range Extender

Operating Frequency

2412-2462MHz

Communication Distance (unobstructed)

500-700m
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Transmitter Power

20dBm

Power Consumption

2W

APPENDIX-B

DJI Phantom 2 Vision+ Manufacturer's User Manual

(Uploaded in a separate attachment, a 72-page document)

APPENDIX – C

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS AIRCRAFT

Weight (Including Battery And Propellers) 1280 g Diagonal Size (Including Propellers) 590 mm 

Max Ascent Speed 5 m/s Max Descent Speed 3 m/s Hover Accuracy

• Vertical: +/- 10cm

• Horizontal: +/- 1m

Max Speed 16 m/s (ATTI mode, no wind) Max Altitude above Sea Level 6000 m

Operating Temperature 0°C to 40°C

Gps Mode GPS/GLONASS

GIMBAL

Controllable Range Pitch -90° to +30° Stabilization 3-axis (pitch, roll, yaw)

REMOTE CONTROLLER

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance 2000m (outdoors and unobstructed) Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S Mobile Device Holder For tablet or phone Receiver Sensitivity

(1%Per) -101 dBm ±2 dBm Transmitter Power (Eirp)

• FCC: 20 dBm

• CE: 16 dBm

Working Voltage 1.2 A @7.4 V

BATTERY CHARGER

Voltage 17.4 V Rated Power Phantom 3 Professional 100 W
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INTELLIGENT FLIGHT BATTERY

Capacity 4480 mAh Voltage 15.2 V Battery Type LiPo 4S Energy 68 Wh Net Weight 365 g

Max Flight Time Approximately 23 minutes

Operating Temperature -10°C to 40°C Max Charging Power 100 W

APPENDIX – D

DJI Phantom 3 Professional Manufacturer’s User Manual

(uploaded in a separate attachment, a 58-page document)

APPENDIX – E

DJI INSPIRE 1 TECHNICAL SPECEFICATIONS AIRCRAFT

Aircraft 

Model: T600

Weight 

(Battery Included): 2935 g

Hovering Accuracy (GPS mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance
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10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Power Spectral Density

9.06mW/MHz

Gimbal

Model

ZENMUSE X3

Output Power (with camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Controllable Range

Pitch: -90° to +30°

Pan: ±320°
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Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera 

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

FOV (Field of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion 
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Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

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

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

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

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller 

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (outdoor and unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply
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Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Charger

Model

A14-100P1A

Voltage

26.3 V

Rated Power

100 W

Battery (Standard) 

Name

Intelligent Flight Battery

Model

TB47
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Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional) 

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh
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Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Altitude Range

5-500 cm

APPENDIX – F

DJI Inspire 1 Manufacturer’s User Manual

(uploaded in a separate attachment, a 58-page document)

APPENDIX – G

E-FLITE APPRENTICE S 15E TECHNICAL SPECEFICATIONS AIRCRAFT

Motor Size: 

15-size brushless outrunner

 

Speed Control: 

30-amp brushless (installed) 

Approximate Assembly Time: 

Less than 1 Hour 

Charger: 

2-3S LiPo balancing charger, 0.5-3.0A (included) 

Control Throw (Ailerons): 

Low: 0.71 in (18mm); High: 0.91 in (23mm) 
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Control Throw (Elevator): 

Low: 0.71 in (18mm); High: 0.91 in (23mm) 

Control Throw (Rudder): 

Low: 1.10 in (28mm); High: 1.35 in (35mm) 

Flaps: 

No 

Flying Weight: 

49.0 oz (1390 g) 

Fuel Type: 

Electric 

Recommended Motor Battery: 

11.1V 3S 3200mAh LiPo (included) 

Retracts: 

No 

Wingspan: 

59.0 in (1500mm)

APPENDIX-B

E-Flite Apprentice S 15e Manufacturer's User Manual

(Uploaded in a separate attachment, a 28-page document)

 
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MONTHLY MAINTENANCE LOG

UAS

#

Date Issue

Discovered

Date Issue

Addressed

Issue Description

& Maintenance

Conducted

Maintenance

Performed By:

Print & Sign

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration

Dampeni

ng

Other: