June 1st 2015 

U.S Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE Washington DC 20590 

Exemption Request Under Section 333 

Dear Sir or Madam 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 C.F.R. Part 11, BirdsiView LLC (a single person Cory Peterson) the operator of a Phantom Vision 2+ and a Phantom 3, seeks 

an exemption from the Federal Aviation Regulations Listed Below. 

The requested exemption would permit Birds-iView to operate their UAV(s) wich weigh under 2.5lbs and 

produced by DJI incorporat4ed for commercial use in the following areas. 

- Real Estate Aerial Photography - Videography - Search and Rescue (on the beach helping to find 

missing persons) - Construction surveying - Golf Course photography - UAV Training 

With the landowner’s permission the DJI products listed above use an onboard camera to capture Digital 

images for commercial use. The Phantom UAVs reduce the need of using conventional aircraft for the 

same purpose and provides very high quality imagery at a fraction of the cost. These savings result in 

enhanced efficiency and productivity for the affected activities listed above as well as environmental 

benefits. 

Operations under the exemption will be subject to strict operating requirements and conditions to 

ensure at least an equivalent level of safety to current authorized operations using manned aircraft and 

under conditions as may be modified by the FAA as required by Section 333. 

As described in this petition the requested exemption would authorize commercial operations of aerial 

use using the Phantom UAVs which at 2.5lbs fall well under guidelines set by the FAA. The phantom 

UAVs will be operated under controlled conditions: 

- Operator has over 50 hours of UAV flight experience. (2 years of flying such UAVs) - Low altitude of less 

than 400 AGL (most of commercial use is under 200 AGL) - Automated control features listed below. 

- GPS lock at all times with safe Return to home functionality - Speeds not to exceed 20 mph - Line of 

Sight operations at all times - First Person view capabilities for added safety 

The Regulations from which this exemption is requested are as follows: 

14 C.F.R. Part 21; 

14 C.F.R. 45.23(b); 
14 C.F.R. 91.7(b); 

14 C.F.R. 91.9(b)(2); 

14 C.F.R. 91.109(a); 

14 C.F.R. 91.119; 

14 C.F.R. 91.151(a); 

14 C.F.R. 91.203 (A &B); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407 (a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a). 

THE APPLICTION LEGAL STNDARD UNDER SECTION 333 Birds-iView LLC submits that grant of this 

exemption application for use of the Phantom 2 Vison + and Phantom 3 quadcopters in commercial 

Photography and Videography will advance the congressional mandate in Section 333 of the Reform act 

to accelerate the Introduction of UAS’s into the national airspace system (NAS) if it can be accomplished 

safely. This law directs the secretary of transportation to consider whether certain UASs may operate 

safely in the NAS before completion of the rulemaking required under Section 333 of the reform act. In 

making this determination, the secretary is required to determine which types of UASs do not create 

hazard to users of the NAS or public or pose a threat to national security in light of the following: 

The UASs size, weight, speed and operational capacity 

Operations of the UAS in close proximity to airports and populated areas 

Operations of the UAS within Visual Line of Sight of the Operator 

Reform Act 333(a)(1). If the Secretary determines that such vehicles “may Operate Safely in the national 

airspace system. The Secretary Shall establish requirements for the safe operations of such aircraft in 

the NAS. 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority, by it’s terms, includes exempting civil aircraft, as the term is defined under 40101 of the act, 

from requirement that all civil aircraft must have a current airworthiness certificate and those 

regulations requiring commercial pilots to operate aircraft in commercial service. 

The grand of the requested exemption is in the public interest based on the clear direction in section 

333 of the reform act; The additional authority in the Federal Aviation Act, as amended: 
The strong equivalent level of safety surrounding the proposed operations; and the significant public 

benefit, including enhanced safety and cost savings associated with transitioning the UASs for aerial 

photography. Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay as these are services that can saves lives from drowning in the Gulf coast. 

Grant of the exemption to Birds-iView LLC will be subject to the following mandatory conditions, which 

are based upon operating conditions set forth for operation of UAS by public entities pursuant to 

certificates of authorization; 

- All operations to occur in class G airspace - Operations to avoid congested or populated areas, which 

are depicted in Yellow on VFR charts - Operations to be conducted over private or controlled-access 

property - Permission from land owners/controller required before commencing and flight - Operations 

to occur during Visual Flight Rules Meteorological conditions - Aircraft to remain within Visual Line of 

Sight (VLOS) - Operations to occur during daylight hours - Above ground Level altitude to be restricted to 

400 Ft - All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline 

azimuth of runway centerline measured from Runway Threshold (Phantom Products have GPS data 

within the controller to warrant no fly zones to airports) - All required permissions and permits will be 

obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire or other 

appropriate governmental agencies 

Operator Requirements 

Birds-iView respectfully proposes that operator requirements should take into account the 

characteristics of the particular UAS. Certain UASs, such as the DJI Phantoms are characterized by a 

high degree of pre-programmed control and various built in technical capabilities that limit potential for 

operation outside of the operating conditions set forth above. 

The DJI Phantom UASs has semi-autonomous navigation and control systems comprised of a ground 

control station, GPS stabilization and Auto-Pilot system. In the case of an unplanned events, the 

operator can allow the aircraft to follow the pre-programmed evasive maneuvers from the control unit 

or enable assisted steering for direction control and Return to Home takeoff point. 

Pre-Flight Checklist 

The list below is very important procedure before each and every flight. It is very important that all steps 

are taking to ensure safety. I have been preforming these procedures and have been very successful 

with no accidents or errors during flights. 

- Make sure that all UAS propellers are snug tight. - Check battery levels before takeoff. (controller and 

UAS) Never fly on less than half battery} - Inspect that there is no debris in the motors or gimbal areas) - 

Attach and power up the FPV screen and controller) - Power up the UAS. - Wait for UAS and controller to 

sync and connect to no less than 10 satellite signals. (this ensures safe locking of location for Return to 

home and stable hovering) - Before powering on the motors make sure you are in an open area free 

from people, animals and large interfering objects. 
Sincerely 

Birds-iView LLC 

Cory Peterson 

72 Secret harbor Dr 

Miramar Beach FL 32550 

(Phone) 763.670.0874 

Link to DJI Quick start PDF.

Appendix 

DJI flight manuals. 

Quick Start Guide V1.0

PHANTOM 3 PROFESSIONAL

Phantom 3 Professional It’s time to meet your Phantom 3 Professional. The Phantom 3 Professional’s 

camera records video at up to 4K and captures 12 megapixel photos. Review the diagram below for a full 

list of your Phantom 3 Professional’s parts:

2

7

4

5

9

8

6

3

1

1. Gimbal and Camera 2. Vision Positioning System 3. Camera Micro-SD Card Slot 4. Aircraft Micro-USB 

Port 5. Front LEDs 6. Motors 7. Propellers 
8. Aircraft Status Indicators 9. Antennas 10. Intelligent Flight Battery 11. Power Button 12. Battery Level 

Indicators 13. Link Button 14. Camera Micro-USB Port

12

11

14

10

13

11. Gimbal Dial 12. Camera Settings Dial 13. Video Recording Button 14. Flight Mode Switch 15. Shutter 

Button 16. Playback Button 17. C1/C2 Buttons (Customizable) 18. USB Port 19. Micro-USB Port

1. Power Button 2. Return to Home (RTH) Button 3. Control Sticks 4. Status LED 5. Battery Level LEDs 6. 

Power Port 7. Mobile Device Holder 8. Small Device Positioning Tabs (such as mobile phone) 9. Antennas 

10. Handle Bar

Remote Controller

Folded

This powerful Remote Controller allows you to pilot and maneuver your Phantom 3 Professional at 

distances over 6,000 feet (2 km)* away, while putting selected camera controls at your fingertips. Built 

into your Remote Controller is a rechargeable LiPo battery and DJI Lightbridge, which when paired with 

a compatible mobile device gives you a live HD view from the Phantom’s camera.

* This maximum transmission distance was tested in a lab environment and is for reference only. The 

maximum operating distance may vary depending on conditions in your immediate surroundings.

Mobile device connection

10

9

8

7

3

4

5

1
2

6

14

12

1615

11

17

19 18

13

17

● Environmental Considerations: 1. Do not fly in severe weather conditions. This includes high winds 

(speeds of 22 mph or 10 m/s or more), snow, rain, and fog. 2. Only fly in open areas. Tall buildings and 

steel structures may affect the accuracy of the on-board compass and GPS signal. 3. Avoid obstacles, 

crowds, high-voltage power lines, trees, and bodies of water. 4. Minimize electromagnetic interference 

by avoiding areas with high levels of electromagnetism, including mobile phone base stations, radio 

transmission towers, or Wi-Fi hotspots. 5. Aircraft and battery performance are subject to 

environmental factors such as air density and temperature. Be very careful when flying 19,600 feet (6 

km) or more above sea level, as battery and aircraft performance may not be at peak efficiency. 6. The 

Phantom 3 Professional cannot operate in P Mode or use GPS at polar latitudes. Only ATTI Mode and the 

Vision Positioning system will be operational.

● Calibrang the Compass: Make sure to calibrate the compass at every new flight location. The 

compass is very sensitive to electromagnetic interference, which can cause abnormal compass data, 

leading to poor flight performance or even failure. Regular calibration is required for optimal 

performance. 1. DO NOT calibrate your compass where there is a chance of strong magnetic 

interference, such as magnetite, parking structures, and steel reinforcements underground. 2. DO NOT 

carry ferromagnetic materials with you during calibration such as keys or cellular phones. 3. DO NOT 

calibrate beside massive metal objects. 4. If the Aircraft Status Indicators are showing solid red, then try 

to calibrate again. If they are blinking red and yellow alternately after placing the aircraft on the ground, 

the compass has detected magnetic interference. Change your location.

Fly Safe

● P Mode: In this mode, the Phantom 3 Professional can use GPS and the Vision Posioning system, 

allowing it to hover accurately in position indoors and out. When GPS is available, a Home Point will be 

locked so that the Phantom 3 Professional can Return to Home if the Remote Controller signal is lost.
There are three states in P mode: P-GPS: GPS works best when outdoors and in a wide open area. Your 

Phantom 3 Professional uses GPS to hover in place when there is a strong GPS signal. P-OPTI: If GPS is 

not available, the aircraft can use the Vision Positioning system to hover accurately. P-ATTI: Neither GPS 

nor the Vision Positioning system are available. The aircraft will only use its barometer for altitude and 

other on-board sensors for attitude stabilization. Note that the Vision Positioning system may not work 

properly when the Phantom 3 Professional is flying over water, over surfaces without a clear pattern, or 

in a low-light environment.

● Return to Home: When there is a strong GPS signal, the aircraft will be able to record a Home Point 

and return to that Home Point when required. The Home Point location is recorded when the GPS signal 

icon in the DJI Pilot app is either yellow or green. The aircraft will return to the Home Point 

automatically in the following scenarios (all require a strong GPS signal): Smart RTH: When the RTH 

button on the Remote Controller or in the DJI Pilot app is pressed. Low-Battery RTH: A notification will 

appear in the DJI Pilot app requesting the pilot to take action when the battery level falls under a certain 

level. Failsafe RTH: When the Remote Controller’s signal is lost.

GPS Positioning 

DJI encourages you to enjoy flying your Phantom 3 Professional in a safe, responsible, and smart way. 

To do this, it is important to understand some basic flight guidelines, both for your protection and for 

the safety of those around you. 1. Fly in Open Areas: Always fly in locations that are free and clear of 

buildings, trees, power lines, and other obstacles. Do not fly above or near people or animals. 2. 

Maintain Control at All Times: Even when using DJI autopilot functions such as Auto-Takeoff, AutoLanding, and Auto-Return to Home, always keep your hands on the Remote Controller and maintain 

control of your aircraft when it is in flight. 3. Maintain Line of Sight: Keep your aircraft in sight at all 

times, and avoid flying behind buildings or other obstacles that may block your view. 4. Monitor Your 

Altitude: For the safety of full-sized aircraft and other air traffic, always fly at altitudes less than 400 feet 

(120 meters) above ground level, or in line with your local laws and regulations. Visit 

http://flysafe.dji.com/no-fly for more information on critical safety features such as No-Fly Zones.

To enable P Mode, toggle the Flight Mode Switch to the P position.

● While returning to the Home Point, the aircra’s altude can be adjusted to avoid obstacles. Tall 

buildings may affect the Remote Controller’s signal. The Failsafe Return to Home procedure will be 

triggered if the signal is lost. Be sure to fly higher than any nearby buildings to avoid crashing.

Return to home

9 feet 10 inches

1 foot 

Vision Positioning Altitude

Appendix
※ This Quick Start Guide is subject to change without prior notice.

● Remote Controller Operating Frequency 2.400 GHz-2.483 GHz Max. Transmission Distance 2 km 

(outdoors and unobstructed) Video Output Port USB Operating Temperature Range 0°C to 40°C Battery 

6000 mAh LiPo 2S Mobile Device Holder Tablets and smartphones Transmitter Power (EIRP) FCC: 

20 dbm; CE:16 dbm Working Voltage 1.2 A @7.4 V ● Charger Voltage 17.4 V Rated 

Power 100 W ● Intelligent Flight Baery(PH3-4480 mAh-15.2 V ) Capacity 4480 mAh Voltage 15.2 V 

Battery Type LiPo 4S Energy 68 Wh Net Weight 365 g Operating Temperature -10°C to 40°C Max. 

Charging Power 100 W

FCC ID:SS3-WM3231503 FCC ID: SS3-GL3001501 This device complies with part 15 of the FCC Rules. 

Operation is subject to the following two conditions: (1) This device may not cause harmful interference, 

and (2) this device must accept any interference received, including interference that may cause 

undesired operation.

● Aircra Weight (Including Baery) 1280 g Max. Ascent Speed 5 m/s Max. Descent Speed 3 m/s Max. 

Speed 16 m/s (ATTI mode, no wind) Max. Flight Altitude 6000 m Max. Flight Time Approximately 23 

minutes Operating Temperature Range 0°C to 40°C GPS GPS/GLONASS ● Gimbal Angular Vibraon 

Range Pitch: − 90° to +30° ● Vision Posioning Velocity Range <8 m/s (Altude 2 m) Altude Range 30 

cm-300 cm Operating Range 30 cm-300 cm Operating Environment Surface with clear pattern and 

adequate lighting (Lux > 15) ● Camera Sensor Sony EXMOR 1/2.3” Effecve pixels:12.4 M (total pixels: 

12.76 M) Lens FOV (Field Of View) 94° 20 mm (35 mm format equivalent) f/2.8 ISO Range 100-3200 

(video) 100-1600 (photo) Electronic Shutter Speed 8 s - 1/8000 s Image Max. Size 4000 x 3000 Still 

Photography Modes Single shot Burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 

bracketed frames at 0.7EV Bias Time-lapse Video Recording Modes UHD : 4096x2160p 24/25, 

3840x2160p 24/25/30 FHD: 1920x1080p 24/25/30/48/50/60 HD: 1280x720p 24/25/30/48/50/60 Max. 

Bitrate of Video Storage 60 Mbps Supported File Formats FAT32/exFAT Photo: JPEG, DNG Video: 

MP4/MOV (MPEG-4 AVC/H.264) Supported SD Card Types Micro-SD, Max. capacity: 64GB. Class 10 or 

UHS-1 rating required Operating Temperature Range 0°C to 40°C

182 mm

172 mm

105 mm

71 mm

289.5 mm

289 mm

185 mm

4. Charging the Batteries
Preparing Your Phantom 3 Professional Before Flying

1. Download the DJI Pilot App Search ‘DJI Pilot’ on the App Store or Google Play and download the DJI 

Pilot app to your mobile device.

● For the best experience, use a mobile device that runs iOS 8.0 or above or Android 4.1.2 or above.

● Only use the official DJI Phantom 3 Professional charger. Remove the Intelligent Flight Battery from 

the aircraft before charging. ● It is recommended that you turn off the Intelligent Flight Baery or 

Remote Controller before charging. ● Connect the charger to a suitable power source (100-240V 

50/60Hz). ● Connect the charger to the Intelligent Flight Battery or Remote Controller. The LEDs will 

display the current charge level, and when fully charged, they will automatically turn off.

Watch the tutorial videos on www.dji.com or in the DJI Pilot app. 2. Watch the Tutorial Videos 

Phantom 3 tutorial videos DJI Pilot app

Read the User Manual and watch the video tutorials in the DJI Pilot app or on the official DJI website 

(www.dji.com), and read the following documents included in the box before using your Phantom 3 

Professional for the first time: Phantom 3 Professional Quick Start Guide, Phantom 3 Professional / 

Advanced Safety Guidelines and Disclaimer, Phantom 3 Professional / Advanced Intelligent Flight Battery 

Safety Guidelines, In the Box.

B

A

B A

Remove the Intelligent Flight Battery

3. Check Battery Levels Pressing the Power Button once on either your Intelligent Flight Battery or 

Remote Controller displays the battery level. Be sure to fully charge both batteries before your first 

flight.

io tte evel i o tte evel 

● To avoid signal interference, do not use other 2.4GHz devices when flying.

● You can customize or change these controls through the DJI Pilot app.

6. Flight Controls Here are the default flight controls (Mode 2). The left stick controls altitude and 

rotation, while the right stick controls the forward, backward, left or right movements. The gimbal dial 

controls the camera’s tilt.
5. Preparing the Remote Controller Tilt the Mobile Device Holder to the desired position, and then 

adjust the antennas as shown. The strength of the Remote Controller’s signal will fluctuate depending 

on the positions of the antennas.

Strong Weak

1 Press the button on the side of the Mobile Device Holder to release the clamp. Place your mobile 

device into the clamp and adjust it so that the mobile device is held securely in place. Connect your 

mobile device to the Remote Controller with a USB cable. Plug one end of the cable into your mobile 

device, and the other end into the USB port on the back of the Remote Controller.

The transmission signal between the aircraft and Remote Controller will be strongest within the range 

illustrated here. If the signal is weak, adjust the positions of the antennas and fly the aircraft closer to 

achieve optimal signal performance.

3

1

U P

D o w n

T u r n R i g h t

T u r n L e f t

U P

D o w n

T u r n R i g h t

T u r n L e f t

F o r w a r d

B a c k w a r d 

R i g h t 

L e f t

F o r w a r d

B a c k w a r d

R i g h t 
L e f t

Left Stick Right Stick Gimbal Dial

2

Before taking off, make sure the Aircraft Status Bar in the DJI Pilot app indicates ‘Safe to Fly (GPS)’ or 

‘Safe to fly (non-GPS)’ if flying indoors.

8. Flight Safe to Fly ( GPS )

●

● Be sure to match all the propellers to motors with the correct colors and ghten by hand before flying. 

● If you wish to record photos or videos, insert a Micro-SD card into the Camera’s Micro-SD Card Slot. ● 

The Flight Mode Switch is locked in P Mode by default. Refer to the User Manual to learn how to unlock 

the switch and change to other modes. ● When not in P mode, the Phantom 3 Professional will only 

maintain altitude, not position, and will drift with wind or user input. Return to Home is not available in 

F mode.

7. Getting Ready for Takeoff Remove the gimbal clamp as shown on the right. Place your Phantom 3 

Professional on a flat surface, in an open space, with the nose facing away from you. Then follow the 

steps below in this order:

Your Phantom 3 Professional can automatically takeoff and land at the tap of a button in the Camera 

screen of the DJI Pilot app.

1

2

4

6

7 8

3

5

DJI Pilot App

1

5

6
7

8

Toggle the Flight Mode Switch on your Remote Controller to the right (P Mode). P Mode is Positioning 

Mode, A Mode is ATTI Mode, and F Mode is Function Mode. Turn on the Remote Controller by pressing 

the power button once, releasing it, and then pressing and holding for 2 seconds. Insert the Intelligent 

Flight Battery into your Phantom 3 Professional. Turn on the battery by pressing the power button once, 

releasing it, and then pressing and holding for 2 seconds. Ensure the LED on your Remote Controller is 

green, indicating it is ready to be used. Connect your mobile device to the Remote Controller with a USB 

cable and launch the DJI Pilot app. Follow the instructions within the app. In the app, tap ‘Camera’. 

Ensure your Phantom 3 Professional is ready to fly by completing the on-screen Checklist. Beginner 

Mode is enabled by default when you launch the DJI Pilot app for the first time. The aircraft’s altitude 

and flight distance are restricted when flying in Beginner Mode. You can disable Beginner Mode in the 

Settings Page of the DJI Pilot app. Calibrate the compass by tapping the Aircraft Status Bar in the app 

and selecting ‘Calibrate’. Then follow the on-screen instructions. Attach the propellers with a black nut

onto the motors with a black axis and spin them counter-clockwise to secure. Attach the propellers with 

a gray nut onto the motors with a gray axis and spin them clockwise to secure.

Tap and slide to confirm automatic takeoff. The aircraft will automatically takeoff and hover at 4 feet 

(1.2 meters).

Tap and slide to confirm automatic landing. The aircraft will automatically land.

Appendix

To land, gently pull the left stick (throttle stick) down to lower the aircraft until it touches the ground. 

Then pull both sticks to the bottom inside corners to stop the motors.

Start the motors by pulling both control sticks to the bottom inside (or outside) corners. Release the 

sticks once the motors start. Slowly push the left stick (throttle stick) up to takeoff.

Remote Controller is functioning normally, but is not connected to the aircraft. Remote Controller is 

functioning normally and is connected to the aircraft. B-B-B... Aircraft Low Battery Level Warning or 

Remote Controller error. ... Remote Controller has been idle for 5 minutes. 

● Never stop the motors mid-flight, otherwise the aircraft will crash. Only stop the motors when on the 

ground or as required in emergency situations to reduce the risk of damage or injury. ● You cannot 

takeoff if the Intelligent Flight Battery is not sufficiently charged and the Critical Low Battery Warning is 

active. ● The Intelligent Flight Baery must warm up if the outside temperature is low. A warning will 

appear in the DJI Pilot app in this scenario. ● Once spinning, the rotating propellers can be dangerous. 

Do not start the motors when there are people nearby and always fly in a wide-open area. ● Power off

your Phantom 3 Professional before switching off the Remote Controller after landing.

©2015 DJI. All Rights Reserved Designed by DJI. Printed in China.
Left stick down (Slowly)

Slowly: P-ATTI or ATTI Mode Quickly: Not connected to the Remote Controller Slowly: Low Battery Level 

Warning Quickly: Critical Low Battery Level Warning Solid: Critical error Blinking Alternately: Compass 

calibration required

Slowly: Safe to fly, GPS working Continuously: Vision Positioning system working, no GPS X2

● While returning home, you can sll control your Phantom 3 Professional’s altude to avoid any 

obstacles.

●:

The app’s RTH ButtonRTH Button

1. Press and hold the Return to Home Button on your Remote Controller until the LED surrounding the 

button starts blinking white and starts beeping. Your Phantom 3 Professional will return to the set Home 

Point. Press the button once to stop the procedure.

2. The DJI Pilot app will warn you if your Phantom 3 Professional’s battery level falls under a certain 

level. This warning threshold can be set in the app. The aircraft will land immediately if the battery 

power reaches a critical level and the Critical Low Battery Level Warning appears. 3. Failsafe: The 

Phantom 3 Professional will enter Return to Home Mode if the signal to the Remote Controller is lost.

http://www.dji.com/phantom3 Fo moe inomtion

● Adjust the camera parameters using the Camera Sengs Dial on the Remote Controller or through the 

DJI Pilot app. Press the Shutter Button or Video Recording Button to capture photos or record videos. 

●Adjust the gimbal’s lt using the Gimbal Dial. ● Download photos and videos from the Micro-SD card 

to your mobile device through the DJI Pilot app. You can also use a SD-card reader to export files to your 

computer.