1 

UNITED STATES OF AMERICA DEPARTMENT 

OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION WASHINGTON, D.C. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Sheldon S Devantier with 

Designetic Designs LLC (DBA Dragonfly FX) 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

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

OPERATION OF DJI PHANTOM 3, DJI INSPIRE 1 AND DJI SPREADING 

WINGS S900 & S1000+ (W/ A2 FC) 

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on January 29th, 2016 

Sheldon S Devantier 

Designetic Designs LLC (DBA Dragonfly FX) 

4223 Canton Crest Dr. 

Katy, TX 77494 

Tel: (323) 325-2200 

Email: sd@dragonflyfx.com 
2 

Table of Contents 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER ...........................................................................6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DESIGNETIC DESIGNS LLC 

SEEKS EXEMPTION ..............................................................................................................7

THE EXTENT OF RELIEF DESIGNETIC DESIGNS LLC SEEKS AND THE 

DESIGNETIC DESIGNS LLC SEEKS THE RELIEF ............................................................8 

THE REASONS WHY GRANTING DESIGNETIC DESIGNS LLC’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST ..........................................................................12 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY .................................................................................................................14 

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

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT DESIGNETIC DESIGNS LLC’S REQUEST ....................................................25 

CONCLUSION ..............................................................................................................................26 

APPENDICES ...............................................................................................................................27
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 

FC Flight Controller 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

RC Remote Control 

Section 333 FAA Modernization & 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

 Designetic Designs LLC seeks exemption from the requirements of 14 C.F.R §§ 

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

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

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will Sheldon S 

Devantier, with Designetic Designs LLC, to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial photography, videography, and cinematography 

for weddings, real estate, special events, film sets, television, public events, newsgathering, 

and land surveying, as well as create company photography and videography for promotional 

videos and training for UAS operations over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

 Designetic Designs LLC provides its clients with expertise and knowledge in 

production and cinematography technologies as well provide audio/video solutions to present, 

produce, and educate. Designetic Designs LLC also provides its clients with the highest 

quality digital equipment for use in their commercial, personal, and non-profit multimedia 

projects. Designetic Designs LLC has over 5 years of professional audio, video and 

cinematography experience and is recognized as an expert in this field. Designetic Designs 

LLC has over 22 years of private aviation experience, and over 3 years of professional aerial 

video and photography. The objective of Designetic Designs LLC ‘s aerial video and 

photography operations is to provide high quality imaging for a variety of promotional, 

wedding, commercial, public, and residential uses, specifically targeting:

 Production and Motion Picture Filming 

 Television/Film 

 Wedding Videography and Photography 

 Real Estate Videography and Photography 

 Land and Construction Surveying 

 Increase public knowledge of UAS 

 Provide training and promote safe UAS operations for resale of DJI products by 

doing promotional and training videos and flight demonstrations.

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1, DJI S900 & S1000+ UASs 

 Designetic Designs LLC seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ 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 3 has 

a maximum gross weight of approximately 3 pounds, while having a length of 16 inches, width 

of 16 inches, height of 8 inches, and a maximum speed of approximately 31 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. The DJI 

S900 has a maximum gross weight of 18 pounds, a length of approx. 50 inches, width of 50 

inches, height of approx. 15 inches, and a maximum speed of approximately 42 knots. 
5 

The DJI S1000+ has a maximum gross weight of 24 pounds 4 ounces, a length of approx. 53 

inches, width of 53 inches, height of approx. 16 inches, and a maximum speed of approximately 

45 knots. The DJI Phantom 3, and DJI Inspire 1UA’s are equipped with four main rotors; driven 

by Lithium Polymer battery powered electric motors. The DJI S900 UA is equipped with 6 main 

rotors; driven by Lithium Polymer battery powered electric motors. The DJI S1000+ UA is 

equipped with 8 main rotors; driven by Lithium Polymer battery powered electric motors 

BASIS FOR PETITION 

 Petitioner, Designetic Designs LLC, 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 3, DJI Inspire 1, DJI Spreading Wings 

S900 & S1000+ UAS’s 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, Designetic Designs LLC ‘s operation of DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s 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, Designetic Designs LLC 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. 

 Designetic Designs LLC submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Designetic Designs LLC 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 3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ 

Instruction Manuals). Furthermore, Designetic Designs LLC will document and maintain all 

maintenance records for the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UAS’s. 

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

privileges and limitations: Pilot in command, is requested by Designetic Designs LLC 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 3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ UAS’s in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

 Designetic Designs LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ 

UAS’s do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. As such, Designetic Designs LLC submits that he will ensure that the DJI Phantom 3, DJI 

Inspire 1, DJI Spreading Wings S900 & S1000+ UAS’s 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 3, DJI Inspire 1, DJI Spreading Wings S900 & 

S1000+ Instruction Manuals), and that the aircraft are in a condition for safe flight. 
6 

 Designetic Designs LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings 

S900 & S1000+ UA’s will not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ UA’s 

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 Designetic Designs 

LLC’s operation of the DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ 

UAS’s within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

 Additionally, Designetic Designs LLC seeks an exemption from the requirements of 

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

LLC submits that safety will not be affected by operation of the DJI Phantom 3, DJI Inspire 1, 

DJI Spreading Wings S900 & S1000+ 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 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, Designetic Designs LLC 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: 

Sheldon S Devantier 

Designetic Designs LLC (DBA Dragonfly FX) 

4223 Canton Crest Dr. 

Katy, TX 77494 

Tel: (323) 325-2200 

Email: sd@dragonflyfx.com 

 
7 

B. The Specific Sections Of 14 C.F.R. From Which DESIGNETIC DESIGNS LLC seeks 

Exemption. 

1. Designetic Designs LLC Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) 

of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if— 

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

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

2. Designetic Designs LLC 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. Designetic Designs LLC 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. Designetic Designs LLC 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: 
8 

(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. Designetic Designs LLC 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. Designetic Designs LLC 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[.] 

7. Designetic Designs LLC 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. Designetic Designs LLC 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: 
9 

(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. 

(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. 
10 

(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 Designetic Designs LLC Seeks And The Reason Designetic 

Designs LLC Seeks The Relief. 

 1. Extent Of Relief Designetic Designs LLC Seeks And The Reason Designetic 

Designs LLC 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 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, Designetic Designs LLC submits that an equivalent 

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

3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s unless that PIC has met 

certain flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate either the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs 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, Designetic Designs LLC submits that all flights of the DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+UASs, conducted by the PIC pursuant to 

the grant of this Petition: (1) will be incidental to Designetic Designs LLC’s business; and (2) 

will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Designetic Designs LLC Seeks And The Reason DESIGNETIC 

DESIGNS LLC 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 Designetic Designs LLC to determine that the DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ UAS’s are in airworthy condition prior to every flight 

by ensuring that the UAS is in compliance with the operating documents (i.e., the Designetic 

Designs LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ Instruction Manuals). 

 Designetic Designs LLC seeks the requested relief because the DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Designetic Designs LLC

will ensure that the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UAS’s are in airworthy condition based upon its compliance with the operating documents (i.e., 
11 

Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ Instruction Manuals) 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 Designetic Designs LLC Seeks And The Reason Designetic 

Designs LLC 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 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UAS’s, 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), Designetic 

Designs LLC seeks the requested relief because the DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UA’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 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s 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 Designetic Designs LLC Seeks And The Reason Designetic 

Designs LLC 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 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 14.5 

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

that for at least 5.5 minutes. Designetic Designs LLC seeks the requested relief because without 

an exemption from Section 91.151(b), the flight time duration of the battery powered DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s will severely 

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

Designs LLC proposes to conduct pursuant to this Petition. 

 Significantly, as set forth below, the technical specifications of the DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s, the DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ operating documents, and Designetic Designs LLC s 

proposed operating limitations, ensure that Designetic Designs LLC will safely operate the 

battery powered DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s 

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

(VFR), with enough battery power to fly for a total duration of 14.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5.5 minutes. 
12 

5. Extent Of Relief Designetic Designs LLC Seeks And The Reason Designetic 

Designs LLC 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, Designetic Designs LLC requests relief from 

these Sections because the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UAS’s do not require airworthiness certificates. As set forth more fully below, the DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s meet the conditions 

of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

Designetic Designs LLC will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and practices prescribed in 

the UAS operating documents (i.e., the Designetic Designs LLC Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ Instruction Manuals). Furthermore, Designetic Designs LLC will document and 

maintain all maintenance records for the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings 

S900 & S1000+ UASs. 

D. The Reasons Why Granting Designetic Designs LLC’s Request Would Be In 

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

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

Designs LLC to safely, efficiently, and economically perform aerial video and photography for 

wedding films, real estate, special events, film sets, and landscape over certain areas of the 

United States. 

 Additionally, use of the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UAS’s will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Designetic Designs LLC’s proposed operation 

of the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s will be 

realized without implicating any privacy issues. 

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

The DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UA’s 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 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s 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 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s 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. 
13 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s. 

 Conducting aerial acquisitions with the DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UAS’s, instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels 

of air and noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Phantom 3, DJI Inspire 1, and 

DJI Spreading Wings S900 & S1000+ UAS’s 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 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ 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 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 

& S1000+ UAs (weighing approximately only 2 pounds 11 ounces to 24 pounds respectively, at 

their maximum gross weights, with lengths of 16 inches to 53 inches respectively, widths of 16 

inches to 53 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 3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs Will Benefit The 

Economy. 

 In addition to being safe and efficient, the DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3, DJI Inspire 

1, and DJI Spreading Wings S900 & S1000+ UASs will allow United States based companies, 

like Designetic Designs LLC, 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 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs 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 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UASs, companies such as Designetic Designs LLC, 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 3, DJI Inspire 1, and DJI Spreading 
14 

Wings S900 & S1000+ UASs, 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, Designetic Designs LLC’s proposed operation of the DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ UASs will not implicate any privacy issues. 

Specifically, the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs will be operated only in compliance with operating documents (i.e., 

the Designetic Designs LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ Instruction Manuals) 

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 Designetic Designs LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings 

S900 & S1000+ UASs 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, Designetic Designs LLC’s operation of the DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs 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 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 
15 

 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, Designetic Designs LLC submits that the DJI Phantom 3 

and DJI Inspire 1UASs can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs; (b) the pilot certification requirement; and (c) 

the specific operating limitations. 

 a. The Specifications Of The DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UASs Demonstrate Its Safe Characteristics. 

 The DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs 

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. 

 

 i. Technical Specifications Of The DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs, and DJI A2 FC.

 The technical specifications of the DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UASs are set forth by the DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ Specifications and Data Sheet, attached hereto as 

Appendices A, B, C, D, E and F. 

 

 ii. The DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UASs Autonomous Flight And Navigation Modes Enable The UASs To 

Remain Within A Defined Operational Area. 

 The DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UASs may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI Phantom 3, DJI Inspire 

1, and DJI Spreading Wings S900 & S1000+ UASs is provided at pages 25-35 of the page 

11-14 of the DJI Phantom 3, pages 12-16 and 45-50 of the DJI Inspire 1, and pages 23, 30-31 

and 33-37 of the A2 FC (used for the DJI Spreading Wings S900 & S1000+ UAVs) User 

Manuals, attached hereto as Appendices G, H, I, J, K and L. 

 
16 

 iii. The DJI Phantom 3, DJI Inspire 1, and DJI SpreadingWings S900 & 

S1000+ UASs 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 3, DJI Inspire 1, and 

DJI Spreading Wings S900 & S1000+ UAs will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ 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 of the DJI Phantom 2 UAS are set 

forth at pages 27-29, pages 12-14 for the DJI Phantom 3, pages 13-15 for the DJI Inspire 1, 

and pages 30-31 of the A2 FC (used for the DJI Spreading Wings S900 & S1000+ UAVs) 

User Manuals, attached hereto as Appendices G, H, I, J, K and L. 

 

 b. Flight Operations Of DJI Phantom 3, DJI Inspire 1, and

DJI Spreading Wings S900 & S1000+ UASs Are Limited To The Line Of Sight Of A 

Certificated PIC With A Safety Observer. 

 Sheldon S Devantier is a commercially rated pilot, and Designetic Designs LLC will 

only utilize certificated pilots who possess a current and valid airman medical certificate to 

act as a pilot in command (PIC) of the DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+UASs. Additionally, a safety observer will assist all pilots during 

flight time. 

 c. Flights Of DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+UASs Will Be Conducted Pursuant To Specific Operating Limitations. 

 In seeking this exemption, Designetic Designs LLC proposes to commercially operate 

DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs 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 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs. 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, photography and cinematography. 

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 
17 

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. 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. 

7. 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. 

8. 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. 

9. 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. 

10. 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. 
18 

11. 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. 

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

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

13. 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. 

14. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

15. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections. 

16. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate. 

17. 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. 

18. 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. 

19. 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. 
19 

20. 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. 

21. 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 the COA 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. 

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; 
20 

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. 

Designetic Designs LLC 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 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

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

currency requirements, that the PIC is able to safely operate the DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Considering DESIGNETIC DESIGNS LLC’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 3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS, Designetic Designs 

LLC submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for 

DESIGNETIC DESIGNS LLC’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). 

 Designetic Designs LLC will not allow any PIC to operate the DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UAS training and currency requirements, that the PIC is 
21 

able to safely operate the DJI Phantom 2 or 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 Designetic Designs LLC’s proposed operations. The Administrator has held 

that prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows: 

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 experience 

building flights can also be conducted under the grant of exemption to accomplish the 

required flight time. During training, proficiency, and experience-building flights the 

PIC is required to operate the UA with appropriate distances in accordance with 14 

C.F.R 91.119. Exemption No. 11138 at page 15. 

Accordingly, Designetic Designs LLC will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ 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 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ 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 
22 

because prior to every flight, DESIGNETIC DESIGNS LLC will ensure that the DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ 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 

Designetic Designs LLC’s operation of the DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ 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 by 

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

2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, Designetic Designs LLC will ensure that it will safely operate the 

battery powered DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

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 3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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 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 
23 

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

DJI Phantom 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, Designetic Designs LLC 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 Designetic Designs LLC 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 Designetic Designs LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, DJI Inspire 1, and 

DJI Spreading Wings S900 & S1000+ Instruction Manual). Furthermore, Designetic 

Designs LLC will document and maintain all maintenance records for the DJI Phantom 3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs. 

 Since the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs will be inspected as prescribed by the operating documents, Designetic Designs LLC 

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 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ User Manuals are attached hereto as Appendices A, B, C, 

D, E and F; a copy of the DJI Phantom 2 and DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Appendix G. 

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

Designs LLC 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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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 
24 

considered. 

 In consideration of Designetic Designs LLC’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ UASs, Designetic Designs LLC 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, Designetic Designs LLC 

requests that the FAA prescribe special conditions for the intended operation of the DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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 §§ 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 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ 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 S with Designetic Designs LLC intended operation of 

the DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

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 
25 

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 Designetic Designs LLC Seeks Exemption:

 Designetic Designs LLC 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 Designetic Designs LLC 

Seeks: 

This exemption will permit Designetic Designs LLC to commercially operate an 

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

and cinematography including photo and/or video for television, public events, 

newsgathering, real estate and land surveying over certain areas of the United States. As 

well as assist with company promotional videos and training demonstrations for UAS 

operations.

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

Designetic Designs LLC’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, Designetic Designs LLC’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, Designetic Designs LLC will operate the DJI Phantom3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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. 

 
26 

CONCLUSION 

 As set forth herein, Designetic Designs LLC 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 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs 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 Designetic Designs LLC to safely, 

efficiently, and economically operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and 

DJI Spreading Wings S900 & S1000+ UASs commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Designetic Designs LLC 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 Sheldon Devantier to operate the DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs commercially for 

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

States. 

Dated: January 29th, 2016 

Respectfully submitted, 

_______________________________ 

Sheldon S Devantier 

Designetic Designs LLC (DBA Dragonfly FX) 

4223 Canton Crest Dr. 

Katy, TX 77494 

(323) 325-2200 

sd@dragonflyfx.com 

 
27 

Appendices: 

A – DJI Phantom 3 Specifications Data Sheet 

B – DJI Inspire 1 Specifications Data Sheet 

C – DJI S900 Specifications Data Sheet 

D – DJI S1000+ Specifications Data Sheet 

E – DJI A2 Flight Controller Data Sheet 

F – DJI Phantom 3 Manufacturer’s User Manual 

G – DJI Inspire 1 Manufacturer’s User Manual 

H – DJI S900 Manufacturer’s User Manual 

I – DJI S1000+ Manufacturer’s User Manual 

J – DJI A2 FC Manufacturer’s User Manual 

K – Monthly Maintenance Log 

APPENDIX – A 

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

 Designetic Designs LLC 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 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 
28 
29 

APPENDIX – B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

 Designetic Designs LLC 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) 
30 

2.2 DJI Inspire 1 
31 
32 
33 

APPENDIX – C 

DJI SPREADING WINGS S900 TECHNICAL SPECIFICATIONS 

 Designetic Designs LLC 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) 
34 
35 

APPENDIX – D 

DJI SPREADING WINGS S1000+ TECHNICAL SPECIFICATIONS 

 Designetic Designs LLC 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) 
36 
37 

APPENDIX – E 

DJI A2 FLIGHT CONTROLLER TECHNICAL SPECIFICATIONS 

(USED AS THE FC FOR DJI SPREADING WINGS S900 & S1000+) 

 Designetic Designs LLC 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) 
38 

APPENDIX – F 

DJI Phantom 3 Manufacturer’s User Manual 

APPENDIX – G 

DJI Inspire 1 Manufacturer’s User Manual 

APPENDIX – H 

DJI Spreading Wings S900 Manufacturer’s User Manual 

APPENDIX – I 

DJI Spreading Wings S1000+ Manufacturer’s User Manual 

APPENDIX – J 

DJI A2 Flight Controller Manufacturer’s User Manual 
39 

APPENDIX – K 

 

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(Dampening) 

Other: