UNITED	STATES	OF	AMERICA

DEPARTMENT	OF	TRANSPORTATION

FEDERAL	AVIATION	ADMINISTRATION

WASHINGTON,	DC

Regulatory	Docket	No.___________________________

IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF:

DANE	HAROLD	EVANS

FOR	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF

TITLE	14	CODE	OF	FEDERAL	REGULATION

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

91.409(a)(1)	&(1)	&	(a)(2),	and	91.417(a)&(b)	CONCERNING	COMMERCIAL

OPERATION	OF	DJI	PHANTOM	3	PROFESSIONAL	AND	DJI	INSPIRE 1	

UNMANNED	AIRCRAFT	SYSTEMS

PURSUANT	TO	SECTION	333	OF

THE	FAA	MODERNIZATION	AND	REFORM	ACT	OF	2012

(PUBLIC	LAW	112-95)

Submitted	on	June	19,	2015

Dane	Harold	Evans

318	Lindbergh	Dr NE

Atlanta,	GA	30305

404.219.5980
TABLE	OF	CONTENTS

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

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

INTRODUCTION	AND	INTERESTS	OF	PETITION................. 4

BACKGROUND.......................................................................... 5

BASIS	FOR	PETITION............................................................. 5

NAME	AND	ADDRESS	OF	PETITIONER................................ 7

THE SPECIFICS	OF	14	C.F.R	FROM	WHICH

DANE	HAROLD	EVANS	SEEKS	EXEMPTION........................ 8

THE	EXTENT	OF	RELIEF	DANE	HAROLD	EVANS	SEEKS.... 14

THE	REASONS	WHY	GRANTING	DANE	HAROLD	EVANS’

REQUEST	WOULD	BE	IN	THE	PUBLIC	INTEREST................18

THE	REASON	WHY	GRANTING	AN	EXEMPTION	WOULD

NOT	ADVERSELY	AFFECT	SAFETY........................................36

CONCLUSION........................................................................... 43
GLOSSARY	OF	ABREVIATIONS

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	Authorizations

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	Systems

VFR Visual	Flight	Rules

VLOS Visual	Line of	Site

VMC Visual	Meteorological	Conditions

VTOL Vertical	Takeoff	and	Landing
SUMMARY

Dane	Harold	Evans	seeks	exemption	from	the	requirements of	

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

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

Unmanned	Aircraft	System	in	pursuant	to	Section	333	of	the	

FAA	Modernization	and	Reform	Act	of	2012.		This	exemption	

will	permit	Dane	Harold	Evans to	operate	an	Unmanned	

Aircraft	System	for	commercial	purpose	of	conducting	aerial	

video	and	photography	over	certain	areas	of	the	United	States.

INTRODUCTION	AND	INTERESTS	OF	PETITION

My	name	is	Dane	Harold	Evans,	a	professional	Airline	

Transport	Pilot	(2707087ATP)	rated	pilot	with	4000	hours	

flight	time.		

The	objective	of	Dane	Harold	Evans	is	to provide	aerial	

imagery	specifically	targeting:

- Real	estate	photography	and	videography

- Commercial	property	development	imagery
BACKGROUND

Dane	Harold	Evans	seeks	an	exemption	to	operate	a	DJI	

Phantom	3	Unmanned	Aircraft	for	compensation	or	hire	within	

the	National	Airspace	System.		The	DJI	Phantom	3 is	a	vertical	

takeoff	and	landing	(VTOL)	Unmanned	Aircraft	(UA)	with	a	

Ground	Control	Station(GCS)	coupled	with	a	tablet	computer	

display	screen.		The	DJI	Phantom	measures	16inH	X	16inW	X	

8inD	and	3	has a	maximum	gross	weight	of	2.82lbs.		The	

maximum	speed	of	the	Phantom	is	30kts.

The	DJI	Phantom	3	UAS	that	will	be	operated	by	Dane	

Harold	Evans	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,	Dane	Harold	Evans,	pursuant	to	the	provisions	

of	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	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,	Dane	Harold	Evans	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,	Dane	Harold	Evans	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	requirments	for	

maintenance	that	only	apply	to	aircraft	with	an	airworthiness	

certificate.

Dane	Harold	Evans	submits	that	the	requested	relief	is	

proper	since	an	equivalent	level	of	safety	will	be	ensured.		

Dane	Harold	Evans	will	experienced	personnel	to	perform	

maintenance	and	checks	on	the	Phantom	UAS	in	accordance	

with	the	owner’s	manual.		In	addition,	Dane	Harold	Evans	will	

document	all maintenance	items	for	the	DJI	Phantom	3	UAS.

Relief	from	certain	requirements	of	Section	61.113(a)	and	

(b),	entitled	private	pilot	privileges	and	limitations:	Pilot	in	
Command,	is	requested	by	Dane	Harold	Evans	to	the	extent	

necessary	to	allow	a	Pilot	in Command	(PIC)	holding	a	private	

pilot	or	higher	level	certificate,	as	well	as	an	airman	1st Class	

Medical	Certificate,	and	who	as	demonstrated,	by	meeting	

flight	hour	currency	requirements,	that	the	PIC	is	able	to	safely	

operate	the	DJI	Phantom	3	UAS	in	a manner	consistent	with	

this	exemption,	including	evasive	and	emergency	maneuvers	

and	maintaining	appropriate	distances	from	people,	vessels,	

vehicle	and	structures.

Dane	Harold	Evans	seeks	relief	from	91.7(a),	entitled	Civil	

Aircraft	Airworthiness,	because	the	DJI	Phantom	3	UAS	does	not	

require	an	airworthiness	certificate	in	accordance	with	14	

C.F.R.	Part	21,	Subpart	H.			As	such,	Dane	Harold	Evans submits	

that	he	will	ensure	the	DJI	Phantom	3	UAS	are	in	an	airworthy	

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

compliance	with	operating	documents(i.e.,	Maintenance	Log,	

DJI	Phantom	3	Instruction	Manual),	and	that	the	aircraft	are	in	

a	condition	for	safe	flight.

Dane	Harold	Evans	also	seeks	an	exemption	from	the	

requirements	of	Section 91.121,	entitled	Altimeter	Settings,	as	

the	DJI	Phantom	3	UAS	does	not	have	an adjustable	barometric	

altimeter	onboard.		However,	altitude	information	of	the	DJI

Phantom	will	be	displayed	to	the	PIC	via	Global	Positioning	

System	(GPS)	equipment	and	radiot communications	telemetry	

date	link,	which	downlinks	from	the	UAS	to	the	GCS	for	active	

monitoring	of	the	flight	path.		This	altitude	information,	

combined	with	Dane	Harold	Evans’	operation	of	the	DJI	

Phantom	3	within	visual	line	of	sight	(VLOS),	at	or	below	400	

feet	AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	

91.121.
Additionally,	Dane	Harold	Evans seeks	an	exemption	from	

the	requirements	of	Section	91.151(b),	entitled	Fuel	

requirements	for	flight	in VFR	conditions.	Dane	Harold	Evans

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	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,	Dane	Harold	Evans

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:

Dane	Harold	Evans

318	Lindbergh	Dr	NE

Atlanta,	GA	30305

404.219.5980

email:	evans.dane@gmail.com

B.	The	specific	sections	of	14	C.F.R	from	which	Dane	

Harold	Evans	seeks	exemption

1.	Dane	Harold	Evans	seeks	exemption	from	the	

requirements	of	Section	91.7(a),	entitled	Civil	

Aircraft	Airworthiness,	subsection	(a),	states	the	

following:

-(a)	No	person	may	operate	a	civil	aircraft	

unless	it	is	in	an	airworthy	condition.
2.	Dane	Harold	Evans	seeks	exemption	from	the	

requirements	of	Section	91.121,	entitled	Altimeter	

Settings,	subsection(a),	states	the following,	in	part:

(a)	Each	person	operating	an	aircraft	shall	maintain	

cruising	altitude	or	flight	level	of	that	aircraft,	as	the	

case	my	be,	by	reference	to	an	altimeter	that	is	set,	

when	operating:

(1)Below	18,000	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.

3.		Dane	Harold	evans 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.

4.		Dane	Harold	Evans 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[.]

5.		Dane	Harold	Evans 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[.]

6.		Dane	Harold	Evans	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.

7.	Dane	Harold	Evans 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	Dane	Harold	Evans	Seeks	And	

The	Reason	Dane	Harold	Evans	Seeks	The	Relief.
1.	Extent	Of	Relief	Dane	Harold	Evans	Seeks	And	The	

Reason	Dane	Harold	Evans	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,	Dane	Harold	Evans submits	that	an	

equivalent	level of	safety	will	be	maintained	because	no	

PIC	will	be	allowed	to	operate	the	DJI	Phantom	3	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	in	a	manner	

consistent	with	the	operations specifications	as	described	

in	this	exemption,	including evasive	and	emergency

maneuvers,	as	well	as	maintaining	appropriate	distances	

from	people,	vessels,	vehicles and	structures.
Further,	Dane	Harold	Evans	submits	that	all	flights	of	the	

DJI	Phantom	3	UAS,	conducted	by	the	PIC	pursuant	to	the	

grant	of	this	Petition:	(1) will	be	incidental	to	Dane	

Harold	Evans	business;	and	(2)	will	not	carry	passengers	

or property	for	compensation	or	hire.

2.	Extent	Of	Relief	Dane	Harold	Evans Seeks	And	The	

Reason	Thomas	N.	Black	Seeks	Relief	From	Section	

91.7(a).	Relief	from	Section	91.7(a)	entitled	Civil	aircraft	

airworthiness,	is	requested	to	the	extent	required	to	allow	

Dane	Harold	Evans to	determine	that	the	DJI	Phantom	3	

UAS	is	in	airworthy	condition	prior	to	every	flight	by	

ensuring	that	the	UAS	is	in	compliance	with	the	operating	

documents	(i.e.,	Monthly	Maintenance	Log,	and	DJI	

Phantom	3	Instruction	Manual).	Thomas	N.	Black	seeks	

the	requested	relief	because	the	DJI	Phantom	3	UAS does

not	require	an	airworthiness	certificate	in	accordance	

with	14	C.F.R.	Part	21,	Subpart	H.	Therefore,	Dane	Harold	

Evans	will	ensure	that	the	DJI	Phantom	3	UAS are	in	

airworthy	condition	based	upon	its	compliance	with	the	

operating	documents	(i.e.,	Monthly	Maintenance	Log,	and	

DJI	Phantom	3 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	Dane	Harold	Evans Seeks	And	The	

Reason	Dane	Harold	Evans 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,	which	utilize	a barometric	pressure	sensor,	

GPS	equipment,	and	a	radio	communications	telemetry	

data link	to	downlink	altitude	information	from	the	UAS	

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),	Dane	Harold	Evans seeks	

the	requested	relief	because	the	DJI	Phantom	3	UAS

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	UAS are	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	UA	on	

the	heads-up	display	of	the	GCS.

4.	Extent	Of	Relief	Dane	Harold	Evans Seeks	And	The	

Reason	Thomas	N.	Black	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	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.	Dane	

Harold	Evans the	requested	relief	because	without	an	

exemption	from	Section	91.151(b),	the	flight	time	

duration	of	the	battery	powered	DJI	Phantom	3	UAS will	

severely	constrain	the	practicality	of	any	aerial	video	or	

still	photo	flight	operations	that	Dane	Harold	Evans

proposes	to	conduct	pursuant	to	this	Petition.	

Significantly,	as set	forth	below,	the	technical	

specifications	of	the	DJI	Phantom	3 UAS,	the	DJI	Phantom	

3	operating	documents,	and	Dane	Harold	Evans proposed	

operating	limitations,	ensure	that	Dane	Harold	Evans will	

safely	operate	the	battery	powered	DJI	Phantom	3	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	Dane	Harold	Evans	Seeks	And	The	

Reason	Dane	Harold	Evans	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,	Dane	Harold	Evans requests

relief	from	these	Sections	because	the	DJI	Phantom	3	UAS	

do not	require	airworthiness	certificates.	As	set	forth	

more	fully	below,	the	DJI	Phantom	3	UAS	meet	the	

conditions	of	FMRA	Section	333	for	operation without	an	

airworthiness	certificate.	Accordingly,	Thomas	N.	Black	
will	use	trained technicians	to	perform	maintenance,	

alterations,	or	preventive	maintenance	on	the	UASs

using	the	methods,	techniques,	and	practices	prescribed	

in	the	UAS	operating	documents(i.e.,	Monthly	

Maintenance	Log,	andDJI	Phantom	3	Instruction	Manual).	

Dane	Harold	Evans will	document	and	maintain	all	

maintenance	records	for	the	DJI	Phantom	3	UAS.

D.	The	Reasons	Why	Granting	Dane	Harold	Evans	

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	Dane	Harold	Evans	to	safely,	

efficiently,	and	economically	perform	aerial	video	and	

photography	of construction	sites,	real	estate,	and	

landscape	over	certain	areas	of	the	United	States.

Additionally,	use	of	the	DJI	Phantom	3	UAS	will

decrease	congestion	of	the	NAS,	reduce	pollution,	and	

provide	significant	benefits	to	the economy.	Notably,	the	

benefits	of	Dane	Harold	Evans proposed	operation	of	the	

DJI Phantom	3	UAS	will	be	realized	without	implicating	

any privacy	issues.

1. The	Public	Will	Benefit	From Decreased	Congestion	

Of	The	NAS. The	DJI	Phantom	3	UAS	are	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	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	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	UAS.		Conducting	

aerial	acquisitions	with	the	DJI	Phantom 3	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	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	UAS	while	reducing	the	carbon	

footprint	of	aerial acquisitions,	also eliminates	noise	

pollution,	as	the	UAs	are	propelled	by	battery	powered

electric	motors,	rather	than	an	internal	combustion	

engine. By	using	the	DJI	Phantom	2	Vision+	and	DJI	

Inspire	1	UASs	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	2	Vision+	and	DJI	

Inspire	1	UAs	(weighing	approximately	2	pounds	11	at	its	

maximum	gross	weights	with	a	length of	16	inches	and	

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	UAS Will	Benefit	The	Economy.

In	addition	to	being	safe	and	efficient,	the	DJI	Phantom	3

are	also	an	economical	alternative	to	using	manned	

aircraft	to	conduct	similar aerial	operations.	As	such,	

operation	of	the	DJI	Phantom	3	will	allow	United	States	

based	invididuals,	like	Dane	Harold	Evans,	to	remain

competitive	and	contribute	to	growth	of	the	U.S.	economy.	

Specifically,	with	the	rising ost	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	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	UAS	as	Dane	Harold	Evans,	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,	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	remaim	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,	Dane	Harold	Evans

proposed	operation	of	the	DJI	Phantom	3	UAS	will	not	

implicate	any	privacy	issues.	Specifically,	the	DJI	Phantom	

3	UAS will	be	operated	only	in	compliance	with	operating

documents	(i.e.,	Operations	Manual,	Monthly	

Maintenance Log,	and	DJI	Phantom	3	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	Dane	Harold	

Evans	Seeks	Exemption.	

1.	Reasons	Why	The	DJI	Phantom	3	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,	Dane	Harold	Evans operation	of	the	DJI	

Phantom	3	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,	Thomas	N.	Black	submits	that	

the	DJI	Phantom	3	UAS can	operate	safely	in	the	NAS	

pursuant	to	FMRA	Section	333,	as	demonstrated	by:	(a)	

the	characteristics	of	the	DJI	Phantom	3	UAS;	(b)	the	pilot	

certification	requirement;	and	(c)	the	specific	operating	

limitations.

a.	The Specifications	Of	The	DJI	Phantom	3	UAS	

Demonstrate	Its	Safe	Characteristics. The	DJI	Phantom	3	

UAS	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	UAS.

The	technical	specifications	of	the	DJI	Phantom	3	UAS	are	

set	forth	by	the	DJI	Phantom	3	Specifications	and Data	

Sheet,	attached	hereto	as	Exhibit	A	and	B.

ii.	The	DJI	Phantom	3	UAS	Autonomous Flight	And	

Navigation	Modes	Enable	The	UAS To	Remain	Within a	
Defined	Operational	Area.	 The	DJI	Phantom	3	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	UAS	pages	25-

35	of	the	DJI	Phantom	3	and	pages	12-16	User	Manuals,	

attached	hereto	as	Exhibit	C	and	D.

iii.	The	DJI	Phantom	3	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 2	UAS	will	

remain	stationary,	in	flight,	for	3	seconds	or	more.	If,	after	

3	seconds,	the	DJI Phantom	3	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	UAS	are	set	forth	at	pages	27	through	29	

and13	through	15

of	the	DJI	Phantom	3 User	Manuals,	attached	hereto	as	

Exhibit C	and	D.

iv.	The	DJI	Phantom	2	Vision+	and	DJI	Inspire	1	GCS	And	

Its Operation. A	complete	description	of	the	operation	

and	specifications	of	the	DJI	Phantom 3GCS	and	flight	

control	software	is	provided	at	pages	32

through	43	of	the	DJI	Phantom	3User	Manual	and	pages	

40	through	47	DJI	Manual.	DJI	Phantom	3	User	Manuals	

are attached	hereto	as	Exhibits	C	and	D.

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

The	Line	Of	Sight	Of	A	Certificated Pilot	in	Command

With	A	Safety	Observer. Dane	Harold	Evans 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.		Additionally,	a	safety	

observer	will	assist	all	pilots during	flight	time.

c.	Flights	Of	DJI	Phantom 3	UAS Will	Be Conducted	

Pursuant	To	Specific	Operating	Limitations.

In	seeking	this	exemption,	Dane	Harold	Evans proposes	

to	commercially	operate DJI	Phantom	3	UAS	the	special	

purpose	of	conducting aerial	video	and	photography	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 Unmanned	Aircraft	Systems.	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.

3.	The	UAS may	not	be	flown	at	an	indicated	airspeed	

exceeding	20	knots.

4.	The	UAS 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	or	

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	at	least	a	private	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	

UAS	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	FAApublished	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 pre- determined	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	(N- Number)	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.
Dane	Harold	Evans 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 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	UAS	in	a	manner	consistent	with	the

exemption,	including	evasive	and	emergency	maneuvers	

and	maintaining	appropriate distances	from	people,	

vessels,	vehicles	and	structures. Considering	Dane	Harold	

Evans 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	UAS,	Dane	Harold	Evans

submits	that	the	additional	manned	airmanship

experience	of	a	commercially	certificated	pilot	would	not	

correlate	to	the	airmanship skills	necessary	for Dane	

Harold	Evans	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). Dane	Harold	Evans will	not	allow	any	PIC	

to	operate	the	DJI	Phantom	3	UAS	unless	that	PIC	has	

demonstrated,	by	meeting	minimum	flight-hour

requirements	or	the	DJI	Phantom	3	UAS	training	and	

currency requirements,	that	the	PIC	is	able	to	safely	

operate	the	DJI	Phantom	3	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	Thomas	N.	Black’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	multirotor	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	experiencebuilding	flights	can	also	be conducted	under	the	

grant	of	exemption	to	accomplish	the	required	flight	

time.

During	training,	proficiency,	and	experiencebuilding 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,	Thomas	N.	

Black	will	ensure	safe	operations	by	not	allowing	any

PIC	to	operate	the	DJI	Phantom	3	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	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,	

Dane	Harold	Evans will	ensure	that	the	DJI	Phantom	3

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	91.121Would	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	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	Dane	Harold	

Evans	operation of	the	DJI	Phantom 3	UAS within	visual	

line	of	sight,	at	or below	500	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	UAS (2)	the	limitations	on	the	proposed	flight

operations;	and	(3)	the	location	of	the	proposed	flight	

operations.	Accordingly,	Dane	Harold	Evans	will	ensure	

that	it	will	safely	operate	the	battery	powered	DJI	

Phantom	3	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	UAS;	the	limitations	on	the	proposed	flight	operations;	

andthe	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	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	UAS	will	

descend	and	land	automatically.		Significantly,	previous	

exemptions	granted	by	the	FAA	concerning	Section	

91.151establish	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,	Thomas	N.	Black	submits	that	

the	Dane	Harold	Evans 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	Dane	Harold	Evans will	use	trained	technicians	

to	perform maintenance,	alterations,	or	preventive	

maintenance	on	the	UASs	using	the	methods, techniques,

and	practices	prescribed	in	the	operating	documents	(i.e.,	
the	Dane	Harold	Evans Aerial	Operations	Manual,	

Monthly	Maintenance	Log,	and	DJI	Phantom	3	Instruction	

Manual).	Furthermore,	Thomas	N.	Black	will	document	

and maintain	all	maintenance	records	for	the	DJI	

Phantom	3	UAS.		Since	the	DJI	Phantom	3	UAS	will	be	

inspected	as prescribed	by	the	operating	documents,	

Dane	Harold	Evans 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	User	Manuals	are	attached	hereto	as

Exhibit	C	and	D;	a	copy	of	the	DJI	Phantom	3	UAS

Maintenance	LOG	is	attached	hereto	as	Exhibit	E.

Likewise,	the	exemption	sought	will	not	adversely	affect	

safety	because	Dane	Harold	Evans	will	use	trained	

technicians	to	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),	

because	all	maintenance	of	the DJI	Phantom	3	UAS will	be	

performed	by	trained	technicians. 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	Dane	Harold	Evans proposed	

operating	limitations,	the	

operating	documents,	and	the	technical	aspects	of	the	DJI	

Phantom	3	UAS,	Dane	Harold	Evans 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,	Dane	Harold	Evans	requests	

that	the	FAA	prescribe	special	conditions	for	the	intended	

operation	of	the	DJI Phantom 3	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	

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	an	

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	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	Thomas	N	Black	Seeks	Exemption:

Dane	Harold	Evans 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	Dane	Harold	Evans

Seeks:	This	exemption	will	permit	Dane	Harold	Evans to	

commercially	operate	an Unmanned	Aircraft	System	

(UAS)	for	the purpose	of	conducting	aerial	video	and

photography	over	certain	areas	of	the	United	States.

•	Any	Additional	Information,	Views,	Or	Arguments	

Available	To	Support	Dane	Harold	Evans	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,	Dane	

Harold	Evans 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,	Thomas	N	Black	will	operate	

the	DJI	Phantom	3	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,	Thomas	N	Black	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	UAS	commercially,

without	an	airworthiness	certificate,	for	the	limited	purpose	of	

conducting	aerial	video	and	photography	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	Dane	Harold	

Evans to	safely,	efficiently,	and	economically	operate	the	DJI	

Phantom	3	UAS commercially	within	the	NAS.	WHEREFORE,	in	

accordance	with	the	Federal	Aviation	Regulations	and	the	FAA	

Modernization	and	Reform	Act	of	2012,	Section	333,	Thomas	N	

Black	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	Thomas	N	Black	to	operate	the	DJI	Phantom	3	UAS	

commercially	for	the	purpose	of	conducting	aerial	video	and	
photography	over	certain	areas	of	the	United	States.	Dated:	

June	19,	2015

Respectfully	submitted,

Dane	Harold	Evans

___________________________________

Dane	Harold	Evans

Dane	Harold	Evans

318	Lindbergh	Dr	NE

Atlanta,	GA	30305

404.219.5980
APPENDIX	A:	DJI	PHANTOM	3	TECHNICAL	

SPECIFICATIONS

1.1	DJI	Phantom	

1.1.1	Aircraft

1.1.1.1	Supported	Battery	– DJI	6000mAH	LiPo	

Battery	

1.1.1.2	Weight	(Battery	& Propellers	Included)	–

2.65lbs

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