12/15/15 

U.S. Department of Transportation 

Docket Management System

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue,SE

Washington DC 20590

RE: Exemption Request per Section 333 of the FAA Reform Act

Dear Sir or Madam:

We respectfully request exemption under Section 333 of the FAA Reform ACT and 

Part 11 of the Federal Aviation Regulations.

OPERATOR'S NAME AND ADDRESS

D. J. Head, Jr. Owner/President

Two-Head Video, Inc. 

5011 SW 177th Street 

Archer, Florida 32618

Telephone: 352-372-5625 

 

Cell: 352-318-2213

Email: twohead@two-head.com
 COMPANY BACKGROUND

Two-Head Video, Inc. is a full service digital media production company. They were 

established in Gainesville, Florida in 1981 and serve corporate, government, 

educational and nonprofit clients. Their exclusive focus is video production for 

corporate communication, capitol campaigns, promotional, documentary and 

educational purposes. 

Their goal is to create videos that educate, motivate and inspire. 

PROPOSED OPERATIONS

TWO-HEAD VIDEO proposes to use a DJI Phantom 3 Standard Unmanned Aerial 

System for aerial videography.

AIRCRAFT MAKE AND MODEL 

 DJI Phantom 3 UAS

TWO-HEAD VIDEO seeks an exemption to operate DJI Phantom 3 UAS for 

compensation or hire within the NAS. The DJI Phantom 3 is a vertical takeoff and 

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

electronic tablet or smart phone systems with a maximum range of 0.6 miles. The DJI 

Phantom 3 has a maximum gross weight of approximately 2.8 lb. while having a 

diagonal dimension of 23.2”, a maximum vertical speed of approximately 13mph, a 

maximum horizontal speed of approximately 35mph, and a maximum flying height of 

400'. The DJI Phantom 3 is equipped with four main electric rotors driven by a Lithium 

Polymer battery.

Any DJI Phantom 3 operated by TWO-HEAD VIDEO 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.
SPECIFIC SECTIONS for which exemption is sought:

14 C.F.R Part 21 Certification Procedures For Products And Parts

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

the unmanned aircraft and its operation, TWO-HEAD VIDEO operation of DJI 

Phantom 3 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, TWO-HEAD VIDEO 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 apply to aircraft with an airworthiness certificate. 

 

TWO-HEAD VIDEO submits that the airworthiness of the UAS will be determined by 

the PIC before each flight according to the pre-flight checklist in the manufacturer's 

documentation thereby ensuring an equivalent level of safety to Part 21 and related 

Sections as mentioned above.

14 C.F.R. 61.113(a) and (b) – Private pilot privileges and limitations: Pilot in 

command.

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

and limitations: Pilot in command, is requested by TWO-HEAD VIDEO to the extent 

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

certificate, as well as an airman medical certificate to operate the UAS for 

compensation or hire while not carrying passengers or cargo. The PIC will 

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

PIC is able to safely operate the DJI Phantom UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. TWO-HEAD VIDEO submits 

that the PIC will satisfy all of these conditions thus ensuring an equivalent level of 

safety to Section 61.113

14 C.F.R. 91.7(a) – Civil aircraft airworthiness.

In accordance with 14 C.F.R. Part 21, Subpart H, the DJI Phantom 3 UAS does not 

require an airworthiness certificate. TWO-HEAD VIDEO submits that the PIC will 

determine that the UAS is in compliance with the manufacturer's operating documents 

and the aircraft is safe for flight by conducting a thorough pre-flight inspection of the 

UAS. TWO-HEAD VIDEO will keep maintenance records for any work done to the 

UAS and a flight log of all flights executed with the UAS. TWO-HEAD VIDEO submits 

that an equivalent level of safety to Section 91.7 will be maintained.
14 C.F.R. 91.121 – Altimeter settings.

The DJI Phantom 3 UAS will not have a typical barometric altimeter on board. 

However, altitude information of the DJI Phantom 3 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 TWO-HEAD VIDEO’s operation of the 

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

level of safety equivalent to Section 91.121.

14 C.F.R. 91.151(a) – Fuel requirements for flight in VFR conditions.

Since the UAS is battery powered, there is no fuel on board . TWO-HEAD VIDEO 

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

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

(VFR), with enough battery power to fly approximately 23 minutes. Battery power 

indicators show exactly how much battery power/time is left, as well as how much 

time is needed to return safely back to point of take off. To provide an equivalent level 

of safety, the UAS may be programmed to return to home when the battery level 

reaches 25% remaining power. For the Phantom 3, this means over five minutes of 

flight time to return from a position not farther away than 0.6 mile. The power supply 

will provide a level of safety equivalent to Section 91.151.

PUBLIC BENEFIT 

Granting this Petition will further the public interest by allowing TWO-HEAD VIDEO to 

safely, efficiently, and economically perform aerial videography within the United 

States NAS. Use of the DJI Phantom 3 UAS will decrease congestion of the NAS, 

reduce pollution, provide economic benefits to the public, and enhance the safety of 

aerial videography operations.

SUMMARY 

TWO-HEAD VIDEO 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 

TWO-HEAD VIDEO to operate an Unmanned Aircraft System for the commercial 

purpose of conducting aerial videography and photography over areas of the United 

States.
INTERNATIONAL 

TWO-HEAD VIDEO requests permission to exercise the privileges of this exemption 

outside the United States to service clients with international interests in compliance 

with the Standards of the International Civil Aviation Organization (ICAO).