seeks Exemption 2

TABLE OF CONTENTS

Page 

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH KETCHAM AERIAL 

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

THE EXTENT OF RELIEF KETCHAM AERIAL IMAGING SEEKS ANDTHE

REASON KETCHAM AERIAL IMAGING SEEKS THERELIEF................... 11

THE REASONS WHY GRANTING KETCHAM AERIAL IMAGING’S

REQUEST WOULD BE IN THE PUBLIC INTEREST ..................................... 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY......................................................................... 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERALREGISTER. .... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT KETCHAM AERIAL IMAGING’SREQUEST...34

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

APPENDICES........................................................................................37
seeks Exemption 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

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 

SO Safety Observer

SOP Standard OperatingProcedures

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
seeks Exemption 4

SUMMARY

Ketcham Aerial Imaging 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 Ketcham Aerial Imaging to operate an Unmanned Aircraft System (UAS) for the 

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

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

Ketcham Aerial Imaging provides its clients with expertise and knowledge in 

advanced technologies and solutions to increase efficiency, productivity and effectiveness. 

Ketcham Aerial Imaging is experienced in all aspects of aerial video and photography. The 

objective of Ketcham Aerial Imaging’s aerial video and photography operations isto 

provide low cost, high quality imaging for a variety of commercial and residential 

customers.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs

Ketcham Aerial Imaging seeks an exemption to operate DJI systemsfor

compensation or hire within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1 are

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

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 

Vision+ has a maximum gross weight of approximately 2 pounds 11 ounces, while having 

a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speedof
seeks Exemption 5

approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5

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

maximum speed of approximately 42 knots. The DJI Phantom 2 Vision+ and DJIInspire

1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered

electric motors.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs that will be operatedby

Ketcham Aerial Imaging 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 markedin

accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Ketcham Aerial Imaging, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Phantom 2 Vision+,DJI

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

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, Ketcham Aerial Imaging’s operation ofDJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs meets the conditions of FMRA Section333 

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H.
seeks Exemption 6

Accordingly, Ketcham Aerial Imaging 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.

Ketcham Aerial Imaging submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Ketcham Aerial Imaging will useexperienced

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

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

documents (i.e., the Ketcham Aerial Imaging Aerial Operations Manual, Monthly

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

Furthermore, Ketcham Aerial Imaging will document and maintain all maintenance records 

for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs.

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

privileges and limitations: Pilot in command, is requested by Ketcham Aerial Imaging to 

the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher

level certificate, as well as an airman medical certificate, and who has demonstrated, by 

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

operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs in a manner consistentwith 

this exemption, including evasive and emergency maneuvers and maintainingappropriate

distances from people, vessels, vehicles and structures.

Ketcham Aerial Imaging seeks relief from Section 91.7(a), entitled Civilaircraft 

airworthiness, because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do notrequire

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

Ketcham Aerial Imaging submits that it will ensure that the DJI Phantom 2 Vision+ and
seeks Exemption 7

DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that

the UASs are in compliance with the operating documents (i.e., the Ketcham Aerial 

Imaging Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+ and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for 

safe flight.

Ketcham Aerial Imaging also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs 

will not have a typical barometric altimeter onboard. However, altitude information of the 

DJI Phantom 2 Vision+ and DJI Inspire 1UAs will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

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

information, combined with Ketcham Aerial Imaging’s operation of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs within visual line of sight, at or below 400 feet AGL,will 

ensure a level of safety equivalent to Section91.121.

Additionally, Ketcham Aerial Imaging seeks an exemption from the requirements 

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Ketcham 

Aerial Imaging submits that safety will not be affected by operation of the DJI Phantom2 

Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions 

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

duration of approximately 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes.
seeks Exemption 8

In accordance with 14 C.F.R. § 11.81, Ketcham Aerial Imaging provides the 

following information in support of its petition for exemption:

A. Name And Address Of The Petitioner

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

Anthony H. Ketcham

Ketcham Aerial Imaging

2500 Deer Valley Rd. #1421

San Rafael, CA 94903

Tel: (415) 342-9381

Email: ketcham99@comcast.net

B. The Specific Sections Of 14 C.F.R. From Which Ketcham Aerial Imaging seeks 

Exemption

1. Ketcham Aerial Imaging seeks Exemption From The Requirements Of 

Section 61.113(a) and (b).

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

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

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

(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

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

connection with any business or employment if—

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

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

2. Ketcham Aerial Imaging seeks Exemption From The Requirements Of 

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), statesthe

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.
seeks Exemption 9

3. Ketcham Aerial Imaging 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 isset, 

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 anappropriate

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 availablebefore

departure.

4. Ketcham Aerial Imaging 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. Ketcham Aerial Imaging 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[.]
seeks Exemption 10

6. Ketcham Aerial Imaging seeks Exemption From The RequirementsOf 

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states thefollowing:

(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. Ketcham Aerial Imaging 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 andhas

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. Ketcham Aerial Imaging 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--
seeks Exemption 11

(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 whichthe

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 foreach

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 beretained 

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.
seeks Exemption 12

C.The Extent Of Relief Ketcham Aerial Imaging seeks And The Reason Ketcham 

Aerial Imaging seeks The Relief.

1. Extent Of Relief Ketcham Aerial Imaging seeks And The Reason Ketcham 

Aerial Imaging 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 conductthe 

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 tothat 

business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire.

As set forth more fully below, Ketcham Aerial Imaging submits that an equivalent 

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

Phantom 2 Vision+ UAS or DJI Inspire 1 UAS unless that PIC has met certainflight-hour

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

DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with theoperations

specifications as described in this exemption, including evasive and emergency maneuvers,

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

Further, Ketcham Aerial Imaging submits that all flights of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant ofthis
seeks Exemption 13

Petition: (1) will be incidental to Ketcham Aerial Imaging’s business; and (2) will not carry 

passengers or property for compensation or hire.

2. Extent Of Relief Ketcham Aerial Imaging seeks And The Reason Ketcham 

Aerial Imaging 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 Ketcham Aerial Imaging to determine that the DJI Phantom2 

Vision+ and DJI Inspire 1 UASs are in airworthy condition prior to every flight by

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

Aerial Imaging Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+ and DJI Inspire 1 Instruction Manual).

Ketcham Aerial Imaging seeks the requested relief because the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. Therefore, Ketcham Aerial Imaging will ensure that the

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are in airworthy condition based uponits

compliance with the operating documents (i.e., the Ketcham Aerial Imaging Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJIInspire 1

Instruction Manual) prior to every flight, and further, determine that the aircraft are in 

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

3. Extent Of Relief Ketcham Aerial Imaging Seeks And The Reason Ketcham 

Aerial Imaging 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 2 Vision+ and DJI 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
seeks Exemption 14

be reported to air traffic control (ATC) in feet above ground level (AGL), Ketcham Aerial 

Imaging seeks the requested relief because the DJI Phantom 2 Vision+ and DJIInspire 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 2 Vision+ and DJI Inspire 1 UAs are equipped with a 

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

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

altitude information of the UA on the heads-up display of theGCS.

4. Extent Of Relief Ketcham Aerial Imaging Seeks And The Reason Ketcham 

Aerial Imaging Seeks Relief From Section 91.151(b).

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

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological

conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to 

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

at least 4.5 minutes. Ketcham Aerial Imaging seeks the requested relief because withoutan 

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

Phantom 2 Vision+ and DJI Inspire 1 UAs will severely constrain the practicality of any 

aerial video or still photo flight operations that Ketcham Aerial Imaging proposes to 

conduct pursuant to this Petition.
seeks Exemption 15

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating

documents, and Ketcham Aerial Imaging’s proposed operating limitations, ensure that 

Ketcham Aerial Imaging will safely operate the battery powered DJI Phantom 2 Vision+ 

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

under visual flight rules (VFR), with enough battery power to fly for a total duration of

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

fly after that for at least 4.5 minutes.

5. Extent Of Relief Ketcham Aerial Imaging Seeks And The Reason Ketcham 

Aerial Imaging 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, Ketcham Aerial Imaging requests

relief from these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do 

not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Ketcham Aerial Imaging will use trained

technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

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

(i.e., the Ketcham Aerial Imaging Aerial Operations Manual, Monthly Maintenance Log,

and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual).Furthermore, Ketcham 

Aerial Imaging will document and maintain all maintenance records for the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs.

D.The Reasons Why Granting Ketcham Aerial Imaging’s Request Would Be In

The Public Interest; That Is, How It Would Benefit The Public As A Whole.
seeks Exemption 16

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

Aerial Imaging to safely, efficiently, and economically perform aerial video and

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

United States.

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

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

economy. Notably, the benefits of Ketcham Aerial Imaging’s proposed operation of the

DJI Phantom 2 Vision+ and DJI 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 2 Vision+ and DJI Inspire 1 UAs are battery powered and serve

as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized 

to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform 

aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ orDJI 

Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and

air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in theNAS,

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

DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or land. 

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

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

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

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

Phantom 2 Vision+ and DJI Inspire 1 UASs.
seeks Exemption 17

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI 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 2 Vision+ and DJI Inspire 1 UASs produce no air pollution, and is themost

viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video andphotography,

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

Phantom 2 Vision+ and DJI Inspire 1 UAs, while reducing the carbon footprint ofaerial

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered 

electric motors, rather than an internal combustionengine.

By using the DJI Phantom 2 Vision+ and DJI 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 memberslocated

onboard the aircraft, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs(weighing

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 

16 inches and 17.7 inches respectively, and with no fuel on board), has less physical

potential for collateral damage to life and property on the ground, and in the air, compared

to the manned aircraft that typically conduct similar operations (weighing approximately

6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and afuel

capacity of 180 gallons).
seeks Exemption 18

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs Will Benefit The Economy.

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

1 UASs are also an economical alternative to using manned aircraft to conduct similar 

aerial operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Inspire1 

UASs will allow United States based companies, like Ketcham Aerial Imaging, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the rising

cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered DJI 

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

as Ketcham Aerial Imaging, 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 2 Vision+ and DJI Inspire 1 UASs, provides astable 

workforce that increases consumer spending; improves local, state, and federal tax 

revenues; and allows companies to invest in research and development in order toremain 

competitive both in the United States andabroad.

4. There Are No Privacy Issues.

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

decades, Ketcham Aerial Imaging’s proposed operation of the DJI Phantom 2 Vision+ and
seeks Exemption 19

DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs will be operated only in compliance with operating

documents (i.e., the Ketcham Aerial Imaging Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 InstructionManual)

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 Ketcham Aerial Imaging Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs Meet The 

Conditions Of The FAA Modernization and Reform Act of 2012(FMRA)

Section 333.

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

with the unmanned aircraft and its operation, Ketcham Aerial Imaging’s operation ofthe 

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs meet the conditions of FMRA Section 

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

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

Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretaryof

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.
seeks Exemption 20

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

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

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

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

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

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

threat to national security; and

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

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines underthis 

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, Ketcham Aerial Imaging submits that the DJI Phantom2 

Vision+ and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRASection 

333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ andDJI 

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

limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI 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 2 Vision+ and DJI 

Inspire 1 UASs.

The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 

are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 Specifications and Data 

Sheet, attached hereto as Exhibit A and B.
seeks Exemption 21

ii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASsAutonomous

Flight And Navigation Modes Enable The UASs To Remain Within 

A Defined Operational Area.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs may be operated in both 

manual and fully autonomous flight modes. A complete description of the flightand

navigational modes of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs is provided at

pages 25-35 of the DJI Phantom 2 Vision+ and pages 12-16 and 45-50 of the DJI Inspire 1 

User Manuals, attached hereto as Exhibit C and D.

iii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs AreDesigned 

For Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs

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

2 Vision+ and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs 

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

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

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+ 

UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through15

of the DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals, attached hereto as Exhibit 

C and D.

iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS AndIts

Operation.

A complete description of the operation and specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1 GCS and flight control software is provided at pages 32 through

43 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 of the DJIInspire
seeks Exemption 22

1 User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached

hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1UASs 

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

With A Safety Observer.

Ketcham Aerial Imaging will only utilize certificated pilots who possess a current 

and valid airman medical certificate or a valid U.S. driver’s license issued by a state to act 

as a pilot in command (PIC) of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. 

Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Be 

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Ketcham Aerial Imaging proposes to commercially

operate DJI Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purposeof

conducting aerial video and photography over certain areas of United States, pursuant to 

the following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighingless 

than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and DJIInspire

1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will

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

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

for the purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 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 UAs must be operated within visual line of sight (VLOS) of the PIC at all 

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

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

medical certificate.
seeks Exemption 23

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

permitted.

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

the VLOS requirement as long as the PIC always maintains VLOS capability. 

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation forthe 

duration of the flight. The PIC must ensure that the SO can perform the

functions prescribed in the operatingdocuments.

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 operatordetermines

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

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

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

questions arise regarding updates or revisions to the operating documents.

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

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

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

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

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

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

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

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

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

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

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

relevant sections of the operating documents.
seeks Exemption 24

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

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

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

requirements, in accordance with the operating documents.Maintenance,

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service.

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

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

17. The PIC must hold either an Airline Transport, Commercial, Private, 

Recreational, or Sport Pilot certificate. The PIC must also hold a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state. 

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. Duringtraining,

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. §

19.1. 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.
seeks Exemption 25

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered

in accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by

serial number, registered in accordance with 14 C.F.R. part 47, andhave

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

Subpart C. Markings must be as large as practicable.

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

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency

requirements.

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

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

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

Administrator or any law enforcement official upon request.

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

operations and activities at all times.

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

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

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:
seeks Exemption 26

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 leavesuch 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per §91.119(a).

32. All operations shall be conducted over private or controlled-access property 

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS-80) within24 

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.

Ketcham Aerial Imaging submits that the equivalent level of safety establishedby

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the 

DJI Phantom 2 Vision+ and DJI 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 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Considering Ketcham Aerial Imaging’s proposed area of operations, and the

operating limitations set forth-above; the parallel nature of private pilot aeronautical
seeks Exemption 27

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the DJI Phantom 2Vision+

or DJI Inspire 1 UAS, Ketcham Aerial Imaging submits that the additionalmanned 

airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Ketcham Aerial Imaging’s specific proposed flight 

operations.

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

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

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

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Ketcham Aerial Imaging will not allow any PIC to operate the DJI Phantom2 

Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS trainingand

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+or 

DJI Inspire 1 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels,

vehicles and structures.

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

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

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

UAS to be used for operations under the exemption). In addition to the hour requirements, 

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

purposes).
seeks Exemption 28

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 Ketcham Aerial Imaging’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows:

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

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

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

exemption. For clarification, the FAA considers these minimum hour requirements

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

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

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

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

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

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

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

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

Exemption No. 11138 at page 15.

Accordingly, Ketcham Aerial Imaging will ensure safe operations by not allowing

any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIChas 

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

able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS in amanner

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.
seeks Exemption 29

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, Ketcham Aerial Imaging will ensure that the DJI Phantom 2 

Vision+ or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s

compliance with its operating documents and as stated in the conditions and limitations 

herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

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

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

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will bemaintained

because the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAswill 

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 Ketcham Aerial Imaging’s operation of 

the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs within visual line of sight, at or below

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

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

each flight, a zero altitude initiation point is automatically established by the UASs at

ground level.

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

circumstances similar, in all material respects, to those presented herein (e.g. Exemption
seeks Exemption 30

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 theDJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs; (2) the limitations on the proposed flight

operations; and (3) the location of the proposed flight operations. Accordingly, Ketcham 

Aerial Imaging will ensure that it will safely operate the battery powered DJI Phantom2 

Vision+ and DJI Inspire 1 UAs during daylight hours in VFR conditions, withenough

battery power to fly for a total duration of 13.5 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the 

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

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom2 

Vision+ and DJI Inspire 1 UASs provide audible and visual warnings to the PIC atthe

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 Vision+ and DJIInspire

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 characteristicsand

operating limitations of the UAS are considered. Relief has been granted for manned
seeks Exemption 31

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, Ketcham Aerial Imaging 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 Ketcham Aerial Imaging will use trained technicians to perform

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

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

Imaging Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and 

DJI Inspire 1 Instruction Manual). Furthermore, Ketcham Aerial Imaging will document 

and maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs.

Since the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be inspected as 

prescribed by the operating documents, Ketcham Aerial Imaging 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 2 Vision+ and DJI Inspire 1 User Manuals are

attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UAS Maintenance LOG is attached hereto as Exhibit E.
seeks Exemption 32

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

Aerial Imaging will use trained technicians to perform maintenance, alterations or

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

prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be performed by trainedtechnicians.

Maintenance will be documented and maintained utilizing the monthly maintenancelog.

Significantly, previous exemptions granted by the FAA concerningSections

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 Ketcham Aerial Imaging’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2 Vision+ andDJI 

Inspire 1 UASs, Ketcham Aerial Imaging submits that safety will not be adverselyaffected

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, Ketcham Aerial Imaging
33

seeks Exemption

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

Phantom 2 Vision+ and DJI Inspire 1 UASs, which contain such safety standards thatthe

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 Statesfor 

compensation or hire. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate

without airworthiness certification in accordance with any requirements that must be

established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, since the

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

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

entitled Special Conditions, states thefollowing:

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.
seeks Exemption 34

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

may prescribe special conditions for Leading Edge’s intended operation of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs, which contain such safety standards thatthe

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 Ketcham Aerial Imaging Seeks Exemption:

Ketcham Aerial Imaging 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 Ketcham Aerial 

Imaging Seeks:

This exemption will permit Ketcham Aerial Imaging to commercially operate an 

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

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available ToSupport 

Ketcham Aerial Imaging’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, Ketcham Aerial Imaging’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.
seeks Exemption 35

As discussed in detail above, Ketcham Aerial Imaging will operate the DJI

Phantom 2 Vision+ and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to

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

CONCLUSION

As set forth herein, Ketcham Aerial Imaging 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 2 Vision+ and DJI Inspire 1 

UASs commercially, without an airworthiness certificate, for the limited purposeof

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 Ketcham Aerial Imaging to safely, efficiently, and economically

operate the DJI Phantom 2 Vision+ and DJI 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, Ketcham Aerial Imaging

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 Leading Edge to operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs commercially for the purpose ofconducting

aerial video and photography over certain areas of the United States.

Dated: June 22, 2015
seeks Exemption 36

Respectfully submitted, 

Ketcham Aerial Imaging

/s/ Anthony H. Ketcham 

Anthony H. Ketcham

Ketcham Aerial Imaging

2500 Deer Valley Rd. 1421

San Rafael, CA 94903

(415) 342-9381

ketcham99@comcast.net

Appendices:

A – DJI Phantom 2 Vision+ Specifications DataSheet

B – DJI Inspire 1 Specifications DataSheet

C – DJI Phantom 2 Vision+ Manufacturer’s User Manual 

D – DJI Inspire 1 Manufacturer’s UserManual

E – Monthly Maintenance Log
seeks Exemption 37

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

Ketcham Aerial Imaging only utilizes safe and reliable UASs. DJI is an industry leaderin 

small UAS production. DJI UASs are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitude as well as limit 

flight to a predetermined and set distance. In addition, DJI software provides real-time 

altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices)

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

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

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

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

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

1.1.2 Gimbal

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

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender
seeks Exemption 38

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W
seeks Exemption 39

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Ketcham Aerial Imaging only utilizes safe and reliable UASs. DJI is an industry leader in 

small UAS production. DJI UASs are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can

also be set to limit flight to no higher than a predetermined and set altitude as well as limit 

flight to a predetermined and set distance. In addition, DJI software provides real-time 

altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices)

2.2	DJI	Inspire 1

2.2.1Aircraft

2.2.1.1Model	– T600

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

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

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

2.2.1.5	Max	Tilt	Angle	- 350	

2.2.1.6	Max	Ascent	Speed	–5m/s

2.2.1.7Max	Descent	Speed	– 4m/s

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

RECOMMENDED)

2.2.1.9Max	Flight	Altitude	– 4500m

2.2.1.10	Max	Wind	Resistance	– 10m/s

2.2.1.11	Max	Flight	Time	– Approximately	18 minutes	

2.2.1.12	Motor	Model	– DJI3510

2.2.1.13Propeller	Model	– DJI 1345

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

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

2.2.2	Gimbal

2.2.2.1Model	– ZENMUSE X3

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

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

2.2.2.4	Angular	Vibration	Range	- ±0.030

2.2.2.5Mounting	– Detachable

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

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

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

2.2.3 Camera

2.2.3.1Name	– X3

2.2.3.2Model	– FC350

2.2.3.3	Total	Pixels	– 12.76M
seeks Exemption 40

2.2.3.4 Effective	Pixels	– 12.4M

2.2.3.5 Image	Max	Size	– 4000x3000

2.2.3.6	ISO	Range	– 100-3200

2.2.3.7 Field	of	View	- 940

2.2.3.8 CMOS	– Sony	EXMOR 1/2.3”

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

3840x2160p24/25/30;	FHD:	1920x1080p24/25/30/48/50/60;	

HD: 1280x720p24/25/30/48/50/60

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

2.2.4 Transmitter

2.2.4.1 Name	– C1

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

2.2.4.3 Communicating	Distance	(unobstructed)	– 2000m

2.2.4.4 Output	Power	– 9W

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

2.2.4.6 Battery	– 600mAh	LiPo 2S
seeks Exemption 41

APPENDIX – C

DJI Phantom 2 Vision+ Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_M

anual_v1.6_en.pdf
seeks Exemption 42

APPENDIX – D

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf
seeks Exemption 43

APPENDIX – E

MONTHLY$MAINTENANCE$LOG

month: (year:

UAS$#:$ Date(Issue(

Discovered

Date(Issue(

Addressed Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:(((

Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: