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February 8, 2016

Attn:

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: PREMIER DRONE PRODUCTIONS, LLC 

REQUESTS AN EXEMPTION 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 4k and Inspire 1 Pro UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Robert McChesney 

Managing Partner and Chief Pilot

FAA Private Pilot SEL # 3406645

UAS Certificate #FA3K44RW9R

PREMIER DRONE PRODUCTIONS, LLC

PO Box 451

Gotha, FL 34734

407-744-1163

bob@premierdroneproductions.com

 
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TABLE OF CONTENTS

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PREMIER DRONE 

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

THE EXTENT OF RELIEF PREMIER DRONE PRODUCTIONS SEEKS AND THE 

REASON PREMIER DRONE PRODUCTIONS SEEKS THE RELIEF............................11

THE REASONS WHY GRANTING PREMIER DRONE PRODUCTIONS’ REQUEST 

WOULDBE IN THE PUBLIC INTEREST ........................................................................ 14

THE REASONS WHY GRANTING THE EXEMPTION TO PREMIER DRONE 

PRODUCTIONS WOULD NOT ADVERSELY AFFECT SAFETY. ............................... 16

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.................. 27

CONCLUSION...................................................................................................................... 28

APPENDICES... ....................................................................................................................29
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

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

PREMIER DRONE PRODUCTIONS LLC seeks exemption from the requirements of 14 

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate Unmanned Aircraft Systems 

(DJI Phantom 3 and Inspire 1 Pro) pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit PREMIER DRONE 

PRODUCTIONS to operate Unmanned Aircraft Systems (UASs) for the commercial 

purpose of conducting aerial video and photography of construction sites, residential and 

commercial real estate, civil landscapes and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE

PETITIONER

PREMIER DRONE PRODUCTIONS is a newly established group headed by a former 

US Naval Aviator and private pilot (Commanding Officer of a US Navy squadron with 

over 2000 logged flight hours in various US Navy and civilian aircraft) and a world 

renowned photographer and digital videographer. Each has over thirty years’ successful 

experience in their respective fields. Building on our success in aviation and 

photographic excellence we bring experience in all skill sets for the aerial drone business. 

These include safe aviation leadership, flight preparation, flight training, flight 

standardizations, best aviation maintenance practices and “by the book” flight operations. 

On the production side, we provide expert digital photograph and videography techniques 

and products for commercial and private sector businesses, non-profit and federal 

agencies. PREMIER DRONE PRODUCTIONS’ staff have worked on thousands of 

productions over the past 30 years in all types of locations with a perfect client and 

employee safety record. The objective of PREMIER DRONE PRODUCTIONS and our 

Unmanned Aircraft Systems (DJI Phantom 3 4k and Inspire 1 Pro) aerial operations is to 

provide safe flight operations and high-quality video products for a variety of 

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

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic landmarks

• Special event coverage

• Private and governmental training

• Golf course and golf related properties

• Commercial Real Estate Development

Our staff has safely flown DJI Phantom quadcopters recreationally for approximately 2 

years without incident.
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BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, UAS

PREMIER DRONE PRODUCTIONS seeks an exemption to operate DJI Phantom 3 4k 

and Inspire 1 UAS systems for compensation or hire within the NAS. The DJI Phantom 3 

4k and Inspire 1 UASs are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) 

with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. 

Unmanned Aircraft Systems: DJI Phantom 3 4k, UAS

The DJI Phantom 3 4k UAS has a maximum gross weight of approximately 2.8 lbs. while 

having a diagonal dimension of 23.2”, a maximum speed of approximately 16.4’fps and a 

maximum flying height of 400'. The DJI Phantom 3 4k is equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors.

Unmanned Aircraft Systems: DJI Inspire 1, UAS

The DJI Inspire 1 UAS has a maximum gross weight of approximately 7.7 lbs. while 

having a diagonal dimension of 22.8”, a maximum speed of approximately 54fps and a 

maximum flying height of 400 feet. The DJI Phantom Inspire 1 is equipped with four 

main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 3 4k and Inspire 1 UASs that will be operated by PREMIER DRONE 

PRODUCTIONS 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, PREMIER DRONE PRODUCTIONS, 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 

4k and Inspire 1 UASs in the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

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

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

unmanned aircraft and its operation, PREMIER DRONE PRODUCTIONS operation of 

DJI Phantom 3 4k and Inspire 1 UASs meet 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.
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Accordingly, PREMIER DRONE PRODUCTIONS 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.

PREMIER DRONE PRODUCTIONS submits that the requested relief is proper since an 

equivalent level of safety will be ensured. PREMIER DRONE PRODUCTIONS will use 

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

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

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 4k and Inspire 

1 UASs Instruction Manuals). Furthermore, PREMIER DRONE PRODUCTIONS will

document and maintain all maintenance records for the DJI Phantom 3 4k and Inspire 1 

UASs.

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

privileges and limitations: Pilot in Command, is requested by PREMIER DRONE 

PRODUCTIONS 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 4k and Inspire 1 UASs in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

PREMIER DRONE PRODUCTIONS Seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom 3 4k and Inspire 1 UASs do not require 

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

PREMIER DRONE PRODUCTIONS submits that they will ensure that the DJI Phantom 

3 4k and Inspire 1 UASs are in an airworthy condition, prior to every flight, by 

determining that the UAS are in compliance with the operating documents (i.e., Monthly 

Maintenance Log, Pre- Flight Checklists and DJI Phantom 3 4k and Inspire 1 UASs 

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

DRONE PRODUCTIONS also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 4k and Inspire 1 UASs will not 

have a typical barometric altimeter onboard. However, altitude information of the DJI 

Phantom 3 4k and Inspire 1 UASs 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 PREMIER DRONE PRODUCTIONS’ operation of the DJI 

Phantom 3 4k and Inspire 1 UASs within visual line of sight, at or below 400 feet AGL, 

will ensure a level of safety equivalent to Section 91.121.

Additionally, PREMIER DRONE PRODUCTIONS Seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR 
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conditions. PREMIER DRONE PRODUCTIONS submits that safety will not be affected 

by operation of the DJI Phantom 3 4k and Inspire 1 UASs 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 23 minutes. Battery power indicators 

are also able to show exactly how much battery power is left, as well as how much time is 

needed to return safely back to point of takeoff.

In accordance with 14 C.F.R. § 11.81, PREMIER DRONE PRODUCTIONS provides 

the following information in support of its petition for exemption:

E. Name And Address Of The Petitioner.

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

Robert McChesney 

Managing Partner and Chief Pilot

FAA Private Pilot SEL # 3406645

sUAS Certificate 

#FA3K44RW9R

PREMIER DRONE PRODUCTIONS LLC

PO Box 451

Gotha, FL 34743

407-744-1163 

bob@premierdroneproductions.com

F. The Specific Sections Of 14 C.F.R. From Which PREMIER DRONE 

PRODUCTIONS Seeks Exemption.

1. PREMIER DRONE PRODUCTIONS 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 employmentif—

(1)The flight is only incidental to that business or employment; and
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(2)The aircraft does not carry passengers or property for compensation or hire.

2. PREMIER DRONE PRODUCTIONS 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. PREMIER DRONE PRODUCTIONS 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. PREMIER DRONE PRODUCTIONS 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. PREMIER DRONE PRODUCTIONS Seeks Exemption From The Requirement 

Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the 
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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. PREMIER DRONE PRODUCTIONS 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 alterationunless--

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

under § 43.7 of this chapter[.]

7. PREMIER DRONE PRODUCTIONS Seeks Exemption From The Requirements 

Of Sections 91.409(a)(1) And91.409(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. The PREMIER DRONE PRODUCTIONS 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--
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(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.

B. The Extent Of Relief PREMIER DRONE PRODUCTIONS Seeks And The 
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Reason PREMIER DRONE PRODUCTIONS Seeks The Relief.

1. Extent Of Relief PREMIER DRONE PRODUCTIONS Seeks And The Reason 

PREMIER DRONE PRODUCTIONS 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, PREMIER DRONE PRODUCTIONS submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate 

the DJI Phantom 3 4k and Inspire 1 UASs 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 4k and Inspire 1 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, PREMIER DRONE PRODUCTIONS submits that all flights of the DJI 

Phantom 3 4k and Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to PREMIER DRONE PRODUCTIONS’ business; and 

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

C. The Extent Of Relief PREMIER DRONE PRODUCTIONS Seeks And The 

Reason PREMIER DRONE PRODUCTIONS Seeks The Relief.

1. Extent Of Relief PREMIER DRONE PRODUCTIONS Seeks And The Reason 

PREMIER DRONE PRODUCTIONS 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: 
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(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, PREMIER DRONE PRODUCTIONS submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate 

the DJI Phantom 3 4k and Inspire 1 UASs 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 4k and Inspire 1 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, PREMIER DRONE PRODUCTIONS submits that all flights of the DJI 

Phantom 3 4k and Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to PREMIER DRONE PRODUCTIONS’ business; and 

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

2. Of Relief PREMIER DRONE PRODUCTIONS Seeks And The Reason 

PREMIER DRONE PRODUCTIONS 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 PREMIER DRONE PRODUCTIONS to determine that the DJI 

Phantom 3 4k and Inspire 1 UASs are in airworthy condition prior to every flight by 

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

DRONE PRODUCTIONS Aerial Operations Manual, Monthly Maintenance Log, and 

DJI Phantom 3 InstructionManual).

PREMIER DRONE PRODUCTIONS seeks the requested relief because the DJI 

Phantom 3 4k and Inspire 1 UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, PREMIER DRONE 

PRODUCTIONS will ensure that the DJI Phantom 3 4k and Inspire 1 UASs are in 

airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 3 4k and Inspire 1 UAS 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 PREMIER DRONE PRODUCTIONS Seeks And The Reason 

PREMIER DRONE PRODUCTIONS 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 4k and Inspire 1 UASs, 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), PREMIER 
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DRONE PRODUCTIONS seeks the requested relief because the DJI Phantom 3 4k and 

Inspire 1 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 4k and Inspire 1 UASs 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 PREMIER DRONE PRODUCTIONS Seeks And The Reason 

PREMIER DRONE PRODUCTIONS 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 4k 

and Inspire 1 UASs during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 11-23 minutes. PREMIER 

DRONE PRODUCTIONS seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the

battery powered DJI Phantom 3 4k and Inspire 1 UASs will severely constrain the 

practicality of any aerial video or still photo flight operations that PREMIER DRONE 

PRODUCTIONS proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 4k 

and Inspire 1 UASs, the DJI Phantom 3 4k and Inspire 1 UAS’ operating documents, and 

PREMIER DRONE PRODUCTIONS’ proposed operating limitations, ensure that 

PREMIER DRONE PRODUCTIONS will safely operate the battery powered DJI 

Phantom 3 4k and Inspire 1 UASs during daylight hours in visual meteorological 

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

a total duration of 15 or 23 minutes.

5. Extent Of Relief PREMIER DRONE PRODUCTIONS Seeks And The Reason 

PREMIER DRONE PRODUCTIONS 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, PREMIER DRONE PRODUCTIONS

requests relief from these Sections because the DJI Phantom 3 4k and Inspire 1 UASs do 

not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 

4k and Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, PREMIER DRONE PRODUCTIONS 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 
14

documents (i.e., the PREMIER DRONE PRODUCTIONS Aerial Operations Manuals, 

Monthly Maintenance Logs, and DJI Phantom 3 4k and Inspire 1 UAS’ Instruction 

Manuals). Furthermore, PREMIER DRONE PRODUCTIONS will document and 

maintain all maintenance records for the DJI Phantom 3 4k and Inspire 1 UASs.

D. The Reasons Why Granting PREMIER DRONE PRODUCTIONS 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 PREMIER 

DRONE PRODUCTIONS to safely, efficiently, and economically perform aerial video 

and photography of construction sites, real estate, events and civic landscape over certain 

areas of the UnitedStates.

Additionally, use of the DJI Phantom 3 4k and Inspire 1 UASs will decrease congestion 

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

the benefits of PREMIER DRONE PRODUCTIONS’ proposed operation of the DJI 

Phantom 3 4k and Inspire 1 UASs will be realized without implicating any privacy

issues.

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

The DJI Phantom 3 4k and Inspire 1 UASs 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 4k and Inspire 1 

UASs 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 theground.

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 4k and Inspire 1 UASs do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations.

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

UAS.

Conducting aerial acquisitions with the DJI Phantom 3 4k and Inspire 1 UASs, 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 and Inspire 1 

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

alternative to the cabin class, six-cylinder internal combustion engine aircraft that are 
15

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

gallons per hour of leaded aviation fuel. The DJI Phantom 3 4k and Inspire 1 UASs, 

while reducing the carbon footprint of aerial acquisitions, also eliminate noise pollution, 

as the UASs are propelled by battery powered electric motors, rather than an internal 

combustion engine.

By using the DJI Phantom 3 4k and Inspire 1 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 4k UAS (weighing approximately 2.8 pounds at 

its maximum gross weight with diagonal dimension of 23.2 inches, and with no fuel on 

board) and the DJI Inspire 1 Pro (weighing approximately 7.7 pounds at its maximum 

gross weight with diagonal dimension of 22.8 inches, and with no fuel on board), have

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 4k and Inspire 1 UASs Will Benefit TheEconomy.

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical 

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

operation of the DJI Phantom 3 4k and Inspire 1 UASs will allow United States based 

companies, like PREMIER DRONE PRODUCTIONS, 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 4k and Inspire 1 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 UAS, companies such as PREMIER DRONE 

PRODUCTIONS, 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 4k and Inspire 1 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 andabroad.

4. There Are No Privacy Issues.
16

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, PREMIER DRONE PRODUCTIONS’ proposed operation of the DJI Phantom 

3 4k and Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI 

Phantom 3 4k and Inspire 1 UASs will be operated only in compliance with operating 

documents (i.e., PREMIER DRONE PRODUCTIONS Aerial Operations Manuals, 

Monthly Maintenance Logs, and DJI Phantom 3 4k and Inspire 1 UAS’s 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 PREMIER DRONE PRODUCTIONS Seeks

Exemption.

1. Reasons Why The DJI Phantom 3 4k and Inspire 1 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, PREMIER DRONE PRODUCTIONS operation of 

the DJI Phantom 3 and Inspire 1 UASs 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).
17

(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, PREMIER DRONE PRODUCTIONS submits that the DJI 

Phantom 3 4k and Inspire 1 UASs can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 4k and 

Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating 

limitations.

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe

Characteristics.

The DJI Phantom 3 4k and Inspire 1 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 UAS.

The technical specifications of the DJI Phantom 3 4k and Inspire 1 UASs are set forth by 

the DJI Phantom 3 4k and Inspire 1 UAS’s User Manuals, attached hereto as Appendix

A.

ii. The DJI Phantom 3 4k and Inspire 1 UAS’s Global Positioning Modes 

Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 4k and Inspire 1 UASs may be operated in both manual and global 

positioning flight modes. A complete description of the flight and navigational modes of 

the DJI Phantom 3 4k and Inspire 1 UASs is provided at page 11 of the DJI Phantom 3 

User Manual and page 15 of the DJI Inspire 1 User Manual attached hereto as Appendix

A.

iii. The DJI Phantom 3 4k and Inspire 1 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 4k and Inspire 1 UASs will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 4k and 

Inspire 1 UASs do not reacquire control link data from the GCS, the UAS will assume 

that the Control Link is lost and the 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 3 4k and Inspire 1 

UASs are set forth on pages 12 through 14 of the DJI Phantom 3 4k User Manual and 14 

through 18 of the Inspire 1 User Manual, attached hereto as Appendix A.

iv. The DJI Phantom 3 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 4k and 
18

Inspire 1 GCSs and flight control software is provided at pages 23 through 29 of the DJI 

Phantom 3 4k User Manual and pages 25 through 34 of the DJI Inspire 1 Pro User 

Manual. DJI Phantom 3 4k and Inspire 1 Pro User Manuals are attached hereto as 

Appendix A.

b. Flight Operations Of DJI Phantom 3 4k and Inspire 1 UASs Is Limited 

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

Observer.

PREMIER DRONE PRODUCTIONS’ certified pilot staff will be the only persons to act 

as a pilot in command (PIC) of the DJI Phantom 3 4k and Inspire 1 UASs. Additionally, 

a safety observer will assist him at all times during flight time and will remain in hand 

held radio contact.

c. Flights Of DJI Phantom 3 4k and Inspire 1 UASs Will Be Conducted 

Pursuant To Specific Operating Limitations.

In seeking this exemption, PREMIER DRONE PRODUCTIONS proposes to 

commercially operate DJI Phantom 3 UAS for the special purpose of conducting aerial

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

specific operating limitations.

1. Operations authorized by this grant of exemption will be limited to the 

following aircraft described in the operating documents, rotorcraft UAS weighing 

less than 55 pounds maximum gross weight: DJI Phantom 3 4k and Inspire 1 

Unmanned Aircraft Systems. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this grant.

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

operations for the purpose of aerial video andphotography.

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

4. The UASs must be operated at an altitude of no more than 400 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 UASs 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 
19

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 UASs to ensure that it is in a 

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

operation of the UASs, the aircraft are prohibited from operating until the 

necessary maintenance has been performed and the UASs are 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 UASs manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements.
20

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.
21

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 operatingdocuments.

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 UASs 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 structuresunless:

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 
22

leave such protection and are within 500 feet of the UA, flight operations 

must cease immediatelyand/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.

PREMIER DRONE PRODUCTIONS 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 4k and Inspire 1 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 4k and Inspire 1 UASs in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Considering PREMIER DRONE PRODUCTIONS’ 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 4k and 

Inspire 1 UASs, PREMIER DRONE PRODUCTIONS submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate 

to the airmanship skills necessary for PREMIER DRONE PRODUCTIONS specific 

proposed flightoperations.

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).
23

PREMIER DRONE PRODUCTIONS will not allow any PIC to operate the DJI 

Phantom 3 4k and Inspire 1 UASs unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements or the DJI Phantom 3 4k and Inspire 1 UAS’s 

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

Phantom 3 4k and Inspire 1 UASs in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles andstructures.

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 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 PREMIER DRONE PRODUCTIONS’ 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 experiencebuilding flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and experiencebuilding flights the PIC is required to operate the UA with appropriate distances 

in accordance with 14 C.F.R 91.119.

Accordingly, PREMIER DRONE PRODUCTIONS will ensure safe operations by not 

allowing any PIC to operate the DJI Phantom 3 4k and Inspire 1 UASs unless that PIC 
24

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

PIC is able to safely operate the DJI Phantom 3 4k and Inspire 1 UASs in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

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

Not Adversely Affect Safety.

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

prior to every flight, PREMIER DRONE PRODUCTIONS will ensure that the DJI 

Phantom 3 4k and Inspire 1 UASs are 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 4k and Inspire 1 UASs will be provided to 

the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path and altitude. 

This altitude information, combined with PREMIER DRONE PRODUCTIONS’

operation of the DJI Phantom 3 4k and Inspire 1 UASs within visual line of sight, at or 

below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The 

altitude information will be generated by GPS equipment installed onboard the aircraft. 

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

UAS at groundlevel.

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 4k and Inspire 1 UASs; (2) the limitations on the proposed flight operations; 

and (3) the location of the proposed flight operations. Accordingly, PREMIER DRONE 

PRODUCTIONS will ensure that it will safely operate the battery powered DJI Phantom 
25

3 4k and Inspire 1 UASs during daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of 15 minutes for the Inspire 1 Pro or 23 minutes for 

Phantom 3 4k.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 4k 

and Inspire 1 UASs; the limitations on the proposed flight operations; and the location of 

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

C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 4k 

and Inspire 1 UASs provides audible and visual warnings to the PIC at the GCS when 

the UAS experiences low battery voltage, the first warning occurring at approximately 

33% remaining battery power, and again at approximately 10% remaining battery

power. At the critically low battery level, the DJI Phantom 3 4k and 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, PREMIER DRONE PRODUCTIONS 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 PREMIER DRONE PRODUCTIONS will use 

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

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

documents (i.e., PREMIER DRONE PRODUCTIONS’ Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 4k and Inspire 1 Pro Instruction 

Manuals). Furthermore, PREMIER DRONE PRODUCTIONS will document and 

maintain all maintenance records for the DJI Phantom 3 4k and Inspire 1 UASs.

Since the DJI Phantom 3 4k and Inspire 1 UASs will be inspected as prescribed by the 

operating documents, PREMIER DRONE PRODUCTIONS 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 4k and Inspire 1 UAS User Manuals are attached hereto as 

Appendix A and B; a copy of the DJI Phantom 3 4k and Inspire 1 UAS’s Maintenance 

LOG is attached hereto as Appendix C.
26

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

DRONE PRODUCTIONS 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 4k and Inspire 1 UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log.

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

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

adversely affected when the technical characteristics and operating limitations of the 

UAS are considered.

In consideration of PREMIER DRONE PRODUCTIONS’ proposed operating 

limitations, the operating documents, and the technical aspects of the DJI Phantom 3 and 

Inspire 1 UASs, PREMIER DRONE PRODUCTIONS 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 SafeOperation.

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, PREMIER DRONE 

PRODUCTIONS requests that the FAA prescribe special conditions for the intended 

operation of the DJI Phantom 3 4k and Inspire 1 UASs, which contain such safety 

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

to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 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 4k and Inspire 1 UASs, since the

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

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following:
27

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 PREMIER DRONE PRODUCTIONS intended operation 

of the DJI Phantom 3 4k and Inspire 1 UASs, which contain such safety standards that 

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

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

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

& (b).

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

Rules From Which PREMIER DRONE PRODUCTIONS Seeks Exemption:

PREMIER DRONE PRODUCTIONS 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 PREMIER DRONE 

PRODUCTIONS Seeks:

This exemption will permit PREMIER DRONE PRODUCTIONS LLC to 

commercially operate Unmanned Aircraft Systems (UASs) 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 

PREMIER DRONE PRODUCTIONS’ 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 

UASs may operate safely in the NAS. As such, PREMIER DRONE PRODUCTIONS’

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.
28

As discussed in detail above, PREMIER DRONE PRODUCTIONS will operate the DJI 

Phantom 3 4k and Inspire 1 UASs safely in the NAS, without creating a hazard to users 

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

CONCLUSION

As set forth herein, PREMIER DRONE PRODUCTIONS 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 4k and Inspire 1 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 PREMIER DRONE PRODUCTIONS to safely, efficiently, and economically

operate the DJI Phantom 3 4k and Inspire 1 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, PREMIER DRONE 

PRODUCTIONS 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 PREMIER DRONE PRODUCTIONS to operate the DJI Phantom 3 4k 

and Inspire 1 UASs commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: February 9, 2016

Respectfully submitted,

Robert McChesney 

Managing Partner and Chief 

Pilot

FAA Private Pilot SEL # 3406645

UAS Certificate #FA3K44RW9R

PREMIER DRONE PRODUCTIONS, LLC

PO Box 451

Gotha, FL 34734

407-744-1163 

bob@premierdroneproductions.com
29

Appendices:

A – Links to DJI Phantom 3 4k and Inspire 1 Pro User Manuals: Click on the hot links below.

DJI Phantom 3 4k

http://www.manualslib.com/manual/979955/Dji-Phantom-3-Professional.html 

B – Links to DJI Phantom 3 and Inspire 1 Pro User Manuals

Inspire 1 Pro User Manual

http://www.manualslib.com/manual/895190/Dji-Inspire-1.html#manual

C – Link to Drone Log Book Web Site for Maintenance, Flight Log tracking IAW FARs

Drone Log Book

https://www.dronelogbook.com/homePage/index.php