UNITED	STATES	OF	AMERICA	

DEPARTMENT	OF	TRANSPORTATION

FEDERAL	AVIATION	ADMINISTRATION

DOCKET	MANAGEMENT	SYSTEM

1200	NEW	JERSEY	AVE.,	SE

WASHINGTON,	DC	20590

IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF:	

JEFFREY	SCOTT	GORA

FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM	THE	REQUIREMENTS	OF	

TITLE	14	OF	THE	CODE	OF	FEDERAL	REGULATIONS

SECTIONS	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)	

CONCERNING	COMMERCIAL	OPERATION	OF	UNMANNED	AIRCRAFT	SYSTEMS

PURSUANT	TO	SECTION	333	OF THE	FAA	MODERNIZATION	AND	

REFORM	ACT	OF	2012	(PUBLIC	LAW	112-95)

Submitted	on March 7, 2016

Jeffrey	Scott	Gora

5308	Foxwood	Drive

Crestwood,	KY	40014
SUMMARY

JEFFREY	SCOTT	GORA	seeks	exemption	from	the	requirements	of	14	C.F.R	§§	91.7(a),	

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

operate	an	Unmanned	Aircraft	System	pursuant	to	Section	333	of	the	FAA	Modernization

and	Reform	Act	of	2012	(FMRA).	This	exemption	will	permit	JEFFREY	SCOTT	GORA	to	

operate	an	Unmanned	Aircraft	System	(UAS)	for	the	commercial	purpose	of	general	

contract	photography/videography,	cinematography,	inspections,	search	and	rescue,	

marketing,	surveying,	and	training.

INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER

I,	JEFFREY	SCOTT	GORA,	a	certified	Private	Pilot	- Airplane	Single	Engine	Land	(FAA	

Certification:	3836750 &	sUAS	Certification:	FA3KHYCKMM),	am	requesting	an	exemption	

so	that	I	may	commercially	operate	a	small	ultra	lightweight	unmanned	aircraft	system	

(UAS),	specifically	the	DJI	Phantom	4 quad-copter, or	equivalent, Unmanned	Aircraft, and	

ground	station-based	equipment	and	crew.

I	have	been	an	FAA-certified	Private	Pilot	since	November	10,	2015, and	have	been	a	UAS	

hobbyist	for	the	past	15 years,	both	without	incident.	I	am	applying	for	this	exemption	to	

allow	me	to	legally	perform	aerial	photography/videography	contract	work	for	real	estate	

agencies,	private	individuals,	photography/videography	organizations,	and	any	other	

entity	that	may	desire	aerial	photography/videography.	As	a	Private	Pilot,	I	understand	

the	importance	of	pre-flight,	in-flight,	and	post-flight	safety	measures	to	ensure	public	

safety.	As	a	pilot	of	a	UAS,	all	UAS-pertinent	safety	and	risk	management	measures	as	

specified	in	the	FAA’s	Risk	Management	Handbook	shall	be	complied	with.

In	summary	and	in	accordance	with	this	request	of	exemption	as	authorized	and	outlined	

by	the	FAA	under	section	333(c)	of	the	Reform	Act	specified	for	use	of	UAS	for	general	

contract	purposes,	I,	JEFFREY	SCOTT	GORA,	will	adhere	to	all	FAA	regulations	at	all	times	

and	shall	conduct	all	flight	operations	in	strict	compliance	and	safety	protocols	as	

mandated	and	required	by	regulations	and	best	practices.	I	request	the	grant	of	

exemption	to	operate	the	above-specified	UAS	for	commercial	purposes	as	described	in	

this	request	and	as	allowable	by	law.	This	grant	of	exemption	will	allow	me	to	offer	my	

services	to	real	estate	agencies,	private	individuals,	and	any	other	organization	requiring	

aerial	photography/videography	who	do	not	have	the	required	knowledge,	experience,	or	

certifications	to	operate	a	UAS	safely	and	in	compliance	with	FAA	regulations.	The	

essence	of	this	application	is	that	I,	JEFFREY	SCOTT	GORA,	meet	and	exceed	the	FAA’s	

expected	competency	for	piloting	my	UAS	for	commercial	purposes	and	that	my	UAS	

meets	and	exceeds	the	safety	requirements	set	forth	by	the	Secretary	of	Transportation	

thereby	prompting	my	request	for	COA	under	section	333.
BACKGROUND

Unmanned	Aircraft	Systems:	DJI	Phantom	4 UAS

JEFFREY	SCOTT	GORA	seeks	an	exemption	to	operate	DJI,	or	equivalent,	system for	

compensation	or	hire	within	the	NAS.	The	DJI	Phantom	4 is	a vertical	takeoff	and	landing	

(VTOL)	Unmanned	Aircraft	(US)	with	a	Ground	Control	Station	(GCS)	utilizing	electronic	

tablet	or	smart	phone	systems.	The	DJI	Phantom	4 has	a	maximum	gross	weight	of	

approximately	3	pounds	while	having	an	approximate	length	of	20	inches,	width	of	20	

inches,	height	of	10	inches,	and	a	maximum	speed	of	up	to	40	knots.	The	DJI	Phantom	4

UAS	is	equipped	with	four	main	rotors,	driven	by	Lithium	Polymer	battery	powered	

electric	motors.

All UAS	operated	by	JEFFREY	SCOTT	GORA	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,	JEFFREY	SCOTT	GORA,	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	4 UAS	in	the	

National	Airspace	System	(NAS),	and	for	an	exemption	from	the	requirements	of	14	C.F.R	

§§	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	

&	(b).

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

unmanned	aircraft	and	its	operation,	JEFFREY	SCOTT	GORA’s	operation	of	the	DJI	

Phantom	4 UAS	meet	the	conditions	of	FMRA	Section	333	and	therefore,	will	not	require	

an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.

Accordingly,	JEFFREY	SCOTT	GORA	requests	relief	from	Sections	91.405(a),	91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b),	as	these	sections	set	forth	requirements	for

maintenance	that	only	apply	to	aircraft	with	an	airworthiness	certificate.	JEFFREY	SCOTT	

GORA	submits	that	the	requested	relief	is	proper	since	an	equivalent	level	of	safety	will	

be	ensured.

JEFFREY	SCOTT	GORA	will	use	experienced	personnel	or	technicians	to	perform	

maintenance,	alterations,	or	preventive	maintenance	on	the	UAS	using	the	methods,	

techniques,	and	practices	prescribed	in	the	operating	documents	(i.e.,	Monthly	

Maintenance	Log,	and	DJI	Instruction	Manual).	Furthermore,	JEFFREY	SCOTT	GORA	will

document	and	maintain	all	maintenance	records	for	the	DJI	Phantom	4	UA.
Privileges	and	Limitations:	Pilot	in	Command,	is	requested	by	JEFFREY	SCOTT	GORA	to	the	

extent	necessary	to	allow	a	Pilot	in	Command	(PIC)	who	has	demonstrated,	by	meeting	

minimum	20	flight-hour	requirements	and	that	the	PIC	is	able	to	safely	operate	the	said	

DJI UAS	in	a	manner	consistent	with	this	exemption,	including	evasive	and	emergency	

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

structures.

JEFFREY	SCOTT	GORA	seeks	relief	from	Section	91.7(a),	entitled	Civil	Aircraft	

Airworthiness,	because	the	DJI	Phantom	4 UAS	do	not	require	an	airworthiness	certificate	

in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	As	such,	JEFFREY	SCOTT	GORA	submits

that	he	will	ensure	that	the	DJI	Phantom	4 UAS	is in	an	airworthy	condition,	prior	to	every	

flight,	by	determining	that	the UAS	is	in	compliance	with	the	operating	documents	(i.e.,	

Monthly	Maintenance	Log,	and	DJI	Instruction	Manual),	and	that	the	aircraft	is	in	a	

condition	for	safe	flight.

JEFFREY	SCOTT	GORA	also	seeks	an	exemption	from	the	requirements	of	Section	91.121,	

entitled	Altimeter	Settings,	as	the	DJI	Phantom	4 UAS	will	not	have	a	typical	barometric	

altimeter	onboard.	However,	altitude	information	of	these	said UAS	will	be	provided	to	

the	PIC	via	Global	Positioning	System	(GPS)	equipment	and	radio	communications	

telemetry	data	link,	which	downlinks	from	the UAS	to	the	GCS	for	active	monitoring	of	

the	flight	path.	This	altitude	information,	combined	with	JEFFREY	SCOTT	GORA’s	

operation	of	the	DJI	Phantom	4 UAS	within	visual	line	of	sight,	at	or	below	500	feet	AGL,	

will	ensure	a	level	of	safety	equivalent	to	Section	91.121.

Additionally,	JEFFREY	SCOTT	GORA	seeks	an	exemption	from	the	requirements	of	Section	

91.151(b),	entitled	Fuel	Requirements	for	Flight	in	VFR	Conditions.	JEFFREY	SCOTT	GORA	

submits	that	safety	will	not	be	affected	by	operation	of	the	DJI	Phantom	4	UAS	during	

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

with	enough	battery	power	to	fly	for	a	total	duration	of	approximately	17.5	minutes	to	

the	first	point	of	intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	

for	at	least	4.5	minutes.

In	accordance	with	14	C.F.R.	§	11.81,	JEFFREY	SCOTT	GORA	provides	the	following	

information	in	support	of	his	petition	for	exemption

Name	and	Address	of	the	Petitioner

Jeffrey	Scott	Gora

5308	Foxwood	Drive

Crestwood,	KY	40014

JSGora@gmail.com
The	Specific	Sections	of	14	C.F.R.	from	Which	JEFFREY	SCOTT	GORA	Seeks	Exemption.

1. JEFFREY	SCOTT	GORA	Seeks	Exemption	from	The	Requirements	of	Section	91.7(a).

Section	91.7,	entitled	Civil	Aircraft	Airworthiness,	subsection	(a),	states	the	following:

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

2. JEFFREY	SCOTT	GORA	Seeks	Exemption	from	The	Requirements	of	Section	91.121.

Section	91.121,	entitled	Altimeter	Settings,	subsection	(a),	states	the	following,	in	part:

(a) Each	person	operating	an	aircraft	shall	maintain	the	cruising	altitude	or	flight	level	

of	that	aircraft,	as	the	case	may	be,	by	reference	to	an	altimeter	that	is	set,	when	

operating-

(1) Below	18,000	feet	MSL,	to—

(i) The	current	reported	altimeter	setting	of	a	station	along	the	route	and	within	100	

nautical	miles	of	the	aircraft;

(ii) If	there	is	no	station	within	the	area	prescribed	in	paragraph	(a)(1)(i)	of	this	section,	

the	current	reported	altimeter	setting	of	an	appropriate	available	station;	or

(iii) In	the	case	of	an	aircraft	not	equipped	with	a	radio,	the	elevation	of	the	departure	

airport	or	an	appropriate	altimeter	setting	available	before	departure.

3. JEFFREY	SCOTT	GORA	Seeks	Exemption	from	The	Requirements	of	Section	

91.151(b).

Section	91.151,	entitled	Fuel	Requirements	for	Flight	in	VFR	Conditions,	subsection	(b),	

states	the	following:

(b)	No	person	may	begin	a	flight	in	a	rotorcraft	under	VFR	conditions	unless	(considering	

wind	and	forecast	weather	conditions)	there	is	enough	fuel	to	fly

to	the	first	point	of	intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	

that	for	at	least	20	minutes.

4. JEFFREY	SCOTT	GORA	Seeks	Exemption	from	The	Requirement	of	Section	91.405(a).	

Section	91.405,	entitled	Maintenance	required,	subsection	(a),	states	the	following:	Each	

owner	or	operator	of	an	aircraft—

(a)	Shall	have	that	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	

between	required	inspections,	except	as	provided	in	paragraph	(c)	of	this	section,	have	

discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter[.]
5. JEFFREY	SCOTT	GORA	Seeks	Exemption	from	The	Requirements	of Section	

91.407(a)(1)

Section	91.407,	entitled	Operation	After	Maintenance,	Preventive	Maintenance,	

Rebuilding,	or	Alteration, subsection	(a)(1),	states	the	following:

(a) No	person	may	operate	any	aircraft	that	has	undergone	maintenance,	preventive	

maintenance,	rebuilding,	or	alteration	unless--

(1) It	has	been	approved	for	return	to	service	by	a	person	authorized	under	§

43.7	of	this	chapter.

6.				JEFFREY	SCOTT	GORA	Seeks	Exemption	from	The	Requirements	of	Sections	

91.409(a)(1)	and	91.409(a)(2).

Section	91.409,	entitled	Inspections,	subsection	(a),	states	the	following:

(a) Except	as	provided	in	paragraph	(c)	of	this	section,	no	person	may	operate	an	

aircraft	unless,	within	the	preceding	12	calendar	months,	it	has	had	--

(1) An	annual	inspection	in	accordance	with	part	43	of	this	chapter	and	has	been	

approved	for	return	to	service	by	a	person	authorized	by	§	43.7	of	this	chapter;	or

(2) An	inspection	for	the	issuance	of	an	airworthiness	certificate	in	accordance	with	

part	21	of	this	chapter.

7.				JEFFREY	SCOTT	GORA	Seeks	Exemption	from	The	Requirements	of	Sections	

91.417(a)	and	91.417(b).

Section	91.417,	entitled	Maintenance	Records,	subsections	(a)	and	(b),	state	the	

following:

(a) Except	for	work	performed	in	accordance	with	§§	91.411	and	91.413,	each	

registered	owner	or	operator	shall	keep	the	following	records	for	the	periods	specified	in	

paragraph	(b)	of	this	section:

(1) Records	of	the	maintenance,	preventive	maintenance,	and	alteration	and	records	

of	the	100- hour,	annual,	progressive,	and	other	required	or	approved	inspections,	as	

appropriate,	for	each	aircraft	(including	the	airframe)	and	each	engine,	propeller,	rotor,

and	appliance	of	an	aircraft.	The	records	must	include--

(i) A	description	(or	reference	to	data	acceptable	to	the	Administrator)	of	the	work	

performed;	and
(ii) The	date	of	completion	of	the	work	performed;	and

(iii) The	signature,	and	certificate	number	of	the	person	approving	the	aircraft	for	

return	to	service.

(2) Records	containing	the	following	information:

(i) The	total	time	in	service	of	the	airframe,	each	engine,	each	propeller,	and	each	

rotor.

(ii) The	current	status	of	life-limited	parts	of	each	airframe,	engine,	propeller,	rotor,	

and	appliance.

(iii) The	time	since	last	overhaul	of	all	items	installed	on	the	aircraft	which	are	required	

to	be	overhauled	on	a	specified	time	basis.

(iv) The	current	inspection	status	of	the	aircraft,	including	the	time	since	the	last	

inspection	required	by	the	inspection	program	under	which	the	aircraft	and	its	appliances	

are	maintained.

(v) The	current	status	of	applicable	airworthiness	directives	(AD)	and	safety	directives	

including,	for	each,	the	method	of	compliance,	the	AD	or	safety	directive	number	and	

revision	date.	If	the	AD	or	safety	directive	involves	recurring	action,	the	time	and	date	

when	the	next	action	is	required.

(vi) Copies	of	the	forms	prescribed	by	§	43.9(d)	of	this	chapter	for	each	major	

alteration	to	the	airframe	and	currently	installed	engines,	rotors,	propellers,	and	

appliances.

(b) The	owner	or	operator	shall	retain	the	following	records	for	the	periods	prescribed:

(1) The	records	specified	in	paragraph	(a)(1)	of	this	section	shall	be	retained	until	the	

work	is	repeated	or	superseded	by	other	work	or	for	1	year	after	the	work	is	performed.

(2) The	records	specified	in	paragraph	(a)(2)	of	this	section	shall	be	retained	and	

transferred	with	the	aircraft	at	the	time	the	aircraft	is	sold.

(3) A	list	of	defects	furnished	to	a	registered	owner	or	operator	under	§	43.11	of	this	

chapter	shall	be	retained	until	the	defects	are	repaired	and	the	aircraft	is	approved	for	

return	to	service.
The	Extent	of	Relief	JEFFREY	SCOTT	GORA	Seeks	and	the	Reason	JEFFREY	SCOTT	GORA	

Seeks	the	Relief.

1. Extent	of	Relief	JEFFREY	SCOTT	GORA	Seeks	and	the	Reason JEFFREY	SCOTT	GORA	

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	JEFFREY	SCOTT	GORA	to	determine	that	the	DJI	Phantom	4 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	Instruction	Manual).

JEFFREY	SCOTT	GORA	seeks	the	requested	relief	because	the	DJI	Phantom	4 UAS	does	not	

require	an	airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.	

Therefore,	JEFFREY	SCOTT	GORA	will	ensure	that	the	DJI	Phantom	4 UAS	are	in	airworthy

condition	based	upon	its	compliance	with	the	operating	documents	(i.e.,	Monthly	

Maintenance	Log,	and	DJI	Instruction	Manual)	prior	to	every	flight,	and	further,	

determine	that	the	aircraft	is	in	condition	for	safe	flight,	as	stated	in	the	conditions	and	

limitations	below.

2. Extent	of	Relief	JEFFREY	SCOTT	GORA	Seeks	and	the	Reason JEFFREY	SCOTT	GORA	

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	2	UA,	which	utilizes	a	barometric	pressure	sensor,	GPS	

equipment,	and	a	radio	communications	telemetry	data	link	to	downlink	altitude	

information	from	the UAS	to	the	PIC	at	the	ground	control	station	(GCS).	Since	the	FAA	

requires	that	any	altitude	information	concerning	UAS	operations	be	reported	to	air	

traffic	control	(ATC)	in	feet	above	ground	level	(AGL),	JEFFREY	SCOTT	GORA	seeks	the	

requested	relief	because	the	DJI	Phantom	4UA’s	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	4 UAS	is	equipped	with	a	barometric	pressure	

sensor	and	GPS	equipment,	which	automatically	ensures	that	a	ground	level	pressure	

setting	will	be	established	prior	to	each	flight,	and	provides	the	PIC	with	altitude	

information	of	the UAS	on	the	heads-up	display	of	the	GCS.
3. Extent	of	Relief	JEFFREY	SCOTT	GORA	Seeks	and	the	Reason JEFFREY	SCOTT	GORA	

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	4

UAS	during	daylight	hours	in	visual	meteorological	conditions	(VMC),	under	visual	flight	

rules	(VFR),	for	a	total	duration	of	17.5	minutes	to	the	first	point	of	intended	landing	and,	

assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	minutes.	JEFFREY	SCOTT	

GORA	seeks	the	requested	relief	because	without	an	exemption	from	Section	91.151(b),	

the	flight	time	duration	of	the	battery	powered	DJI	Phantom	4 UAS	will	severely	constrain	

the	practicality	of	any	aerial	video	or	still	photo	flight	operations	that	JEFFREY	SCOTT	

GORA	proposes	to	conduct	pursuant	to	this	Petition.

Significantly,	as	set	forth	below,	the	technical	specifications	of	the	DJI	Phantom	4	UA,	the	

DJI	Phantom	4	and	JEFFREY	SCOTT	GORA’s	proposed	operating	limitations,	ensure	that	

JEFFREY	SCOTT	GORA	will	safely	operate	the	battery	powered	DJI	Phantom	4 UAS	during	

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

with	enough	battery	power	to	fly	for	a	total	duration	of	17.5	minutes	to	the	first	point	of	

intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	

minutes.

4. Extent	of	Relief	JEFFREY	SCOTT	GORA	Seeks	and	the	Reason JEFFREY	SCOTT	GORA	

Seeks	Relief	from	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	

91.417(a)	&	(b).

Since	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	only	

apply	to	aircraft	with	an	airworthiness	certificate,	JEFFREY	SCOTT	GORA	requests	relief	

from	these	Sections	because	the	DJI	Phantom	4 UAS	does	not	require	airworthiness	

certificates.	As	set	forth	more	fully	below,	the	DJI	UAS	meets	the	conditions	of	FMRA	

Section	333	for	operation	without	an	airworthiness	certificate.	Accordingly,	JEFFREY	

SCOTT	GORA	will	use	trained	technicians	to	perform	maintenance,	alterations,	or	

preventive	maintenance	on	the	UAS	using	the	methods,	techniques,	and	practices	

prescribed	in	the	UAS	operating	documents	(i.e.,	the	Monthly	Maintenance	Log,	and	DJI	

Instruction	Manual).	Furthermore,	JEFFREY	SCOTT	GORA	will	document	and	maintain	all	

maintenance	records	for	the	DJI	Phantom	4	UAS.
The	Reasons	Why	Granting	JEFFREY	SCOTT	GORA’s	Request	Would	be	in	the	Public	

Interest;	That	is,	how	it	Would	Benefit	the	Public	as	a Whole.

Granting	the	present	Petition	will	further	the	public	interest	by	allowing	JEFFREY	SCOTT	

GORA	to	safely,	efficiently,	and	economically	perform	aerial	video	and	photography	of	

construction	sites,	real	estate,	and	landscape	over	certain	areas	of	the	United	States.

Additionally,	use	of	the	DJI	Phantom	4	UAS	will	decrease	congestion	of	the	NAS,	reduce	

pollution,	and	provide significant	benefits	to	the	economy.	Notably,	the	benefits	of	

JEFFREY	SCOTT	GORA’s	proposed	operation	of	the	DJI	UAS	will	be	realized	without	

implicating	any	privacy	issues.

1. The	Public	Will	Benefit	from	Decreased	Congestion	of	The	NAS.

The	DJI	Phantom	4 UAS	is	battery	powered	and	serves	as	a	safe,	efficient,	and	economical	

alternative	to	the	manned	aircraft	traditionally	utilized	to	obtain	aerial	imagery.	An	

exemption	allowing	the	use	of	a	DJI	UAS	would	reduce	the	number	of	manned	aircraft	in	

the	NAS	and	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 UAS	does	not	require	an	airport	to	takeoff	or	land.	Likewise,	a	reduction	of	manned	

aircraft	conducting	aerial	video	and	photography	missions	would	result	in	fewer	aircraft	

that	must	be	handled	by	air	traffic	control	during	the	ground, takeoff,	departure,	arrival,	

and	landing	phases	of	flight	operations.

2. The	Public	Will	Benefit	from	The	Safety	and	Efficiency	of	The	DJI	UAS.

Conducting	aerial	acquisitions	with	the	DJI	Phantom	4 UAS,	instead	of	manned	aircraft,	

will	greatly	benefit	the	public	by	drastically	reducing	the	levels	of	air	and	noise	pollution	

generated	during	traditional	aerial	video	and	still	photography	flight	operations.	By	using	

battery	power	and	electric	motors,	the	DJI	UAS	produce	no	air	pollution,	and	is	the	most	

viable	environmentally	conscious	alternative	to	the	cabin	class,	six-cylinder internal	

combustion	engine	aircraft	that	are	typically	utilized	for	aerial	video	and	photography,	

while	burning	approximately 20-30	gallons	per	hour	of	leaded	aviation	fuel.	The	DJI	

Phantom	4	UA,	while	reducing	the	carbon	footprint	of	aerial	acquisitions,	also	eliminates	

noise	pollution,	as	the	UAs	are	propelled	by	battery-powered	electric	motors,	rather	than	

an	internal	combustion	engine.
By	using	the	DJI	UAS	to	perform	aerial	acquisitions,	the	substantial	risk	to	life	and	

property	in	the	air	and	on	the	ground,	which	is	usually	associated	with	traditional	

manned	aircraft	flight	operations,	will	be	substantially	reduced	or	completely	eliminated.	

Aside	from	the	lack	of	flight	crew	members	located	onboard	the	aircraft,	the	DJI UAS	

(weighing	approximately	3	&	15	pounds	and	with	a	length	of	16	&	20	inches	and	widths	

of	16	inches	and	with	no	fuel	on	board),	has	less	physical	potential	for	collateral	damage	

to	life	and	property	on	the	ground,	and	in	the	air,	compared	to	the	manned	aircraft	that	

typically	conduct	similar	operations	(weighing	approximately	6,000	pounds	with	a	

wingspan	of	approximately	42	feet,	a	length	of	34	feet,	and	a fuel	capacity	of	180	

gallons).

3. Performing	Aerial	Video	and	Photography	Operations	with	the	DJI UAS	Will	Benefit	the	

Economy.

In	addition	to	being	safe	and	efficient,	the	DJI	Phantom	4 UAS	is	also	an	economical	

alternative	to	using	manned	aircraft	to	conduct	similar	aerial	operations.	As	such,	

operation	of	the	DJI	Phantom	4	UAS	will	allow	United	States	based	companies,	like	

JEFFREY	SCOTT	GORA,	to	remain	competitive	and	contribute	to	growth	of	the	U.S.	

economy.	Specifically,	with	the	rising	cost	of	aviation	fuel	and	the	Environmental	

Protection	Agency	(EPA)	regulatory	actions	phasing	out	leaded	aviation	fuels,	U.S.	owned	

and	operated	companies	must	adopt	new	and	alternative	technology	in	order	to	remain	

competitive.	Operating	the	battery	powered	DJI	UAS	is	one	such	technology	that	not	only	

allows	companies	greater	operational flexibility	compared	to	manned	aircraft,	but	

provides	such	flexibility	without	the	high	operational	cost	of	a	traditional	manned	

aircraft.

By operating	the	DJI	Phantom	4	UAS,	companies	such	as	JEFFREY	SCOTT	GORA,	can	

remain	competitive	and	profitable,	and	therefore,	provide	greater	job	stability	to	

employees	and	contractors,	which	will	ultimately	contribute	to	growth	of	the	U.S.	

economy.	Improved	financial	performance	of	U.S.	companies,	through	commercial	use	of	

the	DJI	UAS,	provides	a	stable	workforce	that	increases	consumer	spending;	improves	

local,	state,	and	federal	tax	revenues;	and	allows	companies	to	invest	in	research	and	

development	in	order	to	remain	competitive	both	in	the	United	States	and	abroad.

4. There	Are	No	Privacy	Issues.

Similar	to	the	manned	aerial	acquisition	flight	operations	that	have	been	conducted	for	

decades,	JEFFREY	SCOTT	GORA’s	proposed	operation	of	the	DJI	UAS	will	not implicate	any	

privacy	issues.	Specifically,	the	DJI	UAS	will	be	operated	only	in	compliance	with	

operating	documents	(i.e.,	The	Monthly	Maintenance	Log,	and	DJI	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.
Rule	from	Which	JEFFREY	SCOTT	GORA	Seeks	Exemption.

1. Reasons	Why	The	DJI	Phantom	4 UAS	Meets	the	Conditions	of	The FAA	

Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333.

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

unmanned	aircraft	and	its	operation,	JEFFREY	SCOTT	GORA’s	operation	of	the	DJI	UAS	

meets	the	conditions	of	FMRA	Section	333,	and	will	not	require	an	airworthiness	

certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.

Section	333	provides	authority	for	a	UAS	to	operate	without	airworthiness	certification	

and	sets	forth	requirements	for	considering	whether	a	UAS	will	create	a	hazard	to	users	

of	the	NAS	or	the	public,	or	otherwise	pose	a	threat	to	national	security.	Specifically,	

FMRA	Section	333	states	the	following,	in	part:

(a) In	General.--Notwithstanding	any	other	requirement	of	this	subtitle,	and not	later	

than	180	days	after	the	date	of	enactment	of	this	Act,	the	Secretary	of	Transportation	

shall	determine	if	certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	

airspace	system	before	completion	of	the	plan	and	rulemaking	required	by	section	332	of	

this	Act	or	the	guidance	required	by	section	334	of	this	Act.

(b) Assessment	of	Unmanned	Aircraft	Systems.--In	making	the	determination	under	

subsection	(a),	the	Secretary	shall	determine,	at	a	minimum--

(1) )	which	types	of	unmanned	aircraft	systems,	if	any,	as	a	result	of	their	size,	weight,	

speed,	operational	capability,	proximity	to	airports	and

populated	areas,	and	operation	within	visual	line	of	sight	do	not	create	a	hazard	to	users	

of	the	national	airspace	system	or	the	public	or	pose	a	threat	to	national	security;	and

(2) )	whether	a	certificate	of	waiver,	certificate	of	authorization,	or	airworthiness	

certification	under	section	44704	of	title	49,	United	States	Code,	is	required	for	the	

operation	of	unmanned	aircraft	systems	identified	under	paragraph	(1).

(c) Requirements	for	Safe	Operation.--If	the	Secretary	determines	under	this	section	

that	certain	unmanned	aircraft	systems	may	operate	safely	in	the	national	airspace	

system,	the	Secretary	shall	establish	requirements	for	the	safe	operation	of	such	aircraft	

systems	in	the	national	airspace	system.

In	seeking	this	exemption,	JEFFREY	SCOTT	GORA	submits	that	the	DJI	Phantom	4	UAS	can	

operate	safely	in	the	NAS	pursuant	to	FMRA	Section	333,	as	demonstrated	by:	(a)	the	

characteristics	of	the	DJI	Phantom	4	UA;	(b)	the	pilot	certification	requirement;	and

(c)	the	specific	operating	limitations.

A	complete	description	of	the	operation	and	specifications	of	the	DJI	Phantom	4	and	

flight	control	software	is	provided	at	DJI	WEB	SITE.
1. Reasons	Why	an	Exemption	from	the	Requirements	of	Section	91.121	Would	Not	

Adversely	Affect	Safety.

The	equivalent	level	of	safety	established	by	Section	91.121	will	be	maintained	because	

the	altitude	information	of	the	DJI	Phantom	4 UAS	will	be	provided to	the	PIC	via	GPS	

equipment	and	a	radio	communications	telemetry	data	link,	which	downlinks	from	the

UAS	to	the	GCS	for	active	monitoring	of	the	flight	path	and	altitude.	This	altitude	

information,	combined	with	JEFFREY	SCOTT	GORA’s	operation	of	the	DJI	Phantom	4 UAS	

within	visual	line	of	sight,	at	or	below	500	feet	AGL,	will	ensure	a	level	of	safety	

equivalent	to	Section 91.121.	The	altitude	information	will	be	generated	by	GPS	

equipment	installed	onboard	the	aircraft.	Prior	to	each	flight,	a	zero	altitude	initiation	

point	is	automatically	established	by	the	UAS	at	ground	level.

The	FAA	has	previously	granted	relief	from	Section	91.121	specific	to	UAS,	in	

circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	

Nos.	11062,	11063,	11064,	11065,	11066,	11067,	11080,	11109,	11112,	11136,	11138,	

11150,	11153,	11156,	11157, 11158,	11159,	11160, 11161).

2. Reasons	Why	an	Exemption	from	the	Requirements	of	Section	91.151(b)	Would	Not	

Adversely	Affect	Safety.

A	grant	of	this	exemption	would	ensure	an	equivalent	level	of	safety	established	by	14	

C.F.R.	Section	91.151(b)	as	a	result	of	(1)	the	technical	specifications	of	the	DJI	Phantom	4	

UAS;	(2)	the	limitations	on	the	proposed	flight	operations;	and	(3)	the	location	of	the	

proposed	flight	operations.	Accordingly,	JEFFREY	SCOTT	GORA	will	ensure	that	it	will	

safely	operate	the	battery- powered	DJI UAS	during	daylight	hours	in	VFR	conditions,	with	

enough	battery	power	to	fly	for	a	total	duration	of	17.5	minutes	to	the	first	point	of	

intended	landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	4.5	

minutes.

Here,	as	in	Exemption	No.	11109,	the	technical	specifications	of	the	DJI	UAS,	the	

limitations	on	the	proposed	flight	operations,	and	the	location	of	the	proposed	

operations,	will	ensure	an	equivalent	level	of	safety	established	by	14	C.F.R.	Section	

91.151(b).	Furthermore,	safety	will	be	ensured	as	the	DJI	UAS	provides	audible	and	visual	

warnings	to	the	PIC	at	the	GCS	when	the UAS	experiences low	battery	voltage,	the	first	

warning	occurring	at	approximately	33%	remaining	battery	power,	and	again	at	

approximately	10%	remaining	battery	power.	At	the	critically	low	battery	level,	the	DJI	

Phantom	4	UAS	will	descend	and	land	automatically.

Significantly,	previous	exemptions	granted	by	the	FAA	concerning	Section	91.151	

establish	that	safety	is	not	adversely	affected	when	the	technical	characteristics	and

operating	limitations	of	the	UAS	are	considered.	Relief	has	been	granted	for	manned	

aircraft	to	operate	at	less	than	the	minimums	prescribed	in	Section	91.151,	including	

Exemption	Nos.	2689,	5745,	and	10650.	Moreover,	the	FAA	has	previously	granted	relief	

from	Section	91.151	specific	to	UAS,	in	circumstances	similar,	in	all	material	respects,	to	

those	presented	herein	(e.g. Exemption	Nos.	8811,	10808,	10673,	11042,	11062,	11063,	

11064,	11065,	11066,	11067,	11080, 11109,	11110,	11136,	11138,	11150,	11153,	11156,	

11157,	11158,	11159,	11160,	11161).
3.			Reasons	Why	an	Exemption	from	the	Requirements	of	Sections	91.405(a),	

						91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	Would	Not	Adversely

						Affect	Safety.	

In	seeking	this	exemption,	JEFFREY	SCOTT	GORA	submits	that	the	equivalent	level	of	

safety	with	regard	to	the	regulatory	maintenance	and	alteration	requirements	

established	by	Sections	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b)	

will be	met	because	JEFFREY	SCOTT	GORA	will	use	trained	technicians	to	perform	

maintenance,	alterations,	or	preventive	maintenance	on	the	UAS	using	the	methods,	

techniques,	and	practices	prescribed	in	the	operating	documents	(i.e.	The	Monthly	

Maintenance	Log	and	DJI	Instruction	Manual).	Furthermore,	JEFFREY	SCOTT	GORA	will	

document	and	maintain	all	maintenance	records	for	the	DJI	UAS.	Since	the	DJI	UAS	will	be	

inspected	as	prescribed	by	the	operating	documents,	JEFFREY	SCOTT	GORA	will	maintain	

the	equivalent	level	of	safety	established	by	Sections	91.405(a),	91.409(a)(1),	and	

91.409(a)(2).

Likewise,	the	exemption	sought	will	not	adversely	affect	safety	because	JEFFREY	SCOTT	

GORA	will	use	trained	technicians	to	perform	maintenance,	alterations	or	preventive	

maintenance	on	the	UAS	using	the	methods,	techniques,	and	practices	prescribed	by	the	

operating	documents.

Furthermore,	the	exemption	sought	would	maintain	an	equivalent	level	of	safety	

established	by	Sections	91.407,	91.417(a)	and	91.417(b),	because	all	maintenance	of	the	

DJI	Phantom	4	UAS	will	be	performed	by	trained	technicians.	Maintenance	will	be	

documented	and	maintained	utilizing	the	monthly	maintenance	log.		Significantly,	

previous	exemptions	granted	by	the	FAA	concerning	Sections	91.405(a),	91.407(a)(1),	

91.409(a)(1)	&	(a)(2),	and	91.417(a)	&

(b)	establish	that	safety	is	not	adversely	affected	when	the	technical	characteristics	and	

operating	limitations	of	the	UAS	are	considered.

In	consideration	of	JEFFREY	SCOTT	GORA’s	proposed	operating	limitations, the	operating	

documents,	and	the	technical	aspects	of	the	DJI	Phantom	4	UAS,	JEFFREY	SCOTT	GORA	

submits	that	safety	will	not	be	adversely	affected	by	granting	exemption	from	14	C.F.R.	

Sections	91.405(a),	91.407(a)(1)	and	(a)(2),	91.409(a)(2),	and	91.417(a)	and	(b).	The

FAA	has	previously	granted	relief	specific	to	UAS	in	circumstances	similar,	in	all	material	

respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062,	11063,	11064,	11065,	

11066, 11067,	11080,	11109,	11110,	11112, 11136,	11138,	11150,	11153,	11156,	11157,	

11158,	11159,	11160,	11161).
CONCLUSION

As	set	forth	herein,	JEFFREY	SCOTT	GORA	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	4	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	JEFFREY	

SCOTT	GORA to	safely,	efficiently,	and	economically	operate	the	DJI	Phantom	4	UAS	

commercially	within	the	NAS.

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

Modernization	and	Reform	Act	of	2012,	Section	333,	JEFFREY	SCOTT	GORA	respectfully	

requests	that	the	Administrator	grant	this	Petition	for	an	exemption	from	the	

requirements	of	14	C.F.R	Sections 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	JEFFREY	SCOTT	GORA	to	operate	the	DJI	Phantom	4	UAS	

commercially	for	the	purpose	of	conducting	aerial	video	and	photography	over	certain	

areas	of	the	United	States.

Dated:	07	March	2016

Respectfully,

Jeff	S. Gora