UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

CHRISTOPHER L MEYER

FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1),91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIALOPERATION OF 

DJI PHANTOM 3 PROFESIONAL

UNMANNEDAIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on July 29, 2015

Christopher L Meyer

38619 Wakefield Ct.

Northville, Michigan 48167
TABLE OF CONTENTS

Page

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

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

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

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

BASIS FOR PETITION....................................................................................4

NAME AND ADDRESS OF PETITIONER........................................................................5

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CHRISTOPHER L MEYER 

SEEKS EXEMPTION........................................................................................................6

THE EXTENT OF RELIEF CHRISTOPHER L MEER SEEKS AND THE REASON

HE SEEKS THE RELIEF..................................................................................8

THE REASONS WHY GRANTING CHRISTOPHER L MEYER’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ....................................................................................10

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY....................................................................................12

CONCLUSION................................................................................................................21
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
SUMMARY

Christopher L Meyer seeks exemption from the requirements of 14 C.F.R §§ 61.113(a)

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

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of 

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit

Christopher L Meyer to operate an Unmanned Aircraft Systems (UAS) for the 

commercial purpose of conducting aerial video and photography and training. Such 

commercial ventures include weddings, family photography, demonstrations,

promotional advertisement, special events, sporting events, inspections, and real estate 

over certain areas of the United States. This exemption would also include training 

students on how to safely operate Unmanned Aircraft Systems including the laws and 

regulations and how they apply to UAS’s for commercial applications.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Christopher L Meyer, I am a 36 year old High School Teacher and Flight 

Instructor. I am also a former Regional Airline Pilot with over 5,000 hours of total time as 

a commercially rated pilot. I am interested in using UAV’s for multiple commercial 

ventures. I am also interested in adding a credited course to our high school curriculum 

to include all aspects of UAV’s.

BACKGROUND

Christopher L Meyer seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Phantom 3 Professional is a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet or smart phone systems. The DJI Phantom 3 Professional has a maximum gross 

weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width 

of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The 

DJI Phantom 3 Professional is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. The DJI Phantom 3 Professional will be 

operated by Christopher L Meyer and will be registered in accordance with 49 U.S.C. 

44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and 

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

BASIS FOR PETITION

Petitioner, Christopher L Meyer, pursuant to the provisions of the Federal Aviation

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012

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

petitions the Administrator to commercially operate the DJI Phantom 3 Professional 

UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

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

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

with the unmanned aircraft and its operation, Christopher L Meyer operation of DJI 

Phantom 3 Professional UAS meets the conditions of FMRA Section 333 and therefore, 

will not require an airworthiness certificate in accordance with 14 C.F.R. Part
21, Subpart H. Accordingly, Christopher L Meyer requests relief from Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections 

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

certificate. Christopher L Meyer submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Christopher L Meyer will perform 

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

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

Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, 

Christopher L Meyer will document and maintain all maintenance records for the DJI 

Phantom 3 Professional UAS.

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

pilot privileges and limitations: Pilot in command, is requested by Christopher L Meyer

to the extent necessary to allow a Pilot in Command (PIC) holding a pilot certificate, as 

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

flight- hour and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 3 Professional UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Christopher L Meyer seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Professional UAS do not require an 

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

Christopher L Meyer submits that he will ensure that the DJI Phantom 3 Professional 

UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Phantom 3 Professional Instruction Manual), and that the aircraft is in a condition for 

safe flight. Christopher L Meyer also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS will

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

Phantom 3 Professional UAS will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from 

the UA to the GCS for active monitoring of the flight path. This altitude information, 

combined with Christopher L Meyer’s operation of the DJI Phantom 3 Professional UAS

within visual line of sight, at or below 400 feet

AGL, will ensure a level of safety equivalent to Section 91.121. Additionally, 

Christopher L Meyer seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Christopher L Meyer submits that 

safety will not be affected by operation of the DJI Phantom 3 Professional UAS during 

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), 

with enough battery power to fly for a total duration of approximately 13.5 minutes to the 

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

at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Christopher L Meyer provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:
Christopher L Meyer

38619 Wakefield Ct.

Northville, Michigan 48167

(734) 730-1612

CMeyer789@Hotmail.com

B. The Specific Sections Of 14 C.F.R. From Which 

Christopher L Meyer Seeks Exemption.

1. Christopher L Meyer Seeks Exemption From The Requirements Of Section

61.113(a) and (b).

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

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

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

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor 

may that person, for compensation or hire, act as PIC of an aircraft.

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

with any business or employment if—

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

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

2. Christopher L Meyer Seeks Exemption From The Requirements Of Section

91.7(a).

Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states the following:

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

3. Christopher L Meyer Seeks Exemption From The Requirements Of Section

91.121.

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

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

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

operating--

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

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

nautical miles of the aircraft;

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

the current reported altimeter setting of an appropriate available station; or

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

airport or an appropriate altimeter setting available before departure.

4. Christopher L Meyer Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless

(considering wind and forecast weather conditions) there is enough fuel to fly to the first 

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

least 20 minutes.

5. Christopher L Meyer Seeks Exemption From The Requirement Of Section
91.405(a).

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

Each owner or operator of an aircraft—

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

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

discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Christopher L Meyer Seeks Exemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter[.]

7. Christopher L Meyer Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

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

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

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

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

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

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

21 of this chapter.

8. Christopher L Meyer Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).

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

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of 

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft.

The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work 

performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return 

to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and 

appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis.
(iv) The current inspection status of the aircraft, including the time since the last 

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives 

including, for each, the method of compliance, the

AD or safety directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration 

to the airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the 

work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this 

chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

C. The Extent Of Relief Christopher L Meyer Seeks And The 

Reason Christopher L Meyer Seeks The Relief.

1. Extent Of Relief Christopher L Meyer Seeks And The Reason Christopher L 

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

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a private pilot or higher level certificate, as well as a current and valid airman 

medical certificate, and who has met certain flight-hour and currency requirements, to 

conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that business or 

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

compensation or hire.

As set forth more fully below, Christopher L Meyer submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3

Professional UAS unless that PIC has met certain flight-hour and currency 

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

Phantom 3 Professional UAS in a manner consistent with the operations and

specifications as described in this exemption, including evasive and emergency 

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

and structures.

Further, Christopher L Meyer submits that all flights of the DJI Phantom 3 Professional 

UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to 

Christopher L Meyer’s business; and (2) will not carry passengers or property for 

compensation or hire.
2. Extent Of Relief Christopher L Meyer Seeks And The Reason Christopher L 

Meyer Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested tothe extent 

required to allow Christopher L Meyer to determine that the DJI Phantom 3

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

UAS is in compliance with the operating documents (i.e., the Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual).

Christopher L Meyer seeks the requested relief because the DJI Phantom 3 

Professional UAS does not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Christopher L Meyer will ensure that the DJI 

Phantom 3 Professional UAS are in airworthy condition based upon its compliance with 

the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 

Professional Instruction Manual) prior to every flight, and further, determine that the 

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

3. Extent Of Relief Christopher L Meyer Seeks And The Reason Christopher L 

Meyer Seeks Relief From Section 91.121.

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

operations of the DJI Phantom 3 Professional UAS, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UA to the PIC at the ground control station (GCS). Since 

the FAA requires that any altitude information concerning

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

Christopher L Meyer seeks the requested relief because the DJI Phantom 3 

Professional UAS’s altimeter may be set on the ground to zero feet AGL, rather than the 

local barometric pressure or field altitude, before each flight. Considering the limited 

altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent 

necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the DJI 

Phantom 3 Professional UAS is equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the 

UAS on the heads-up display of the GCS.

4. Extent Of Relief Christopher L Meyer Seeks And The Reason Christopher L 

Meyer Seeks Relief From Section 91.151(b).

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

requested to the extent required to allow flights of the battery powered DJI

Phantom 3 Professional UAS during daylight hours in visual meteorological conditions 

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

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

least 4.5 minutes. Christopher L Meyer seeks the requested relief because without an 

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

Phantom 3 Professional UAS will severely constrain the practicality of any aerial video 

or still photo flight operations that Christopher L Meyer proposes to conduct pursuant to 

this Petition. Significantly, as set forth below, the technical specifications of the DJI 

Phantom 3 Professional UAS, the DJI Phantom 3 Professional operating documents, 
and Christopher L Meyer proposed operating limitations, ensure that Christopher L 

Meyer will safely operate the battery powered DJI Phantom 3 Professional UAS during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), 

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

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

minutes.

5. Extent Of Relief Christopher L Meyer Seeks And The Reason Christopher L 

Meyer Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b) only apply to aircraft with an airworthiness certificate, Christopher L Meyer requests 

relief from these Sections because the DJI Phantom 3 Professional UAS does not 

require an airworthiness certificate. As set forth more fully below, the DJI Phantom 3

Professional UAS meets the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Christopher L Meyer will perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the Monthly Maintenance

Log, and DJI Phantom 3 Professional Instruction Manual).

Furthermore, Christopher L Meyer will document and maintain all maintenance records 

for the DJI Phantom 3 Professional UAS.

D. The Reasons Why Granting Christopher L Meyer’s

Request Would Be In The Public Interest; That Is, How It 

Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Christopher L 

Meyer to safely, efficiently, and economically perform aerial video and photography and 

training for commercial ventures over certain areas of the United States. Additionally, 

use of the DJI Phantom 3 Professional UAS will decrease congestion of the NAS, 

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

of Christopher L Meyer’s proposed operation of the DJI Phantom 3 Professional UAS 

will be realized without implicating any privacy issues. Lastly, training novice individuals 

on how to properly operate an UAS safely and legally can only benefit the future of 

integrating UAS’s into the NAS.

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

The DJI Phantom 3 Professional UAS is battery powered and serve as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

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

acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, 

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

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

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

The DJI Phantom 3 Professional UAS does not require an airport to takeoff or land. 
Likewise, a reduction of manned aircraft conducting aerial video and photography 

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

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

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

Professional UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS, instead of 

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

and noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Phantom 3 Professional 

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

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

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

gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UAS, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as 

the UAS is propelled by battery powered electric motors, rather than an internal 

combustion engine. By using the DJI Phantom 3 Professional UAS to perform aerial 

acquisitions, the substantial risk to life and property in the air and on the ground, which 

is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew

members located onboard the aircraft, the DJI Phantom 3 Professional UAS (weighing 

approximately 2 pounds 11 ounces, at its maximum gross weights with length of 16 

inches, width of 16 inches, and with no fuel on board), has less physical potential for 

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

manned aircraft that typically conduct similar operations (weighing approximately 6,000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel 

capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 3 Professional UAS Will Benefit The Economy.

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

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Phantom 3 Professional UAS will allow United States based 

companies, like Christopher L Meyer, to remain competitive and contribute to growth of 

the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative 

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

3 Professional UAS is one such technology that not only allows companies greater 

operational flexibility compared to manned aircraft, but provides such flexibility without

the high operational cost of a traditional manned aircraft. By operating the DJI Phantom 

3 Professional UAS, companies such as Christopher L Meyer, can remain competitive 

and profitable, and therefore, provide greater job stability to employees and contractors, 

which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the DJI Phantom 3 

Professional UAS, provides a stable workforce that increases consumer spending; 
improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States and 

abroad.

4. There Are No Privacy Issues.

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

decades, Christopher L Meyer’s proposed operation of the DJI Phantom 3 Professional 

UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3

Professional UAS will be operated only in compliance with operating documents (i.e., 

the Aerial Operations Manual, Monthly Maintenance Log, and DJI

Phantom 3 Professional Instruction Manual) which requires property owner involvement 

as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14

C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not 

Adversely Affect Safety, Or How The Exemption Would 

Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which Christopher L Meyer Seeks 

Exemption.

1. Reasons Why The DJI Phantom 3 Professional UAS Meet The Conditions Of 

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

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

the unmanned aircraft and its operation, Christopher L Meyer’s operation of the DJI

Phantom 3 Professional UAS meet the conditions of FMRA Section 333, and will not 

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

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users 

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

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

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

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking required by section 332 

of this Act or the guidance required by section 334 of this Act.

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

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

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

speed, operational capability, proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of the national airspace system 

or the public or pose a threat to national security; and

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

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1).
(c) Requirements for Safe Operation.--If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft 

systems in the national airspace system.

In seeking this exemption, Christopher L Meyer submits that the DJI Phantom 3

Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS; (b) the 

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

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

Safe Characteristics.

The DJI Phantom 3 Professional UAS do not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 Professional UAS.

The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the 

DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as 

Appendix A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight And Navigation 

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

The DJI Phantom 3 Professional UAS may be operated in both manual and fully 

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

the DJI Phantom 3 Professional UAS is provided at pages 25-35 of the DJI Phantom 3 

Professional User Manual, attached hereto in Appendix B.

iii. The DJI Phantom 3 Professional UAS Is Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 Professional UAS will remain 

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

Professional UAS do not reacquire control link data from the GCS, the UAS will assume 

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

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

A complete description of the Failsafe Functions of the DJI Phantom 3 Professional 

UAS are set forth at pages 27 through 29 of the DJI Phantom 3 Professional User 

Manual, attached hereto in Appendix B.

iv. The DJI Phantom 3 Professional GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 

Professional GCS and flight control software is provided at pages 32 through 43 of the 

DJI Phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manual is

attached hereto in Appendix B.

b. Flight Operations Of DJI Phantom 3 Professional UAS Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Christopher L Meyer will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3

Professional UAS. Additionally, a safety observer will assist all pilots during flight time.
c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted Pursuant To 

Specific Operating Limitations.

In seeking this exemption, Christopher L Meyer proposes to commercially operate DJI

Phantom 3 Professional UAS for the special purpose of conducting aerial video and 

photography and UAS training over certain areas of United States, pursuant to the 

following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 

pounds maximum gross weight: DJI Phantom 3 Professional Unmanned Aircraft

System. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant.

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

purpose of aerial video and photography and training.

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

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a 

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL.

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

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

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

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

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

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and 

PIC must be able to communicate verbally at all times. Electronic messaging or texting 

is not permitted during flight operations. The PIC must be designated before the flight

and cannot transfer his or her designation for the duration of the flight. The PIC must 

ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during

UAS operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions and limitations 

contained in the grant of exemption take precedence and must be followed. Otherwise, 

the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s responsibility 

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

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

petitions for extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the

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

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

questions arise regarding updates or revisions to the operating documents.
10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition 

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

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

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

Station must be included in the preflight inspection. All maintenance and alterations 

must be properly documented in the aircraft records.

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

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

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

make an entry in the aircraft records.

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

components, items, or equipment, not already covered in the relevant sections of the 

operating documents.

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

overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service.

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

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

17. The PIC must possess a FAA Pilot Certificate and at least a current third- class 

medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the UAS in 

a manner consistent with how the UAS will be operated under the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. PIC qualification flight hours must be logged 

in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the 

operator’s PICs are permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training sessions. During training,

proficiency, and experience-building flights, all persons not essential for flight operations 

are considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA office 

closest to proposed area of operations. Flights under special visual flight rules (SVFR) 

are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator’s COA.
The letter of agreement with the airport management must be made available to the 

Administrator upon request.

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

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

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

accordance with the operating documents.

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

in accordance with the operating documents.

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

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

intended landing point and land the UA with 25% battery power remaining.

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

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

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

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

operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be 

as large as practicable.

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

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

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

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request.

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

operations and activities at all times.

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

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

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

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where 

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

operations must cease immediately and/or;

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

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

PIC has made a safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard, and;
c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

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

permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be obtained for 

each flight to be conducted.

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

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

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

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And 

(b) Would Not Adversely Affect Safety.

Christopher L Meyer submits that the equivalent level of safety established by Section

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

Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 3 Professional UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. Considering Christopher L Meyer’s proposed area of 

operations, and the operating limitations set forth-above; the parallel nature of private 

pilot aeronautical knowledge requirements to those of commercial pilot requirements

(See Exemption No. 11062); and the airmanship skills necessary to safely operate the 

DJI Phantom 3 Professional UAS, Christopher L Meyer submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate 

to the airmanship skills necessary for Christopher L Meyer’s specific proposed flight 

operations.

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

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

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

11112,11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Christopher L Meyer will not allow any PIC to operate the DJI Phantom 3 Professional

UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements 

or the DJI Phantom 3 Professional UAS training and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

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

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

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

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

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

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes).
As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience 

that was obtained in compliance with applicable regulations will ensure an equivalent 

level of safety during Christopher L Meyer’s proposed operations. The Administrator has 

held that prior documented flight experience that was obtained in compliance with 

applicable regulations would ensure safe operations, stating as follows:

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

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

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

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

a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also 

have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same 

make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive rather 

than additive; i.e. 5 hours make and model time may be included in the 10 hours of 

multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft 

time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to 

practice and build proficiency in the skills necessary to safely conduct the petitioner’s 

proposed operations. The FAA also finds that prior documented flight experience that 

was obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted under the 

grant of exemption to accomplish the required flight time. During training, proficiency, 

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

distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

Accordingly, Christopher L Meyer will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by 

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

operate the DJI Phantom 3 Professional UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

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

Would Not Adversely Affect Safety.

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

prior to every flight, Christopher L Meyer will ensure that the DJI Phantom 3

Professional UAS is in an airworthy condition based upon the UAS’s compliance with its 

operating documents and as stated in the conditions and limitations herein.

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

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

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

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because 

the altitude information of the DJI Phantom 3 Professional UAS will be provided to the 
PIC via GPS equipment and a radio communications telemetry data link, which 

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

This altitude information, combined with Christopher L Meyer’s operation of the DJI 

Phantom 3 Professional UAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero 

altitude initiation point is automatically established by the UASs at ground level.

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

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

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

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI

Phantom 3 Professional UAS; (2) the limitations on the proposed flight operations; and 

(3) the location of the proposed flight operations. Accordingly, Christopher L Meyer will 

ensure that it will safely operate the battery powered DJI Phantom 3

Professional UAS during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 13.5 minutes to the first point of intended landing and, 

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

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

3 Professional UAS; the limitations on the proposed flight operations; and the location of 

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

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

DJI Phantom 3 Professional UAS provide audible and visual warnings to the PIC at the 

GCS when the UAs experiences low battery voltage, the first warning occurring at 

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

remaining battery power. At the critically low battery level, the DJI Phantom 3 

Professional UAS will descend and land automatically. Significantly, previous 

exemptions granted by the FAA concerning Section 91.151 establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than 

the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to 

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

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, Christopher L Meyer submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) will be met because Christopher L Meyer will perform maintenance, alterations, or 
preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI

Phantom 3 Professional Instruction Manual). Furthermore, Christopher L Meyer will 

document and maintain all maintenance records for the DJI Phantom 3 Professional 

UAS. Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the 

operating documents, Christopher L Meyer will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI 

Phantom 3 Professional User Manual is attached hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because Christopher L 

Meyer will perform maintenance, alterations or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed by the operating documents.

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

established by Sections 91.407, 91.417(a) and 91.417(b). 

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

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety 

is not adversely affected when the technical characteristics and operating limitations of

the UAS are considered.

In consideration of Christopher L Meyer’s proposed operating limitations, the operating

documents, and the technical aspects of the DJI Phantom 3 Professional UAS, 

Christopher L Meyer submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), 

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

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

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

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Christopher L Meyer

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

Phantom 3 Professional UAS, which contain such safety standards that the

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

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121,

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

special conditions will permit safe operation of the UAs for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

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

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

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

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. Likewise, the Administrator 

may prescribe special conditions pursuant to 14 C.F.R.§ 21.16, for operation of the DJI 

Phantom 3 Professional UAS, since the airworthiness regulations of 14 C.F.R. Part 21 

do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following:
If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

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

§ 21.16, the FAA may prescribe special conditions for Leading Edge’s intended 

operation of the DJI Phantom 3 Professional UAS, which contain such safety standards 

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

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

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

91.417(a)

& (b).

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

Rules From Which Christopher L Meyer Seeks Exemption:

Christopher L Meyer seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption Christopher L Meyer Seeks:

This exemption will permit Christopher L Meyer to commercially operate an Unmanned

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

Photography and Training over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support

Christopher L Meyer’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, Christopher L Meyer’s request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 

C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for 

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

otherwise pose a threat to national security; and further, provides the authority for such 

UAS to operate without airworthiness certification.

As discussed in detail above, Christopher L Meyer will operate the DJI Phantom 3

Professional UAS safely in the NAS, without creating a hazard to users of the NAS, or 

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

CONCLUSION

As set forth herein, Christopher L Meyer seeks an exemption pursuant to 14 C.F.R. §

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

which will permit safe operation of the DJI Phantom 3 Professional UAS commercially, 

without an airworthiness certificate, for the limited purpose of conducting aerial video 

and photography and Training over certain areas of the United States. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of
the public, by allowing Christopher L Meyer to safely, efficiently, and economically 

operate the DJI Phantom 3 Professional UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, Christopher L Meyer

respectfully requests that the Administrator grant this Petition for an exemption from the 

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

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

Edge to operate the DJI Phantom 3 Professional UAS commercially for the purpose of

conducting aerial video and photography and training over certain areas of the United 

States.

Dated: July 29, 2015

Respectfully submitted,

Christopher L Meyer

_________________________

Christopher L Meyer

38619 Wakefield Ct.

Northville, Michigan 48167

Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Phantom 3 Professional User Manual Hyperlink

APPENDIX – A

DJI Phantom 3 Professional TECHNICAL SPECIFICATIONS

Christopher L Meyer only utilizes safe and reliable UAS. DJI is an industry leader in 

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

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

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

as limit flight to a predetermined and set distance. In addition, DJI software provides 

real-time altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices)

1.1 DJI Phantom 3 Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

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

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

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

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

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA
1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

APPENDIX – B

DJI Phantom 3 Professional User Manual Hyperlink

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.

2_en.pdf