UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

WILLIAM J CAMP 

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 Professional UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on June 28, 2015

WILLIAM J. CAMP

76321 OVERSEAS HWY

ISLAMORADA, FL 33036

305-879-8243

RGEPRODUCTIONS@GMAIL.COM
TABLE OF CONTENTS

Page 

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WILLIAM J CAMP 

SEEKS EXEMPTION........................................................................8

THE EXTENT OF RELIEF WILLIAM J CAMP SEEKS AND THE REASON WILLIAM 

J CAMP SEEKS THE RELIEF.......................................12

THE REASONS WHY GRANTING WILLIAM J CAMP’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ........................................................ 15
THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY .........................................................................18

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.............33

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT WILLIAM J CAMP’S REQUEST............34 

CONCLUSION ...................................................................................................................35

APPENDICES........................................................................................36

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations 

COA Certificate of Authorization

FAA Federal Aviation 

Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

MSL Mean Sea Level

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 

Proceedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meterological 

Conditions

VTOL Vertical Takeoff and 

Landing
SUMMARY

WILLIAM J CAMP 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 WILLIAM J CAMP to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of construction sites, real 

estate, farmland, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

WILLIAM J CAMP provides his clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness.

WILLIAM J CAMP has completed Flight Training Ground School and logged over 45

hours of flying experience. He has over 10 years recreational/hobby experience in all 

aspects of aerial video and photography. The objective of WILLIAM J CAMP and his

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

public, and residential uses, specifically targeting:

• General aerial still photos

• Commercial Media Applications i.e. 

Wedding Videography and Business 

Promotional Video

• Wildlife population surveys

• Real Estate marketing

• Aerial inspections of public and private 

structures.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UASs

WILLIAM J CAMP seeks an exemption to operate DJI Phantom 3 Professional for

compensation or
hire within the NAS. The DJI Phantom 3 Professional is a 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 Professional has a maximum 

gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches, 

width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. 

The DJI Phantom 3 Professional UA is equipped with four main rotors, driven by Lithium 

Polymer battery powered electric motors.

The DJI Phantom 3 Professional UA that will be operated by WILLIAM J CAMP will be 

registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, WILLIAM J CAMP , 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 Professional 

UA 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, WILLIAM J CAMP ’s operation of the DJI 

Phantom 3 Professional UA 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, WILLIAM J CAMP 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.

WILLIAM J CAMP submits that the requested relief is proper since an equivalent level 

of safety will be ensured. WILLIAM J CAMP 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 3 Professional Instruction Manual).

Furthermore, WILLIAM J CAMP will document and maintain all maintenance records for 

the DJI Phantom 3 Professional UA.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private Pilot
Privileges and Limitations: Pilot in Command, is requested by WILLIAM J CAMP 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 Professional UA in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles, and structures.

WILLIAM J CAMP seeks relief from Section 91.7(a), entitled Civil Aircraft 

Airworthiness, because the DJI Phantom 3 Professional UA does not require an

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

WILLIAM J CAMP submits that he will ensure that the DJI Phantom 3 Professional UA 

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

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

Phantom 3 Professional Instruction Manual), and that the aircraft is in a condition for safe

flight.

WILLIAM J CAMP also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3 Professional UA will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 

Professional UA 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 WILLIAM J CAMP’s operation of the DJI Phantom 3 Professional UA within visual 

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

91.121.

Additionally, WILLIAM J CAMP seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel Requirements for Flight in VFR Conditions. WILLIAM J CAMP 

submits that safety will not be affected by operation of the DJI Phantom 3 Professional 

UA 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, WILLIAM J CAMP provides the following 

information in support of his petition for exemption:
Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: 

WILLIAM J. CAMP

76321 OVERSEAS HWY

ISLAMORADA, FL 33036

305-879-8243

RGEPRODUCTIONS@GMAIL.COM
The Specific Sections Of 14 C.F.R. From Which WILLIAM J CAMP

Seeks Exemption.

1. WILLIAM J CAMP 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. WILLIAM J CAMP 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. WILLIAM J CAMP 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. WILLIAM J CAMP Seeks Exemption From The 

Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel Requirements for Flight in VFR Conditions, 

subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly

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

after that for at least 20 minutes.

5. WILLIAM J CAMP 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. WILLIAM J CAMP 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. WILLIAM J CAMP 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.

1. WILLIAM J CAMP Seeks Exemption From The 

Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance Records, subsections (a) and (b), state the 

following:

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

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

specified in paragraph (b) of this section:

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

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

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

the work performed; and

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

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

the aircraft for return to service.

(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, 

and each rotor.

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

propeller, rotor, and appliance.

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

which are required to be overhauled on a specified time basis.

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

since the last inspection required by the inspection program under 

which the aircraft and its appliances are maintained.

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

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

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

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

action is required.

(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.
The Extent Of Relief WILLIAM J CAMP Seeks And The Reason 

WILLIAM J CAMP Seeks The Relief.

1. Extent Of Relief WILLIAM J CAMP Seeks And The Reason 

WILLIAM J CAMP 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, WILLIAM J CAMP submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 

Professional UA 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 Professional 

UA 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, WILLIAM J CAMP submits that all flights of the DJI Phantom 3 Professional 

UA, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to 

WILLIAM J CAMP’s business; and (2) will not carry passengers or property for 

compensation or hire.
2. Extent Of Relief WILLIAM J CAMP Seeks And The Reason 

WILLIAM J CAMP 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 WILLIAM J CAMP to determine that the DJI Phantom 3 Professional 

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

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

Phantom 3 Professional Instruction Manual).

WILLIAM J CAMP seeks the requested relief because the DJI Phantom 3 Professional 

UA does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, WILLIAM J CAMP will ensure that the DJI Phantom 3 

Professional UA is in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction 

Manual) prior to every flight, and further, determine that the aircraft is in condition for 

safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief WILLIAM J CAMP Seeks And The Reason 

WILLIAM J CAMP 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 Professional UA, which utilizes 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), WILLIAM J CAMP seeks the 

requested relief because the DJI Phantom 3 Professional 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 Professional UA is equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground level 

pressure setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS.
4. Extent Of Relief WILLIAM J CAMP Seeks And The Reason 

WILLIAM J CAMP 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 

Professional UA 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.

WILLIAM J CAMP seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 3 Professional UA 

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

that WILLIAM J CAMP proposes to conduct pursuant to this Petition.

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

Professional UA, the DJI Phantom 3 Professional and WILLIAM J CAMP ’s proposed 

operating limitations, ensure that WILLIAM J CAMP will safely operate the battery 

powered DJI Phantom 3 Professional UA during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 19 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least

4.5 minutes.

5. Extent Of Relief WILLIAM J CAMP Seeks And The Reason 

WILLIAM J CAMP 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, WILLIAM J CAMP requests relief from 

these Sections because the DJI Phantom 3 Professional UA does not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom UAS meets the conditions of 

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

WILLIAM J CAMP will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

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

Phantom 3 Professional Instruction Manual). Furthermore, WILLIAM J CAMP will

document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.
The Reasons Why Granting WILLIAM J CAMP’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 WILLIAM 

J CAMP to safely, efficiently, and economically perform aerial video and 

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

the United States.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the 

benefits of WILLIAM J CAMP’s proposed operation of the DJI Phantom 3 Professional

UAS will be realized without implicating any privacy issues.

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

The DJI Phantom 3 Professional UA is battery powered and serves as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the number of manned aircraft needed to perform aerial acquisitions,

an exemption allowing the use of a DJI Phantom 3 Professional UAS would reduce the 

number of manned aircraft in the NAS and 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 Professional UA does 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 3 Professional UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air 

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

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

UAS produce no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UA, while
reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the

UAs are propelled by battery-powered electric motors, rather than an internal combustion 

engine.

By using the DJI Phantom 3 Professional UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Phantom 3 Professional UA (weighing approximately 2 pounds 11 

ounces at its maximum gross weight with a length of 16 inches and widths of 16 inches 

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 Professional UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional UA is also an

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Phantom 3 Professional UAS will allow United States based 

companies, like WILLIAM J CAMP, 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 Professional 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 3 Professional UAS, companies such as WILLIAM J 

CAMP, 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 Professional 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

fordecades, WILLIAM J CAMP’s proposed operation of the DJI Phantom 3 Professional

UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional 

UAS will be operated only in compliance with operating documents (i.e., The Monthly 

Maintenance Log, and DJI Phantom 3 Professional 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.
The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal ToThat 

Provided By The Rule From Which WILLIAM J CAMP SeeksExemption.

1. Reasons Why The DJI Phantom 3 Professional UA Meets 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, WILLIAM J CAMP’s operation of the DJI Phantom 3 

Professional UAS meets 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 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, WILLIAM J CAMP submits that the DJI Phantom 3 

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

demonstrated by:

(a) ) the characteristics of the DJI Phantom 3 Professional UA; (b) the pilot

certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Professional UAS 

Demonstrates Its Safe Characteristics.

The DJI Phantom 3 Professional UAS does not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, speed,

and operational capability.

i. Technical Specifications Of The DJI Phantom 3 Professional UAS

The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the 

DJI Phantom 3 Professional User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight 

And Navigation Modes Enable The UAS To Remain Within A

Defined Operational Area.
The DJI Phantom 3 Professional 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 3 Professional UAS is provided at pages 25-35 of the DJI Phantom 3 

Professional User Manual, attached hereto as Appendix A.

iii. The DJI Phantom 3 Professional 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 3 Professional UA will remain 

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

Professional UA does not reacquire control link data from the GCS, the UA will assume 

that the Control Link is lost and the UA will return to the home position (i.e., failsafe 

mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Function of the DJI Phantom 3 Professional UAS

is set forth at pages 27 through 29 of the DJI Phantom 3 Professional User Manual, 

attached hereto as Appendix A.

iv. The DJI Phantom 3 Professional GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 

Professional GCS and flight control software is provided at pages 32 through 43 of the 

DJI Phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manuals 

are attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 Professional UAS Are 

Limited To The Line Of Sight Of A Certificated Pilot in Command 

With A Safety Observer.

WILLIAM J CAMP will be the only person to act as a pilot in command (PIC) of the DJI 

Phantom 3 Professional UAS. Additionally, a safety observer will assist him during flight

time.

c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted 

Pursuant To Specific Operating Limitations.
In seeking this exemption, WILLIAM J CAMP proposes to commercially operate DJI 

Phantom 3 Professional UAS for the special purpose of conducting aerial video and

photography over certain areas of the 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 

Professional Unmanned Aircraft System. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this grant.

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

for the purpose of aerial video and photography.

3. The UA 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 UA must be operated within visual line of sight (VLOS) of the PIC at all 

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

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

medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is 

not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to 

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times.
Electronic messaging or texting is not permitted during flight operations. The 

PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO 

can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC 

with seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments.

9. The operating documents and the grant of exemption must be accessible 

during UAS operations and made available to the Administrator upon request. If 

a discrepancy exists between the conditions and limitations contained in the 

grant of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

that any update or revision would affect the basis upon which the FAA granted 

the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

condition for safe flight. If the inspection reveals a condition that affects the 

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical
component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records.

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

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

relevant sections of the operating documents.

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

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

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

keeping requirements, in accordance with the operating documents. 

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

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

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

person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all 

manufacturer Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a 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 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.

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.

WILLIAM J CAMP 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 Professional 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 Professional UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles, and structures.

Considering WILLIAM J CAMP’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 Professional UAS,

WILLIAM J CAMP submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

WILLIAM J CAMP’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).

WILLIAM J CAMP will not allow any PIC to operate the DJI Phantom 3 Professional 

UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or

the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 Professional 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 WILLIAM J CAMP’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.

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, WILLIAM J CAMP will ensure that the DJI Phantom 3 

Professional UAS is in an airworthy condition based upon the UAS’ 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 Professional UA 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 WILLIAM J CAMP’s operation of the DJI 

Phantom 3 Professional UA 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 

3 Professional UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, WILLIAM J CAMPwill ensure 

that it will safely operate the battery-powered DJI Phantom 3 Professional UA 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 

Professional UAS, the limitations on the proposed flight operations, and the location of 

the proposed operations, will ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 

Professional UAS provides audible and visual warnings to the PIC at the GCS when the 

UA 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 3 Professional UAS 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, WILLIAM J CAMP 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 WILLIAM J CAMP 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 Monthly Maintenance Log and 

DJI Phantom 3 Professional Instruction Manual). Furthermore, WILLIAM J CAMP will 

document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the

operating documents, WILLIAM J CAMP 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 Professional User Manual is attached hereto as Appendix A; a copy of the 

DJI Phantom 3 Professional UAS Maintenance LOG is attached hereto as Appendix B.

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

J CAMP 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 3 Professional UAS will be performed by trained technicians. Maintenance 

will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

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

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

are considered.
In consideration of WILLIAM J CAMP ’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 Professional UAS, WILLIAM 

J CAMP 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, WILLIAM J CAMP requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

Professional UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will 

permit safe operation of the UA 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 Professional UAS, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of 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 Leading Edge’s intended operation of the DJI Phantom 3 

Professional UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
A Summary That Can Be Published In The Federal Register, 

stating: The Rules From Which WILLIAM J CAMP Seeks 

Exemption:

WILLIAM J CAMP 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 WILLIAM J 

CAMP Seeks:

This exemption will permit WILLIAM J CAMP 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 WILLIAM J CAMP’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, WILLIAM J CAMP’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, WILLIAM J CAMP will operate the DJI Phantom 

3 Professional UAS safely in the NAS, without creating a hazard to users of

the NAS, or the public, or otherwise pose a threat to national security.

Listed in Appendix C is a link to a brief article outlining the environmental 

benefits of commercial use of a UAS.
CONCLUSION

As set forth herein, WILLIAM J CAMP 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 

Professional UAS commercially, without an airworthiness certificate, for the 

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

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

fulfilling the Congressional mandate of the FAA Modernization and Reform Act 

of 2012, while also advancing the interests of the public, by allowing WILLIAM J 

CAMP to safely, efficiently, and economically operate the DJI Phantom 3 

Professional UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, WILLIAM J CAMP

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 WILLIAM J CAMP to operate the DJI Phantom 3 

Professional UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: June28, 2015

Respectfully submitted,

WILLIAM J CAMP 

WILLIAM J. CAMP

76321 OVERSEAS HWY

ISLAMORADA, FL 33036

305-879-8243

RGEPRODUCTIONS@GMAIL.COM

Apendix

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

A. DJI Phantom 3 Professional User Manual
B. Proposed Maintenance Log

C. Link to a Supportive Article 

http://rotordronemag.com/can-drones-save-planet/

Service Date

Aircraft 

Hours Items performed Items Needing Attention