June 30, 2015

Exemption No. 11958

Regulatory Docket No. FAA–2015–1197

Mr. Terence G. Haglund

205-B Bulifants Boulevard

Williamsburg, VA 23188

Dear Mr. Haglund:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 17, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct aerial photography and videography.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+.

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. In accordance with the statutory criteria 

provided in Section 333 of Public Law 112−95 in reference to 49 U.S.C. § 44704, and in 

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

aircraft and its operation, the Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 
2

14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness 

Certificates, and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Terence G. Haglund is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to 

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection.

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Terence G. Haglund is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
3

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

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

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

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

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times; 

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 VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein 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 or any law enforcement official upon request. The 
4

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an 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.

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

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

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is 

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
5

(training, proficiency, and experience-building) and determining the PIC’s ability to 

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

under this exemption are permitted under the terms of this exemption. However, 

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

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

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

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

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

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. 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.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

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

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

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

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

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

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

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

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

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects 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.

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

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
7

30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

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

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

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

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

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

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.
8

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

John S. Duncan

Director, Flight Standards Service

Enclosures
17 April 2015 

The following petition is submitted by TERENCE G. HAGLUND, Petitioner, and made to

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

for an exemption from Title 14, Code of Federal Regulations (14 CFR) Sections 

45.23(a)(b); 45.27(a); 45.29; 47.15; 91.7(a); 91.119(b)(c); 91.121, 91.151(a); 91.405(a); 

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

ALL OPERATIONS WILL BE CONDUCTED BELOW 200 FEET, WITHIN 

VISUAL-LINE-OF-SIGHT, DURING DAYLIGHT HOURS AND ROUGHLY 

FIVE MILES AWAY FROM ANY AIRPORT OR HELIPORT LOCATION.

PREVIOUS GRANT OF EXEMPTION

I submit the following approved exemption as reference (a):

Exemption No. 11191 / Regulatory Docket No. FAA–2014–0915

By letter dated July 12, 2014, Mr. Michael Singer of Singer’s Creations, of Harrisburg, 

PA., petitioned the Federal Aviation Administration (FAA) for an exemption from 14 CFR 

Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.109; 14 CFR 91.121; 14 

CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(l); 14 CFR 91.409 (a)(l); 14 

CFR 91.409 (a)(2); 14 CFR 91.417 (a) and (b) of Title 14, Code of Federal Regulations 

(14CFR). The proposed exemption would allow Singer’s Creations to operate the 

PHANTOM 2 Vision+ quadcopter unmanned aircraft system (UAS) to conduct aerial 

videography and cinematography to enhance academic community awareness for those 

individuals and companies unfamiliar with the geographical layout of the metro Tucson 

area and augment real estate listing videos.

The FAAs decision pertaining to Exemption No. 11191:
“In consideration of the foregoing, I find that a grant of exemption is in the public 

interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113,and 

44701, delegated to me by the Administrator, Singer’s Creations is granted an 

exemption from 14 CFR §§ 61.113(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 

91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b) to the extent 

necessary to conduct aerial photography and videography for homeowners, realtors, 

home builders, home contractors, and/or home inspectors for use in real estate 

marketing and inspections of home exteriors.”

************

CURRENT PETITION FOR EXEMPTION

I, TERENCE G. HAGLUND, submit the following:

Summary of request

I am submitting this petition pursuant to the FAA Modernization and Reform Act of 2012 

and the procedures contained within 14 C.F.R. 11, so that I may operate the DJI 

PHANTOM 2 Vision+ (or similar, should newer, safer and/or more advanced models 

become available) quadcopter unmanned aircraft system (UAS) for the limited purpose 

of conducting aerial photography and videography below 200 feet AGL and further than 

5 miles from any airport or heliport, in order to safely and legally capture aerial 

photography and videography for use by owners of commercial and residential 

properties, building contractors and inspectors, developers, realty agents, and for the 

inspection of stacks, towers, bridges, power lines, wind turbines, generating facilities 

and other infrastructure. for compensation or hire. I will also offer at no charge aerial 

photo/video services to law enforcement and other first responder agencies.

In reference (a), Exemption No. 11191 (which is essentially identical to my request), an 

exemption was approved for an individual with no pilot certificate or experience. I 

currently hold a commercial pilot certificate, MEL, SEL, and instrument ratings. I 
formerly held certificated flight instructor and advanced ground instructor certificates. I 

will be supporting my request with the following information:

1) Uploaded file Drone Exemption Request – Terence G. Haglund.pdf, 2) PHANTOM 

Flying Flow Chart V1.0 (Simplified Version); 3) PHANTOM 2 Vision+ Quick Start Guide, 

4) PHANTOM 2 Vision+ Pilot Training Guide v1.1; 5) PHANTOM 2 Vision+ User 

Manual v1.8, (all hereinafter referred to as operating documents); and 6) Personal 

protocols and controls.

I believe my request for exemption as outlined in the uploaded file Drone Exemption 

Request – Terence G. Haglund.pdf is warranted in this case and respectfully request 

that it be granted without termination date for the reasons I have stated therein. Aerial 

photography and videography operations for private and/or commercial properties and 

businesses benefit the public with enhanced perspectives of characteristics, amenities, 

and benefits a property has that cannot be displayed through ground level photography 

and videography. Aerial videography and photography for inspections of stacks, towers, 

bridges, power lines, wind turbines, generating facilities and other infrastructure

provides a much higher level of safety to the public and the structures at a fraction of the 

cost and without the burning of fossil fuels which contaminate the atmosphere. And 

while this is essentially the same request as the one granted under Exemption No. 

11191 / Regulatory Docket No. FAA–2014–0915, my request goes further in that I 

currently hold a commercial pilot certificate.

Thank you for your time and attention to my request.

Yours truly,

Terence G. Haglund
17 April 2015

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590

RE: REQUEST FOR EXEMPTION UNDER SECTION 333 FROM 14 CFR PART 21, 

SUBPART H; 14 CFR 61.113 (A) AND (B); 14 CFR 91.109; 14 CFR 91.121; 14 CFR 91.151; 

(A); 14 CFR 91.405 (A); 14 CFR 91.407 (A)(L); 14 CFR 91.409 (A)(L); 14 CFR 91.409 (A)(2); 

14 CFR 91.417 (A) AND (B) 

Dear Sir or Madam: 

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

Reform Act) and 14 CFR Part 11, Petitioner hereby applies for an exemption from the 

listed Federal Aviation Regulations (FARs) to allow commercial use of its Small 

Unmanned Aircraft Systems (SUASs), so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

An exemption is being requested because (1) existing regulations will burden Petitioner, 

(2) Petitioner can provide a level of safety that is equal (or greater than in many cases) 

to those provided by existing rules, and (3) the request is in the public interest. The 

FAA's authority to issue exemptions from operating rules, and the Secretary's authority 

granted by Section 333 of P.L. 112-95, Special Rules for Certain Unmanned Aircraft 

Systems, provide an opportunity to authorize certain SUAS operations in the National 

Airspace System (NAS) prior to implementation of the SUAS rule. This incremental step 
will allow Petitioner to safely and legally enter into the NAS. 

As described in detail below, the requested exemption would permit Petitioner to 

operate SUASs under controlled conditions in airspace that is (1) limited, (2) 

predetermined, (3) controlled as to access, and (4) would provide safety enhancements 

to the already safe operations of those aircraft of similar size, weight, speed, and 

operating capability that have been granted entry into the NAS via the rules in Academy 

of Model Aeronautics (AMA) National Aircraft Safety Code.1

ALL COMMERCIAL OPERATIONS WILL BE CONDUCTED BELOW 200 

FEET, WITHIN VISUAL-LINE-OF-SIGHT, DURING DAYLIGHT HOURS 

AND ROUGHLY FIVE MILES AWAY FROM ANY AIRPORT OR HELIPORT 

LOCATION.

Approval of this exemption would thereby greatly enhance safety and fulfill the 

Secretary of Transportation's (the Secretary) responsibilities to " ... establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system" per Section 333 (c) of the Reform Act.2

Petitioner is requesting exemption from the following regulations: 

14 CFR Part 21, Subpart H 14 

CFR 61.23 (a) 

14 CFR 61.113 (a) and (b) 14 

CFR 91.109 

14 CFR 91.121 

14 CFR 91.151 (a) 14 

																																																							 1 See the attached" AMA SafetyCode.pdf document.

2 Petitioner interprets this provision to place the duty on the Secretary to not only process applications for 

exemptions under section 333 of the Reform Act, but for the Secretary to craft conditions for safe 

operations of SUAS, if it should be determined that the conditions set forth herein do not fulfill the 

statutory requirements for approval.
CFR 91.405 (a) 14 CFR 

91.407 (a)(l) 14 CFR 

91.409 (a)(l) 14 CFR 

91.409 (a)(2) 

14 CFR 91.417 (a) and (b) 

This exemption application is expressly submitted to fulfill Congress' goal in passing 

Section 333 (a) through (c) of the Reform Act. This law directs the Secretary to consider 

whether certain unmanned aircraft systems may operate safely in the NAS before 

completion of the rulemaking required under Section 332 of the Reform Act. In making 

this determination, the Secretary is required to determine which types of SUAS’ do not 

create a hazard to users of the NAS, to the public, or pose a threat to national security. 

Section 333 of the Reform Act grants the Secretary authority to determine (1) if an 

unmanned aircraft system, as a result of its size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation within visual line of sight 

(VLOS) does not create a hazard to users of the NAS or the public, or pose a threat to 

national security, and (2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under 49 USC 44704 is required for the operation of civil 

(nongovernmental) UASs. Therefore, if the Secretary determines that such vehicles 

"may operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft in the national airspace system". 3

Operation Overview 

Petitioner’s DJI Phantom 2 Vision+ (“SUAS”) is a quadcopter, weighing 3 or fewer Ibs. 

(including payload). The aircraft has the capability to hover and move in the vertical and 

horizontal planes simultaneously. They will operate only in visual line of slight (VLOS) 

and will operate only in tightly controlled and limited airspace. They are capable of 

operating at speeds of up to 29 knots, but will be routinely operated at much lower 

																																																							 3 Reform Act Section 333 (b)
speeds. They will routinely be operated below 200 feet above ground level (AGL), and 

unless and until regulations permit otherwise, never about 400 feet AGL.

Aerial photography and videography services will be offered for use by owners of 

commercial and residential properties, building contractors and inspectors, developers, 

realty agents, law enforcement and other first responders, and for the inspection of 

stacks, towers, bridges, power lines, wind turbines, generating facilities and other 

infrastructure. All operations (with the possible exception of assisting law 

enforcement/first responders) will be conducted on private property and with the written 

and/or oral permission of the property owner(s). Operations will always be conducted in 

areas that are clear of people, except the pilot in command (PIC) and the PIC's 

helper(s). Such operations will ensure that the UAS will "not create a hazard to users of 

the national airspace system or the public" 4

Aircraft 

Petitioner operates a Phantom 2 Vision+ (Phantom) SUAS manufactured by DJI, a wellknown leader in quadcopter technology. DJI strives to bring new perspectives to aerial 

work and helps companies accomplish feats safer, faster, and with greater efficiency. 

They have an unparalleled commitment to R&D, a culture of constant innovation, and a 

focus on transforming complex technology into easy-to-use devices. 

The standard Phantom quadcopter package includes the Phantom itself, camera, 

gimbal, propulsion system, flight control system, 5.8 GHz remote controller, and 2.4 

GHz Wi-Fi communication system. The remote uses a 5.8 GHz frequency to prevent 

interference with the video/telemetry channel. This second channel allows for a 

constant connection with the Phantom to monitor it via a smartphone that is attached to 

the remote controller. 

The Phantom is about 1 foot square in size. It has a maximum ascent speed of 11 

																																																							 4 http://www.dji.com/product/phantom-2-vision-plus
knots, a maximum descent speed of 3 knots, and a maximum flight speed of 29 knots. 

While operating within VLOS, the remote control has a range of 2,624 feet. The total

weight (including the payload) is 2.55 pounds. 5

The Phantom is equipped with a DJI Naza-M V2 flight control system. This provides for 

incredible ease of use and stability. Pilots can control the Phantom's movements in 

many directions - including forward and backward, climb and descend, yaw (turn left 

and right), and roll (bank left or right). The flight control system can also provide 

Intelligent Orientation Control (IOC), failsafe, battery level warnings, and show the 

aircraft's current heading, direction, and approximate distance from home on the onscreen radar. The built-in GPS system aids in stabilizing the aircraft and automatically 

and safely returns it back to its home point if communication between the remote 

control and quadcopter are lost or the battery level becomes too low. 

The Inertial Measurement Unit (IMU) has a built-in inertial sensor and a barometric 

altimeter that measures both attitude (ATTI) and altitude. The inertial measurement tells 

the Phantom how it's tilted. And the gyros tell it if it's rotating in any particular direction. 

The Phantom's compass reads geomagnetic information and assists the Global 

Positioning System (GPS) to accurately calculate the position and height of the aircraft. 

The vertical hover accuracy is +/- 2.6 ft. The horizontal hover accuracy is +/- 8.2 ft. 

The Phantom has LED flight indicators beneath each of its four rotor arms. The LEDs 

illuminate to indicate the status of the flight control system and alert the PIC of any 

possible issues. 

Such highly advanced capabilities will ensure that the Phantom can be safely operated and 

"not create a hazard to users of the national airspace system or the public." 6

																																																							 5 http://www.dji.com/product/phantom-2-vision/spec

6 Reform Act Section 333 (b)
Equivalent Level of Safety 

In an effort to join the FAA in its mission to provide the safest, most efficient aerospace 

system in the world and to minimize the risk to the NAS or to persons and property on 

the ground, Petitioner agrees to be bound by the following limitations and conditions 

when conducting commercial operations under an FAA issued exemption: 

A. For the purposes of ensuring the aircraft will be operated within the standards 

that the FAA has allowed in the AMA National Model Aircraft Safety Code, except 

as modified or superseded by the proposed FAR Part 107: 

1. SUASs will not be flown: 

a. In a careless or reckless manner. 

b. At a location where SUAS activities are prohibited. 

2. SUAS pilots will: 

a. Yield the right of way to all human-carrying aircraft. 

b. See and avoid all aircraft and a spotter will be used when 

appropriate. 7

c. Not conduct commercial operations higher than 200 feet above 

ground level or within five (5) miles of an airport or heliport without 

notifying the airport operator, until such time as the FARs have 

been written or revised to permit higher flights or flights closer to an 

airport. 

d. Not interfere with operations and traffic patterns at any airport, 

heliport or seaplane base except where there is a mixed-use 

agreement. 

e. Not exceed a takeoff weight of 55 pounds (including payload). 

f. Ensure that the aircraft is identified by affixing the owner's contact 

information to the outside of the SUAS. 

																																																							 7 AMA Document #540-D
g. Not operate SUAS while under the influence of alcohol or while 

using any drug that could adversely affect the PIC's ability to safely 

control the model. 

h. Not operate SUASs carrying pyrotechnic devices that explode or 

burn, or any device that propels a projectile or drops any object that 

creates a hazard to persons or property. 

3. SUASs will not be flown unless: 

a. The aircraft, control system and pilot skills have successfully 

demonstrated all maneuvers intended or anticipated prior to the 

specific event. 

b. An inexperienced pilot is assisted by an experienced pilot. 

4. All pilots will avoid flying directly over unprotected people, vessels, 

vehicles or structures and shall avoid endangerment of life and property of 

others. 

5. A successful radio equipment ground-range check in accordance 

with manufacturer's recommendations will be completed before the first flight of a 

new or repaired model aircraft. 

6. SUASs will use the radio-control frequencies currently allowed by 

the Federal Communications Commission (FCC). 

7. SUASs will not knowingly operate within five (5) miles of any preexisting flying site without a frequency-management agreement.8

8. Excluding takeoff and landing, no SUASs will be flown outdoors 

closer than 25 feet to any individual, except for the PIC and the PIC's 

helper(s) located at the takeoff/landing site. 

9. Under no circumstances will a pilot or other person touch a SUAS 

in flight while it is still under power, except to divert it from striking an 

individual. 

10. The PIC of the SUAS shall: 

a. Maintain control during the entire flight, maintaining visual 

																																																							 8 AMA Documents #922 and #923
contact without enhancement other than by corrective lenses 

prescribed for the pilot. 

b. Fly using the assistance of a camera or First-Person View (FPV) 

only in accordance with the procedures outlined in AMA Document 

#550. 

c. Fly using the assistance of autopilot or stabilization system only 

in accordance with the procedures outlined in AMA Document 

#560. 

11. The flying area will be clear of all utility wires or poles and, except 

for utility line inspections, an SUAV will not be flown closer than 50 feet to 

any above-ground electric utility lines. 

12. The flying area will be clear before the engines are started, except 

for PIC and the PIC's helper(s). 

B. In addition to the above rules outlined by the AMA National Model Aircraft 

Safety Code and in an effort to enhance the safety offered by the already safe 

operations mentioned above, Petitioner also agrees to be bound by the following 

limitations and conditions: 

1. Flights will be operated within VLOS of the PIC. 

2. Maximum total flight time for each operational flight will be 30

minutes. Flights will be terminated at 25% battery power reserve should 

that occur prior to the 30 minute limit. 

3. The SUAS will only operate in tightly controlled and limited 

airspace. 

4. A briefing will be conducted in regard to the planned SUAS 

operations prior to each flight. It will be mandatory that all personnel who 

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

present for this briefing. 

5. The PIC and the PIC's helper(s) will have been trained in operation 

of SUAS and received up-to-date information on the particular SUAS to be 
operated. 

6. The pilot and the PIC's helper(s) will at all times be able to 

communicate by voice. 

7. If the SUAS loses communications or loses its GPS signal, the 

SUAS will have capability to return to a pre-determined location within the 

security perimeter and safely land. 

8. The SUAS will have the capability to abort a flight in case of 

unpredicted obstacles or emergencies. 

9. With the possible exception of flights conducted in support of law 

enforcement/first responder operations, all flights will be conducted on 

private property and with the written and/or oral permission of the property 

owner(s). 

10. Flights will always be conducted in areas that are clear of all

people, except for the PIC and the PIC's helper(s). 

11. All flights will be conducted outdoors in visual meteorological 

conditions (VMC) and never during severe weather conditions. 

12. Flights will not occur in weather conditions that prevent the PIC 

from operating within visual line-of-sight (VLOS) at all times or in weather 

conditions that dramatically affect the UAS's flight (e.g. high winds). 

13. If an operation occurs in an area where people could inadvertently 

enter the area, an operational border will be established with traffic cones. 

If it is not feasible to use traffic cones due to interference with the 

photography/videography, the PIC's helper(s) will be responsible for 

keeping a safe perimeter around the operation. The operation will cease 

immediately and be rescheduled if it is impossible to establish a safe 

perimeter around the operation. 

The operation of SUAS weighing less than 3 pounds, conducted in the strict conditions 

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

exemptions requested herein, including exempting the applicant from the requirements 
of Part 21 and allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground, and in a tightly 

controlled environment. As a result, they offer a much safer way to capture aerial 

photography and videography. Furthermore, the proposed operations represent a 

safety enhancement to the already safe operations that have been granted by the FAA 

for the establishment of the AMA National Model Aircraft Safety Code. 

Preflight Action Plan

The PIC will follow a comprehensive pre-flight checklist to ensure that the SUAS is in a 

condition for safe flight. This plan will be revised as needed in order to ensure all known 

safety precautions and/or safety precautions suggested by the manufacturer are being 

accounted for. 

A. Pre-flight Inspection 

1. Check that the remote control, aircraft battery, Wi-Fi range 

extender, and smartphone are all fully charged. 

2. Verify that the aircraft battery is not swollen or damaged in any way. 

Clean the contact needles and pads if necessary. 

3. Manually turn the motor shafts to verify they are smooth and 

without excessive play or binding. 

4. Verify that the propellers are mounted correctly. Propellers with a 

black top shall be mounted on the mount shafts that have a black dot.

Propellers with a silver top shall be mounted on the mount shafts that have 

a silver dot. Each propeller should spin all the way down onto the motor 

shaft. 

5. Run finger along the edge of edge of each rotor blade to check for 

any rough edges. 

6. Flex both sides of the rotor blades to check for hairline cracks 

where the blades connect in the center of the rotor. 
7. Verify that the landing gear is secure (not cracked/broken/loose). 

8. Verify that the compass and compass cable is firmly attached to the 

landing gear. 

9. Verify that the Micro-SD card has been inserted and formatted. 

10. Verify that the damping absorbers are not broken and/or worn. 

11. Verify that the anti-drop pins are in place and locked. 

12. Remove the gimbal guard and camera lens cap. 

13. Verify that the camera is secure and clean. Inspect the camera 

ribbon cables for tears and/or signs of wear. 

14. Verify that the smartphone's or tablet’s GPS is enabled. 

15. Set the smartphone or tablet to do-not-disturb mode to prevent 

distractions while flying. 

16. Set the smartphone or tablet to forget any Wi-Fi networks in range 

in order to prevent the Wi-Fi connection from changing mid-flight. 

17. Verify that the smartphone or tablet’s audio is on to ensure the low 

battery warning and other alarms can be heard. 

B. Power Up 

1. Verify that S1 and S2 switches are in the top position on the remote 

control. 

2. Power on the equipment in the following sequential order: 

a. Range Extender ("System" is blinking green; "Power" is solid 

green) 

b. Remote Control (2 beeps to indicate it's in FCC mode) 

c. Insert and start the Phantom battery. 

3. Watch the Phantom LED startup sequence for abnormal 

indications. The rear LEDs should blink green for at least 10-15 seconds 

to indicate that it locked onto 6+ satellites and has marked the home point 

(for use by the failsafe feature). 

4. Calibrate the Phantom's compass. 

5. Place the Phantom at least 10 feet away on open, flat ground with 
the battery indicators facing towards the PIC. 

C. DJI Vision Application 

1. Connect the smartphone or tablet Wi-Fi to the range extender. 

2. Launch the "DJI Vision" application on the smartphone. 

a. Verify that the Wi-Fi connection is "Phantom-#####" and is 

marked with a green dot. 

b. Verify the number of satellites is 6+. 

c. Verify the Wi-Fi signal strength. 

d. Verify that the Phantom and range extender batteries are 

reporting a full charge. 

e. Verify that both the PIC's and Phantom's location are the 

same before taking off to ensure the home point has been 

accurately marked. 

f. Verify the location of the Phantom in the "Flight Radar". If it's 

not in the correct position/direction and/or shows a distance of "N/ 

A", it did not mark the home point. 

g. Use the "Find my Phantom" feature to ensure the blue (home 

point location) and red (Phantom location) dots are in the same 

location on the screen. 

D. Ready to Fly 

1. Verify that the remote control antenna is perpendicular to the 

ground (pointing skyward). 

2. Verify that the front, flat face of the range extender is pointed 

toward the Phantom. 

3. Verify that the rear LEDs are still slowly blinking green and still 

connected to 6+ satellites. 

4. Start the Phantom motors using the CSC command on the remote 

control. 

5. Verify that the motors are functioning normally, are not making any 
unusual noises, and are all spinning at the same speed. 

6. Verify that the area is still clear of obstructions, people, power lines, 

etc. 

7. Take off and hover at about 6-8 feet above the takeoff point to 

verify that the Phantom has a solid GPS lock. If any abnormalities are 

noticed (drifting, flying in circles, etc.), land immediately and repeat the 

"Pre-flight Inspection" and "Power Up" sequences. 

8. Verify that the Phantom holds a steady position while yawing 360 

degrees. 

9. Verify that the Phantom response appropriately to all controls - yaw 

left/right, forward/backward, bank left/right, and throttle up/down. 

Preventative Maintenance 

A comprehensive preventative maintenance plan will be followed in order to ensure the 

SUAS's software is up-to-date, the batteries are in good health, and the aircraft itself is 

always ready for safe flight9. 

Pilot in Command (PIC) Qualifications 

The Petitioner is the holder of commercial pilot certificate 2133412, single and multi 

engine land, single engine sea, with and instrument rating, and is a former certificated 

flight instructor and advanced ground instructor. 

The Petitioner holds a Bachelor of Science degree in Business Administration (Aviation 

Administration) granted from the University of North Dakota. Courses in that curriculum 

included lengthy studies of aviation meteorology and airspace regulations and 

restrictions. Accordingly, It may be assumed that the Petitioner (with UH-34 Navy 

helicopter experience and over 1500 hours of fixed wing experience, along with 

hundreds of hours operating various radio controlled helicopters and quadrotors) has 

																																																							 9 See the "Preventative Maintenance Checklist" on page 41 of the attached "PhantomGuide.pdf" 

document.
the skill and ability to safely operate an unmanned aerial vehicle conducting commercial 

operations below 200 feet within strictly controlled, pre-approved airspace. Since there 

are no standards for either private or commercial SUAS pilot certificates, knowledge of 

airspace regulations and dexterity in the control and operation of the SUAS acquired 

from actual operation of the aircraft will be the most important factors in establishing an 

equivalent level of safety. 

Furthermore, the petitioner has accomplished the following:

1. Performed in excess of 50 flights with the Phantom. 

2. Successfully learned and demonstrated all flight maneuvers in the "Phantom 

Pilot Training Guide".10

3. Studied and is familiar with all sections of the "Phantom 2 Vision+ User 

Manual".

11

4. Studied and is familiar with all sections of the "Guide to the Phantom 2 Vision 

& Vision+" 12

5. Studied, is familiar with, and can demonstrate (where possible) the "Always 

Be Prepared for the Worst" scenarios.

13

Public Interest

Granting this exemption would benefit the public as a whole. SUASs offer a strong 

equivalent or greater level of safety, a reduction in environmental impacts, and are free 

from the harmful emissions associated with the manned aircraft that are currently used 

for aerial photography and videography. Due to the small size of the SUAS and the 

tightly controlled and limited airspace in which the SUAS will operate, approval of this 

application presents no risk to the public. Furthermore, the public will be able to legally 

																																																							 10 See the attached "PhantomTrainingGuide.pdf" document.

11 See the attached "PhantomUserManual.pdf" document.

12 See the attached "PhantomGuide.pdf" document.

13 See "Always be prepared for the Worst" on page 13 of the attached "Guide to the 

Phantom 2 Vision & Vision+". 
acquire aerial photography and videography to help in advertising commercial, 

residential and agricultural property for sale or development, safely accessing high 

and/or awkward areas of a building exteriors to assess damage that needs to be 

repaired, and stack, tower, wind turbine and bridge inspections, and assisting first 

responders at no charge in crowd management and search and rescue operations.

Privacy 

Since most of the areas being photographed or videoed will be on private property, 

accessed only after receiving written and/or oral consent by the property owner(s), and 

clear of people except for the PIC and the PIC's helper(s), approval of this application 

presents no risk to the public privacy. And as a former federal law enforcement officer 

the petitioner is cognizant of and sensitive to privacy issues and the necessity to avoid

invasions of privacy rights.

National Security 

Due to the small size of the SUAS and the tightly controlled and limited airspace in 

which the SUAS will operate, approval of this application presents no risk to national 

security. 

Requested Exemptions 

Petitioner requests exemption from the following regulations since it is not possible to 

fully comply with them, and since attempting to follow them for the purposes of 

operating a SUAS would be unreasonably burdensome: 

Airworthiness Certificates 14 CFR Part 21, Subpart H

Subpart H establishes the procedural requirements for the issuance of 

airworthiness certificates as required by FAR 91.203 (a) (1). Given the size and 

limited operating area associated with the aircraft to be utilized by Petitioner, an 

exemption from Part 21 Subpart H meets the requirements of an equivalent level 

of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation 
Act (49 USC 44701 (f)) and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon 

consideration of the size, weight, speed, operational capability, and proximity to 

airports and populated areas of the particular SUAS. In all cases, an analysis of 

these criteria demonstrates that the SUAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed, will 

be at least as safe, or safer, than a conventional aircraft operating with an 

airworthiness certificate without the restrictions and conditions proposed. 

Medical certificates 14 CFR 61.23 (a) 

This regulation requires pilots of manned aircraft to hold a medical certificate. 

Risks associated with the operation of the proposed SUAS are greatly diminished 

from the level of risk associated with any manned aircraft due, in part, to the 

SUAS’ small size, light weight, low speed, and operational capabilities which 

makes it much safer than any manned aircraft. And since operations will occur in 

tightly controlled and limited airspace, obtaining and maintaining a medical 

certificate would not improve the safety of the operation. In the very rare case of 

a mishap, the SUAS being flown will pose significantly less of a threat than 

manned helicopters and fixed wing aircraft because the SUASs are a tiny fraction 

of the size, a fraction of the weight, will be flown at a fraction of the speed, carry 

no flammable fuel, carry no crew or passengers, and will autonomously return to 

home in the event of loss of communications with the pilot.

Civil Aircraft Airworthiness 14 CFR 91.7(a)

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Petitioner to determine that the DJI Phantom 2 Vision+

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

is in compliance with the DJI Phantom 2 Vision+ User Manual, and that the 

aircraft is in a condition for safe flight. 
Petitioner seeks the requested relief because the DJI Phantom 2 Vision+ does 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, prior to every flight, Petitioner will ensure that the DJI 

Phantom 2 Vision+ is in an airworthy condition based upon a visual inspection, in 

order to determine that the aircraft and its components are in compliance with its 

type design and operating documents (i.e., the Phantom 2 Vision+ User Manual), 

and that the aircraft can be operated safely pursuant to the conditions and 

limitations stated herein. 

Flight instruction 14 CFR 91.109

This regulation provides that no person may operate a civil aircraft (except a 

manned free balloon) that is being used for flight instruction unless that aircraft 

has fully functioning dual controls. 

SUASs and other remotely piloted aircraft, by their design, do not have fully 

functional dual controls. Flight control is accomplished through the use of a 

control box that communicates with the aircraft via radio communications. The 

FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. 

The equivalent level of safety is provided by the fact that neither a pilot nor 

passengers will be carried in the aircraft and by the small size and slow speed of 

the aircraft. 

Altimeter settings 14 CFR 91.121 

This regulation requires each person operating an aircraft to maintain cruising 

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

departure airport or an appropriate altimeter setting available before departure." 

As the SUAS does not have a barometric altimeter, but instead a is equipped 

with a barometric pressure sensor and GPS equipment that automatically 

ensures that a ground level pressure setting will be established prior to each 
flight, and provides the PIC with altitude information of the aircraft on the headsup display of the remote controller, an exemption may be needed. The operator 

will achieve an equivalent level of safety by confirming the altitude of the launch 

site shown on the GPS altitude indicator before flight. 

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

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; 

or (2) At night, to fly after that for at least 45 minutes." 

The battery powering the SUAS provides a maximum of 35 minutes of powered 

flight; that would make it impossible to meet the 30-minute reserve requirement. 

Given the limitations on the SUAS's proposed flight area and the location of its 

proposed operations within a predetermined area, a shorter time frame for flight in 

daylight VFR conditions is reasonable. 

An equivalent level of safety can be achieved by limiting flights to 30 minutes or 

25% of remaining battery power (whichever occurs first). This restriction would be 

more than adequate to return the SUAS to its planned landing zone from 

anywhere in its limited operating area. 

Maintenance Inspections 

14 CFR 91.405 (a); 14 CFR 91.407 (a)(l); 14 CFR 91.409 (a)(l); 14 CFR 91.409 

(a)(2); 14 CFR 91.417 (a) and (b) 

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 paragraph (c) of this section, have 
discrepancies repaired as prescribed in part 43 of this chapter...", and others 

shall inspect or maintain the aircraft in compliance with Part 43. 

Given that these sections and Part 43 apply only to aircraft with an airworthiness 

certificate, they do not apply to the operation of this SUAS. The operator,

pursuant to the aforementioned DJI Phantom 2 Vision+ user manual and guide,

will accomplish any required maintenance. An equivalent level of safety will be 

achieved because these small SUASs are very limited in size, will carry a small 

payload, and operate only in restricted areas for limited periods of time. If 

mechanical issues arise, the SUAS can land immediately and will be operating 

from no higher than 200 feet AGL (until such time as regulations permit 

operations at higher altitudes). As outlined in the aforementioned Pre-flight 

Action Plan, the operator will ensure that the SUAS is in working order prior to 

initiating flight and will perform maintenance as required. Moreover, the operator 

is the person most familiar with the aircraft and best suited to maintain the aircraft 

in an airworthy condition to provide the equivalent level of safety. 

In accordance with 14 CFR Part 11, the following summary is provided for 

publication in the Federal Register: 

Petitioner seeks an exemption from the following rules: 14 CFR Part 21, 

Subpart H; 14 CFR 61.113 (a) and (b); 14.CFR 91.7(a); 14 CFR 91.109; 14 CFR 

91.121; 14 CFR 91.151; (a); 14 CFR 91.405 (a); 14 CFR 91.407 (a)(l); 14 CFR 

91.409 (a)(l) & (a)(2); 14 CFR 91.417 (a) and (b) to commercially operate 

small unmanned aircraft systems (55 Ibs. or less) below 200 feet AGL and 

further than 5 miles from any airport or heliport, in order to safely and 

legally capture aerial photography and videography for use by 

homeowners, builders and inspectors, realty agents, first responders/law 

enforcement, and for the inspection of stacks, towers, bridges, power lines, 

wind turbines, generating facilities and other infrastructure.
The operation of SUASs conducted in the strict conditions outlined above, will provide 

an equivalent and/or greater level of safety supporting the grant of the exemptions 

requested herein, including exempting the applicant from the requirements of Part 21 

and allowing commercial operations. These lightweight aircraft operate at slow speeds, 

close to the ground, and in a sterile environment, and as a result, are far safer than 

existing operations conducted with helicopters operating in close proximity to the 

ground, people, or other buildings in the vicinity. 

Given the small size of the SUASs involved, the slow speed at which they must be 

operated in order to capture photos and videos, and the restricted environment within 

which they will operate, the Phantom demonstrates that it can be operated within an 

equivalent level of safety in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of SUASs to commence immediately. Also, due 

to the size of the SUASs and the restricted areas in which the relevant SUASs will 

operate, approval of this application presents no threat to national security. Given the 

clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, the strong equivalent level of safety surrounding the proposed operations, 

the significant public benefit - including enhanced safety, reduction in environmental 

impacts, no emissions, ability to legally obtain aerial photography and videography 

services - the grant of the requested exemptions is in the public interest. Accordingly, 

Petitioner respectfully requests that the FAA grant the requested exemption without 

delay. 

Satisfaction of the criteria provided in Section 333 of the Reform Act - size, weight, 

speed, operating capability, proximity to airports and populated areas, operation within 

the visual line of sight, public safety, and national security - provide more than adequate 

justification to grant petitioner’s requested exemption, allowing for commercial 

operations as described herewith. 
CONCLUSION 

As set forth herein, Petitioner 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 2 Vision+ SUAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial photography and 

videography for use by owners of commercial and residential properties, realty agents, 

builders, contractors, developers and/or inspectors, first responders/law enforcement, 

and for inspections of stacks, towers, bridges, power lines, wind turbines, generating 

facilities and other infrastructure, and any other lawful purposes, for compensation or 

hire. 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 Petitioner to safely, efficiently, and economically 

operate the DJI Phantom 2 Vision+ SUAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012, Section 333, Petitioner 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 Petitioner to operate SUAS 

commercially for the purpose of conducting aerial photography and videography for use 

by owners of commercial and residential properties, realty agents, builders, contractors, 

developers and/or inspectors, first responders/law enforcement, and for inspections of 

stacks, towers, bridges, power lines, wind turbines, generating facilities and other 

infrastructure, and any other lawful purposes, for compensation or hire. 

Dated: April 17, 2015 

Sincerely, 

Terence G. Haglund

Enclosures (4)