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January 25th 2016 

Mr. James Williams 

Manager, Flight Standards Service 

Unmanned Aircraft Systems Integration 

Office Federal Aviation Administration 

800 Independence Avenue, 

SW Washington, DC 20591 

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room 12-40 

1200 New Jersey Avenue, 

SE Washington, DC 20590 

Re: Request for Section 333 Exclusion Exemption 

Dear Mr. Williams: 

Fine Aperture Photography, respectfully requests and exemption from several provisions of Title 14 of 

the Code of Federal Regulations (C.F.R.) to permit the use of small unmanned aerial systems (sUAS) to 

assist in the evaluation of real estate property for our clients. This request is motivated primarily by the 

interest in the buying public to be able to inspect photos in size and scope that allows for an intelligent 

decision making process in the evaluation of the propose purchase of real estate. While an exemption 

would not eliminate the current need for in-person visual inspection of the proposed property it would 

allow a broader scope of the evaluation. Accordingly, the grant of an exemption is consistent with 

Congress’ intent, reflected in Section 333 of the FAA Modernization and Reform Act of 2012 

(Modernization Act), 

1. Provided that safe systems be permitted in the national airspace prior to the issuance of final 

regulations governing general use of these systems. 

2. A summary of this request suitable for publication in the Federal Register is provided as 

Appendix A. 

3. Appendix B provides the manufacturers information regarding the design, 

aircraft performance, and fail-safe features. We have provided manufacturer 

information related to operating limitations, normal and emergency 

procedures, and maintenance and inspection procedures. As we add aircraft 

designs, we will update this appendix appropriately.

4. Appendix C provides the Operations Training Manual for flights covered 

under this Exemption Request.

1 P.L. 112-95, 126 Stat 11, February 14, 2012.

2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a 

type of UAS, as a result of its size, weight, speed, operational capacity, proximity to airports and populated areas, 

and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to 

national security.

Fine Aperture Photography 

Jean-Claude Gureghian 

16120 4th Avenue N 

Plymouth MN 5547-3616 

Phone Number: 763-923-4218 

sUas Certificate Number FA33WHTTA 

One DJ1 PHANTOM 2 VISION 

Docket ID: FAA-2015-6024 

Issued 12/21/2015 Expires 12/20/2018
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Background Information

Fine Aperture Photography is in the business of Photography service for Real estate 

brokers, home sellers, commercial real estate brokers, public works department, and City 

communication departments. Fine Aperture Photography Clients look to us for safe 

operations of sUAS. We have developed specific safe UAV Operational Procedures. 

As part of this business procedure Fine Aperture Photography is requesting FAA 

Exemption for sUAS operations for safety, inspection and video capture usage. 

Regulatory Basis for Exemption Request

In addition to the waiver authority provided in §333 of the Modernization Act, the FAA 

may grant an exemption under 49 U.S.C. §44701(f) if it has determined that such an 

exemption is in the public interest. The FAA has imposed a separate requirement in its 

procedural regulations, providing that the petitioner shall explain why granting the 

exemption would not adversely affect safety or how the exemption would provide at least 

an equivalent level of safety as compliance with the underlying regulation. In this case, 

approval of this exemption would advance the public interest by significantly enhancing 

the safety and efficiency of infrastructure operations and by providing the FAA with 

valuable user experience on sUAS in a context with appreciable economic and societal 

benefits. As described more fully below, the requested exemption would permit the 

operation of sUAS under tightly controlled conditions, thus ensuring that operations will 

not have an adverse impact on safety. To the contrary, as explained below, Fine Aperture 

Photography anticipates that use of sUAS will enhance safety in infrastructure operations. 

Granting an Exemption is in the Public Interest. The safety and efficiency of infrastructure 

operations is heavily dependent upon constant analysis of assets, right-of-way, 

infrastructure and other assets/facilities. There are a wide variety of factors that can affect 

conditions and cause problems for infrastructure. Even relatively small objects or minor 

failures can lead to accidents or other incidents causing downtime of infrastructure. 

Extreme weather events can lead to flooding or overheating infrastructure. For example 

earthquakes, landslides, and abandoned vehicles at grade crossings can block 

infrastructure. The potential for sabotage and terrorism – or even just trespassing – are 

also among the many risks that modern infrastructure faces. 

As a result, pursuant to federal regulations and company policy, our client’s maintenance 

employees routinely inspect the infrastructure, such as bridges, tunnels, support 

structures, and signals. At present, this work is done primarily by company personnel in 

motor vehicles, on foot, in specialized equipment. This is often a labor-intensive and 

sometimes arduous job. While our clients do all they can to make these inspections as safe 

as possible, there is an irreducible element of risk involved whenever employees are 

required to go out on structures. Employees may need to climb over or onto structures, 

which can be slippery, rough, and/or exposed to the elements. Some structures, such as 

bridges, are high above the ground. Equipment moving through inspection zones can 

increase risk as well, especially in high-traffic areas. While the use of sUAS for 

supplemental infrastructure and general asset evaluation would not eliminate 

These risks entirely (as it is an additive safety measure), it would reduce the risks to 

employees by allowing for remote aerial review. 

Additionally, the sheer amount of assets and the widely dispersed locations – in many 
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instances far from sizeable population centers – means that visual inspection in all 

instances by company personnel can be inefficient. Aerial analysis by traditional fixed 

wing aircraft is impractical because the required altitudes for safe flight reduce visibility 

below meaningful levels – it is simply not possible to see all asset anomalies from such 

heights. Helicopters present better vantage points; however manned helicopters are much 

more costly, subject to human safety and carry highly explosive jet fuel making them 

impractical for deployment. By using sUAS for supplemental asset evaluation, Fine 

Aperture Photography will be able to substantially upgrade its capacity to detect and 

address issues with the right-of-way and other assets before they become a problem for 

safe operations. Thus, the use of sUAS has the potential to improve efficiency, resulting in 

faster and safer delivery of goods, energy & natural resources vital to the U.S. economy. 

Granting an Exemption will not adversely affect Safety

Fine Aperture Photography notes that there is no applicable standard for an equivalency 

determination. Some have argued that the appropriate standard is that for model aircraft, 

noting that their operations, if conducted for recreational purposes, would fall completely 

within the allowable operations for model aircraft. We believe it is difficult to argue that 

there is sufficient correlation between model operations controlled by the Academy of 

Model Aeronautics and the ones contemplated by Fine Aperture Photography. At the 

same time, it is clear that equivalency cannot be established for traditional, manned civil 

aircraft because the design and use profiles between traditional aircraft and sUAS are 

simply too different. As such, we believe it makes more sense to focus on why the 

contemplated operations would not adversely affect safety, which is all that §11.81(e) 

requires. 

Granting an exemption will not adversely affect safety. Fine Aperture Photography 

contemplates conducting sUAS operations over client owned or controlled land, solely 

during daylight hours, at altitudes well below that which would pose a risk to other 

aircraft. In general, sUAS operations are intended to be conducted in areas distant from 

both congested areas and airports. The nature of operations anticipated by Fine Aperture 

Photography requires that the sUAS be flown at relatively low altitudes and relatively low 

speeds. Fine aperture photography expects that in most instances, the sUAS will be flown 

less than 75 feet from the highest structure along the path of the sUAS. Accordingly, the 

risk of interference with another aircraft is minimal. Fine aperture photography also plans 

to conduct sUAS operations at least three miles from any public airports (including 

heliports). In the event an operation needs to be conducted closer to an airport, Fine 

Aperture Photography will inform the airport operator and airport air traffic control tower 

of the contemplated operation and will comply with any directions issued by air traffic 

control at that airport. 

Approval of exemptions allowing commercial operations of sass in the infrastructure 

aerial inspection industry will enhance safety by reducing risk. Conventional operations, 

using jet or piston power aircraft, operate at extremely low altitudes just feet from the 

subject being inspected and in extreme proximity to people and structures; and present 

the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carrying 

large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must 

fly to and from the inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel carried on board. The sUAS is carried to the inspection site. The 
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sUAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. 

The operation of small UASs, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including 333 Aircraft Exemption Status exempting 

the applicant from conventional aircraft requirements and allowing commercial 

Operations. These lightweight aircraft operate at slow speeds, close to the ground, and in 

a controlled environment and, as a result, are far safer than conventional operations 

conducted with turbine helicopters operating in close proximity to the ground and people. 

Fine Aperture Photography initially intends to use Jean-Claude Gureghian for sUAS 

operations. All operations will be within visual line-of-sight (i.e., no more than 

approximately 0.5 miles from the manipulator of the controls, or pilot in command (PIC)). 

Each PIC will conduct at least three take-offs and landings with the sUAS on which he or 

she is trained every 90 days. PIC’s will establish their qualifications thru a combination of 

aeronautical knowledge, UAS airmanship skills, and verification through testing of flight 

ability before infrastructures operations have commenced. Depending on the type of 

operation, additional ground-based visual observers may be employed as well. These 

observers will be within constant visual line of sight and in constant contact with the PIC. 

The visual observers will assist the PIC in avoiding objects near the sUAS. 

There are no standards for either Private or Commercial sUAS pilot certificates. The safe 

operation and control of the UAS as described in this application does not depend on the 

type of FAA license held by the PIC. Given the restricted and controlled airspace within 

which operations will take place, the key factors needed by the PIC are knowledge of the 

airspace within which the operation will take place and how that airspace fits into the 

National Airspace System (NAS). That knowledge can be and is gained primarily through 

ground school and not through flight training in fixed wing or rotor aircraft, nor is it 

dependent on the acquisition of a commercial or private pilot’s certificate. Those 

certificates demonstrate knowledge of the factors and skills needed for the safe operation 

of those types of aircraft (fixed wing or rotorcraft). It cannot be assumed that a 

commercial pilot, approved to operate a helicopter or fixed wing aircraft, has the skill or 

ability to safely operate a small unmanned aerial vehicle, operating at 400 AGL or lower, 

within strictly controlled pre-approved airspace. Besides knowledge of airspace 

regulations, dexterity in the control and operation of the sUAS acquired from actual 

operation of the aircraft is the most important factor in establishing an equivalent level of 

safety. 

If the PIC has acquired the necessary knowledge of airspace requirements, the relevant 

issues are (1) where the aircraft will be flown, (2) the size of the aircraft relative to what is 

being used today to accomplish the same mission, and (3) what precautions will be taken to 

ensure the safety of those in the area of operation. We propose that the PIC has at least an 

FAA Private Pilots Certificate and a Class III medical; the aircraft be operated within a 

secure environment; and that no one be allowed to enter the secure environment unless they 

are part of the operation, have been fully briefed of the risks prior to operation of the sUAS, 

and have consented to the risks associated with being in the operating area. Should there be 

a mishap, the sUAS being flown pose significantly less of a threat than the helicopters and 

fixed wing aircraft now being employed because they are a fraction of the size, carry no 
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flammable fuel, do not carry crew or passengers, and pose an infinitesimal risk to others. 

This is in stark contrast to conventional aircraft that are flown to the site, carry explosive 

fuel, carry passengers and crew, and operate in a much larger area. 

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots who 

are also qualified to fly the type of sUAS that are utilized for infrastructure image-capture 

operations. There are even fewer commercial pilots that can fly these sUAS – to the point 

that to do both is considered rare. Assuming that it is unlikely for a company to find a 

pilot that has both qualifications that company would either have to source a qualified 

sUAS pilot to train and obtain a commercial certificate, or find a commercial certificated 

pilot who would be willing to learn to fly a sUAS to the competency level required for 

professional use. 

Minimum requirements for the PIC include: 

1) A minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft 

pilot and at least 10 hours logged as a sUAS pilot with a similar sUAS type (single 

blade or multirotor); YES 

2) A minimum of 5 hours as sUAS pilot with the make and model of sUAS to be 

utilized for operations under the exemption and - 3 take offs and landings in the 

preceding 90 days; - 

Fine Aperture Photography intends to use commercially available sUAS Components 

for sUAS. These sUAS systems will be tested for quality & safety in our test facility 

before being deployed to the field. The sUAS is less than 55 lbs. fully loaded, carries 

neither a pilot nor passenger, and operates exclusively within a secured area. We have a 

routine maintenance schedule to verify that the sUAS will remain in safe and 

operational condition. Please see Appendix B, for Specific Types of sUAS. 

Notes Regarding: 14 C.F.R. Part 21, Subpart H 

In accordance with the statutory criteria provided in Section 333 of PL 112--‐95 in 

reference to 49 USC 44704, and in consideration of the size, weight, speed, and 

limited operating area associated with the aircraft and its operation, we request that 

this aircraft exemption meets the conditions of Section 333. Therefore, if granted 

Section 333 relief of 14 CFR part 21, and any associated noise certification and 

testing requirements of part 36, is not necessary. 

Notes Regarding: 14 C.F.R. § 45.23 (b). Marking of the Aircraft 

Given the size of the sUAV, two-inch lettering will be impossible. UA will be identified 

by serial number, registered in accordance with 14 CFR part 47, and have identification 

(N--‐Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be 

as large as practicable. 

Notes Regarding: 14 CFR § 91.7(a) Civil Aircraft Airworthiness 

Fine Aperture Photography’s request is based on the fact that no airworthiness certificate 

will be issued for the UAS. Fine Aperture Photography UAS will not require an 

airworthiness certificate in accordance with 14 CFR part 21, Subpart H. Based on the fact 

that an airworthiness certificate will not be issued, exemption from § 91.7(a) is not 

necessary. 
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Notes Regarding: 14 CFR § 91.9(b)(2) Civil aircraft flight manual, marking & placard 

Certifications required, the original intent of these regulations was to display an aircraft’s 

airworthiness, certification, and registration documents so they would be easily available 

to inspectors and passengers. Based on the FAA Memorandum subject “Interpretation 

regarding whether certain required documents may be kept at an unmanned aircraft’s 

control station,” dated August 8, 2014, the requested relief from 14 CFR §§ 91.9(b) (2) 

and 91.203(a) and (b) is not necessary. 

Notes regarding: §91.109 Flight instruction; Simulated instrument & certain flight tests 

Small UASs, by their design, do not have fully functional dual controls. Flight control is 

accomplished through the use of a control box that communicates with the aircraft via 

radio communications. Aircraft being considered for use by Fine Aperture Photography 

allow the UAS Instructor to place the aircraft into ‘loiter’ mode (fixed altitude stationary 

hold). In the event of the student losing control, the UAS Instructor can quickly and via 

alternate equipment (equipment not in the hands of the student) place the aircraft into a 

mode that then allows the instructor to bring the aircraft back into control and back to the 

pre- determined and/or safe landing location. 

Fine Aperture Photography does not describe training scenarios in which a dual set of 

controls would be utilized or required, i.e. dual flight instruction, provided by a flight 

instructor or other company-designated individual that would require that individual to 

have fully functioning dual controls. Rather, Fine Aperture Photography evaluates the 

qualification of its PICs based on their experience with the UAS to be operated and 

verifies through testing, in lieu of formalized training. As such, Fine Aperture 

Photography does not seek relief from 14 CFR § 91.109. 

Notes Regarding § 14 CFR 91.119(b) 

Relief from § 14 CFR 91.119(b), operation over congested areas, is not applicable, 

because the Fine Aperture Photography’s operations will only be conducted within the 

secured area described herein. 

FINE APERTURE PHOTOGRAPHY Safety Operations & Procedures Overview:

Technology Considerations:

Best-in-class, tried and proven technologies that are in advanced iterations. 

Software from highly-reputable industry partners will include features -

1. Auto descent (landing) if communication signal were to be severed. If 

the sUAS loses communications, the sUAS will have capability to return to 

a pre-determined location within the Security Perimeter and land.

2. Auto descent (landing) if battery were to drop lower than nominal level.

3. Flights will be terminated at 25% battery power reserve.

4. Live video for operator gives real-time positioning feedback. In other 

words, we can monitor the scene from the vehicle's perspective for collision 

avoidance, and to maintain spatial orientation.

5. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.

6. On-Screen-Display (OSD) contains operating information to ascertain 

vehicle health at all times: speed, altitude, number of GPS satellites 
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(when available), heading and voltage.

7. GPS lock supplies for return-to-home (RTH). Should Command and 

Control (C2) link failures occur (highly improbable), vehicle returns 

automatically to the point of launch.

8. Altitude information will be provided to the sUAS pilot via a digitally 

encoded telemetric data feed, which downlinks from the aircraft to a groundbased on-screen display. This altitude information will be generated by 

equipment installed on board the aircraft, using GPS triangulation, or 

digitally encoded barometric altimeter, or radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude initiation point will 

be established and confirmed for accuracy by the pilot.

Mechanical/Physical:

1. We will fly line-of-sight (LOS) only. The vehicle will always remain in 

direct LOS to the pilot, thus eliminating the concern of signal severance 

(flying behind objects/walls).

2. The sUAS will weigh less than 55 lbs. and travel at less than 50 knots.

3. Batteries should far exceed the capacity required for actual flight time.

4. Flights will be operated at an altitude of no more than 400 feet AGL.

5. Fireproof bags for storage and charging of high capacity Lip batteries onsite.

6. UA operated under this exemption will be marked in accordance with 14 

CFR part 45 or as otherwise authorized by the FAA.

Personnel:

1. Spotters ensure safe operation and act as a redundant set of eyes for 

operators (pilot, gimbal op, director)

2. Radio spectrum analysis for interference on the frequencies utilized for 

vehicle control/communication.

3. A briefing will be conducted in regard to the planned sUAS operations 

prior to each day’s activities. It will be mandatory that all personnel who 

will be performing duties within the boundaries of the safety perimeter be 

present for this briefing.

4. The operator will obtain the consent of all persons involved in the sUAS 

operations and ensure that only consenting persons will be allowed within 100 

feet of the flight operations.

5. Observer and pilot will at all times be able to communicate by voice.

6. Written and/or oral permission from the relevant property holders will be 

obtained.

7. Pilot and observer will have been trained in operation of UAS 

generally and received up-to-date information on the particular UAS to 

be operated.

Operations:

1. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), including energy 

source(s) and equipment. Operations authorized by this petition of exemption are limited to 

the following aircraft described in Appendix B. Proposed operations of any other aircraft 
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will require a new petition or a petition amendment to this request.

2. The UA may not be flown at a ground speed exceeding 50 knots. 

3. Flights must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operator’s manual. All altitudes 

reported to ATC must be in feet AGL. 

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

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued medical certificate. 

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

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

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

6. The operator’s manual included as Appendix C and this petition of exemption must 

be maintained and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations in this exemption and the procedures 

outlined in the operator’s manual, the conditions and limitations herein take precedence 

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

its operator’s manual. 

The operator may update or revise its operator’s manual. It is the operator’s responsibility 

to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment. If the operator determines that any update or 

revision would affect the basis for which the FAA grants this petition for exemption, then 

the operator must petition for amendment to their exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operator’s manual. 

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for 

safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station, if utilized, must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

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

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

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

requirements and procedures for a functional test flight and aircraft record entry must be 

added to the operator’s manual. 

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

overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft 

maintenance/component/overhaul, replacement, and inspection/maintenance requirements 
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must be established and identified in the operator’s manual. At a minimum, requirements 

for the following must be included in the operator’s manual: 

a. Actuators / Servos; 

b. Transmission (single rotor); 

c. Power plant (motors); 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 

g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

i. Ground control station (if used); and 

j. Any other components as determined by the operator; 

10. The Pilot in Command (PIC) must possess at least a private pilot certificate and at 

least a current third-class medical certificate. 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. 

11. Prior to operations conducted for the purpose of infrastructure inspections, the PIC 

must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a 

minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at 

least 10 hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). 

Prior documented flight experience that was obtained in compliance with applicable 

regulations may satisfy this requirement. Training, proficiency, and experience-building 

flights can also be conducted under this petition of exemption to accomplish the required 

flight cycles and flight time. During training, proficiency, and experience-building flights, 

all persons not essential for flight operations are considered nonparticipants, and the PIC 

must operate the UA with appropriate distance from nonparticipants in accordance with 14 

CFR § 91.119. 

12. Prior to operations conducted for the purpose of infrastructure inspection, the PIC 

must have accumulated and logged, in a manner consistent with 14 CFR § 61.51(b), a 

minimum of five hours as UAS pilot operating the make and model of UAS to be utilized 

for operations under the exemption and three take-offs and three landings in the preceding 

90 days. Training, proficiency, experience- building, and take-off and landing currency 

flights can be conducted under this petition of exemption to accomplish the required flight 

time and 90 day currency. During training, proficiency, experience-building, and take-off 

and landing currency 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 CFR § 91.119. 

13. Prior to any flight operations authorized by this petition of exemption, the PIC and VO 

must have successfully completed a qualification process, as outlined in the operator’s 

manual. As this is a requirement stipulated by the operator, the test must be developed and 

implemented by a qualified person designated at the sole discretion of the operator. A 

record of completion of this qualification process must be documented and made available 

to the Administrator upon request. 

14. Prior to operations conducted for the purpose of infrastructure inspection, a flight 
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demonstration, administered by an operator-approved and -qualified pilot must be 

successfully completed and documented. This documentation must be available for review 

upon request by the Administrator. Because the knowledge and airmanship test qualifications 

have been developed by the operator, and there are no established practical test standards that 

support a jurisdictional FAA FSDO evaluation and approval of company designated 

examiners, the petitioner will conduct these tests in accordance with the operator’s manual.

15. The UA may not be operated directly over any person, except authorized and 

consenting personnel, below an altitude that is hazardous to persons or property on the 

surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety 

mitigations for authorized and consenting personnel. At all times, those persons must be 

essential to the operations.

17. Regarding distance from nonparticipating persons, the operator must ensure that no 

persons are allowed within 500 feet of the area except those consenting to be involved and 

necessary for the infrastructure inspection operations. This provision may be reduced to no 

less than 200 feet if it would not adversely affect safety and the Administrator has approved it. 

For example, an equivalent level of safety may be determined by an aviation safety 

inspector’s evaluation of the infrastructure inspection area to note terrain features, 

obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating 

persons (observers, the public, news media, etc.) from debris in the event of an accident.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance 

with the operator’s manual.

19. The UAS must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operator’s manual.

20. Each UAS operation must be completed with 25% battery power remaining.

21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under this petition 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.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N-Number) 

markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as 

practicable.

23. The operator must develop procedures to document and maintain a record of the UAS 

maintenance, preventative maintenance, alterations, status of replacement/overhaul 

component parts, and the total time in service of the UAS. These procedures must be added 

to the operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins.
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25. The operator must develop UAS technician qualification criteria. These criteria must be 

added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include 

the following requirement: The preflight inspection must account for all discrepancies, i.e. 

inoperable components, items, or equipment, not covered in the relevant preflight 

inspection sections of the operator’s manual.

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. At least three days before scheduled infrastructure inspection, the operator of the UAS 

affected by this exemption must submit a written Plan of Activities to the local FSDO with 

jurisdiction over the area of proposed infrastructure inspection. The 3-day notification may be 

waived with the concurrence of the FSDO. The plan of activities must include at least the 

following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS infrastructure

Inspection operations conducted under this petition of exemption;

c. Name and phone number of the person responsible for the on-scene 

operation of the UAS;

d. Make, model, and serial or N-number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the infrastructure 

inspection event;

f. A statement that the operator has obtained permission from property 

owners and/or local officials to conduct the infrastructure inspection event; 

the list of those who gave permission must be made available to the inspector 

upon request;

g. Signature of exemption-holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which infrastructure inspection will be 

conducted and the altitudes essential to accomplish the operation.

29. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating. These documents 

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

30. The UA must remain clear and yield the right of way to all other manned operations and 

activities at all times (including, but not limited to, ultralight vehicles, parachute activities, 

parasailing activities, hang gliders, etc.).

31. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under 

special visual flight rules (SVFR) are not authorized.

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

33. 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.
12 

34. The UA may not operate in Class B, C, or D airspace without written approval from the 

FAA. The UA may not operate within 5 nautical miles of the geographic center of a nontowered airport 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.

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

boundaries of the operational area as defined by the applicable COA must be reported to the 

FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the 

National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web 

site: www.ntsb.gov. Further flight operations may not be conducted until the incident, 

accident, or transgression is reviewed by AFS-80 and authorization to resume operations is 

provided.

Support for Petition for Exemption

In accordance with the procedural requirements of 14 C.F.R. §11.81, Fine Aperture 

Photography provides the following information: 

Contact Information:

Jean-Claude Gureghian 

Fine Aperture Photography 

16120 4th Avenue N 

Plymouth MN 5547-3616 

Phone Number: 763-923-4218 

jcgureghian@gmail.com 

Regulatory Provisions from which FINE APERTURE PHOTOGRAPHY seeks an 

Exemption 

Fine Aperture Photography believes it may need an exemption from the following 

provisions to conduct the contemplated operations. In some instances, relief is needed 

because relief from another provision renders compliance with the regulation at hand 

infeasible. 

333 Aircraft Exemption Status 14 C.F.R. 

§61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) (1) & (2) 

14 C.F.R. §91.417(a) & (b) 

Fine Aperture Photography believes an exemption is only needed from the above-listed 

regulatory provisions. To the extent that the FAA believes that additional relief is required 

for Fine Aperture Photography to conduct the operations described here, we request an 

exemption from any such regulatory provisions as well.3 

__________________________________________ 

3 For example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as applicable”. 

Since none of the underlying requirements (e.g., inspection intervals) can be met and will require an exemption, 

Fine Aperture Photography believes a separate exemption should not be required for §91.417(a).

The Extent of Requested Relief and the Reasons Relief is Needed
13 

Section 333 Aircraft Exemption Status:

Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the 

Requirement for an airworthiness certificate based on a consideration of the size, 

weight, speed, operational capability of the particular UAS, as well as its proximity to 

airports and populated areas. An analysis of these criteria demonstrates that the sUAS 

operated without an airworthiness certificate in the areas and under the conditions 

contemplated by Fine Aperture Photography will be at least as safe, or safer, than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness 

certificate without the conditions proposed in this request.

The sUAS is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, and 

operates exclusively within a secured area. Unlike other civil aircraft, operations under 

this exemption will be tightly controlled and monitored by the operator and observer. 

Operations will be conducted in compliance with the FAA and with local public 

safety requirements to provide security for the area of operation as is now done with 

conventional equipment, infrastructure, bridge and out building evaluation. These 

safety enhancements provide an expanded degree of safety to the inspectors over 

conventional operations. Lastly, application of these same criteria demonstrates that 

there is no credible threat to national security posed by the sUAS, due to its size, 

speed of operation, location of operation, lack of explosive materials and inability to 

carry a substantial external load.

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and 

Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, 

operational capability, and proximity to airports and populated areas of the particular 

sUAS. In all cases, an analysis of these criteria demonstrates that the UAS operated 

without an airworthiness certificate, in the restricted environment and under the 

conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed 

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

14 C.F.R. §61.113(a) and (b) 

§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person 

who holds a private pilot certificate may act as pilot in command of an 

aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as pilot in command of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command 

of an aircraft in connection with any business or employment if: 

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

Fine Aperture Photography anticipates initially using one person specially trained 
14 

staff to conduct the sUAS operations. While these individuals will not hold commercial 

pilot licenses. The sUAS will not carry property for compensation or hire since they will 

be used solely to assist in evaluation of the infrastructure, equipment, right-of-way, 

assets, bridges, tunnels and out-buildings in furtherance of Fine Aperture Photography’s 

client’s primary business, the successful operation of a infrastructure; however, the 

employees’ operation of the sUAS will not be incidental to their employment with Fine 

Aperture Photography, and they will be compensated for such work. Without an 

exemption, the pilot would be required to hold a commercial pilot certificate under 

§61.133. However, the risk associated with the contemplated operations is less than the 

risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the 

permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within 

a geographical envelope under the sole control of Fine Aperture Photography clients. 

Accordingly, the risk would be limited to Fine Aperture Photography personnel, who will 

be appropriately outfitted in safety gear, and Fine Aperture Photography client’s property 

on the ground. Requiring a commercial pilot certificate would provide no appreciable 

safety benefit and would needlessly impose additional cost on Fine Aperture 

Photography Because the contemplated operations would not comply with §61.113(b) (1) 

and none of the other exceptions to paragraph (a) apply, relief is needed from both 

paragraphs (a) and (b). 

14 C.F.R. 91.119(c) 

§91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an 

aircraft 

Below the following altitudes: 

*** 

(c) Over other than congested areas. An altitude of 500 feet above the surface, 

except over open water or sparsely populated areas. In those cases, the aircraft 

may not be operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

***** 

Fine Aperture Photography submits that the only relief it requires from §91.119 

is from the minimum altitudes listed in paragraph (c). Relief is required from paragraph 

(c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is 

insufficiently distinct to be meaningful. Since operations at this altitude also pose a 

heightened risk of collision with another aircraft, safety can only be assured through the 

grant of an exemption. The anticipated rotorcraft operations should be adequately 

addressed by paragraph (d) (1). Additionally, relief should not be needed from paragraph 

(a) because an emergency landing of the aircraft due to a power failure will not create an 

undue hazard to persons or property on the surface. As noted in the explanation of why 

an exemption will not adversely affect safety, Fine Aperture Photography clients has 

exclusive use of the land over which the sUAS will be operated, and public access is 

restricted. It also has exclusive use of significant portions of land adjacent to the 

infrastructure and structures that will be the objects of evaluation and analysis. Fine 

Aperture Photography Clients tightly control access to land and have the ability to assure 

that no individuals unassociated with the planned operations are on the affected land. As 

such, the risk of injury is minimal. Fine Aperture Photography does not contemplate 
15 

conducting operations over congested areas, so relief is not requested from paragraph 

(b). 

14 C.F.R. 91.121 

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising 

altitude by reference to an altimeter that is set “...to the elevation of the departure 

airport or an appropriate altimeter setting available before departure.” 

***** 

As the sUAS may not have a barometric altimeter, but instead a GPS altitude read 

out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric 

data feed, which downlinks from the aircraft to a ground-based on-screen display. This 

altitude information will be generated by equipment installed on board the aircraft, using 

GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any 

combination thereof. Prior to each flight, a zero altitude initiation point will be established 

and confirmed for accuracy by the pilot.

14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane 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 – 

(1) During the day, to fly after that for at least 30 minutes. 

(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. 

***** 

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve 

fuel does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could 

run out of fuel in the event it has to be flown to an alternate airport or circle the planned 

airport in the event of unanticipated conditions. Fine Aperture Photography does not 

intend to use the sUAS for point-to-point flights and will not operate the sUAS beyond 

visual line of sight. Nor will the sUAS require an airport in order to land. Rather, Fine 

Aperture Photography will operate the sUAS using pre-planned flight paths (taking into 

account weather conditions) designed to allow the sUAS to fly to the point of intended 

landing. As such, there is no need for a time- based excess fuel requirement. Rather it 

should be sufficient to require only as much additional excess flight capacity as 

necessary to safely land the sUAS. We believe that a 25% battery reserve is more than 

sufficient to meet this objective. 

14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1) & (2) and 14 C.F.R. 91.417(a) & (b)

§91.405 Maintenance required.

Each owner or operator of an aircraft – 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and 
shall between requjred inspections, except as provided in paxagraph (c) ofthis

section, have discrcpancies rcpaired as prescribed in part 43 ofthis chapter;

**rt* *

S91,407 Operation after maidtenance, preventive maintenance,

rebuilding, or alteration.

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

rebuilding, or alteration unless -

(1) It has been approved for retum to seflice by a person authorized under

S43.7 ofthis chapter;

S91.409 Inspections.

(a) Except as provided in paragraph (c) ofthis 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 ofthis chapter and has

been approved for retum to seNice by a person authorized by $43.7 ofthis

chapter; or

(2) An inspection for the issuance ofan airworthiness certificate in

accordance with part 2l ofthis chapter.

*,r.*'i *

S91.417 (a) & (b)

* +***

Fine Aperture Photography believes that an exemption from these three

maintenance rcquirements is appropriate because the IAA has not developed

maintenance standards that would allow an operator to meet the part 91 maintenance

requirements. In particular, there are no individuals authorized by the FAA to approve a

SUAS for rctum to seftice undet

$9 1 .407(a) or to conduct the idtial airworthiness and annual return to service inspections

required by $91.409(a). Fine Aperture Photography will maintain the aircraft as

instructed in the owner's manual and ASTM F2909, where applicable, and will not

operate the aircraft until it has reasonably determined that any needed repafus have been

made. However, because ofthe technical impossibility ofmeeting the requirements of

$$91.405(a), 407(a), 409(a) and 417(a) & (b), we believe an exemption from these

provisions is appropriate.

Please do not hesitate to contact me at the phone number or via the e-mail address

provided above should you have any questions or concerns.

Respectfu lly submitted,

Fine Aperture Photography CEO

Appendix A

Summary for Federal Register Publication

16
17 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register should the FAA determine that publication is needed? 

Petitioner: Fine Aperture Photography 

Sections of 14 C.F.R. Affected: 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.119(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) 

14 C.F.R. §91.417(a) & (b) 

Description of Relief Sought: 

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 

C.F.R., 61.113(a) & (b)), 91.119(c), 91.121, 91.151, 91.405(a), 91.407(a), 91.409(a), 

and 

91.417(a)&(b) to conduct sUAS operations over FINE APERTURE PHOTOGRAPHY 

Client’s owned or controlled land, solely during daylight hours, to assist in the safe 

evaluation and analysis of infrastructure and operations. In general, sUAS operations are 

intended to be conducted in areas remote from both congested areas and airports. The 

nature of operations anticipated by FINE APERTURE PHOTOGRAPHY requires that 

the sUAS be flown at relatively low altitudes. FINE APERTURE PHOTOGRAPHY 

expects that in most instances, the sUAS will be flown less than 75 feet from the highest 

structure along the path of the sUAS and in no instances will be flown higher than 400 

feet above the ground. Accordingly, the risk of interference with other aircraft is 

minimal. 

Appendix B

Specific type(s), make, model and specifications 

PHANTOM 2 VISION+

AIRCRAFT 

Supported Battery DJI 5200mAh Lip Battery 

Weight (Battery & Propellers included) 1242g 

Hover Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity 200°/s 
18 

Max Tillable Angle 35° 

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s 

Max Flight Speed 15m/s (Not Recommended) 

Diagonal motor-motor distance 350mm 

CAMERA 

Operating Environment Temperature 0°C-40°C

Sensor size 1/2.3" 

Effective Pixels 14 Megapixels 

Resolution 4384×3288 

HD Recording 1080p30 & 720p

Recording FOV 110° / 85° 

RANGE EXTENDER 

Operating Frequency 2412-2462MHz

Communication Distance (open area) 500-700m 

Transmitter Power 20dBm 

Power Consumption 2W 

GIMBAL 

Working Current Static : 750mA; Dynamic : 900mA

Control Accuracy ±0.03° 

Controllable Range Pitch : -90°-0° 

Maximum Angular Speed Pitch : 90°/s 

REMOTE CONTROL 

Operating Frequency 5.728 GHz-5.85 GHz 

Communication Distance (open area) CE Compliance: 400m; FCC Compliance: 800m 

Receiver Sensitivity (1%PER) -93dBm 

Transmitter Power CE Compliance: 25mW; FCC Compliance: 100mW

Working Voltage 120 mA@3.7V 

Built-in Lip Battery Working Current/Capacity 3.7V, 2000mAh 

RANGE EXTENDER 

Operating Frequency 2412-2462MHz

Communication Distance (open area) 500-700m 

Transmitter Power 20dBm 

Power Consumption 2W 
19 
20 

Appendix C

Please see the attached Confidential & Proprietary: Drone Fleet & Aerospace Management, Inc. 

Flight Operation & Procedures Manual (FOPM) 

#2 --- DJI Phantom 2

See Attached Flight Manuals:

DJI Phantom 2 User Manual

NAZA---Flight Control System_v1.26 

CAUTION

This product is not suitable for people under the age of 18. Please carefully read the "Quick Start Guide", "User 

Manual", "Disclaimer", and fully watch the tutorial videos before using the PHANTOM. Users should make every 

effort to fly regularly in order to improve their flight skills as an advanced level pilot. Please fly safely and 

responsibly. 

Please follow these guidelines prior to flying your Phantom:

1. Always turn on the Remote Controller prior to turning on the Phantom. 

2. Toggle SL, S2 to the top. 

3. Be sure there are no distractions when you’re flying. 

4. When starting your training, be sure you are in a very large open area. Be aware of your surroundings. 

Always fly in areas void of obstacles and away from traffic and people. 
21 

5. Before actually taking off, be sure you have calibrated the compass and you have full GPS satellite 

reception (Slow Continuous Green Flashing). 

6. Never fly higher than 400 feet. 

7. During training, stay behind your imaginary barrier and never fly behind yourself. (;) When in doubt, 

gently pull down on the throttle stick and land. 

8. DO NOT PANIC. 

CAUTION

FORBIDDEN

NO TOUCH

Nose

 Tail 
22 

(

Basic Flight Maneuvers 

Rotate left, rotate right but try to keep the battery pointed at yourself. 

,, A

I

I

Basic Flight Maneuvers 

Take off and land with battery facing you.

Hover in one spot keeping battery facing you, 

make sure to control Left/Right/Forward/Back 

movement
23 

Mark a spot (8) on the ground oft away from the Phantom's 

Slowly fly forward/back/left/right with back of Phantom pointed at your 

Hlf. 

Fly forward to a spot 2030 feet away. 

Then fly back keeping the battery pointed at yourself. 

take off point. Hover and fly towards that spot and land at 

the spot (B) Then go back into a hover and bring the 

Phantom back to its original position (A) and land again. 
24 

; '

_

Basic Flight Maneuvers

Do the same as above but fly the 4 point box formation counter-clockwise. 

Be sure to be in control and stop and hover in place at each point before 

proceeding to the next point.

_ _ _ _ _ ...,.._

,

"'"

/ '

_ _

take-off 

.
25 

, ' ,

Skilled Flight Maneuvers 

In a hover, starting with the battery pointed at yourself, rotate 360 degrees 

counter-clockwise. 

Starting with the battery pointed at yourself, go into a hover. Then rotate 

the Phantom 90 degrees facing left, and fly a 4 point square re box 

formation going clockwise. Be sure to be in control and stop and hover in 

place at each point before proceeding to the next point.

'

'

'

'

'

'

'
26 

Skilled Flight Maneuvers 

Starting with the battery pointed at yourself, go into a hover. Then rotate the Phantom 90 degrees facing right, 

and fly a 4 point square box formation going counter-clockwise.

Be sure to be in control and stop and hover in place at each point before proceeding to the next point.

Hover with the aircraft nose pointed at yourself and try to keep the Phantom in one place.
27 

Fly a circle and keep the aircraft nose pointed towards 

you. Be sure to keep the altitude the same and the circle as 

uniform as possible. 

Advanced Flight Maneuvers 

Fly a 4 point square box clockwise and rotate the phantom in the direction of 

travel.

- - - - - - - I

''

'

- - - - - - - - - -

'

-

 

Fly a 4 point square box counter-clockwise while 

keeping the aircraft nose facing in your direction. 

Advanced Flight Maneuvers
28 

Fly a circle counter-clockwise and keep the aircraft Nose pointed in the direction of travel. Be sure to 

keep the altitude the same and the circle as uniform as possible.

---:

Fly a circle counter-clockwise with the aircraft nose pointed at the center of the circle. 

Be sure to keep the altitude the same and the circle as uniform as possible.
29 

Advanced Flight Maneuvers <** *)

Fly a figure 8 without rotating the Phantom. Be sure to keep the altitude 

the same and the circle as uniform as possible.

Fly a Figure 8 with the aircraft nose of the Phantom pointed 

in the direction of travel. Be sure to keep the 

Altitude the same and the circle as uniform as possible.

Fly Figure 8 patterns while experimenting with different orientations. For 

example, aircraft nose always pointed in a given direction or opposite/left/right 

the direction of travel, etc. Be sure to keep the altitude the same and the circle 

as uniform as possible.
30 

Emergency Situations

Return Home & Land Mode

Be sure you are in a large open area. Before you take off, make sure you have 

a good GPS lock by ensuring your LED indicators are flashing Green. Fly the 

Phantom at least 50ft away from your take off point. Turn off the Remote 

Controller. The Phantom will enter its failsafe Return-To-Home Mode. Let the 

Phantom finish its routine and land itself within 2 meters of the take off point.

15 meters

Intercepting Return Home & Land Mode

Be sure you are in a large open area. Before you take off, make sure you have a 

good GPS lock by ensuring your LED indicators are flashing Green. Fly the 

Phantom 50ft away from your take off point. Turn off the Remote Controller. The 

Phantom will enter its failsafe Return-To-Home Mode. When the Phantom is 

returning home, you can intercept RTH Mode by switching the SL Switch from the 

top position to the middle or lower position, then continue flying the Phantom.