KEN SHAMRELL

SHAMRELL AERIAL IMAGERY

A DIVISION OF ALLISON SHAMRELL PHOTOGRAPHY, INC.

3251 Adams Ave, Suite C

San Diego, CA 92116

(619) 357-6625

Ken@AllisonShamrell.com

July 22, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave, SE

Washington, DC 20590

RE: Exemption Request to Section 333 of the FAA Modernization & Reform Act of 2012 and Part 

11 of Title 14, Code of Federal Regulations (14 CFR) from: Part 21, Subpart H; 45.23(b); 

61.23(a)&(c); 61.101(e)(4)&(5); 61.113(a); 61.315(a); 91.7(a); 91.9(b)(2); 91.109; 91.119(c); 

91.121; 91.151(a)(1); 91.203(a)&(b); 91.405(a); 91.407(a)(1); 91.409(a)(1)&(2); 91.417(a)&(b).

Dear Sir or Madam,

I, Ken Shamrell, herewith known as the petitioner, am writing pursuant to the FAA Modernization & Reform 

Act of 2012 (henceforth known as the “Reform Act”) and 14 CFR Part 11 to request an exemption from the 

above referenced Federal Aviation Regulations (FARs) to allow for the operation of a small ultra lightweight 

unmanned aircraft system (UAS), a DJI Phantom 3 Professional, for commercial aerial photography and 

videography purposes in the National Airspace System (NAS) regulated by the FAA.

The petitioner was a Naval Aviator for the U.S. Navy (helicopter pilot #31260) and currently holds a 

commercial pilot’s license (#3601978) for both fixed-wing single-engine land and rotary aircraft, as well as 

instrument ratings for both fixed-wing and rotary aircraft. He also holds a current 2nd class medical 

certificate (GX0720163) and has completed the DJI “New Pilot Experience” introduction class taught by 

Drones Made Easy, a DJI authorized dealer in San Diego, CA. He is the business owner and operator of 

Shamrell Aerial Imagery, a division of Allison Shamrell Photography, Inc., which is his wife’s professional 

photography business.

As described fully below, the granting of this exemption would permit the operation of a small UAS under 

carefully-crafted conditions in the NAS that would be a) limited, b) controlled, c) predetermined, and 

d) safer than present industry standards of using conventional manned aircraft. Use of fixed-wing aircraft 
and helicopters for aerial photography is cost-prohibitive for small business owners, so granting this 

exemption would allow Shamrell Aerial Imagery to provide this service at a much lower cost. Approval of 

this exemption would thereby enhance NAS safety and fulfill the Secretary of Transportation’s (the FAA 

Administrator’s) responsibilities to “establish requirements for the safe operation of such aircraft systems in 

the national airspace system.” This will also enhance public awareness of the benefits and proper safety 

precautions of small UASs by allowing qualified personnel with sufficient knowledge of airspaces and the 

piloting of conventional manned aircraft to operate a small UAS safely and to teach others how to do so in 

a safe manner as well. The operation will minimize ecological damage by utilizing an electrically powered

aircraft that does not pollute the environment, and it will promote economic growth by allowing fellow 

business owners to afford aerial photography and videography services.

Commercial operation of a small UAS, as described herein, which is equipped with a camera and sensors, 

would operate in the following manner:

• Aerial photography and/or videography for public and/or private use to include professional family 

portrait sessions (including pets and domesticated animals), weddings, real estate, architecture, 

land surveying, engineering, television, news gathering, and other professional-related activities.

• Aerial inspection/photography of residential/commercial structures under contract with the owners 

or local government authority.

• Aerial inspection/photography of residential/commercial utility infrastructure including but not 

limited to electrical power lines, wind turbines, and cell towers.

• Aerial photography and/or videography and/or providing live video feed to assist with search and 

rescue operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it.

• The ability to offer training to persons individually or belonging to private and/or public 

organizations (to include educational groups) that have interests in the application of small UAS

operations, to properly train potential UAS pilots in the appropriate safety precautions, for 

educational reasons, and/or for the purpose of enhancing safety of small UAS operations in the 

NAS as well as for the protection of persons and property.

Regulations from which the exemption is requested:

• 14 CFR Part 21, Subpart H

• 14 CFR § 45.23(b)

• 14 CFR § 61.23(a)&(c)

• 14 CFR § 61.101(e)(4)&(5)

• 14 CFR § 61.113(a)

• 14 CFR § 61.315(a)

• 14 CFR § 91.7(a)

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• 14 CFR § 91.9(b)(2)

• 14 CFR § 91.109

• 14 CFR § 91.119(c)

• 14 CFR § 91.121

• 14 CFR § 91.151(a)(1)

• 14 CFR § 91.203(a)&(b)

• 14 CFR § 91.405(a)

• 14 CFR § 91.407(a)(1)

• 14 CFR § 91.409(a)(1)&(2)

• 14 CFR § 91.417(a)&(b)

The petitioner plans to use a DJI Phantom 3 Professional. It is a battery-operated quadcopter driven by 

electric motors (Model DJI 3510) with a maximum gross weight of 1280 grams (~2.82 lbs), a maximum 

airspeed of 16 m/s (~31.1 knots or ~35.8 mph), a maximum operating distance of 2000 meters (~1.2 

miles), and powered by a 4480 mAh 4S Lithium Polymer (LiPo) battery. The dimensions are 40.36 cm x 

40.36 cm x 19.05 cm (16 in x 16 in x 7.5 in) with a diagonal size of 59.0 cm (~23.2 in) to include the 

propellers. It includes a Sony 4K camera that allows for First Person View (FPV), a GPS receiver, a Vision 

Positioning System (VPS), and software safety features that prevent the small UAS from flying in FAA ‘No 

Fly Zones’. The DJI Phantom 3 Professional will be controlled by a C3 remote controller with an operating 

frequency of 2.400GHz – 2.483GHz, and the live video feed will have an operating frequency of 2.4GHz 

ISM. It is able to provide real-time flight data to the PIC via the DJI Pilot app, which further increases

situational awareness. Both the aircraft’s firmware and DJI Pilot app are updatable to add additional 

capabilities and safety enhancements. The DJI Phantom 3 Professional has the ability to hover and move 

along a vertical and horizontal plane simultaneously. Given its small size/weight and lack of combustible 

fuel, this small UAS will pose significantly less threat to the public compared to a much larger conventional 

manned aircraft, so thus it is much safer for the public. The petitioner will always operate the small UAS in 

visual line of sight (VLOS) within a predetermined area with sufficient preflight planning to ensure the safe 

operation for those involved in the flight activity as well as flying at a sufficiently safe distance away from 

nonparticipants.

Pilot in Command (PIC)

The Pilot in Command of the small UAS shall hold at least a sport pilot certificate or higher, a 3rd class 

medical certificate or valid U.S. driver’s license, shall have at least 10 total hours of UAS operations (5 of 

which in the respective make/model), and, when one is available, attend the DJI New Pilot Experience 

course offered by the manufacturer or authorized dealer. The requirement for the UAS PIC to hold a sport 

pilot certificate or higher for a conventional manned aircraft shall remain in effect unless the FAA rescinds

this requirement. All other requirements listed herein shall continue to stay in effect regardless.

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OPERATING PARAMETERS

The petitioner agrees to adhere to the following limitations and conditions when conducting commercial 

operations under the FAA issued exemption as set forth in the Flight Operations Manual (FOM):

• The UAS shall weigh less than 55 lbs including payload. The DJI Phantom 3 Professional only 

weighs 1280g or 2.82 lbs.

• The UAS shall have a maximum operating speed of no more than 87 knots (100 mph). The 

maximum recommended airspeed by the aircraft manufacturer for the DJI Phantom 3 Professional

is 16 m/s (~31.1 knots or ~35.8 mph).

• The UAS shall be operated at an altitude of no more than 400 feet above ground level (AGL).

• The UAS shall be operated within visual line of sight (VLOS) of the PIC at all times using only 

unaided human vision (other than corrective lenses).

• All operations shall utilize a visual observer (VO). The UAS shall be operated within the VLOS of 

the PIC and VO at all times, and the PIC and VO shall be able to communicate verbally at all times 

during operation. The PIC shall ensure that the VO is capable of performing the duties and 

responsibilities required of the VO.

• All operating documents shall be accessible during UAS operations and can be made available to 

the FAA Administrator or any law enforcement official upon request. Operating documents include 

this petition, the granted exemption letter, and all documents needed to safely operate and fly the 

UAS. These documents shall be available to the PIC at the ground control point of the UAS any 

time the aircraft is operating.

• If the UAS has undergone any maintenance or alterations that affect its operation or flight 

characteristics, then a functional test flight shall be conducted prior to any further commercial 

operations. The functional test flight shall abide by all regulations specified herein and shall be 

conducted in such a manner that it will not pose an undue hazard to persons and property. 

• The operator shall be responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation.

• Prior to each flight, the PIC shall conduct a thorough preflight inspection and determine that the

UAS is in a condition for safe flight. In accordance with the DJI Phantom 3 Professional user 

manual, the preflight checklist items will at a minimum include:

1. Remote controller, intelligent flight battery, and mobile device are fully charged.

2. Propellers are mounted correctly & firmly.

3. Micro-SD card has been inserted, if necessary.

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4. Gimbal is functioning properly.

5. Motors can start & are functioning properly.

6. The DJI Pilot app is successfully connected to the aircraft.

• The PIC shall follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and 

life limit requirements for the aircraft and aircraft components.

• The PIC shall comply with all manufacturer safety bulletins while operating the UAS.

• A PIC must hold either an airline transport, commercial, private, recreational, or sport pilot 

certificate. The PIC must also hold a current FAA airman certificate or a valid U.S. driver’s license, 

and will take and pass all necessary certifications/courses currently or in the future being approved 

by the FAA for commercial use.

• The operator shall only allow a PIC to operate the UAS if that PIC can demonstrate the ability to 

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

exemption, including evasive & emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles, and structures.

• UAS operations shall only be conducted during daytime visual meteorological conditions (VMC). 

The PIC shall not fly during night, which is defined in 14 CFR §1.1 as “the time between the end of 

evening civil twilight and the beginning of morning civil twilight.”

• The majority of operations shall take place outside of 5 nautical miles (nm) from the geographic 

center or Airport Reference Point (ARP) of a tower-controlled or -uncontrolled airport as denoted in 

the current FAA Airport/Facility Directory (AFD). However, if operations are to be within 5 nm of 

an ARP of a tower-controlled or -uncontrolled airport but outside 1.5 nm, the PIC shall notify the 

respective airport of the location, estimated flight time, duration, elevation, and any other 

pertinent information. Under these conditions, the altitude will also be restricted on a sliding scale 

starting at 66 feet AGL at 1.5 nm and increasing to a height of 400 feet AGL at 5 nm. Operations 

shall not take place within 1.5 nm of an ARP. The DJI Phantom 3 Professional has built-in 

software for all FAA regulated ‘No Fly Zones’ to prevent any possible flights occurring within these 

No Fly Zones. The PIC shall continuously check for updates by the manufacturer to the aircraft’s 

firmware and DJI Pilot app to stay current on all No Fly Zones and any enhanced safety features.

• The UAS shall only operate in weather that allows for an operating distance of 500 feet or greater 

below any clouds, an operating distance of 2,000 feet or greater horizontally from any clouds, and 

when visibility is greater than 3 statute miles from the PIC.

• If the UAS loses communications or loses its GPS signal, the UAS shall return to a safe 

predetermined location and land autonomously.

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• The PIC shall abort the flight in the event of unpredicted obstacles or emergencies.

• The PIC shall only begin a flight if there is enough available power for the UAS to conduct the 

intended operation and to operate after that for at least 5 minutes. The maximum flight time for 

the DJI Phantom 3 Professional is ~23 minutes, so flights shall be terminated at 25% battery 

power reserve to allow for at least 5 minutes of reserve power. The DJI Phantom 3 Professional

has built-in software to automatically land the aircraft if the battery gets too low.

• The petitioner shall apply for an Air Traffic Organization (ATO) Certificate of Waiver or 

Authorization (COA) upon receiving this exemption and shall conduct operations in compliance with 

said COA.

• The UAS shall be identified by serial number and registered with the FAA in accordance with 14 

CFR Part 47 to include as large as practicable identification (N-Number) markings in accordance 

with 14 CFR Part 45, Subpart C.

• The UAS shall remain clear and give way to all manned aviation operations and activities at all 

times.

• The UAS shall not be operated by the PIC from any moving device or vehicle.

• The operator shall obtain verbal/written consent of all persons involved with the planned operation 

of the UAS, and all flight operations shall be conducted at least 500 feet away from all 

nonparticipating persons, vessels, vehicles, and structures unless:

o Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UAS and/or debris in the event of an accident and the operator will ensure that 

nonparticipating persons remain under such protection.

o The owner/controller of any vessels, vehicles, or structures has granted permission for 

operating closer to those objects and the PIC has made an independent safety assessment 

of the risk of operating closer to those objects and determined that it does not present an 

undue hazard.

The PIC, VO, operator trainees, or essential persons are not considered nonparticipating persons. 

The PIC shall only operate in reasonably safe environments that are strictly controlled and are 

away from power lines, elevated lights, and airports.

• Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the 

operational area as defined by the applicable COA will be reported to the FAA’s UAS Integration 

Office (AFS-80) within 24 hours. Accidents will also be reported to the National Transportation 

Safety Board (NTSB) per their instructions.

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EXEMPTION REQUESTS

14 CFR Part 21, Subpart H: Airworthiness Certificates

This regulation establishes the procedural requirements for the issuance of airworthiness certificates as 

required by FAR §91.203(a)(1). 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 UAS. In all cases, an analysis of these criteria demonstrates that the 

small 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 manned aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate but without the restrictions and conditions proposed

herein. Thus, given the size and limited operating area associated with the aircraft to be utilized by the 

petitioner, an exemption from 14 CFR Part 21, Subpart H meets the requirements of an equivalent level of 

safety under Part 11 and Section 333 of the Reform Act.

The small UAS to be operated hereunder is less than 55 lbs (~2.82 lbs) fully loaded, carries neither a pilot 

nor passengers, carries no explosive materials or flammable liquid fuels, and operates exclusively in 

carefully monitored areas. Unlike other civil aircraft, operations under this exemption will be tightly 

controlled and overseen by the operator, will abide by the restrictions and conditions proposed herein, and

will comply with local public safety requirements. These safety enhancements provide a greater degree of 

safety to the public and property owners than conventional manned operations conducted with 

airworthiness certificates issued under 14 CFR Part 21, Subpart H. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by the small UAS due to its 

size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and its

inability to carry a substantial external load.

14 CFR § 45.23(b): Display of Marks

This regulation requires visible marks to include the Roman capital letter "N" followed by the registration 

number, the size to be at least 3 inches high, and to be displayed on limited, restricted, or light-sport 

category aircraft or experimental or provisionally certificated aircraft. The operator must also display on 

that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as 

applicable.

Even though the small UAS will have no airworthiness certificate (via an exemption to 14 CFR Part 21, 

Subpart H), an exemption will be needed for this regulation as the small UAS will have no entrance to the 

cabin, cockpit or pilot station on which the word “Experimental” can be placed. Also, given the size of the 

small UAS, the 3 inch registration number and 2 inch “Experimental” lettering requirements will be 

impossible. However, both the registration number and the word “Experimental” will be placed on the 

fuselage as large as practicable in compliance with §45.29(f). The equivalent level of safety will be 

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provided by having the small UAS marked on its fuselage as required by §45.29(f) where the pilot, 

observer, and others working with the UAS will see its identification.

14 CFR § 61.23(a)&(c): Medical Certificates

Section (a) of this regulation requires different levels of medical certificates depending on the desired type 

of flying. Section (c) allows for either a medical certificate or valid U.S. driver’s license if exercising the 

privileges of a sport pilot certificate. If the person uses a U.S. driver’s license, then they must comply with 

that person’s restrictions or limitations imposed, have been found eligible for the issuance of at least a 

3rd class airman medical certificate at the time of the most recent application, not have had his or her most 

recently issued medical certificate suspended or revoked, and not know or have a reason to know of any 

medical condition that would make that person unable to operate a light-sport aircraft in a safe manner.

This application’s operational conditions specify that the PIC of the small UAS shall hold at least a sport 

pilot certificate or higher and also possess a valid medical certificate or U.S. driver’s license. Since the 

training requirements listed herein are the same as a conventional manned aircraft pilot, then an 

equivalent level of safety can be achieved and thus the medical certificate requirements for operating a 

small UAS should be the same to hold either a valid medical airman certificate or U.S. driver’s license. 

Therefore, an exemption is requested for this regulation.

14 CFR § 61.101(e)(4)&(5): Recreational Pilot Privileges & Limitations

This regulation prevents a recreational pilot from acting as the PIC of an aircraft for compensation or hire

or in furtherance of a business. The intent of this regulation is to prevent non-commercial pilots from 

operating conventional manned aircraft for commercial purposes. It does not refer to unmanned aircraft 

systems and the qualifications to fly a small UAS for business purposes should be considerably less than 

the requirements for conventional manned aircraft since small UASs are so much smaller in size, weight, 

and speed and thus pose a significantly less risk to persons or property on the surface. The main reason 

the petitioner is submitting this exemption request is to allow for the commercial use of a small UAS for 

business-related operations, so thus an exemption is requested for this particular regulation.

14 CFR § 61.113(a): Private Pilot Privileges and Limitations – Pilot in Command

This regulation states that no person who holds a private pilot certificate may act as a 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 PIC of an aircraft.

An equivalent level of safety can be achieved by current regulations because the petitioner’s small UAS

does not carry any pilots, passengers, or property. The proposed operational conditions herein require 

that the PIC must hold at least a sport pilot certificate or higher with either a 3rd class medical certificate 

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issued by the FAA or a valid U.S. driver’s license. Also, the risks attendant to the operation of a small UAS

is far less than the risk levels inherent in the commercial activities outlined in 14 CFR §61. The intent of 

this application is to conduct a business, but the operation and limitations set forth in the FOM will equate 

to the safe operation of the small UAS.

14 CFR § 61.315(a): Sport Pilot Certificate Privileges

This regulation allows a person holding a sport pilot certificate to act as PIC of a light-sport aircraft, but 

does not allow them to fly for compensation or hire or in furtherance of a business. Since the operational 

conditions specified herein requires the PIC of the small UAS to hold at least a sport pilot certificate or 

higher and the intent of this application is to conduct a business, an exemption is requested for this 

regulation. An equivalent level of safety can be met by requiring the small UAS’s PIC to undergo the same 

level of training as a fully qualified pilot of a conventional manned aircraft, and the risks associated with 

flying a small UAS is far less than those associated with conventional manned aircraft due to the size, 

weight, and speed of the UAS.

14 CFR § 91.7(a): Civil Aircraft Airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in an airworthy condition. As 

there will be no airworthiness certificate issued for this aircraft (via an exemption to 14 CFR Part 21, 

Subpart H), should this exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness and thus this regulation is not applicable. Given the size of the aircraft and the use of safety 

checklists prior to each flight, an equivalent level of safety will be achieved.

14 CFR § 91.9(b)(2): Civil Aircraft Flight Manual, Marking, & Placard Requirements

This regulation states that no person may operate a U.S.-registered civil aircraft unless current, approved 

flight manual material, markings, and placards reside inside the aircraft. The intent of this regulation is to 

have flight manual information readily available to the aircrew while operating the aircraft. Given the size 

and configuration of the small UAS, an exemption is requested since it is unable to carry people or 

documentation onboard the aircraft. However, in order to obtain an equivalent level of safety and meet 

the intent of this regulation, the UAS operating documents (to include the flight manual) will be readily 

available to the PIC at the ground control point at all times during preflight and while conducting 

operational flights.

14 CFR §91.109: Flight Instruction

This regulation provides that no person may operate a civil aircraft that is being used for flight instruction 

unless that aircraft has fully functioning dual controls. By their design, small UASs and remotely piloted 

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aircraft (RPA) do not have fully functional dual controls. Flight control is accomplished through the use of 

a single control box that communicates with the aircraft via radio communications. The FAA has approved 

exemptions for flight training without fully functioning dual controls for a number of aircraft and for flight 

instruction in experimental aircraft. Since neither a pilot nor passengers will be carried in the small UAS

and the size and speed of this aircraft is drastically smaller than a conventional manned aircraft, an 

equivalent level of safety can be accomplished by conducting flight instruction at a controlled RPA field and 

with the instructor standing directly next to the student at the controls.

14 CFR § 91.119(c): Minimum Safe Altitudes

This regulation establishes safe altitudes for operation of civil aircraft, specifically stating that the aircraft 

cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure over sparsely 

populated areas. Helicopters may be operated at less than the minimums if each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA and the 

operation can be conducted without hazard to persons or property on the surface.

Since the typical mission of the small UAS would be for photography/videography purposes or the survey 

of persons, vessels, vehicles, or structures, it would be necessary for the small UAS to operate closer than 

500 feet in order to obtain useable footage. The small UAS is a rotorcraft similar to a helicopter and will 

never operate higher than 400 feet AGL, unless the structure to survey is higher than 400 feet AGL and in 

this case the small UAS will not operate higher than 200 feet above the highest point on the structure. 

Operations will only be flown when carefully preplanned flight paths have been prepared and performed. 

In addition, the small UAS will only fly over individuals who are aware of the planned flight operations and 

have given verbal or written consent. The aircraft will be operated at a low enough altitude to allow for 

safe separation from conventional manned aircraft and to allow for an emergency landing without undue 

hazard to persons or property on the surface should a power unit fail. Therefore, due to the small size, 

weight, and speed of the UAS and the functions to be performed, an exemption is requested to allow for 

closer operation than specified in §91.119 since an equivalent level of safety can be obtained due to the 

fact that the hazards to persons and property are minimal compared to conventional manned aircraft.

14 CFR § 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 and within 100 nm. Although the DJI Phantom 3 Professional does have a barometer, it 

primarily utilizes GPS and its Vision Positioning System (VPS) to determine its height above the ground and 

uses the barometer as a backup. However, an equivalent level of safety can be achieved because an AGL 

altimeter measurement is constantly transmitted via radio from the small UAS’s onboard computer to the 

display screen held by the PIC to provide real-time flight data monitoring, including a constantly updated 

AGL readout.

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14 CFR § 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions

This regulation prohibits an individual from beginning “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.” The intent of this regulation is to provide a safety reserve in case of delays prior to landing.

The small UAS is battery operated and provides a maximum flight time of approximately 23 minutes. The 

battery level indicator is transmitted to the main controller and is constantly updated on the display screen

to provide real-time flight data monitoring with an estimated remaining flight time based on the current 

battery level. The small UAS utilizes LiPo 4S 4480 mAh intelligent flight batteries with an advanced power 

management system that triggers failsafe modes if the battery depletes to a point that may affect the safe 

return of the aircraft. Users are advised to return home or land the aircraft immediately when prompted of 

a low battery level. The small UAS will automatically land if the current battery level can only support the 

aircraft long enough to descend from its current altitude. The small UAS will also not be able to takeoff 

unless a sufficient battery level is available prior to takeoff.

An exemption is requested from this regulation since the small UAS cannot even fly for the length of time 

specified for the 30 minute reserve, its distance is limited to 2 km from the PIC, and the intelligent flight 

batteries provide real-time battery level monitoring while also having failsafe modes that can automatically 

land the aircraft if the battery level gets too low, so thus an equivalent level of safety can be achieved.

14 CFR §91.203(a)&(b): Civil Aircraft – Certifications Required

This regulation states that no person may operate a civil aircraft unless (a) it has an appropriate and 

current airworthiness certificate and (b) the airworthiness certificate is displayed at the cabin or cockpit 

entrance so that it is legible to passengers or crew.

The small UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, 

there is no ability or place to carry certification and registration documents or to display them on the small 

UAS. Also, via an exemption to 14 CFR Part 21, Subpart H, there will be no airworthiness requirement and 

thus this regulation is not applicable. An equivalent level of safety will be achieved by obtaining an 

exemption to Section 333 via this petition, obtaining a Certificate of Waiver or Authorization (COA) from 

the FAA Air Traffic Organization (ATO) prior to conducting operations in the NAS, and registering the UAS

with the FAA in accordance with Part 47. These documents will be kept at the ground control point where

the pilot flying the UAS will have immediate access to them.

14 CFR Part 91, Subpart E [§91.405(a), 407(a)(1), 409(a)(1)&(2), 417(a)&(b)]: Maintenance, 

Preventative Maintenance, & Alterations

These regulations require that an aircraft operator or owner “shall have that aircraft inspected as 

prescribed in Subpart E of this part and shall between required inspections, except as provided in 

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DJI Phantom 3 Professional

GENERAL FEATURES

• Ready-to-fly

• 3-axis camera stabilization

• Precision flight & stable hovering

• GPS/GLONASS positioning & auto return home

• Onscreen real-time flight parameters

• High Definition 4k Camera

• Camera tilt control

• Film straight down

• Supports Adobe DNG RAW

• Adobe lens profile support

• Camera parameter setting

• Album synchronization

• FAA no-fly zones locked out via installed software

AIRCRAFT SPECS

• Weight (including battery & propellers): 1280 g

• Diagonal Size (including propellers): 590 mm

• Max Ascent Speed: 5 m/s

• Max Descent Speed: 3 m/s

• Hover Accuracy

o Vertical: +/- 0.1 m (when the Vision Positioning System is active) or +/- 0.5 m

o Horizontal: +/- 1.5 m

• Max Speed: 16 m/s (ATTI mode, no wind)

• Max Altitude Above Sea Level: 6000 m

• Operating Temperature: 0°C – 40°C

• GPS Mode: GPS/GLONASS

VISION POSITIONING SYSTEM

• Max Velocity: Less than 8 m/s (when 2 m above ground)

• Operating Range: 30 cm – 300 cm

• Operating Environment: Surface with clear pattern & adequate lighting (Lux > 15)

REMOTE CONTROLLER

• Operating Frequency: 2.400 GHz – 2.483 GHz

• Max Distance: 2000 m (outdoors & unobstructed)

• Video Output Port: USB

• Operating Temperature: 0°C – 40°C

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• Battery: 6000 mAh LiPo 2S

• Mobile Device Holder: For tablet or phone

• Receiver Sensitivity (1%PER): -101 dBm + 2 dBm

• Transmitter Power (EIRP)

o FCC: 20 dBm

o CE: 16 dBm

• Working Voltage: 1.2 A @ 7.4 V

INTELLIGENT FIGHT BATTERY

• Capacity: 4480 mAh

• Voltage: 15.2 V

• Battery Type: LiPo 4S

• Energy: 68 Wh

• Net Weight: 365 g

• Max Flight Time: ~23 minutes

• Operating Temperature: -10°C – 40°C

• Max Charging Power: 100 W

• Battery Charger

o Voltage: 17.4 V

o Rated Power: 100 W

CAMERA

• Sensor: Sony EXMOR 1/2.3” effective pixels: 12.4 M (total pixels: 12.76 M)

• Lens: FOV 94° 20 mm (35 mm format equivalent), f/2.8, focus at infinity

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

• Shutter Speed: 8s-1/8000s

• Image Max Size: 4000 x 3000

• Still Photography Modes

o Single-shot

o Burst Shooting: 3/5/7 shots

o Auto Exposure Bracketing (AEB): 3/5

o Bracketed Frames at 0.7EV Bias

o Time-lapse

• Video Recording Modes

o UHD: 4096x2160p @ 24/25 fps, 3840x2160p @ 24/25/30 fps

o FHD: 1920x1080p @ 24/25/30/48/50/60 fps

o HD: 1280x720p @ 24/25/30/48/50/60 fps

• Supported SD Card Types: Micro SD (Class 10 or UHS-1 rating, 64 GB max capacity)

• Max Bitrate of Video Storage: 60 Mbps

• Supported File Formats

o FAT32/exFAT

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o Photo: JPEG, DNG

o Video: MP4, MOV (MPEG-4 AVC/H.264)

• Operating Environment Temperature: 0°C – 40°C

• Gimbal

o Controllable Range: Pitch -90° to +30°

o Stabilization: 3-axis (pitch, roll, yaw)

APP/LIVE VIEW

• Mobile App: DJI Pilot

• EIRP: 100mW

• Live View Working Frequency: 2.4 GHz ISM

• Live View Quality: 720P @ 30fps (depending on conditions & mobile device)

• Latency: 220ms (depending on conditions & mobile device)

• Required Operating Systems

o iOS 8.0 or later

o Android 4.1.2 or later

• Recommended Devices

o iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air (WiFi-only), iPad Air (WiFi +Cellular), iPad 

Mini 2 (WiFi-only), iPad Mini 2 (WiFi + Cellular), iPad Air 2 (WiFi-only), iPad Air 2 (WiFi + 

Cellular), iPad Mini 3 (WiFi-only), iPad Mini 3 (WiFi + Cellular)

o Android: Samsung S5, Note 3, Sonly Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, 

Nubia Z7 Mini

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