1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

JULIAN EVERLY CREATIVE VENTURES, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS 

OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 91.9(b), 91.203(a), 91.203(b), 45.23(b) AND 21.185

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on September 9, 2015

JULIAN EVERLY CREATIVE VENTURES, INC

Julian Everly Shervington Wright

2024 R Street, NW

Washington, DC 20009

Tel: (202) 656-622

Julian@julianeverly.com

Petitioner
2

CONTENTS

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

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

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

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

BASIS FOR PETITION............................................................................ 6

A. Name And Address Of The Petitioner.................................................. 7

B. The Specific Sections Of 14 C.F.R. From 

Which JECV Seeks Exemption....................................................... 8

C. The Extent Of Relief JECV Seeks And The 

Reason JECV Seeks The Relief................................................................. 11

D. The Reasons Why Granting JECV’s 

Request Would Be In The Public Interest................................................ 14

E. The Reasons Why Granting The Exemption 

Would Not Adversely Affect Safety........................................................... 17

CONCLUSION......................................................................................... 32
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

JECV Julian Everly Creative Ventures, Inc.

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)

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
4

SUMMARY

JULIAN EVERLY CREATIVE VENTURES, INC. (JECV) 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 

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

purpose of conducting aerial video and photography for real estate 

photography, wedding videography, special events, film sets and landscape 

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Julian Everly Shervington Wright, and his company Julian Everly Creative 

Ventures, Inc., is an experienced year veteran of the entertainment industry.

Mr. Wright has 22 years experience producing content for Sony/BMG, 

Universal, EMI and WEG of which he has won sales awards for his efforts. In 

addition to his professional credentials, Mr. Wright holds:

• A valid Medical Certificate Third Class and Student Pilot Certificate 

(Certificate Number GX1242573)

• Student Pilot- Pre-Solo Aeronautical Knowledge Endorsement

• FAA Certificate of Achievement DC Special Flight Rules Area, Course 

ALC-405 (Certificate number 0741613-20140723-00405)

• 11.5 hours of fixed wing piston engine experience flying in and out of 

the DC Special Flight Rules Area

As an aviation enthusiast, Mr Wright and JECV have chosen to comply with 

any applicable FARs despite the decision of Administrative Law Judge 

Patrick G. Geraghty in Administrator v Pirker. As a result of our policy to 

“err on the side of caution”, JECV has conducted no commercial UAS 

missions until the FAA has granted JECV an authorization via Section 333 

exemption. 

The objective of JECV.’s contemplated aerial video and photography 

operations is to provide high quality imaging for a variety of commercial

projects including:

• Creation of commercial messages for Television

• Motion Picture Filming

• Real Estate Videography and Photography
5

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Search and Rescue Operations

• Increase public knowledge of UAS and promote safe UAS operations

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Phantom 3 and 

DJI Inspire 1 UASs

JECV seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 

1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground Control Station (GCS) utilizing electronic tablet or smart phone 

systems. 

• The DJI Phantom 2 Vision+ has a maximum gross weight of 

approximately 2 pounds 11 ounces, length of 16 inches, width of 16 

inches, height of 8 inches, and a maximum speed of approximately 

29 knots. 

• The DJI Phantom 3 has a maximum gross weight of approximately 

1280 g, length of 23 inches width of 23 inches, height of 8 inches, 

and a maximum speed of approximately 30 knots. 

• The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 

ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 

inches, and a maximum speed of approximately 42 knots. 

• All are equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors.

The UAS operating software and GPS navigation systems do not allow any of 

the JECV UAS vehicles to operate near airports or restricted fly zones. The 

failsafe software will disable the UAS vehicles from taking off and also limit 

the UAS systems from operating within specific GPS preset no-fly zones.

The DJI products are common, commercially available, models of remote 

multi-rotor aircraft. They are currently operating safely within the National 
6

Airspace System (NAS) pursuant to Advisory Circular 9157, June 9, 1981. 

The DJI Phantom family of aircraft has been operating worldwide since 2006.

BASIS FOR PETITION

Petitioner, Julian Everly Creative Ventures, Inc., 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, DJI

Inspire 1 UASs in the National Airspace System (NAS), and for an exemption 

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

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

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

associated with the unmanned aircraft and its operation, Julian Everly 

Creative Ventures, Inc. operation of DJI Phantom 2 Vision+, DJI Phantom 3

and DJI Inspire 1 UASs 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, Julian Everly Creative Ventures, Inc. 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.

Julian Everly Creative Ventures, Inc. submits that the requested relief is 

proper since an equivalent level of safety will be ensured. Julian Everly 

Creative Ventures, Inc. will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs

using the methods, techniques, and practices prescribed in the operating 

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

DJI Inspire 1 Instruction Manual). Furthermore, Julian Everly Creative 

Ventures, Inc. will document and maintain all maintenance records for the 

DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs.

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

Pilot privileges and limitations: Pilot in command, is requested by Julian 

Everly Creative Ventures, Inc., to the extent necessary to allow a Pilot in 

Command (PIC) holding a private pilot or higher level certificate, as well as 

an airman medical 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 and DJI Inspire 1 

UASs in a manner consistent with this exemption, including evasive and 
7

emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Julian Everly Creative Ventures, Inc., seeks relief from Section 91.7(a), 

entitled Civil aircraft airworthiness, because the DJI Phantom 2 Vision+, DJI 

Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness 

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

such, Julian Everly Creative Ventures, Inc., submits that they will ensure 

that the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs are 

in an airworthy condition, prior to every flight, by determining that the UASs 

are in compliance with the operating documents (i.e., Monthly Maintenance 

Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and 

that the aircraft are in a condition for safe flight.

Julian Everly Creative Ventures, Inc., also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings , as the DJI 

Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UAs will not have a 

typical barometric altimeter onboard. However, altitude information of the

DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1UAs 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 Julian Everly Creative Ventures, Inc.’s operation of the DJI 

Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs within visual 

line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent 

to Section 91.121.

Additionally, Julian Everly Creative Ventures, Inc., seeks an exemption from 

the requirements of Section 91.151(b), entitled Fuel requirements for flight in 

VFR conditions. Julian Everly Creative Ventures, Inc. submits that safety 

will not be affected by operation of the DJI Phantom 2 Vision+, DJI Phantom 

3 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, Julian Everly Creative Ventures, Inc.

provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

Julian Everly Shervington Wright

c/o Julian Everly Creative Ventures, Inc.
8

2024 R Street, NW

Washington, DC 20009

Tel: (202) 656-0622

Email: Julian@julianeverly.com

B. The Specific Sections Of 14 C.F.R. From Which Julian Everly Creative 

Ventures, Inc. Seeks Exemption.

1. Julian Everly Creative Ventures, Inc., Seeks Exemption From The 

Requirements Of Section Part 21, Subpart H 14 C.F.R. Part 21, Subpart H, 

establishes the procedural requirements for the issuance of airworthiness 

certificates as required by 14 C.F.R. §91.203(a)(1).

2. Julian Everly Creative Ventures, Inc., 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.

3. Julian Everly Creative Ventures, Inc., 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.

4. Julian Everly Creative Ventures, Inc., 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--
9

(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.

5. Julian Everly Creative Ventures, Inc., 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 f or at least 20 minutes.

6. Julian Everly Creative Ventures, Inc., 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[.]

7. Julian Everly Creative Ventures, Inc., 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.

8. Julian Everly Creative Ventures, Inc., Seeks Exemption From The 
10

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.

9. Julian Everly Creative Ventures, Inc., 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
11

the aircraft and its appliances are maintained.

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

safety directives including, for each, the method of compliance, the

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

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

required.

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

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

propellers, and appliances.

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

prescribed:

(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 Julian Everly Creative Ventures, Inc., Seeks And The 

Reason Julian Everly Creative Ventures, Inc. Seeks The Relief.

1. Relief Julian Everly Creative Ventures, Inc., Seeks Exemption From The 

Requirements Of Section Part 21, Subpart H. Given the size and limited 

operating area associated with the UAS to be utilized by Relief Julian Everly 

Creative Ventures, Inc., an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 

of the Reform Act. The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 

333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and 

populated areas of the particular UAS. In all cases, an analysis of these 

criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed 

will be at least as safe, or safer, than a conventional rotorcraft operating with 

an airworthiness certificate without the restrictions and conditions of the 

proposed UAS operations.

2. Extent Of Relief Julian Everly Creative Ventures, Inc. Seeks And The 

Reason Relief Julian Everly Creative Ventures, Inc. Seeks Relief From 
12

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 private pilot or higher level 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, Relief Julian Everly Creative Ventures, Inc.

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

will be allowed to operate the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 

UAS or 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+ UAS, DJI Phantom 3 UAS or 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.

Further, Julian Everly Creative Ventures, Inc. submits that all flights of the 

DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS, 

conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to Julian Everly Creative Ventures, Inc. 's business; and 

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

3. Extent Of Relief Julian Everly Creative Ventures, Inc. Seeks And The 

Reason Julian Everly Creative Ventures, Inc. 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 Julian Everly Creative Ventures, 

Inc. to determine that the DJI Phantom 2 Vision+ and DJ Inspire 1 UASs are 

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

compliance with the operating documents (i.e., the Julian Everly Creative 

Ventures, Inc. Aerial Operations Manual, Monthly Maintenance Log, and 
13

DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

Instruction Manual). MA Julian Everly Creative Ventures, Inc. seeks the 

requested relief because the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 

UAS or DJI Inspire 1 UAS do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Julian Everly 

Creative Ventures, Inc. will ensure that the DJI Phantom 2 Vision+ UAS, 

DJI Phantom 3 UAS or DJI Inspire 1 UAS are in airworthy condition based 

upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 

DJI Inspire 1 UAS 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.

4. Extent Of Relief Julian Everly Creative Ventures, Inc. Seeks And The 

Reason Julian Everly Creative Ventures, Inc. Seeks Relief From Section 

91.121. Relief from Section 91.12 1, entitled Altimeter settings , may be 

required to allow flight operations of the DJI Phantom 2 Vision+ UAS, DJI 

Phantom 3 UAS or DJI Inspire 1 UAS, which utilize a barometric pressure 

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

downlink altitude information from the UA to the PIC at the ground control

station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), Julian Everly Creative Ventures, Inc. seeks the 

requested relief because the DJI Phantom 2 Vision+, DJI Phantom 3 or DJI 

Inspire 1 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+ 

UAS, DJI Phantom 3 UAS or DJI Inspire 1 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.

5. Extent Of Relief Julian Everly Creative Ventures, Inc. Seeks And The 

Reason Julian Everly Creative Ventures, Inc. Seeks Relief From Section 

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

in VFR conditions, is requested to the extent required to allow flights of the 

battery powered DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI 

Inspire 1 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. Julian Everly Creative Ventures, Inc.
14

seeks the requested relief because without an exemption from Section 

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

Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS will severely 

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

that Julian Everly Creative Ventures, Inc. proposes to conduct pursuant to 

this Petition. Significantly, as set forth below, the technical specifications of 

the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS, 

the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

operating documents, and Julian Everly Creative Ventures, Inc.’s proposed 

operating limitations, ensure that Julian Everly Creative Ventures, Inc.. will 

safely operate the battery powered DJI Phantom 2 Vision+ UAS, DJI 

Phantom 3 UAS or 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 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.

 

6. Extent Of Relief Julian Everly Creative Ventures, Inc. Seeks And The 

Reason Julian Everly Creative Ventures, Inc. Seeks Relief From Sections 

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

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

only apply to aircraft with an airworthiness certificate, Julian Everly 

Creative Ventures, Inc. requests relief from these Sections because DJI 

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS do not 

require airworthiness certificates. As set forth more fully below, the DJI 

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS meet the 

conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Julian Everly Creative Ventures, Inc. 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., the Julian Everly Creative 

Ventures, Inc. Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

Instruction Manual). Furthermore, Julian Everly Creative Ventures, Inc. will 

document and maintain all maintenance records for the DJI Phantom 2 

Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS.

 

D. The Reasons Why Granting Julian Everly Creative Ventures, Inc. 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 

Julian Everly Creative Ventures, Inc. to safely, efficiently, and economically 

perform aerial video and photography of, real estate, wedding films, special 
15

events, precision agriculture, land survey & appraisal, construction sites, 

equipment & roof inspections, film sets and landscape over certain areas of 

the United States.

Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will 

decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Julian Everly Creative 

Ventures, Inc.’s proposed operation of the DJI Phantom 2 Vision+ UAS, DJI 

Phantom 3 UAS or DJI Inspire 1 UAS will be realized without implicating 

any privacy issues.

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

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 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+ 

UAS, DJI Phantom 3 UAS or DJI Inspire 1 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+ UAS, DJI Phantom 3 UAS or 

DJI Inspire 1 UAS do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by 

air traffic control during the ground, takeoff, departure, arrival, and landing 

phases of flight operations.

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

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS.

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

Phantom 3 UAS or DJI Inspire 1 UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography 

flight operations. By using battery power and electric motors, the DJI 

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 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 
16

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise 

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

than an internal combustion engine.

 

By using the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI 

Inspire 1 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+ UAS, DJI Phantom 3 UAS 

or DJI Inspire 1 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+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Will 

Benefit The Economy.

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

Phantom 3 UAS or DJI Inspire 1 UAS are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI 

Inspire 1 UAS will allow United States based companies, like Julian Everly 

Creative Ventures, Inc.to remain competitive and contribute to growth of the 

U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation 

fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered 

DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS is 

one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without 

the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI 

Inspire 1 UAS, companies such as Julian Everly Creative Ventures, Inc. can 
17

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+ UAS, DJI Phantom 3 

UAS or DJI Inspire 1 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, Julian Everly Creative Ventures, Inc.’s proposed 

operation of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI 

Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI 

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS will be 

operated only in compliance with operating documents (i.e., the Julian Everly 

Creative Ventures, Inc. Aerial Operations Manual, Monthly Maintenance

Log, and DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 

UAS 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 Julian Everly Creative 

Ventures, Inc. Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 

DJI Inspire 1 UAS Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333.

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

associated with the unmanned aircraft and its operation, Julian Everly 

Creative Ventures, Inc.’s operation of the DJI Phantom 2 Vision+ UAS, DJI 

Phantom 3 UAS or DJI Inspire 1 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 whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat 
18

to national security. Specifically, FMRA Section 333 states the following, in 

part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and 

not later than 180 days after the date of enactment of this Act, the Secretary 

of Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan

and rulemaking required by section 332 of this Act or the guidance required

by section 334 of this Act.

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

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

(1) which types of unmanned aircraft systems, if any, as a result of their

size, weight, speed, operational capability, proximity to airports and

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose

a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or

airworthiness certification under section 44704 of title 49, United

States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

(c) Requirements for Safe Operation.—

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, Julian Everly Creative Ventures, Inc. submits 

that DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

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

demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ UAS, 

DJI Phantom 3 UAS or DJI Inspire 1 UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 

UAS or DJI Inspire 1 UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

do not create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security considering its size, weight, speed, and operational 

capability.
19

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

3 UAS or DJI Inspire 1 UAS. The technical specifications of the DJI Phantom 

2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS are set forth by 

the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS

Specifications and Data Sheet, attached hereto as Exhibit A, B and C.

ii. The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 

UAS’ Autonomous Flight And Navigation Modes Enable The UASs To 

Remain Within A Defined Operational Area. The DJI Phantom 2 Vision+ 

UAS, DJI Phantom 3 UAS or 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+ UAS, DJI 

Phantom 3 UAS or DJI Inspire 1 UAS are provided at pages 23-41 of the DJI 

Phantom 2 Vision+; pages 25-35 of the DJI Phantom 3; and pages 12-18 and 

45-52 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit D, E and 

F.

iii. The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 

UAS Are Designed For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation. When the Control Link is 

lost, the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 

UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 

seconds, the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI 

Inspire 1 UAS do not reacquire control link data from the GCS, the UAs

will assume that the Control Link is lost and the UAs will return to the home 

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

and shutdown. A complete description of the Failsafe Functions for the DJI 

Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS are set 

forth at pages 32 through 34 of the DJI Phantom 2 Vision+ User Manual; 

pages 13 through 15 of the DJI Phantom 3; and for the DJI Inspire 1 at pages 

13 through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit 

D,E and F.

iv. The DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 

UAS GCS And Its Operation. A complete description of the operation and 

specifications of the DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 

DJI Inspire 1 UAS GCS and flight control software is provided at pages 7 

through 17 of the DJI Phantom 2 Vision+ User Manual; pages 32 through 43 

of the DJI Phantom 3 User Manual; and pages 24 through 34 of the DJI 

Inspire 1 User Manual. DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 

DJI Inspire 1 UAS User Manuals are attached hereto as Exhibits D, E and F.
20

b. Flight Operations Of DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 

DJI Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot 

in Command With A Safety Observer.

Julian Everly Creative Ventures, Inc. 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+, DJI Phantom 3 and DJI 

Inspire 1 UAS. Additionally, a safety observer will assist all pilots during 

flight time.

c. Flights DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 

UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Julian Everly Creative Ventures, Inc. proposes to 

commercially operate DJI Phantom 2 Vision+ UAS, DJI Phantom 3 UAS or 

DJI Inspire 1 UAS for the special purpose of conducting aerial video and 

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

specific operating limitations:

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+ UAS, DJI Phantom 3 UAS or DJI Inspire 1 UAS Unmanned Aircraft 

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

or a petition to amend this grant.

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

operations for the purpose of aerial video and photography.

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

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

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

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

altitudes reported to ATC must be in feet AGL.

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

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

any device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate.

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

permitted.
21

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.

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.
22

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

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

relevant sections of the operating documents.

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

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

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

keeping requirements, in accordance with the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul 

component parts must be noted in the aircraft records, including total time in 

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

person returning the UAS to service.

15. Each UASs 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 private pilot certificate and at least a 

current third-class medical certificate.

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

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

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

the exemption, including evasive and emergency maneuvers and maintaining 

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

qualification flight hours must be logged in a manner consistent with 14 

C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are 

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

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

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

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

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

§ 91.119.

19. UAS operations may not be conducted during night, as defined in 14 

C.F.R. § 1.1. All operations must be conducted under visual meteorological 

conditions (VMC). 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 
23

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.

22. If the UA loses communications or loses its GPS signal, it must return to 

a pre- determined 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 the exemption must be identified 

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

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

Subpart C. Markings must be as large as practicable.

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

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

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

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

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

Administrator or any law enforcement official upon request.
24

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

aviation operations and activities at all times.

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

vehicle.

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

nonparticipating persons (persons other than the PIC, SO, operator trainees 

or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

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

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or;

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.

Julian Everly Creative Ventures, Inc. 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+, DJI Phantom 3 

and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting 
25

minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Considering Julian Everly Creative Ventures, Inc.’s proposed area of 

operations, and the operating limitations set forth-above; the parallel nature 

of private pilot aeronautical knowledge requirements to those of commercial 

pilot requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the DJI Phantom 2 Vision+, DJI Phantom 3 and 

DJI Inspire 1 UAS, Julian Everly Creative Ventures, Inc. submits that the 

additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for Julian Everly 

Creative Ventures, Inc.’s specific proposed flight operations.

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

to UAS, in circumstances similar, in all material respects, to those presented 

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

11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 

11159, 11160, 11161).

Julian Everly Creative Ventures, Inc. will not allow any PIC to operate the 

DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the 

DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UAS UAS training 

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

Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and 

structures.

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

consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS 

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

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

the exemption). In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations will 

ensure an equivalent level of safety during Julian Everly Creative Ventures, 

Inc.’s proposed operations. The Administrator has held that prior documented 
26

flight experience that was obtained in compliance with applicable regulations 

would ensure safe operations, stating as follows:

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

operations for the purpose of motion picture filming (or similar operations), 

the PIC must have accumulated and logged, in a manner consistent with 14 

CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to 

operations under Exemption No. 11062, the PIC must also have accumulated 

and logged a minimum of 5 hours as a UAS pilot operating the same make

and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be 

inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be 

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

requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes). The FAA finds that at a minimum, 

the flight-hour requirements in Exemption No. 11062 are appropriate to 

practice and build proficiency in the skills necessary to safely conduct the 

petitioner’s proposed operations. The FAA also finds that prior documented 

flight experience that was obtained in compliance with applicable regulations 

would satisfy this requirement. Training, proficiency, and experiencebuilding flights can also be conducted under the grant of exemption t 

accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with 

appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Julian Everly Creative Ventures, Inc. will ensure safe 

operations by not allowing any PIC to operate the DJI Phantom 2 Vision+, 

DJI Phantom 3 and DJI Inspire 1 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+, DJI Phantom 3 and DJI 

Inspire 1 UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a)

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be 

maintained because prior to every flight, Julian Everly Creative Ventures, 

Inc. will ensure that the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI 

Inspire 1 UAS in an airworthy condition based upon the UAS’s compliance 
27

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+, 

DJI Phantom 3 and DJI Inspire 1 UASs 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 Julian Everly Creative Ventures, 

Inc.’s operation of the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI 

Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude information 

will be generated by GPS equipment installed onboard the aircraft.

Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs at ground level.

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

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

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

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

11161).

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

Would Not Adversely Affect Safety.

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

established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical 

specifications of the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 

1 UASs; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, Julian Everly Creative 

Ventures, Inc. will ensure that it will safely operate the battery powered DJI 

Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs 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.
28

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

Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs; 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+, 

DJI Phantom 3 and DJI Inspire 1 UASs 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 2 Vision+, DJI Phantom 3 and DJI Inspire 1 

UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section

91.151 establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. 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, Julian Everly Creative Ventures, Inc. 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 Julian Everly 

Creative Ventures, Inc. will use trained technicians to perform maintenance,

alterations, or preventive maintenance on the UASs using the methods, 

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

Julian Everly Creative Ventures, Inc. Aerial Operations Manual, Monthly 

Maintenance Log, and Section 91.121 will be maintained because the altitude 

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

UASs Instruction Manual). Furthermore, Julian Everly Creative Ventures, 

Inc. will document and maintain all maintenance records for the Section 

91.121 will be maintained because the altitude information of the DJI 

Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs.

Since the Section 91.121 will be maintained because the altitude information 

of the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs will 
29

be inspected as prescribed by the operating documents, Julian Everly 

Creative Ventures, Inc. 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 

the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs User 

Manuals are attached hereto as Exhibit D, E and F.

Likewise, the exemption sought will not adversely affect safety because 

Julian Everly Creative Ventures, Inc. 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+, DJI Phantom 3 and DJI Inspire 

1 UASs 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 Julian Everly Creative Ventures, Inc.’s proposed 

operating limitations, the operating documents, and the technical aspects of 

the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs, Julian 

Everly Creative Ventures, Inc. 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, Julian 

Everly Creative Ventures, Inc. requests that the FAA prescribe special

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

Phantom 3 and DJI Inspire 1 UASs, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety 

equivalent to that established
30

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+, DJI Phantom 3 

and DJI Inspire 1 UASs, since the airworthiness regulations of 14 C.F.R. 

Part 21 do not contain adequate or appropriate safety standards, due to the 

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

Special Conditions, states the following: If the FAA finds that the 

airworthiness regulations of this subchapter do not contain adequate or 

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

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

propeller, he prescribes special conditions and amendments thereto for the 

product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent 

to that established in the regulations.

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

14 C.F.R. § 21.16, the FAA may prescribe special conditions for Julian Everly 

Creative Ventures, Inc.’s intended operation of the DJI Phantom 2 Vision+, 

DJI Phantom 3 and DJI Inspire 1 UASs, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 

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

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

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

The Rules From Which Julian Everly Creative Ventures, Inc. Seeks 

Exemption:

Julian Everly Creative Ventures, Inc. 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).
31

A Brief Description Of The Nature Of The Exemption Julian Everly Creative 

Ventures, Inc. Seeks:

This exemption will permit Julian Everly Creative Ventures, Inc. to 

commercially operate an Unmanned Aircraft System (UAS) for the purpose of 

conducting aerial video and photography over certain areas of the United 

States.

Any Additional Information, Views, Or Arguments Available To Support 

Julian Everly Creative Ventures, Inc.’s Request.

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

2012 (FMRA) Section 333, which directs the Secretary of Transportation to 

determine if certain UAS may operate safely in the NAS. As such, Julian 

Everly Creative Ventures, Inc.’s 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, Julian Everly Creative Ventures, Inc. will operate 

the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI Inspire 1 UASs safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or 

otherwise pose a threat to national security.

		
32

CONCLUSION

As set forth above, Julian Everly Creative Ventures, Inc. seeks an exemption 

pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and 

Reform Act of 2012, which will permit safe operation of the DJI Phantom 2

Vision+, DJI Phantom 3 and DJI Inspire 1 UASs commercially, without an 

airworthiness certificate, for the special purpose of conducting aerial 

videography and image processes over certain areas of the Untied 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 REC to safely, 

efficiently, and economically operate the DJI Phantom 2 Vision+, DJI 

Phantom 3 and DJI Inspire 1 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, REC respectfully 

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

requirements of 14 C.F.R. §§ 91.9(b), 91.203(a), 91.203(b), 45.23(b), as well as 

the restricted category airworthiness certification standards specified in 14 

C.F.R. § 21.185, including the requirement to have a certificate of 

airworthiness issued for the DJI Phantom 2 Vision+, DJI Phantom 3 and DJI 

Inspire 1 UASs, as contemplated by 14 C.F.R. Part 21.

Dated:

September 9, 2015

Respectfully submitted,

Julian Everly Creative Ventures, Inc.

/s/ Julian Everly Shervington Wright

_______________________________

Julian Everly Shervington Wright

UAS Project Manager

2024 R Street, NW

Washington, DC 20009

Tel: (202) 656-0622

Julian@julianeverly.com

Petitioner
33

APPENDIX	– A

DJI	PHANTOM	2	VISION+	TECHNICAL	SPECIFICATIONS

Julian	Everly	Creative	Ventures,Inc.	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	

(smarphone/tablet devices)

		

1.1	DJI	Phantom	2	Vision+		

		

1.1.1	Aircraft		

										1.1.1.1	Supported	Battery	– DJI	5200mAH	LiPo	Battery		

										1.1.1.2	Weight	(Battery	&	Propellers	Included)	– 2lbs	11.810oz	(1242g)		

										1.1.1.3	Hover	Accuracy	(Ready	to	Fly)	– Vertical:	.8m;	Horizontal:	2.5m		

										1.1.1.4	Max	Yaw	Angular	Velocity	- 2000/s		

										1.1.1.5	Max	Tilt	Angel	- 350		

										1.1.1.6	Max	Ascent	Speed	– 6m/s		

										1.1.1.7	Max	Descent	Speed	– 2m/s		

										1.1.1.8	Max Flight	Speed	– 15m/s	(NOT	RECOMMENDED)		

																							

1.1.2	Gimbal		

										1.1.2.1	Working	Current	– Static:	750mA;	Dynamic:	900mA		

										1.1.2.2	Control	Accuracy	- ±0.030		

										1.1.2.3	Controllable	Range	– Pitch:	-900	- 00		

										1.1.2.4	Maximum	Angular	Speed	– Pitch:	900/s		

															

1.1.3	Camera		

										1.1.3.1	Operating	Temperature	Range	- 320F	-		1040F	(00C	- 400C)		

										1.1.3.2	Sensor	Size	–		1/2.3”		

										1.1.3.3	Effective	Pixels	–		14M		

										1.1.3.4	Resolution	– 4384x3288		

										1.1.3.5	HD	Video	Recording	–		1080p30	&	720p		

										1.1.3.6	Recording	Field	of	View	-		1100/850		

														

1.1.4	Transmitter		

										1.1.4.1	Operating	Frequency	– 5.728GHz	– 5.85GHz		

										1.1.4.2	Communication	Distance	(unobstructed)	– FCC	Compliance:	800m		

										1.1.4.3	Receiver	Sensitivity	(1%PER)	- -93dBm		

										1.1.4.4	Transmitter	Power	– FCC	Compliance:	100mW		

										1.1.4.5	Working	Voltage	–		120mA@3.7V		

1.1.5	Range	Extender		

												1.1.5.1	Operating	Frequency	– 2412-2462MHz		

												1.1.5.2	Communication	Distance	(unobstructed)	– 500-700m		

												1.1.5.3	Transmitter	Power	– 20dBm		

												1.1.5.4	Power	Consumption	– 2W		
34

APPENDIX	– B

DJI	PHANTOM	3	TECHNICAL	SPECIFICATIONS

Julian	Everly	Creative	Ventures,	Inc.	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)

1.1	DJI	Phantom	3	

1.1.1	Aircraft	

1.1.1.1	Supported	Battery	– DJI	4480	mAh	LiPo	Battery	

1.1.1.2	Weight	(Battery	&	Propellers	Included)	– 2lbs	13.15oz	(1280g)	

1.1.1.3	Hover	Accuracy	(Ready	to	Fly)	– Vertical:	.8m;	Horizontal:	2.5m	

1.1.1.4	Max	Yaw	Angular	Velocity	- 200/s	

1.1.1.5	Max	Tilt	Angel	- 35	

1.1.1.6	Max	Ascent	Speed	– 6m/s	

1.1.1.7	Max	Descent	Speed	– 2m/s	

1.1.1.8	Max	Flight	Speed	– 15m/s	(NOT	RECOMMENDED)	

1.1.2	Gimbal	

1.1.2.1	Working	Current	– Static:	750mA;	Dynamic:	900mA	

1.1.2.2	Control	Accuracy	- ±0.03	

1.1.2.3	Controllable	Range	– Pitch:	-90	- 0	

1.1.2.4	Maximum	Angular	Speed	– Pitch:	90/s	

1.1.3	Camera	

1.1.3.1	Operating	Temperature	Range	- 32F	- 104F	(0C	- 40C)	

1.1.3.2	Sensor	Size	– 1/2.3”	

1.1.3.3	Effective	Pixels	– 12.4M	

1.1.3.4	Resolution	– 4000x3000	

1.1.3.5	HD	Video	Recording	– 4096x2160p	24/25,	3840x2160p	24/25/30	

1.1.3.6	Recording	Field	of	View	- 94°	20mm	

1.1.4	Transmitter	

1.1.4.1	Operating	Frequency	– 5.728-5.850GHz;	2.400-2.483GHz	

1.1.4.2	Communication	Distance	(unobstructed)	– FCC	Compliance:	800m	

1.1.4.3	Receiver	Sensitivity	(1%PER)	- -93dBm	

1.1.4.4	Transmitter	Power	– FCC	Compliance:	100mW	

1.1.4.5	Working	Voltage	– 120mA@3.7V

1.1.5	Range	Extender	

1.1.5.1	Operating	Frequency	– 2412-2462MHz	

1.1.5.2	Communication	Distance	(unobstructed)	– 2000m	

1.1.5.3	Transmitter	Power	– 20dBm	

1.1.5.4	Power	Consumption	– 2W
35

APPENDIX	– C

DJI	INSPIRE	1	TECHNICAL	SPECIFICATIONS

Julian	Everly	Creative	Ventures,	Inc.	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	use	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	

(smartphone/tablet	devices)

		

2.2	DJI	Inspire	1		

		

2.2.1	Aircraft		

										2.2.1.1	Model	– T600		

										2.2.1.2	Weight	(Battery	Included)	– 6lbs	7.5291oz	(2935g)		

										2.2.1.3	Hovering	Accuracy	(GPS	Mode)	– Vertical:	0.5m;	Horizontal:	2.5m		

										2.2.1.4	Max	Angular	Velocity	– Pitch:	3000/s;	Yaw:	1500/s		

										2.2.1.5	Max	Tilt	Angle	- 350		

										2.2.1.6	Max	Ascent	Speed	– 5m/s		

										2.2.1.7	Max	Descent	Speed	– 4m/s		

										2.2.1.8	Max	Speed	– 22m/s	(ATTI	mode,	no	wind	– NOT	RECOMMENDED)		

										2.2.1.9	Max	Flight	Altitude	– 4500m		

										2.2.1.10	Max	Wind	Resistance	–		10m/s		

										2.2.1.11	Max	Flight	Time	– Approximately	18	minutes		

										2.2.1.12	Motor	Model	– DJI	3510		

										2.2.1.13	Propeller	Model	– DJI	1345		

										2.2.1.14	Operating	Temperature	Range	–		140F	to	1040F	(-100C	to	400C)				

										2.2.1.15	Dimensions	–		17	1⁄4”	x	17	3⁄4”	x	12”		

		

2.2.2	Gimbal		

										2.2.2.1	Model	– ZENMUSE	X3		

										2.2.2.2	Output	Power	(with	camera)	– Static:	9W;	In	Motion:	11W		

										2.2.2.3	Operating	Current	– Static:	750mA;	In	Motion:	900mA		

										2.2.2.4	Angular	Vibration	Range	- ±0.030		

										2.2.2.5	Mounting	– Detachable		

										2.2.2.6	Controllable	Range	– Pitch:	-900	to	+300;	Pan:	±3200		

										2.2.2.7	Mechanical	Range	– Pitch:	-1250	to	450;	Pan:	±3300		

										2.2.2.8	Max	Controllable	Speed	– Pitch:	1200/s;	Pan:	1800/s		

		

2.2.3	Camera		

										2.2.3.1	Name	– X3		

										2.2.3.2	Model	– FC350		

										2.2.3.3	Total	Pixels	–		12.76M		

									 2.2.3.4	Effective	Pixels	–		12.4M		

										2.2.3.5	Image	Max	Size	– 4000x3000		

										2.2.3.6	ISO	Range	–		100-3200		

										2.2.3.7	Field	of	View	- 940		

										2.2.3.8	CMOS	– Sony	EXMOR	1/2.3”		

										2.2.3.9	HD	Video	Recording	– UHD(4K):	4096x2160p24/25,	3840x2160p24/25/30;	

										FHD:1920x1080p24/25/30/48/50/60;		HD:	1280x720p24/25/30/48/50/60		

										2.2.3.10	Operating	Temperature	Range	- 320F	-		1040F	(00C	- 400C)		

		

2.2.4	Transmitter		

												2.2.4.1	Name	– C1		

												2.2.4.2	Operating	Frequency	– 5.728-5.850GHz;	2.400-2.483GHz		

												2.2.4.3	Communicating	Distance	(unobstructed)	– 2000m		

												2.2.4.4	Output	Power	– 9W		

												2.2.4.5 Operating	Temperature	Range	-		140F	to	1040F	(-100C	to	400C)		

												2.2.4.6	Battery	– 600mAh	LiPo	2S		
36

APPENDIX	– D

DJI	Phantom	2	Vision	+ Manufacturer’s	User	Manual	See	Attachment	

‘Julian_Everly_Creative_Ventures_Inc_Phantom_2_Vision+_User_Manual_v1.2_en.pdf’	

APPENDIX	– E

DJI	Phantom	3 Manufacturer’s	User	Manual	See	Attachment	

‘Julian_Everly_Creative_Ventures_Inc_Phantom_3_Professional_User_Manual_v1_2’

APPENDIX	– F

DJI Inspire	1	Manufacturer’s	User	Manual	See	Attachment	

‘Julian_Everly_Creative_Ventures_Inc _Inspire_1_User_Manual_v1.0_en.pdf’	

APPENDIX	– G

UAS	Check	List See	Attachment	‘Appendix_G_UAS_checklists.pdf’

APPENDIX- H

Client/Owner	On-Site	Safety	Acknowledgement	Form ‘Appendix_H_Client_Owner_Safety’