Aerial Vision Services, a North Carolina Sole Proprietorship owned by Michael N Boucher seeks 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System 

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit Michael N Boucher, Aerial Vision Services to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of agricultural and forest lands, power 

lines, construction sites, real estate, and landscape over certain areas of the North Carolina and 

Southern Virginia. 

INTRODUCTION AND INTERESTS OF THE PETITIONER Michael N Boucher has held a Private Pilot license 

since 1985 and an instrument rating in complex aircraft since 1994, is a retired United States Air Force 

Officer and service-connected disabled veteran. The objective of Aerial Vision Services’ aerial video and 

photography operations is to provide high quality imaging for a variety of commercial, public, 

agricultural and residential uses, specifically targeting: Agricultural sites, Construction sites before and 

after; Appraisals, Real-estate marketing, Power Line Inspections, Search & Rescue Operations, Aerial 

acquisitions used for inspections of public and private structures. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 Advanced. Aerial Vision seeks an exemption to 

operate DJI Phantom 3 Advance for compensation or hire within the NAS. The DJI Phantom 3 Advanced 

is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizing electronic tablet or smart phone systems. The DJI Phantom 3 Advance has a maximum gross 

weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, 

height of 8 inches, and a maximum speed of approximately 29 knots. The Phantom 3 Advanced is

equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The DJI 

Phantom 3 Advanced UA that will be operated by Aerial Vision Services 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, Michael N Boucher, sole owner of Aerial Vision Services , pursuant to the 

provisions of the 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 Advanced UASs in the National 

Airspace System (NAS), and for an exemption from the 5 requirements of I4 C.F.R §§ 6l.II3(a) & (b), 91. 

7(a), 9l.I2I, 9l.I5I (b), 9I.405(a), 9I.407(a)(I ), 9I.409(a)(I) & (a)(2), and 91.4I7(a) & (b). 6 In consideration of 

the speed, weight, size, and limited operating area associated with the unmanned aircraft and its 

operation, Aerial Vision Services and DJI Phantom 3 Advanced UAS meets the conditions of FMRA 

Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F .R. Part 

2I, Subpart H. Accordingly, Aerial Vision Services, requests relief from Sections 91.405(a), 9I.407(a)(I), 

91.409(a)(l) & (a)(2), and 91.4I7(a) & (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate. Aerial Vision Services submits that the requested 

relief is proper since an equivalent level of safety will be ensured. Aerial Vision Services will use 

experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance 

on the UASs using the methods, techniques, and practices prescribed in the operating documents as 

defined by the manufacturer. Furthermore, Aerial Vision Services will document and maintain all 
maintenance records for the DJI Phantom 3 Advanced UAS. Relief from certain requirements of Section 

61.1I3(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by 

Aerial Vision Services, to the extent necessary to allow a Pilot in Command (PIC) holding a private or 

recreational, or sport pilot certificate or higher level certificate and who has demonstrated, by meeting 

minimum flight- hour and currency requirements flying a UAV, that the PIC is able to safely operate the 

DJI Phantom 3 Advanced UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures. 

The PIC will hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by the 

State of North Carolina or Virginia. The operator will only permit a PIC to operate upon demonstration of 

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 will be logged 

in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs 

and Visual Observers (VO) (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. Training operations will 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 will operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 91.119 

Aerial Vision Services seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

DJI Phantom 3 Advanced UAS does not require an airworthiness certificate in accordance with 14 C.F .R. 

Part 21, Subpart H. As such, Aerial Vision Services, submits that he will ensure that the DJI Phantom 3 

Advanced UAS is in an airworthy condition, prior to every flight, by determining that the UAS are in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Advanced 

Instruction Manual), and that the aircraft is in a condition for safe flight. 

Aerial Vision Services seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom 3 Advanced will not have a typical barometric altimeter onboard. However, 

altitude information of the DJI Phantom 3 Advanced altitude will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with 

PIC operation of the DJI Phantom 3 Advanced within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121.

Additionally, Michael N Boucher seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements/or flight in VFR conditions. Michael N Boucher submits that safety will not be 

affected by operation of the DJI Phantom 3 Advanced UA 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 19 minutes to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 4.0 minutes. 

In accordance with 14 C.F.R. § 11.81, Aerial Vision Services, provide 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: Aerial Vision Services, Michael N Boucher 9950 Semora Rd, Semora, NC 27343 919-951-9433 

theorydoc@aol.com

B. The Specific Sections of 14 C.F.R. From Which Aerial Vision Services, Exemption. 

1. Aerial Vision Services, Seeks Exemption from The Requirements Of:

Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: 
Section 91.7a 9 Section 91.7a, entitled Civil aircraft airworthiness, subsection (a), states the 

following: (a) No person may operate a civil aircraft unless it is in an airworthy condition.

Section 91.121. Section 91.121, entitled Altimeter settings, 

Section 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

Section 91.405a. 10 entitled Maintenance required

Section 91.407(a)(l) Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection 

Sections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection 

Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections 

C. The Extent Of And The Reason Aerial Vision Services Seeks The Relief. 

1. Extent Of Relief And The Reason Aerial Vision Services 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, Aerial Vision 

Services, submits that an equivalent level of safety will be maintained because no PIC will be allowed to 

operate the DJI Phantom 3 Advanced UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate DJI Phantom 3 Advanced UAS 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, Aerial Vision Services submits that all flights of the DJI Phantom 3 Advanced 

UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Aerial Vision 

Services business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent of And The Reason Aerial Vision Services, 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 

Aerial Vision Services, to determine that the Phantom 3 Advanced 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 Advanced Instruction Manual). Aerial Vision Services seeks the 

requested relief because the DJI Phantom 3 Advanced UAS does not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Aerial Vision Services, will ensure that the DJI 

Phantom 3 Advanced UAS is in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Advanced 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 and The Reason Aerial Vision Services, Seeks 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 Advanced UAS, which utilize a, GPS equipment altitude reporting, and a radio 

communications telemetry data link to downlink altitude information from the UA 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), Aerial Vision 

Services, seeks the requested relief because the Phantom 3 Advanced UA 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 Advanced UAS 

is equipped with Altitude GPS reporting 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 UAS on the heads-up display of the GCS.

4. Extent Of The Reason Aerial Vision Service 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 Advanced during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 19 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4 

minutes. Aerial Vision Services seeks the requested relief because without an exemption from Section 

91.151 (b), the flight time duration of the battery powered DJI Phantom 3 Advanced will severely 

constrain the practicality of any aerial video or still photo flight operations proposes to conduct 

pursuant to this Petition. Significantly, as set forth below, the technical specifications of the DJI Phantom 

3 Advanced operating documents, and Aerial Vision Services, proposed operating limitations, ensure 

that Aerial Vision Services will safely operate the battery powered DJI Phantom 3 Advanced UA during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough 

battery power to fly for a total duration of 19 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4 minutes. 

5. Extent Of And The Reason Michael N Boucher Seeks Relief From Sections 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) 

& (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Aerial Vision 

Services, requests relief from these Sections because the DJI Phantom 3 Advanced do not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Advanced UAS meets the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Aerial 

Vision Services 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, and DJI Phantom 3 Advanced Instruction Manual). Furthermore, Aerial Vision Services

will document and maintain all maintenance records for the DJI Phantom 3 Advanced UAS. 

The Reasons Why Granting Aerial Vision Services Request Would Be In The Public Interest; Granting the 

present Petition will further the public interest by allowing Aerial Vision Services to safely, efficiently, 

and economically perform aerial video and photography of agricultural and forest lands, construction 

sites, real estate, and landscape over certain areas of the States of North Carolina and Virginia. 

Additionally, use of the DJI Phantom 3 Advanced will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of Aerial Vision Services proposed 

operation of the DJI Phantom 3 Advanced UAS will be realized without implicating any privacy issues. 

The DJI Phantom 3 Advanced UA is battery powered and serves 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 Advanced 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 Advanced UA 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 17 air traffic control during 

the ground, takeoff, departure, arrival, and landing phases of flight operations. 

Moreover, conducting aerial acquisitions with the DJI Phantom 3 Advanced 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 and increasing 

safety due to the significant reduction in weight, flight personnel, and risk exposure to ground and air 

non-participants. 

Privacy Issues: There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations 

that have been conducted for decades, Aerial Vision Services, proposed operation of the DJI Phantom 3 

Advanced UAS will not implicate any privacy issues. Specifically, Phantom 3 Advanced UAS will be 

operated only in compliance with operating documents (i.e., the Aerial Vision Services, Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Advanced 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 

Aerial Vision Services Seeks Exemption. 1. Reasons Why The DJI Phantom 3 Advanced UAS Meet The 

Conditions Of The FAA Modernization and Reform Act of2012 (FMRA) Section 333. In consideration of 

the size, weight, speed, and limited operating area associated with the unmanned aircraft and its 

operation, Aerial Vision Services, operation of the DJI Phantom 3 Advanced 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. 

The Specifications Of The DJI Phantom 3 Advanced UAS Demonstrate Its Safe Characteristics. 

The DJI Phantom 3 Advanced UAS does 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. The DJI Phantom 3 Advanced UAS may be operated in both manual and fully autonomous 

flight modes. The DJI Phantom 3 Advanced UAS has received and been acknowledged by precedent 

approved exemptions issued by the FAA. The DJI Phantom 3 Advanced Are 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 3 Advanced UA will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Phantom 3 Advanced UA does 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. 

Flight Operations Of DJI Phantom 3 Advanced UAS is Limited To The Line Of Sight Of A 22 

Certificated Pilot in Command With A Safety Observer. Aerial Vision Services will only utilize certificated 

pilots 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 Advanced UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. In seeking this exemption, Aerial Vision Services proposes to 

commercially operate DJI Phantom 3 Advanced UAS for the special purpose of conducting aerial video 

and photography pursuant to the following specific operating limitations as published in prior FAA 

exemptions: 

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 Advanced 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 UA 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 23 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. 

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 of 

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 UA 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 FAA-published aeronautical chart unless a letter of agreement with that airport's management 

is obtained, and the operation is conducted in accordance with a NOT AM 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 predetermined 

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 (as appropriate) must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. 

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 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; 

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. 

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely 

Affect Safety. Aerial Vision Services, 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 

Advanced 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 Advanced UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

The FAA has previously granted relief from prior sections 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, 11109

2689, 5745, and 10650. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

CONCLUSION As set forth herein, Aerial Vision Services, seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which will permit safe 

operation of the DJI Phantom 3 Advanced 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 

Aerial Vision Services to safely, efficiently, and economically operate the DJI Phantom 3 Advanced UAS 

commercially within the NAS. WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of2012, Section 333, Aerial Vision Services 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 Aerial Vision Services, to operate the DJI Phantom 3 Advanced UAS commercially for 

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

August 31, 2015, Aerial Vision Services, Michael N Boucher, 9950 Semora Rd, Semora, NC 27343