UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DronzPlus LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATION

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 THE

 Yuneec Q500

 Yuneec Q500+

 DJI Inspire

 DJI Phantom 3 Advanced

 DJI Professional

 DJI Phantom Standard

UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)
TABLE OF CONTENTS

 page

Glossary of Abbreviations ....................................................... 3

 Summary ........................................................................... 4

 Introduction and Interests of Petitioner ....................................... 5

 Background ........................................................................ 6

 Basis for Petition .................................................................. 7

 Name and Address of Petitioner ................................................ 8

 Specific sections of 14 C.F.R from which DronzPlus LLC seeks

 Exemption .......................................................................... 9

 The extent of relief DronzPlus LLC seeks relief and the reason

 DronzPlus LLC seeks relief........................................... 10

 The reasons why granting DronzPlus LLC’s request would be

 In the public’s interest........................................................... 11

 The reasons why granting the exemptions would not adversely affect

 Safety.............................................................................. 12

 Summary that can be published in the Federal Register..................... 13

Any additional information, views, or arguments available to support

 DronzPlus LLC’s request..............................................

 Conclusion.........................................................................

 Attachments ..............................................................................................

 DJI Phantom manual (covers all models for operation) Exhibit A

 Yuneec manual (covers all models for operation) Exhibit B
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest ATC 

Air Traffic Control

ATO Air Traffic Organization 

AV Aerial Vehicle

C.F.R. Code of Federal Regulations

COA Certificate of Authorization FAA 

Federal Aviation Administration FAR 

Federal Aviation Regulation GCS 

Ground Control Station

GPS Global Positioning 

System LOL Loss of Link

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command

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

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft 

System VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions 

VO Visual Observer

VTOL Vertical Takeoff and Landing 4
SUMMARY

DronzPlus LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an 

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit DronzPlus LLC to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial photographs and video over certain 

public roadways and public areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

The petitioner, DronzPlus LLC is a licensed S.C. unmanned aircraft sales and testing business as 

listed with the Anderson S.C. Governmental Agencies. Sales, repairs, flight training, routine testing, 

and aerial photography are a part of the routine business operation process for DronzPlus LLC.

Primarily, DronzPlus LLC is a sales and drone repair/fight training facility that provides extensive

repairs and intensive drone flight operation training after the sale operation. Secondary UAS 

operations include operation of UAS drones for aerial photography under 400 feet and line of sight 

for non-commercial usage but for testing and demonstrations exclusively.

BACKGROUND

DronzPlus LLC seeks an exemption to operate the DJI Phantom Product and Yuneec UAV Product

UAS for compensation within the NAS. The DJI Phantom products & Yuneec Products are 

comprised of a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) and a transportable 

Ground Control Station (GCS). The DJI Phantom products & Yuneec Products have a maximum 

gross weight of approximately 6.6 pounds, while having a diameter of 31 inches, height of 13 inches, 

and maximum speed of 23 mph. The DJI Phantom Products UAS & Yuneec Products UAS are

equipped with four propellers, each being driven by an electric motor powered by Lithium Polymer 

battery. The DJI Phantom Products UAV & Yuneec Products UAV that will be operated by 

DronzPlus LLC 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, DronzPlus LLC is pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

§ 11.61) and the FAA Modernization and Reform Act of 2012, Section 333,

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to operate

the DJI Phantom Products UAS & Yuneec Products UAS 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 size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, DronzPlus LLC operation of the DJI Phantom Products & Yuneec 

Products UAS meets the conditions of Section 333 and therefore, will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. 6. Accordingly, DronzPlus LLC requests 

relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these 

sections set forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. DronzPlus LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. DronzPlus LLC will use its authorized technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 
prescribed in the manufacturer’s maintenance manual. Furthermore, DronzPlus LLC will document 

and maintain all maintenance records for the DJI Phantom Products & Yuneec Products UAS. Relief 

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

limitations: Pilot in command, is requested by DronzPlus LLC to the extent necessary to allow a 

Pilot in Command (PIC) who has completed the DJI Phantom Products & Yuneec Products UAS 

training and currency requirements, to conduct the proposed UAS flight operations. DronzPlus LLC

submits that the conditions and limitations set forth herein will ensure the safety of the NAS, as well 

as the safety of persons or property on the ground.

DronzPlus LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

DJI Phantom Products & Yuneec Products UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, DronzPlus LLC submits that it will ensure 

that the DJI Phantom Products & Yuneec Products UAS is in an airworthy condition, prior to every 

flight, by determining that the UAS is in compliance with the DJI Flight Manual & Yuneec Flight 

Manual, and that the aircraft is in a condition for safe flight.

DronzPlus LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom Product and Yuneec UAV Product UA will not have a typical 

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

Yuneec UAV Product UAS will be provided to the PIC via Global Positioning System (GPS) 

equipment and a 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 DronzPlus 

LLC operation of the DJI Phantom Product and Yuneec UAV Product UA within visual line of 

sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, DronzPlus LLC seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. DronzPlus LLC submits that safety will not 

be affected by terminating flights of the battery powered DJI Phantom Product and Yuneec UAV 

Product UA after 30 minutes of continuous flight, which would allow for five minutes of battery 

power remaining.

In accordance with 14 C.F.R. § 11.81, DronzPlus LLC provides the following information in support 

of its petition for exemption:

A. Name and Address Of The Petitioner.

The name and address of the Petitioner is: 

DronzPlus LLC

Francisco Farray

304 Hopewell Ridge

Anderson, South Carolina

Contact; Francisco Farray

DronzPlus LLC

B. The Specific Sections Of 14 C.F.R. From Which DronzPlus LLC Seeks Exemption. 1. 

DronzPlus LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

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

and (b) prescribe the following, in relevant part: 8 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. 

(a) 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. DronzPlus LLC Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. DronzPlus LLC, Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that 

aircraft, as the case may be, by reference to an altimeter that is set, when operating--

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

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

the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the

current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure; 

4. DronzPlus LLC Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the 

following:

(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. DronzPlus LLC Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired 

as prescribed in part 43 of this chapter[.]

6. DronzPlus LLC Seeks Exemption From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or

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

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

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. DronzPlus LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 

91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

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

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

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

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

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter. 
8. DronzPlus LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:

(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: 10 

(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. 

C. The Extent Of Relief DronzPlus LLC Seeks And The Reason DronzPlus LLC Seeks The 

Relief. 

1. Extent of Relief DronzPlus LLC Seeks And The Reason DronzPlus LLC

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in

command, is requested to the extent necessary to allow a PIC holding a private pilot certificate and a

third-class airman medical certificate, and who has completed the DJI training and currency 

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

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, DronzPlus LLC submits that an equivalent level of safety will be 

maintained because no person who is not an employee of DronzPlus LLC will have operation rights 

to fly or maintain the DJI Phantom Products & Yuneec Products and fly the UAS in a manner 

consistent with the operations specifications as described in this exemption, including evasive and 

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles 

and structures.
Further, DronzPlus LLC submits that all flights of the DJI Phantom Products & Yuneec Products 

conducted by the PIC pursuant to the grant of this Petition - (1) will be incidental to DronzPlus 

LLC’s business; and (2) will not carry passengers or property for compensation or hire. 12

2. Extent of Relief DronzPlus LLC Seeks And The Reason DronzPlus LLC Seeks Relief 

From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to 

allow American Drones L.L.C. to determine that the DJI Phantom Product and Yuneec UAV Product

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

with the DJI Flight Manual & Yuneec Flight Manual and that the aircraft is in a condition for safe 

flight.

DronzPlus LLC seeks the requested relief because the DJI Phantom Product and Yuneec UAV 

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

Subpart H. Therefore, DronzPlus LLC will ensure that the DJI UAS & Yuneec UAS is in an 

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

Manual & Yuneec Flight Manual) prior to every flight, and as stated in the conditions and limitations 

below.

3. Extent of Relief DronzPlus LLC Seeks And The Reason DronzPlus LLC Seeks Relief 

From Section 91.121.

Relief from Section 91.121 entitled Altimeter settings, may be required to allow flight operations of 

the DIJ UAS, which utilizes GPS equipment and a radio communications telemetry data link to 

downlink altitude information to the PIC from the UA to the GCS. As more fully set forth below, 

safety will be maintained as a result of the DIJ Phantom Product & Yuneec Product UA’s altitude 

readout via GPS equipment, and DronzPlus LLC’s operation of the DJI Phantom Product and 

Yuneec UAV Product UA within visual line of sight, at or below 400 feet AGL.

4. Extent Of Relief DronzPlus LLC Seeks And The Reason DronzPlus LLC Seeks Relief 

From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to 

the extent required to allow flights of the battery powered DJI UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR) conditions, to continue for a total 

duration of 30 minutes, which will ensure that the UA will land with five minutes of battery power 

remaining. DronzPlus LLC seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI UA & Yuneec UA will severely

constrain the practicality of any aerial acquisition and research flight operations that DronzPlus LLC

proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom Product and Yuneec 

UAV Product UAS, the DJI Flight Manual & Yuneec Flight Manual, and DronzPlus LLC’s proposed 

operating limitations, ensure that DronzPlus LLC will safely operate the battery powered DJI UA & 

Yuneec UA during daylight hours in VFR conditions, for a total flight duration of 30 minutes, landing 

with five minutes of battery power remaining.

5. Extent Of Relief DronzPlus LLC Seeks And The Reason DronzPlus LLC Seeks Relief From 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And

91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, DronzPlus LLC requests relief from these Sections because 

the DJI Phantom Product and Yuneec UAV Product UAS does not require an airworthiness 

certificate. As set forth more fully below, the DJI Phantom Product and Yuneec UAV Product UAS 

meets the conditions of Section 333 of the FMRA for operation without an airworthiness certificate. 

Accordingly, DronzPlus LLC will use authorized technicians to perform maintenance, alterations, or 

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

manufacturer’s maintenance manual. Furthermore, DronzPlus LLC will document and maintain all 
maintenance records for the DJI Phantom Product and Yuneec UAV Product UAS.

D. The Reasons Why Granting DronzPlus LLC’s Request Would Be In The Public 

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

Granting the present Petition will further the public interest by allowing DronzPlus LLC to safely, 

efficiently, and economically perform aerial photographs and video over public areas of the United 

States, commercially, in support of government entities, flight training, scientific studies, and sales 

demonstrations. Additionally, use of the DJI Phantom Product and Yuneec UAV Product UAS will 

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

Notably, the benefits of DronzPlus LLC’s proposed operation of the DJI Phantom Product and 

Yuneec UAV Product UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From The Aerial Acquisitioned Photographs and Video Performed.

DronzPlus LLC submits this Petition to commercially operate the DJI Phantom Product and Yuneec 

UAV Product UAS and perform aerial acquisitions and research throughout areas of the United 

States, in support of government entities, private entities, sales, aerial mapping, tests of products, and 

flight instruction pursuant to UAV drone training. The DJI Phantom Product and Yuneec UAV 

Product UAS will provide safe, efficient, and economical aerial acquisition and research operations 

to further each of these fields, all of which are critical to the well-being of the general public.

The specific operations that DronzPlus LLC will perform with the DJI Phantom Product and Yuneec 

UAV Product UAS demonstrate how the requested exemption will directly benefit the abovereferenced industries and the public. 

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

The DJI Phantom 2 Vision 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 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

Of a DJI Phantom Product and Yuneec UAV Product UAS would reduce the amount of manned 

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

in the air and on the ground. Furthermore, by reducing the number of manned aircraft operating in 

the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom Product and Yuneec UAV Product UA does not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial survey 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.

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

Conducting aerial acquisitions with the DJI Phantom Product and Yuneec UAV Product UAS, 

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

noise pollution generated during traditional aerial survey flight operations. By using battery power 

and electric motors, the DJI Phantom Product and Yuneec UAV Product UAS produces no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion twin engine aircraft that are typically utilized for aerial acquisitions, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 

Product and Yuneec UAV Product UA, while reducing the carbon footprint of aerial acquisitions,

also eliminates noise pollution, as the UA is propelled by battery powered electric motors, rather 

than an internal combustion engine.

By using the DJI Phantom Product and Yuneec UAV Product 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 Product and 

Yuneec UAV Product UA (weighing approximately 6.6 pounds at its maximum gross weight with a 

diameter of 31 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 aerial 

acquisitions (weighing approximately 6,500 pounds with a wingspan of approximately 40 feet, a 

length of 34 feet, and a fuel capacity of 180 gallons).

4. Performing Aerial Acquisition Operations With The DJI Phantom Product and Yuneec 

UAV Product UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom Product and Yuneec UAV Product UAS is 

also an economical alternative to using manned aircraft to conduct aerial acquisitions. As such, 

operation of the DJI Phantom Product and Yuneec UAV Product UAS will allow United States based 

companies, like DronzPlus L.L.C, 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 Product and Yuneec UAV Product 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 Products & Yuneec Products UAS, companies such as DronzPlus

L.L.C. 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 

Product and Yuneec UAV Product 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. 

5. There Are No Privacy Issues. 

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

DronzPlus L.L.C’s proposed operation of the DJI Phantom Product and Yuneec UAV Product

UAS will not implicate any privacy issues. Specifically, the DJI Phantom Product and Yuneec 

UAV Product UAS will be operated only in rural areas, and in accordance with all Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. Most 

significantly, the DJI Phantom Product and Yuneec UAV Product UA will not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure, which is not directly involved in the 

operation.

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 DronzPlus L.L.C. Seeks Exemption.

1. Reasons Why The DJI Phantom Products & Yuneec Products UAS 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, DronzPlus L.L.C’s operation of the DJI Phantom Products & Yuneec 

Products 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-- 18

(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, DronzPlus L.L.C submits that the DJI Phantom Product and Yuneec 

UAV Product UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated 

by: (a) the characteristics of the DJI Phantom Product and Yuneec UAV Product UAS; (b) the pilot 

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

a. The Specifications Of The DJI Phantom Product and Yuneec UAV Product UAS 

Demonstrate Its Safe Characteristics.

The DJI Phantom Product and Yuneec UAV Product 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 Product and Yuneec UAV Product UAS.

The technical specifications of the DJI Phantom Product and Yuneec UAV Product UAS are set 

forth in Appendix C of the “Flight Manual For The DJI Phantom Products Unmanned Aircraft 

System (UAS),” & "Flight Manual For The Yuneec Products Unmanned Aircriaft System (UAS), 

attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b)1.

1 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), 

are not to be included in the Federal Docket Management System (FDMS).

ii. The DJI Phantom Product and Yuneec UAV Product UAS Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A Defined Operational Area.

A complete description of the autonomous modes and methods of navigation of the DJI Phantom 

Product and Yuneec Product UAS is provided at pages 2, 4, 5, and 10 of the “Flight Manual For The 

DJI Phantom Products & Yuneec Product Unmanned Aircraft System (UAS),” attached hereto as 

Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 

14 C.F.R. § 11.35(b).

iii. The DJI Phantom Product and Yuneec UAV Product UAS Is Designed For Automatic 

Return To Launch In The Event Of Loss Of The Control Link Or Navigation.

A complete description of the DJI Phantom Product and Yuneec UAV Product UAS’s automatic 

return to launch function in the event of a break in communication or loss of telemetry data is set 

forth on pages 2, 9, and 10 of the “Flight Manual For The DJI Phantom Product and Yuneec UAV 

Product Unmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit A contains 

proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). b. 

Flight Operations Of The DJI Phantom Product and Yuneec UAV Product UAS Are Limited 

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

DronzPlus L.L.C will only utilize certificated pilots who possess a valid airman medical certificate 

to act as a pilot in command (PIC) of the DJI Phantom Product and Yuneec UAV Product UAS. 

Additionally, a safety observer will assist all pilots. The PIC must complete the DJI Phantom 

Product and Yuneec UAV Product UAS training and qualification, as set forth in the “Flight Manual 

For The DJI Phantom Product and Yuneec UAV Product Unmanned Aircraft System (UAS),” 

attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a 

separate file pursuant to 14 C.F.R. § 11.35(b). 20

c. Flights Of The DJI Phantom Product and Yuneec UAV Product UAS Will Be Conducted 

Pursuant To Specific Operating Limitations.

In seeking this exemption, DronzPlus LLC proposes to commercially operate the DJI Phantom

Product & Yuneec Product UAS for the special purpose of conducting aerial acquisitions over public
areas of United States, pursuant to the following specific operating limitations:

1) Operations authorized by this grant of exemption are limited to the following aircraft described in 

the operator’s manual which is a quad rotor aircraft weighing less than 10 pounds: DJI Phantom

Products Unmanned Aircraft System & Yuneec Products Unmanned Aircraft System. Proposed 

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

2) The UA may not be flown at an indicated airspeed exceeding 25 MPH & the UA must be operated 

at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures 

specified in the operator’s manual. All altitudes reported to ATC must be in feet AGL. 

3) 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. 

4) All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS 

requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able 

to communicate verbally at all times. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. 

5) The operator’s manual and this grant of exemption must be maintained and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations in this 

exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein 

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

outlined in its operator’s manual. 

The operator may update or revise its operator’s manual. 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. If the operator determines that any update or revision would affect the basis upon which 

the FAA granted this exemption, then the operator must petition for amendment to their exemption. 

The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates 

or revisions to the operator’s manual. 

6) Prior to each flight the PIC must inspect the UAS to ensure 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. 

7) 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 

in accordance with the operator’s manual. The PIC who conducts the functional test flight must make 

an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional 

test flight and aircraft record entry must be added to the operator’s manual. 

8) The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or 

equipment, not covered in the relevant preflight inspection sections of the operator’s manual. 

9) The operator must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements, with particular attention to flight critical 

components that may not be addressed in the manufacturer’s manuals. 

10) DronzPlus LLC must carry out their maintenance, inspections, and record keeping requirements 

in accordance with the operator’s manual. Maintenance, inspection, and alterations must be noted in 

the aircraft logbook, including total flight hours, description of work accomplished, and the 

signature of the authorized UAS technician or PIC returning the UAS to service. 

11) DronzPlus LLC UAS technicians must receive and document training referenced in the 

operator’s manual. 

12) Each UAS operated under this exemption must comply with all manufacturer System and Safety 

Bulletins. 
13) DronzPlus LLC maintenance personnel must make a record entry in the UAS logbook or 

equivalent document of the corrective action taken against discrepancies discovered between 

inspections. 

15) The PIC must possess at least a private pilot certificate and a third-class airman medical 

certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56 

in an aircraft in which the PIC is rated on his or her pilot certificate. 

16) The operator may not permit any PIC to operate unless that PIC has demonstrated, through 

the training and currency requirements set forth in the operator’s manual, that the PIC is able to 

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

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 22 

17) 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). Flights under special visual flight 

rules (SVFR) are not authorized. 

18) The UA may not operate within 5 nautical miles of the airport reference point as denoted on a 

current FAA-published aeronautical chart. The UA may not operate within 3 nautical miles from any 

city or densely populated area. 

19) 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. 

20) If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the private or controlled-access property and land, or be recovered in accordance with 

the operator’s manual. 

21) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance 

with the operator’s manual. 

22) The PIC is prohibited from beginning a UAS flight unless (considering wind and forecast 

weather conditions and assuming normal cruising speed) there is enough power to fly to the first 

point of intended landing prior to utilizing battery reserve power. 

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

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

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

72 hours in advance, but not less than 48 hours prior to the operation. 

24) All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings 

in accordance with 14 C.F.R. Part 45, Subpart C. Markings must be as large as practicable. 

25) 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. 

26) The documents required under 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 aircraft is operating. These documents must be 

made available to the Administrator or any law enforcement official upon request. 

27) The UA must remain clear and yield the right of way to all other manned aviation operations and 

activities at all times. 

28) The UAS may not be operated by the PIC from any moving device or vehicle. 23 

29) The UA may not be operated over congested or densely populated areas. These areas include but 

are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional 

Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may 

not reflect pertinent local information. Ultimately, it 

is the PIC’s responsibility to maintain the minimum safe altitudes required by § 91.119. 

30) Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons 

other than the PIC or VO), vessels, vehicles, and structures unless: 
a. Barriers or structures are present that sufficiently protect nonparticipating persons from 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 land owner/controller has 

granted permission and the PIC has made a safety assessment of the risk of operating closer to 

those objects and; 

c. operations near the PIC or VO do not present an undue hazard to the PIC or VO, per § 91.119(a). 31) 

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 prior to the beginning of every flight. 

32) 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.

DronzPlus LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) 

will be maintained because no PIC will be allowed to operate the DJI Phantom Product and Yuneec 

UAV Product UAS unless that PIC has demonstrated, through the DJI Phantom Products UAS or 

Yuneec Product UAS training and currency requirements, that the PIC is able to safely operate the 

DJI Phantom Product and Yuneec UAV Product UAS in a manner consistent with this exemption, 

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

vessels, vehicles and structures. 24

Considering DronzPlus LLC’s proposed area of operations, and the operating limitations set forthabove; 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 Product and Yuneec UAV Product UAS, DronzPlus LLC submits 

that the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for DronzPlus LLC’s specific proposed flight 

operations.

The DJI Phantom Products UAS was the subject of a previous Grant of Exemption from Section 

61.113(a) and (b). In Exemption No. 11109, the FAA granted relief from Section 61.113(a) and (b) 

concerning the operation of the DJI Phantom Product and Yuneec UAV Product UAS by a PIC 

holding a private pilot certificate and third class airman medical certificate, based upon the following 

analysis:

The FAA has analyzed Clayco’s proposed operation and has determined that it does not differ 

significantly from the situation described in Grant of Exemption No. 11062 (Astraeus Aerial). 

Clayco plans to operate over private property with controlled access in the NAS. Given: 1) the 

similar nature of Clayco’s proposed operating environment to that of Astraeus’, 2) the parallel nature 

of private pilot aeronautical knowledge requirements to those of commercial requirements [ref: 

Exemption No. 11062], and 3) the airmanship skills necessary to operate the UAS, the FAA finds 

that the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Clayco’s specific proposed operations. Therefore, the 

FAA finds that a PIC holding a private pilot certificate and a third-class airman medical certificate is 

appropriate for the proposed operations.

With regard to the airmanship skills necessary to operate the UAS (item #3 stated above), Clayco 

has proposed a 100 hour training program and 6 month currency requirements. The conditions and 

limitations below stipulate that Clayco may not permit any PIC to operate unless that PIC has 

demonstrated through Clayco’s training and currency requirements that the PIC is able to safely 
operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

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

vessels, vehicles and structures.

See Exemption No. 11109 at 12.

Additionally, 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. 25

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138).

As in Exemption No. 11109, DronzPlus LLC will not allow any PIC to operate the DJI Phantom 

Product and Yuneec UAV Product UAS unless that PIC has demonstrated through the DJI 

Phantom Product and Yuneec UAV Product UAS training and currency requirements, that the PIC 

is able to safely operate the DJI Phantom Product and Yuneec UAV Product UAS in a manner 

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

appropriate distances from people, vessels, vehicles and structures.

A complete description of the DJI Phantom Product and Yuneec UAV Product UAS Training and 

Qualification requirements is set forth at page 5 of the “Flight Manual For The DJI Phantom Product 

and Yuneec UAV Product Unmanned Aircraft System (UAS),” attached hereto as Exhibit A. Exhibit 

A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 

11.35(b).

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, DronzPlus LLC will ensure that the DJI Phantom Product and Yuneec UAV 

Product UAS is in an airworthy condition based upon the DJI Phantom Product and Yuneec 

UAV Product UAS’s compliance with its operating documents (i.e., the DJI Phantom Products 

Flight Manual), and as stated in the conditions and limitations herein.

The DJI Phantom Product and Yuneec UAV Product UAS was the subject of a previous Grant of 

Exemption from Section 91.7(a) (Exemption No. 11109). 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). 26

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 Product and Yuneec UAV Product 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. This altitude information, combined with 

DronzPlus L.L.C’s operation of the DJI Phantom Product and Yuneec UAV Product UA within 

visual line of sight, at or below 400 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 will be established and confirmed for accuracy by 

the UAS PIC. The DJI Phantom Product and Yuneec UAV Product UAS was the subject of a 

previous Grant of Exemption from Section 91.121 (Exemption No. 11109). Additionally, 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).
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 Product and 

Yuneec UAV Product UAS; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, DronzPlus LLC will ensure that it can safely operate 

the battery powered DJI Phantom Product and Yuneec UAV Product UA during daylight hours, in 

VFR conditions, for a total flight duration of no more than 30 minutes, resulting in a landing with 

five minutes of battery power remaining. In a previous Petition for Exemption, in which an operator 

was utilizing a DJI Phantom Product and Yuneec UAV Product UAS identical in all material 

respects to the DJI Phantom Product and Yuneec UAV Product UAS, DronzPlus LLC proposes to 

use, the FAA granted an exemption from the requirements of Section 91.151, stating as follows:

In the event that the UAS should run out of power, it would simply land within the access controlled 

operating area. Given its weight and construction material, the risks are less than contemplated by 

the current regulation. Prior relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in § 91.151 (a), including Exemption Nos. 2689, 5745, and 10650. In addition, 

similar UAS-specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for 

daytime, Visual Flight Rules (VFR) conditions. The DJI Phantom Product and Yuneec UAV Product

provides a battery failsafe that commands the UA’s return to the launch point when critical minimum 

voltage is reached. The UAS batteries provide approximately 35 minutes of powered flight. The 

FAA agrees with Clayco’s proposal to limit UAS flights to not more than 30 minutes, or enough 

battery reserve to ensure that the UAS lands at the ground station with at least 20% battery reserve 

power, whichever happens first. Given the limitations on its proposed operations and the location of 

those proposed operations, a reduced minimum power reserve for flight in daylight VFR conditions 

is reasonable.

See Exemption No. 11109 at 15.

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

Yuneec UAV Product UAS; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure that DronzPlus LLC may safely operate the battery powered DJI 

Phantom Product and Yuneec UAV Product UA during daylight hours in VFR conditions for a total 

duration of not more than 30 minutes, and landing with five minutes of battery power remaining.

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. 

288811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11136, 11138).

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, DronzPlus LLC submits that the equivalent level of safety with regard to 

the regulatory maintenance and alteration requirements established by Sections 91.405(a), 

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

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

unmanned aircraft system using the methods, techniques, and practices prescribed in the 

manufacturer’s maintenance manual. Furthermore, DronzPlus LLC will document and maintain all 

maintenance records for the DJI Phantom Product and Yuneec UAV Product UAS.
Since the DJI Phantom Product and Yuneec UAV Product UAS will be inspected as prescribed 

by the manufacturer’s maintenance manual, DronzPlus LLC will maintain the equivalent level 

of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The Flight Manual 

For The DJI Phantom Product and Yuneec UAV Product UAS sets forth airworthiness 

requirements for the UA, including preflight and post flight inspections, as well as scheduled 

maintenance in four categories: daily, weekly, monthly, and yearly.

Likewise, the exemption sought will not adversely affect safety because DronzPlus LLC will 

perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the manufacturer’s maintenance manual. The Flight Manual 

For The DJI Phantom Product and Yuneec UAV Product UAS details procedures for each 

component of the UA, including the components of the propulsion system, avionics system, and 

payload system.

A complete description of the DJI Phantom Product and Yuneec UAV Product UAS airworthiness 

and maintenance requirements is set forth at page 6 of the “Flight Manual For The DJI Phantom 

Products Unmanned Aircraft 29 System (UAS),” & "Flight Manual For The Yuneec Product 

(UAS)", attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held 

in a separate file pursuant to 14 C.F.R. § 11.35(b).

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 

Product and Yuneec UAV Product UAS will be performed by DronzPlus LLC trained 

technicians, who will document and maintain maintenance records for the DJI Phantom 

Product and Yuneec UAV Product UAS.

Significantly, previous exemptions granted by the FAA concerning the DJI Phantom Product and 

Yuneec UAV Product UAS and 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 Exemption No. 11109, the FAA stated the 

following concerning the DJI Phantom Product and Yuneec UAV Product UAS and the DJI 

Phantom Product and Yuneec UAV Product Flight Manual:

Regarding the petitioner’s requested relief from 14 C.F.R 91.405 (a) Maintenance required, 

91.407(a)(1) Operation after maintenance, preventive maintenance, rebuilding, or alteration, 

91.409(a)(2) Inspections, and 91.417(a) and (b) Maintenance records, the FAA has determined that 

relief from § 91.409(a)(1) is also necessary because it is an alternate inspection requirement of § 

91.409(a)(2). The FAA has carefully evaluated the petitioner’s request and determined that cause for 

granting the exemption is warranted. The FAA notes that the petitioner’s DJI Phantom Product and 

Yuneec UAV Product UAS Flight Manual contain daily, preflight, monthly and yearly checks for the 

UAS. The FAA finds that adherence to the DJI Phantom Product and Yuneec UAV Product Flight 

Manual, as required by the conditions and limitations below, is sufficient to ensure that safety is not 

adversely affected. In accordance with the petitioner’s UAS maintenance, inspection, and 

recordkeeping requirements, the FAA finds that exemption from 14 C.F.R. 91.405(a), 91.407(a)(1), 

91.409(a)(1) and (2), and 91.417(a) and (b) is warranted subject to the conditions and limitations 

below.

In consideration of DronzPlus LLC’s proposed operating limitations, the most recent DJI Phantom 

Product and Yuneec UAV Product Flight Manual, and the technical aspects of the DJI Phantom 

Product and Yuneec UAV Product UAS, DronzPlus LLC submits that safety will not be adversely

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in 

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138).
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, DronzPlus LLC requests that the FAA prescribe 

special conditions for the intended operation of the DJI Phantom Product and Yuneec UAV Product

UAS, which contain such safety standards that the Administrator finds necessary to establish a level 

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) 

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

(b). Such special conditions will permit safe operation of the UAS for the limited purpose of 

conducting aerial acquisitions over certain rural areas of the United States. 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 Product and Yuneec UAV Product 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. 31

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe 

special conditions for DronzPlus LLC’s intended operation of the DJI Phantom Product and Yuneec 

UAV Product 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).

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

The Rules From Which DronzPlus LLC Seeks Exemption:

DronzPlus 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 DronzPlus LLC Seeks:

This exemption will permit DronzPlus LLC to commercially operate an Unmanned Aircraft System 

(UAS) for the purpose of conducting aerial acquisitions and research over certain public areas of 

the United States.

G. Any Additional Information, Views, Or Arguments Available To Support DronzPlus LLC’s 

Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 

333, which directs the Secretary of Transportation to determine if certain UAS may operate safely 

in the NAS. As such, DronzPlus LLC’s request for exemption may be granted pursuant to the 

authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

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

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

provides the authority for such UAS to operate without airworthiness certification. As discussed in 
detail above, DronzPlus LLC will operate the DJI Phantom Product and Yuneec UAV Product 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.

CONCLUSION

As set forth herein, DronzPlus LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation 

of the DJI Phantom Product and Yuneec UAV Product UAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial acquisitions over certain public 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 DronzPlus LLC to safely, efficiently, and economically operate the DJI 

Phantom Product and Yuneec UAV Product UAS commercially within the NAS.

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

Reform Act of 2012, Section 333, DronzPlus LLC respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

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

LLC to operate the DJI Phantom Product and Yuneec UAV Product UAS commercially for the purpose 

of conducting aerial acquisitions, training, sales, research , testing, demonstrations, and aerial 

photography over certain public areas of the United States.

Dated: December 6th 2015

Submitted on behalf of DronzPlus LLC

Francisco Farray

President

DronzPlus LLC

304 Hopewell Ridge

Anderson South Carolina 29621

Email

frank@carolinadronz.com