Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 1 of 20  

March 2, 2016 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

RE: Petition for Section 333 Exemption FAA Modernization and Reform Act of 2012 

Petitioner : Aviation Alternatives Inc. 

Petitioner’s sUAS(s) Models : DJI Inspire 1; DJI Phantom 3 Professional; 

DJI Phantom 4; senseFly eBee 

Petitioner’s sUAS(s) Operations : Aerial Research and Data Collection; 

Aerial Imagery; Aerial Photography; 

Aerial Videography; Aerial Mapping and 

Surveying; 

Regulations Requiring Exemption : 14 CFR §§ 61.23(a) and (c); 

14 C.F.R. §§ 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a); 

14 C.F.R. §61.315(a)

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119(c)

14 C.F.R. §91.121; 

14 C.F.R. §91.151(a)(1)

14 C.F.R. §91.405(a); 

14 C.F.R. §91.407(a)(1)

14 C.F.R. §§ 91.409(a)(1) and (2); and 

14 C.F.R. 91.417(a) and (b)

To whom it may concern, 

On behalf of Aviation Alternatives, Inc., (hereinafter “Aviation Alternatives’), a South Boston, 

Virginia, corporation specializing in aerial research and data collection, including aerial imagery, 

photography, videography, mapping and surveying, the undersigned counsel for Aviation 

Alternatives hereby applies for Section 333 exemption pursuant to the FAA Modernization and 

Reform Act of 2012, Public Law 112-95 (P.L. 112-95), and 14 C.F.R. Part 11. 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 2 of 20  

The operators of Aviation Alternatives understand the importance of safe flight operations and are 

acutely aware of the importance of complying with all Federal Aviation Regulations (F.A.R.s). To 

that end, Charles Clayton Gross, III, and Robert George Potts, Jr., both of whom help operate 

Aviation Alternatives, hold certificates for the operation of manned aircraft. As such, the operators 

of Aviation Alternatives will ensure that all sUAS flight operations are conducted in the safest 

possible manner. To that end, Aviation Alternatives will comply with any flight or atmospheric 

condition limitations imposed upon their commercial sUAS operations. 

This petition will address the following topics, as they relate to Aviation Alternatives’ commercial 

sUAS flight operations: the nature of Aviation Alternatives’ commercial drone operations, as well 

as the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee for which Aviation 

Alternatives seeks exemption; Aviation Alternatives’ proposed sUAS flight operations and 

conditions; privacy concerns; public interest and safety concerns; and, the above specified F.A.R.s 

requiring exemption. Under Section 333(b)(1), Aviation Alternatives’ petition will give the FAA 

cause to issue a Certificate Of Waiver or Authorization by showing that the size, weight, speed, 

operational capacity, proximity to airports and populated areas, and operations within the Visual 

Line of Sight of the Pilot in Command and Visual Observer of Aviation Alternatives’ DJI Inspire 

1, Phantom 3 Professional, Phantom 4, and senseFly eBee neither creates a hazard to users of the 

National Airspace System or public nor poses a threat to national security. 

Additionally, this petition will prove that Aviation Alternatives’ flight operations for the 

commercial usage of the DJI Inspire 1, Phantom 3 Professional, Phantom 4 and senseFly eBee 

provides an equivalent level of safety when compared to the F.A.R.s requiring exemption. To that 

end, this petition will highlight some of the numerous, granted petitions for Section 333 exemption 

for similar commercial operations of the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and 

senseFly eBee. 

Please refer to the “Table of Contents” beginning on page three (3) to assist your review of 

Aviation Alternatives’ petition for Section 333 exemption. If we may provide additional insight or 

information regarding Aviation Alternatives’ petition, please do not hesitate to contact The Ison 

Law Group at 863-712-9475 or IsonLawGroup@outlook.com. 

 Sincerely, 

THE ISON LAW GROUP 

 Christopher Ison, Esq. 

Enclosures 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 3 of 20  

TABLE OF CONTENTS

I. Glossary of Terms ................................................................................4 

II. Publishable Summary ................................................................................5 

III. Petitioner’s Contact Information ..............................................................5 

IV. Aviation Alternatives Inc. Overview ..............................................................6 

V. Aviation Alternatives Inc. sUAS Models .....................................................6 

a. DJI Inspire 1 Specifications .....................................................9 

b. DJI Phantom 3 Professional Specifications ...........................................10 

c. DJI Phantom 4 Specifications ............................................................12 

d. senseFly eBee ...............................................................................13 

VI. Proposed Flight Conditions and Operating Procedures .................................13 

VII. Privacy .......................................................................................17 

VIII. Public Interest and Safety .....................................................................17 

IX. Regulations from Which Exemption is Requested ..........................................17 

a. 14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration ...............17 

b. 14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations ...............18

c. 14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command ......18

d. 14 C.F.R. §61.315(a): What Are The Privileges and 

Limits of My Sport Pilot Certificate? ...................................................18

e. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness ...................................................19 

f. 14 C.F.R. § 91.119(c): Minimum Safe Altitude: General ..........................................19

g. 14 C.F.R. §91.121: Altimeter Settings ............................................................19

h. 14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions ...............20

i. 14 C.F.R. §91.405(a): Maintenance Required ...................................................20

j. 14 C.F.R. §91.407(a)(1): Operation After Maintenance, 

Preventative Maintenance, Rebuilding, Or Alteration ..................................20

k. 14 C.F.R. §§ 91.409(a)(1) and (2): Inspections ...................................................20

l. 14 C.F.R. 91.417(a) and (b): Maintenance Records ..........................................20 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 4 of 20  

GLOSSARY OF TERMS 

Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United 

States Code (49 USC) § 40102). 

National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities, 

equipment and services, airports or landing areas; aeronautical charts, information and services; 

rules, regulations and procedures, technical information, and manpower and material. 

Operational Control: with respect to a flight, means the exercise of authority over initiating, 

conducting or terminating a flight (14 CFR § 1.1). 

Pilot in Command (PIC): the person who has final authority and responsibility for the operation 

and safety of the flight; has been designated as PIC before or during the flight; and holds the 

appropriate category class and type-rating, if appropriate, for the conduct of the flight (14 CFR § 

1.1). 

Small Unmanned Aircraft System (sUAS): an unmanned aircraft and associated elements, 

including communication links and the components that control the unmanned aircraft, that are 

required for the pilot in command to operate safely and efficiently in the national airspace system 

(P.L. 112-95, Section 331), weighing less than 55 pounds, including payload. 

UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air Traffic 

Organization to an operator for a specific unmanned aircraft activity. 

Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) visual

contact between a pilot in command and an unmanned aircraft sufficient to maintain safe 

operational control of the aircraft, know its location, and be able to scan the airspace in which it is 

operating to see and avoid other air traffic or objects aloft or on the ground. 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

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PUBLISHABLE SUMMARY

Pursuant to 14 C.F.R §11.81(f), should the FAA require a publishable summary for the Federal 

Register, Aviation Alternatives, Inc. (hereinafter Aviation Alternatives), submits the following 

information: 

Aviation Alternatives seeks exemption from the following Federal Aviation Regulations 

(F.A.R.s): 

14 CFR §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 

61.113(a); 14 C.F.R. §61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 

C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.405(a); 14 C.F.R. 

§91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b). 

Aviation Alternatives seeks exemption from the above listed F.A.R.s for the purpose of 

commercially operating Small Unmanned Aircraft Systems (sUAS), to wit: the DJI Inspire 1, 

Phantom 3 Professional, Phantom 4, and senseFly eBee. Aviation Alternatives intends to 

commercially operate these sUAS models for aerial research and data collection, including aerial 

imagery, photography, videography, mapping and surveying. As such, this petition will prove that 

Aviation Alternatives’ flight operations for the commercial usage of these sUAS models provides 

an equivalent level of safety when compared to the F.A.R.s requiring exemption. 

In support of this petition, Aviation Alternatives notes that the FAA has already granted numerous 

exemptions for similar commercial operators of the DJI Inspire 1, Phantom 3 Professional, 

Phantom 4, and senseFly eBee. To that end, Aviation Alternatives’ petition will highlight some of 

the numerous, granted petitions for Section 333 exemption for similar commercial operations of 

the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee. 

Under Section 333(b)(1) of the FAA Modernization and Reform Act of 2012, Aviation 

Alternatives’ petition will give the FAA good cause to issue a Certificate Of Authorization by 

showing that the size, weight, speed, operational capacity, proximity to airports and populated 

areas, and operations within the Visual Line of Sight of the Pilot in Command and Visual Observer 

of Aviation Alternatives’ sUAS models neither creates a hazard to users of the National Airspace 

System or public nor poses a threat to national security. To that end, Aviation Alternatives seeks 

exemption from the above specified F.A.R.s as Aviation Alternatives’ flight operations provide an 

equivalent level of safety when compared to the F.A.R.s to be exempted. Aviation Alternatives 

will adhere to any flight or atmospheric condition limitation imposed by the FAA. 

PETITIONER’S CONTACT INFORMATION 

Petitioner: Counsel for Petitioner: 

Summer L. Nix, Owner The Ison Law Group 

Aviation Alternatives, Inc. 2073 US Hwy 92 West, Suite 104 

4131 Birch Elmo Road Winter Haven, FL 33881 

South Boston, VA 24592 Phone: 863-712-9475 

Phone: 434-753-2764 Email: IsonLawGroup@outlook.com 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 6 of 20  

AVIATION ALTERNATIVES, INC., PETITION FOR SECTION 333 EXEMPTION 

Aviation Alternatives, Inc. 

Overview 

Aviation Alternatives, Inc., (hereinafter “Aviation Alternatives”) is a South Boston, Virginia, 

based corporation specializing in aerial research and data collection, including aerial imagery, 

photography, videography, mapping and surveying. Aviation Alternatives provides services to 

individuals and businesses in need of LiDAR imaging vis-à-vis sUAS operation. A few examples 

of Aviation Alternatives’ commercial sUAS practices include providing LiDAR imagery for preconstruction surveys of properties, travel corridors, or floodplains. Moreover, Aviation 

Alternatives’ commercial sUAS operations will also benefit individuals and businesses after 

natural disasters by using aerial LiDAR technology to survey fire damage, flood damage, or any 

other type of damage as a result of a natural disaster. 

As detailed below, Aviation Alternatives will only permit commercial sUAS flight operations of 

the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee by certificated airmen, 

holding at the bare minimum a sport pilot certificate. Currently, Aviation Alternatives employs 

Mr. Charles Clayton Gross, III, and Mr. Robert George Potts, Jr., who are certificated airmen. Mr. 

Gross is a commercially certificated pilot (Certificate #3674786) with 10,000 hours of flight time. 

Additionally, Mr. Potts is a certificated private pilot (Certificate #3290995) with 500 hours of 

flight time. Consequently, Mr. Gross and Mr. Potts, on behalf of Aviation Alternatives, understand 

safe flight operations and will ensure that Aviation Alternatives practices and employs safe flight 

principles during all commercial sUAS operations. 

Based upon Aviation Alternatives’ intended use and proposed flight operations and conditions 

limitations, Aviation Alternatives would like an exemption from the following Federal Aviation 

Regulations (F.A.R.s) to commercially operate the DJI Inspire 1, Phantom 3 Professional, Phantom 

4, and senseFly eBee: 14 CFR §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 

61.113(a); 14 C.F.R. §61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 C.F.R. §91.121; 

14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.405(a); 14 C.F.R. §91.407(a)(1); 14 C.F.R. §§ 

91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b). 

Aviation Alternatives, Inc., sUAS Models 

Aviation Alternatives’ requested exemption from the above specified F.A.R.s will allow for the 

use of the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee for commercial 

operations pertaining to aerial research and data collection, as well as aerial imagery, photography, 

videography, mapping and surveying within the United States of America. These sUAS models 

are either similar to, or the same as, sUAS models for which the FAA has already granted 

exemptions for similar commercial flight operations (as detailed below). 

Given the ease of operation, unique safety features, and PIC situational awareness programs of 

these sUAS models, Aviation Alternatives’ requested exemption from various F.A.R.s will neither 

adversely affect the public’s safety nor create a hazard to users of the National Airspace System 

(NAS) or pose a threat to national security. Moreover, Aviation Alternatives’ use of these sUAS 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 7 of 20  

models for the above described commercial operations will replace the need for fixed winged or 

rotorcraft aircraft with regards to these services. 

By replacing fixed winged or rotorcraft aircraft with sUAS models, the public will benefit in 

several ways. For example, the use of these sUAS models provides significant reductions in the 

risk of injury to property or person should the sUAS require an emergency landing. These sUAS 

models are lightweight, powered by batteries, and carry no passengers. By comparison, fixed 

winged or rotorcraft aircraft, which weigh thousands of pounds, carry flammable fuels, and 

passengers, have been known to cause serious injury or death to passengers and bystanders during 

emergency landings. The use of these particular sUAS models for aerial research and data 

collection, including aerial imagery, photography, videography, mapping and surveying will 

substantially benefit the public from a safety standpoint.

DJI Inspire 1 and Phantom 3 Professional, Phantom 4 

The DJI Inspire 1, Phantom 3 Professional, and Phantom 4 are quad-copter sUAS models capable 

of providing hover flight in both the vertical and horizontal planes. As such, these sUAS models 

provide excellent maneuverability and ease of control for the PIC. The ease with which a PIC can 

control these sUAS models is evidenced by the fact that both sUAS models are commercially 

available for RC hobbyists, requiring no training or experience prior to flight. 

In part, the DJI Inspire 1, Phantom 3 Professional, and Phantom 4 are easy to control because they 

provide excellent situational awareness for the PIC. These sUAS models allow the PIC to 

determine the exact altitude of the sUAS via GPS technology and monitoring. In addition, these 

sUAS models incorporate the use of DJI’s Pilot App which provides an incredible wealth of 

information that will supplement the PIC’s situational awareness while operating either sUAS. As 

such, the DJI Pilot App provides the following information: current flight mode, GPS signal 

strength, system status, battery level indicator, remote controller signal strength, flight telemetry 

(height, distance, and airspeed), and area map. By enhancing the PIC’s situational awareness, the 

PIC will be able to focus on safe flight operations, thereby reducing the likelihood of an incident 

which would lead to property damage or injury to persons. 

Aviation Alternatives’ primary objective with each commercial flight is the safe return of the 

sUAS without injury to property or person. To further that objective, the DJI Inspire 1, Phantom 3 

Professional, and Phantom 4 incorporate unique operating modes that provide for the safe return 

of the sUAS should the PIC experience a loss of signal connectivity between the sUAS model’s 

transmitter and receiver. Moreover, these sUAS models also incorporate three safe modes in such 

a situation: Failsafe, Return to Home, and Dynamic Home Point. 

In addition to the above safety features, the new DJI Phantom 4 boasts ActiveTrack, TapFly, and 

a unique Obstacle Sensing System. ActiveTrack allows the Phantom 4 to track a moving subject 

without a separate GPS tracker. In order to activate this feature, the PIC simply taps on the mobile 

device screen inside the DJI GO app to select the subject to be tracked. The aircraft will lock on 

the subject and start tracking it automatically from a safe distance. To that end, TapFly allows the 

PIC to fly in any direction with a tap of the finger, without a remote controller. And, as one might 

guess, with Obstacle Avoidance turned on, the aircraft will automatically avoid obstacles, slow 

down or hover when required, provided that the scene is bright enough ( < 300 lux) or not too 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 8 of 20  

bright ( > 10,000 lux). With the Obstacle Avoidance system engaged, the Phantom 4 is equipped 

will constantly scan for obstacles in front of it, allowing it to avoid collisions by going around, 

over or hovering. 

The FAA has already granted numerous petitions for Section 333 exemption to commercial sUAS 

operators of the DJI Inspire 1 and Phantom 3 Professional. Below is sampling of granted Section 

333 petitions for the commercial operation of the DJI Inspire 1 and Phantom 3 Professional, as 

well as the petitioner’s proposed commercial usage of the sUAS: 

Exemption 

Number 

Regulatory 

Docket Number 

Flight Operation 

11399A FAA-2015-0147 Aerial Photography/Videography for Real Estate Services 

11845 FAA-2015-0806 Aerial Photography/Videography for Real Estate Services 

12042 FAA-2015-1552 Aerial Photography/Videography 

12046 FAA-2015-1534 Aerial Photography/Videography 

11802 FAA-2015-1050 Aerial Photography/Videography for Real Estate Services 

11977 FAA-2015-1478 Aerial Videography/Photogrammetry 

11953 FAA-2015-1407 Aerial Mapping/Inspection/Photography 

11711 FAA-2015-0777 Aerial Photography/Photogrammetry 

11938 FAA-2015-1390 Aerial Photography/Video 

11172A FAA-2014-0787 Aerial Photography and Wildlife Preservation 

11899 FAA-2015-1249 Aerial Photography/Videography/Mapping 

1306A FAA-2014-1023 Aerial Photogrammetry/Inspection/Analysis 

senseFly eBee 

Unlike the DJI Inspire 1 and Phantom 3 Professional, Phantom 4, the senseFly eBee is a fixedwing sUAS that allows for autonomous flight via a data link. The eBee has a 38 inch wingspan 

and has a maximum take-off weight of 1.7 pounds. Owing to the lightweight of the eBee is the fact 

that the platform is make of flexible foam that has no sharp or hard edges. To that end, the eBee is 

easily hand launched and can land on almost any surface without requiring a parachute or landing 

net when belly landing. 

While the eBee employs a manual control option for the PIC which allows the operator to take 

manual control during the flight, the senseFly eBee also utilizes eMotion technology – an 

integrated software package that allows the PIC to plan a mapping flight through an easy-to-use 

interface. Upon launching the eBee, eMotion’s wireless connection with the sUAS tracks its 

position, monitors the progress of the mapping flight and sends commands to the sUAS if 

necessary. However, similar to the DJI Inspire 1 and Phantom 3 Professional, Phantom 4, the 

senseFly eBee utilizes several failsafe features to ensure a safe flight. For example, as a 

precautionary measure, the eBee has been programmed with a series of emergency maneuvers: 

Land low; Abort landing; Roll; Fast climb; and Fast descent. 

Additionally, the senseFly eBee will warn the PIC with a yellow “ACK WARNING” button for 

in-flight warnings and a red “CRITICAL FAILURE” button for critical failures. To that end, there 

are numerous in-flight warnings that the eBee can tell the PIC, such as: Failure occurred; Low 

battery; Drone flight log malfunction; Flight controller malfunctions; Camera sync malfunction; 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

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Camera power malfunction; Barometer malfunction; Motor malfunction; Battery malfunction; 

Airspeed malfunction; Low airspeed; Overspeed; Ground sensor malfunction; Wings detection 

malfunction; Temperature out of working levels; Above working area ceiling; Out of working area 

radius; Far outside of working area; Poor GPS coverage; Data uplink lost; Ground Proximity 

detected; Ground proximity not detected landing precision decreased; Back wind; Strong wind; 

Cannot maintain altitude; and Pitch or Roll instability. Moreover, there are numerous critical 

failure warnings that the eBee can tell the PIC, such as: Loss of GPS signal; Empty battery; INS 

Malfunction; Motor malfunction; and CPU overload. 

The FAA has already granted numerous petitions for Section 333 exemption to commercial sUAS 

operators of the senseFly eBee. Below is a sampling of granted Section 333 petitions for the 

commercial operation of the senseFly eBee, as well as the petitioner’s proposed commercial usage 

of the sUAS: 

Exemption 

Number 

Regulatory 

Docket Number 

Flight Operation 

11166 FAA-2014-0790 Agriculture Analysis; High-resolution Aerial Imagery

11263 FAA-2014-0727 Mapping and Precision Agriculture 

11285 FAA-2014-1015 Aerial Mapping and Surveying Applications 

11331 FAA-2015-0019 Mapping and Survey Applications 

11801 FAA-2015-1019 Forensic Engineering and Fire Investigation Applications 

11523 FAA-2015-0335 Mapping and Survey Applications 

sUAS Model Specs 

DJI Inspire 1 

Specifications

Aircraft

Weight (Battery Included): 2935 grams 

Hovering Accuracy (P Mode): Vertical: 0.5m; Horizontal: 2.5m 

Max Angular Velocity: Pitch: 300֯/s; Yaw: 150֯/s 

Max Tilt Angle: 35֯

Max Ascent Speed: 5 m/s 

Max Descent Speed: 4 m/s 

Max Speed: 22 m/s (ATTI mode, no wind) 

Max Flight Altitude: 4500 m 

Max Wind Speed Resistance: 10 m/s 

Max Flight Time: Approximately 18 minutes 

Motor Model: DJI 3510 

Propeller Model: DJI 1345 

Indoor Hovering: Enabled by default 

Operating Temperature Range: -10֯ C to 40֯C 

Diagonal Distance: 559 to 581 mm 

Dimensions: 438x451x301mm 

Gimbal
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Aviation Alternatives Inc. 

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Model: ZENMUSE X3 

Output Power (with Camera): Static: 9W; In Motion: 11W 

Operating Current: Station: 750mA; Motion: 900mA 

Angular Vibration Range: ±0.03֯

Mounting: Detachable 

Controllable Range: Pitch: -90֯ to +30֯; Pan: ±320֯

Mechanical Range: Pitch: -125֯ to +45֯; Pan: ±330֯

Max Controllable Speed: Pitch: 120֯/s; Pan: 180֯/s 

Camera

Name: X3 

Model: FC350 

Total Pixels: 12.76M 

Effective Pixels: 12.4M 

Image Max Size: 4000x3000 

ISO Range: 100-3200 (video) 100-1600 (photo) 

Remote Controller 

Name: C1 

Operating Frequency: 5.725~5.825GHz; 2.400~2.483GHZ 

Transmitting Distance: 2km (Outdoor and Unobstructed) 

EIRP: 10dBM@900, 12dBm@5.8G, 20dBm@2.4G 

Video Output Port: USB, Mini-HDMI 

Power Supply: Built-in battery 

Charging: DJI Charger 

Dual User Capability: Host-and Slave connection 

Mobile Devise Holder: Tablet or Smart Phone 

Output Power: 9W 

Operating Temperature Range: -10֯C to 45֯C 

Charging Temperature Range: 0-40֯C 

Battery: 6000 mAh LiPo 2S 

Charger

Model: A11-100P1A 

Voltage: 26.3V 

Rated Power: 100W 

Battery (Standard)

Name: Intelligent Flight Battery 

Model: TB47 

Capacity: 4500mAh 

Voltage: 22.2V 

Battery Type: LiPo 6S High voltage battery 

Energy: 99.9Wh 

Net Weight: 570g 

Operating Temperature Range: -10֯C to 40֯C 

Charging Temperature Range: 0-40֯C 
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Aviation Alternatives Inc. 

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Max Charging Power: 180W 

DJI Phantom 3 Professional 

Specifications 

Aircraft: 

Weight: 1280 g 

Maximum Ascent Speed: 5 m/s 

Maximum Descent Speed: 3 m/s 

Maximum Speed: 16 m/s 

Maximum Flight Altitude: 6000 m 

Maximum Flight Time: 23 minutes (Approximately) 

Operating Temperature Range: 0֯C to 40֯C 

GPS: GPS/GLONASS 

Gimbal:

Controllable Range: Pitch: -90֯ to +30֯

Vision Positioning: 

Velocity Range: <8 m/s (Altitude 2 m) 

Altitude Range: 30 cm – 300 cm 

Operating Range: 30 cm – 300 cm 

Operating Environment: Surface w/Clear Pattern and 

Adequate Lighting (Lux > 15) 

Camera:

Sensor: Sony Exmor 1/2.3” 

Operating Temperature Range: 0֯C to 40֯C 

Remote Controller: 

Operating Frequency: 2.400 GHz – 2.483 GHz 

Maximum Transmission Distance: 2 km (outdoors and unobstructed) 

Operating Temperature Range: 0֯C to 40֯C 

Battery: 6000 mAh LiPo 2S 

Mobile Device Holder: Tablets and smartphones 

Transmitter Power (EIRP): FCC: 20 dbm; CE: 16 dbm 

Working Voltage: 1.2 A @ 7.4 V 

Charger:

Voltage: 17.4 V 

Rated Power: 57 W 

Intelligent Flight Battery (PH3-4480 mAh 15.2V) : 

Capacity: 4480 mAh 

Voltage: 15.2 V 

Battery Type: LiPo 4S 

Energy: 68 Wh 
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Aviation Alternatives Inc. 

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Net Weight: 365 g 

Operating Temperature: -10֯C to 40֯C 

Max Charging Power: 100 W

DJI Phantom 4 

Specifications 

Aircraft: 

Weight (including Battery): 1380g 

Max Ascent Speed: 6 m/s 

Max Descent Speed: 4 m/s 

Max Speed: 20 m/s 

Max Service Ceiling Above Sea Level: 6000m (19,685 ft) 

Max Flight Time: Apprx. 28 min 

Operating Temperature Range: 32֯ to 104֯ F (0֯ to 40֯ C) 

Satellite Systems: GPS / GLONASS 

Hovering Accuracy: Vertical: 

 +/- 0.1m 

 Horizontal: 

 +/- 0.3m 

Obstacle Sensing System: 

Obstacle Sensory Range: 0.7 -15 m (2-49 ft) 

Operating Environment: Surface with clear pattern and 

adequate lighting (lux > 15) 

Camera:

Sensor: 1/2.3” Effective pixels: 12M 

Lens: FOV 

ISO Range: 8s to 1/8000s 

Max Image Size: 4000x3000 

Still Photography Modes: Single Shot 

 Burst Shooting: 3/5/7 frames 

 Auto Exposure Bracketing 

 Time-lapse 

 HDR 

Video Recording Modes: UDH; FHD; HD 

Gimbal:

Controllable Range: Pitch -90֯ to +30֯ 

Vision Positioning System:

Velocity Range: ≤10 m/s ( 2 m above ground ) 

Altitude Range: 0 – 10 m (0-33 feet) 

Operating Range: 0 – 10 m (0-33 feet) 

Operating Environment: Surface with clear pattern and 

adequate lighting (lux > 15) 
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Aviation Alternatives Inc. 

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Remote Controller: 

Operating Frequency: 2.400 GHz to 2.483 GHz 

Max Transmission Distance: FCC Compliant: 5k (3.1 mi) 

Operating Temperature: 32֯ to 104֯ F (0֯ to 40֯ C) 

Battery: 6000 mAh LiPo 2S 

Transmitter Power (EIRP): FCC: 23 dBm 

Operating Voltage: 7.4 @ 1.2A 

Intelligent Flight Battery (PH3-4480 mAh 15.2V) : 

Capacity: 5350 mAh 

Voltage: 15.2 V 

Battery Type: LiPo 4S 

Energy: 81.3 Wh 

Net Weight: 462 g 

Operating Temperature: -10֯C to 40֯C 

Max Charging Power: 100 W

senseFly eBee 

Specifications

Aircraft:

Weight: 0.69 kg (1.52 lbs) 

Wingspan: 96 cm (38 in) 

Material: EPP foam, carbon structure & composite parts 

Propulsion: Electric pusher propeller, 160 W brushless DC motor 

Battery: 11.1 V, 2150 mAh 

Camera: WX (18.2 MP) or S110 RGB, thermoMAP 

Operation:

Maximum Flight Time: 50 minutes 

Nominal Cruise: 40-90 km/h (11-25 m/s or 25-56 mph) 

Radio Link Range: Up to 3 km (1.86 mi) 

Maximum Coverage: 12 sq km/4.6 sq mi 

Wind Resistance: Up to 45 km/h (12 m/s or 28 mph) 

Linear Landing Accuracy: Apprx. 5 m (16.4 ft) 

Proposed Flight Conditions and Operating Procedures 

Aviation Alternatives’ primary objective with every flight is the safe return of the above specified 

sUAS models without injury to property or person. In order to obtain this desired objective, 

Aviation Alternatives will abide by the following flight and atmospheric conditions limitations 

when performing commercial flight operations with the DJI Inspire 1, Phantom 3 Professional, 

Phantom 4, and senseFly eBee: 

1. Aviation Alternatives will not operate the sUAS models when weighing more than 

55 pounds, including payload. 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

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2. Aviation Alternatives will not operate the sUAS models at a speed exceeding 87 

knots (100 miles per hour). Aviation Alternatives will use either groundspeed or 

calibrated airspeed to determine compliance with the 87 knot speed restriction. 

3. Aviation Alternatives will not operate the sUAS models at an altitude of more than 

400 feet above ground level (AGL). Aviation Alternatives will monitor altitude in 

feet AGL via GPS technology and monitoring. 

4. Aviation Alternatives will only operate the sUAS models within VLOS of the PIC 

at all times. Aviation Alternatives will require 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 or U.S. driver’s license. 

5. Aviation Alternatives requires the utilization of a visual observer (VO) on all 

commercial sUAS flights. The sUAS models will be operated within VLOS of the 

PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as 

long as the PIC always maintains VLOS capability. Aviation Alternatives requires 

that the VO and PIC be able to communicate verbally at all times. Aviation 

Alternatives does not permit electronic messaging or texting during flight 

operations. Aviation Alternatives requires the sUAS PIC to be designated before 

the flight and does not allow transfer of his or her designation during the flight. The 

PIC must ensure that the VO can perform the duties required of the VO. 

6. Aviation Alternatives requires that all operating documents (defined as the granted 

exemption and all documents needed to operate the UAS model and conduct its 

operations in accordance with all grants conditions and limitations) must be 

accessible during sUAS operations and made available to the Administrator upon 

reasonable request. 

7. Aviation Alternatives will require a functional test should any sUAS model undergo 

maintenance or alterations that affect that sUAS model’s operation or flight 

characteristics, e.g., replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. 

Aviation Alternatives requires that all function flights be conducted by a PIC with 

a VO and remain at least 500 feet from other people. Aviation Alternatives further 

requires that the functional test flight be conducted in such a manner so as to not 

pose an undue hazard to persons and property. 

8. Aviation Alternatives will be responsible for maintaining and inspecting the sUAS 

model to ensure that the sUAS model is in a condition for safe operation. 

9. Aviation Alternatives requires that, prior to each flight, the PIC conduct a pre-flight 

inspection and determine whether the sUAS model is in a condition for safe flight. 

Aviation Alternatives requires that the pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. Should 

the inspection reveal a condition that affects the safe operation of the sUAS model, 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 15 of 20  

Aviation Alternatives prohibits the aircraft from operating until the necessary 

maintenance has been performed and the sUAS is found to be in a condition for 

safe flight. 

10. Aviation Alternatives requires compliance with the component manufacturer’s 

maintenance, overhaul, replacement, inspection, and life limit requirements for the 

components that combine to assemble the sUAS models. 

11. Aviation Alternatives requires compliance with all sUAS model manufacture’s 

safety bulletins for the sUAS model. 

12. Aviation Alternatives requires all sUAS model PICs to hold either an airline 

transport, commercial, private, recreational, or sport pilot certificate. Further, 

Aviation Alternatives requires the PIC to also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal Government. The PIC must 

also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft 

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

13. Aviation Alternatives prohibits any PIC to operate the sUAS model unless the PIC 

demonstrates the ability to safely operate the sUAS model in a manner consistent 

with how the sUAS will be operated under this petition for exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. To that end, Aviation Alternatives 

requires the PIC’s qualification flight hours and currency to be logged in a manner 

consistent with 14 CFR § 61.51(b). 

14. Aviation Alternatives prohibits flight operations of the sUAS models during night, 

as defined in 14 CFR § 1.1. All flight operations will be conducted under visual 

meteorological conditions (VMC). Aviation Alternatives will not allow the sUAS 

model to be flown during special visual flight rules (SVFR). 

15. Aviation Alternatives will not operate the sUAS model within 5 nautical miles of 

an airport reference point (ARP) as denoted in the current FAA Airport/Facility 

Directory (AFD) or for airports not denoted with an ARP, the center of the airport 

symbol as denoted on the current FAA-published aeronautical chart, unless a letter 

of agreement with that airport’s management is obtained or otherwise permitted by 

a COA issued to the exemption holder. Aviation Alternatives will make the letter 

of agreement with the airport management available to the Administrator or any 

law enforcement official upon request. 

16. Aviation Alternatives will operate the sUAS model at least 500 feet below and/or 

no more than 2,000 feet horizontally from a cloud. Aviation Alternatives will not 

operate the sUAS model when visibility is less than 3 statute miles. 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 16 of 20  

17. Aviation Alternatives requires the sUAS model to return to a pre-determined 

location within the private or controlled-access property should the sUAS model 

lose communications or lose its GPS signal. 

18. Aviation Alternatives requires the PIC of any sUAS model to abort the flight in the 

event of unpredicted obstacles or emergencies. 

19. Aviation Alternatives prohibits the PIC of any sUAS model from beginning a flight 

unless (considering wind and forecast weather conditions) there is enough available 

power for the sUAS model to conduct the intended operation and to operate after 

that for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater. 

20. Aviation Alternatives requires that all documents used to ensure safe operation and 

flight of the sUAS model and any documents required under 14 CFR §§ 91.9 and 

91.203 to be available to the PIC at the Ground Control Station of the sUAS model 

any time the aircraft are operating. Aviation Alternatives will make these 

documents available to the Administrator or any law enforcement official upon 

reasonable request. 

21. Aviation Alternatives requires that during all flights, the sUAS model PIC remain 

clear and give way to all manned aviation operations and activities at all times. 

22. Aviation Alternatives prohibits the PIC of any sUAS model from operating the 

sUAS model from any moving device or vehicle. 

23. Aviation Alternatives requires all flight operations of all sUAS models to be 

conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and 

structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the sUAS and/or debris in the event of an accident. Aviation 

Alternatives will 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 sUAS, Aviation Alternatives 

requires flight operations to cease immediately in a manner ensuring the 

safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects 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. 

24. Aviation Alternatives will operate all sUAS models flights over private or 

controlled-access property with permission from the property owner/controller or 

authorized representative. Aviation Alternatives will obtain permission from the 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 17 of 20  

property owner/controller or authorized representative prior to each flight to be 

conducted. 

PRIVACY

Aviation Alternatives’ commercial operational use of the DJI Inspire 1, Phantom 3 Professional, 

Phantom 4, and senseFly eBee will not implicate any privacy concerns. Since Aviation 

Alternatives will only commercially operate the sUAS models at the request of the property and/or 

business owner(s), Aviation Alternatives will have the express consent and permission of the 

property and/or business owner(s) prior to flying over private property. Aviation Alternatives’ use 

of these sUAS models poses no greater privacy concerns than the use of traditional fixed wing or 

rotorcraft aircraft for similar commercial operations. Should Aviation Alternatives’ commercial 

sUAS activity require aerial based photographic or videographic imagery, images taken will be of 

individuals who have consented to being photographed/filmed or otherwise have agreed to be in 

the area where aerial photographic or videographic imagery will take place. 

PUBLIC INTEREST AND SAFETY

Unlike traditional fixed wing or rotorcraft aircraft, the use of the DJI Inspire 1, Phantom 3 

Professional, Phantom 4, and senseFly eBee for commercial operation promotes public interest 

and safety. Whereas traditional fixed wing or rotorcraft aircraft are large, heavy, noisy, require 

flammable fuels and manned operators (placing the pilot’s life in jeopardy should there be an 

emergency), these sUAS models are small, light, quite, and do not require flammable fuels or a 

manned operator (i.e. not risking human life for the purpose of operation). 

The use of Aviation Alternatives’ sUAS models also benefits the public from a safety perspective 

since these sUAS models do not run on fossil fuels. Because these sUAS models are battery 

powered, their use over the traditional fixed wing or rotorcraft aircraft will be more 

environmentally and ecologically friendly. In addition to the non-use of flammable fuels, given 

the extreme lightness of these sUAS models, should an emergency result in a forced landing, injury 

to property or persons would be negligible compared to the catastrophic injury to property or 

persons that would result in an emergency landing of a traditional fixed wing or rotorcraft aircraft. 

Apart from the added safety benefits of sUAS flight operations, the use of these sUAS models for 

the above noted commercial applications creates new economic opportunities that could fuel the 

continued growth of aviation and aviation related interests. Consequently, the public will benefit 

from the use of sUAS models for commercial purposes as companies like Aviation Alternatives 

will provide new jobs and economic opportunities, fueling innovation and creativity. 

REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration 

Aviation Alternatives requests exemption from 14 CFR §§ 61.23(a) and (c) which provides for 

certain flight operations requiring medical certificates. Aviation Alternatives’ petition for 

exemption provides an equivalent level of safety in that Aviation Alternatives would require a DJI 

Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee to hold either a current medical 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 18 of 20  

certificate, of any class, or a valid U.S. Driver’s License. Aviation Alternatives’ petition for 

exemption provides an equivalent level of safety as provided in 14 C.F.R. §§61.23(a) and (c). 

14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations; 14 C.F.R. § 

61.113(a): Private Pilot Privileges and Limitations: Pilot in Command; and 14 C.F.R. 

§61.315(a): What Are The Privileges and Limits of My Sport Pilot Certificate? 

Aviation Alternatives requests exemption from 14 C.F.R. §§ 61.101(e)(4) and (5) which prohibits 

recreational pilots from receiving compensation for hire or providing flight services in furtherance 

of a business, respectively. In addition, Aviation Alternatives requests exemption from 14 C.F.R. 

§61.113(a), which prohibits a certificated private pilot from receiving compensation or flying for 

hire when acting as PIC; and from 14 C.F.R. §61.315(a), which provides the holder of a sport pilot 

certificate may only act as pilot in command of a light-sport aircraft. 

Aviation Alternatives’ petition for exemption provides an equivalent level of safety in that 

Aviation Alternatives requires the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly 

eBee PIC, at the bare minimum, to hold the privileges of a sport pilot certificate under 14 C.F.R. 

§61 Subpart J, hold either a medical certificate or valid U.S. Driver’s License, and to demonstrate 

proficiency in the PIC’s ability to safely operate the sUAS models in a manner consistent with 

how the sUAS will be operated under this petition for exemption.

Distinct comparisons between the commercial activities of Aviation Alternatives and other 

businesses operating traditional, manned, fixed wing or rotorcraft aircraft expose the unnecessary 

limitations placed upon sport, recreational and private certificated pilots when considering PIC 

privileges of commercial sUAS flight operations. Whereas requiring pilots of traditional, manned, 

fixed wing and rotorcraft aircraft to hold commercial and Airline Transport Pilot (ATP) ratings 

ensures that the pilots possess the necessary skills, training and experience to safely transport 

persons and/or cargo from the point of departure to the intended point of destination, the same 

correlation for sUAS pilots and should not apply to the sUAS flight operations of Aviation 

Alternatives. 

In the case of Aviation Alternatives’ sUAS flight operations, no persons or third-party cargo will 

be carried by the sUAS models during Aviation Alternatives’ aerial based commercial operations. 

Unlike traditional fixed wing or rotorcraft aircraft, which must traverse over a greater distance, 

greater amount of property, and a greater amount of people in order to get from the point of 

departure to the intended point of destination, Aviation Alternatives’ sUAS will only fly over 

property authorized by Aviation Alternatives’ clients. In other words, the sUAS models will not 

have to originate flight from a different location and traverse over the properties of disinterested 

parties in order to fulfill the purpose of Aviation Alternatives’ commercial flight operations. As 

such, the risk of injury to disinterested parties is substantially decreased by the use of a sUAS for 

aerial based commercial applications described within this petition. 

Consequently, Aviation Alternatives’ requirement that the sUAS PIC hold, at least, a sport pilot 

certificate provides an equivalent level of safety to the requirement that a commercial or ATP rated 

pilot transport persons and/or cargo for hire in manned aircraft. 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 19 of 20  

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Aviation Alternatives requests an exemption from 14 C.F.R. §91.7(a) which prohibits the 

operation of civil aircraft unless it is in airworthy condition. As there will be no airworthiness 

certificate issued for Aviation Alternatives’ DJI Inspire 1, Phantom 3 Professional, Phantom 4, 

and senseFly eBee models, no standard will exist for determining airworthiness. In any event, 

Aviation Alternatives’ proposed Flight Conditions and Operating Procedure will ensure an 

equivalent level of safety with 14 C.F.R. §91.7(a). 

14 C.F.R. § 91.119(c): Minimum Safe Altitude: General 

Aviation Alternatives requests an exemption from 14 C.F.R §91.119(c) which provides that except 

when necessary for takeoff or landing, no person may operate an aircraft below an altitude of 500 

feet above the surface. Furthermore, this section provides that an aircraft may not be operated 

closer than 500 feet to any person, vessel, vehicle, or structure. Aviation Alternatives’ petition 

requests that the DJI Inspire 1, Phantom 3 Professional, Phantom 4, and senseFly eBee be flown 

at an altitude no higher than 400 feet AGL and, when complying with the conditions set forth in 

§23(b) of Aviation Alternatives’ Flight Conditions and Operating Procedures, at distances closer 

than 500 feet from any person, vessel, vehicle, or structure. 

The requirement that the sUAS models maintain 400 feet or less AGL helps ensure that signal 

connectivity between the transmitter and receiver will not be lost. In addition, this height restriction 

ensures that the PIC will be able to maintain VLOS while simultaneously limiting the possibility 

of the sUAS models’ interference with other NAS traffic. Moreover, this requirement ensures at 

least 100 feet of vertical separation between sUAS commercial operators and manned aircraft 

operating within the NAS. 

Traditional principles requiring a 500 foot AGL minimum for fixed-wing or rotorcraft aircraft 

stemmed from a desire to protect the public should the need for a forced landing arise due to an 

unforeseen emergency situation or loss of power. These same concerns are not present with 

Aviation Alternatives’ sUAS models as they are extremely lightweight and small. Any injury to 

property or person would be negligible when compared to the catastrophic damage that a fixed 

wing or rotorcraft aircraft would inflict due to a forced landing. Consequently, Aviation 

Alternatives’ Flight Conditions and Operating Procedures provide for an equivalent level of safety 

when compared to 14 C.F.R §91.119(c). 

14 C.F.R. §91.121: Altimeter Settings 

Aviation Alternatives requests exemption from 14 C.F.R. §91.121 which provides guidelines for 

the use of altimeter settings while operating an aircraft. Aviation Alternatives’ petition for 

exemption provides an equivalent level of safety such that the DJI Inspire 1, Phantom 3 

Professional, Phantom 4, and senseFly eBee PIC will be able to determine the AGL height of the 

sUAS model due to GPS technology. The AGL height of the sUAS will be displayed for the PIC 

during all flight operations. As such, the PIC will be able to maintain the requirement that the 

sUAS models fly no higher than 400 feet AGL during all flight operations. 
Petition for Section 333 Exemption 

Aviation Alternatives Inc. 

Page 20 of 20  

14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions 

Aviation Alternatives requests exemption from 14 C.F.R. §91.151(a)(1) which provides that no 

person may begin a flight in an airplane under VFR conditions with less than 30 minutes of reserve 

fuel. Aviation Alternatives’ petition for exemption provides an equivalent level of safety due to 

Aviation Alternatives’ prohibition against the PIC from beginning a flight unless (considering 

wind and forecast weather conditions) there is enough available power for the sUAS model to 

conduct the intended operation and to operate after that for at least 5 minutes or with the reserve 

power recommended by the manufacturer if greater. 

Given the design and technology of the DJI Inspire 1, Phantom 3, and senseFly eBee, Aviation 

Alternatives’ PIC will have access to all relevant information concerning the sUAS model’s battery 

life. The PIC will be able to make an accurate determination as to whether the PIC can comply 

with Aviation Alternatives’ “fuel” requirements for each flight. Consequently, Aviation 

Alternatives’ Flight Conditions and Operating Procedures provide for an equivalent level of safety 

when compared to 14 C.F.R §91.151(a)(1). 

14 C.F.R. §91.405(a): Maintenance Required; 14 C.F.R. §91.407(a)(1): Operation After 

Maintenance, Preventative Maintenance, Rebuilding, Or Alteration; 14 C.F.R. §§ 

91.409(a)(1) and (2): Inspections; 14 C.F.R. 91.417(a) and (b): Maintenance Records

Aviation Alternatives requests exemption from the following F.A.Rs: 14 C.F.R. §91.405(a), which 

provides the owner or operator of aircraft shall have the aircraft inspected pursuant to Subpart E 

of 14 C.F.R; 14 C.F.R. §91.407(a)(1), which provides that no person may operate any aircraft 

having undergone preventive maintenance unless approved for return to service by a person 

authorized under §43.7; 14 C.F.R. §§91.409(a)(1) and (2), which provides that no person may 

operate an aircraft within the preceding 12 calendar months unless an annual inspection has been 

performed; and 14 C.F.R. §§91.417(a) and (b), which provides for the recording of an aircraft’s 

maintenance if the aircraft holds an airworthiness certificate.

Aviation Alternatives’ petition for exemption provides an equivalent level of safety since Aviation 

Alternatives requires compliance with the sUAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the DJI Inspire 1, Phantom 3 Professional, 

Phantom 4, and senseFly eBee. Due to the nature of a sUAS, compliance with certain maintenance 

requirements under Subpart E of 14 C.F.R. are either impossible or cost prohibitive to implement 

when applied to a sUAS. As such, Aviation Alternatives should be exempt from these regulations 

as Aviation Alternatives’ Flight Conditions and Operating Procedures provide for an equivalent 

level of safety when compared to these F.A.R.s.