September 8, 2015 

US Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and CFR 

Part 11, I am submitting a request to be exempt from the Federal Aviation Regulations 

(FAR) listed below so I may operate UASs commercially in airspace regulated by the 

FAA as long as such operations are conducted within and under the conditions outlined 

herein or as may be established by FAA as required by Section 333. 

All operations will be performed with the public's safety and right to privacy at all times. 

Respectfully 

Gale Stoner 

7 44 Stonetrace Drive 

Murfreesboro, TN 37128 

615-473-7674 

gale@galestoner .com 
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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION WASHINGTON, DC 

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: GALE L. STONER 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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) CONCERNING COMMERCIAL OPERATION 

DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS and a BLANKET 

EXEMPTION FOR UAS OPERATION LESS THAN 55 POUNDS, DAYLIGHT OPERATION, VLOS, 

VFR AND BELOW 200 FEET AGL 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112--95) 

Submitted on SEPTEMBER 8, 2015 

GALE L. STONER 

744 STONETRACE DRIVE 

MURFREESBORO, TN 37128 

615-473-7674 

GALE@GALESTONER.COM 
•. 

TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS .................................................•......•.....................................................•..... iii 

SUMMARY ..................................••.......•...................•...................•.......••••.............•....................................... ! 

INTRODUCTION AND INTERESTS OF THE PETITIONER ...............•.•............................................................... 1 

BACKGROUND .............................................................................................................................................. 1 

Unmanned Aircraft Systems: DJI Phantom 3 {Hereafter the DJI UAS Aircraft) ............................................ 1 

BASIS FOR PETITION ..................................................................................................................................... 1 

Name And Address Of The Petitioner .......................................................................................................... 3 

THE SPECIFIC SECTIONS OF 14C.F.R. FROM WHICH GALE L. STONER SEEKS EXEMPTION ........................... 3 

GALE L. STONER Seeks Exemption From The Requirements Of Section 61.113(a) And (b) .................... 3 

GALE L. STONER Seeks Exemption From The Requirements Of Section 91.7{a) ..................................... 3 

GALE L. STONER Seeks Exemption From The Requirements Of Section 91.121 ..................................... 3 

GALE L. STONER Seeks Exemption From The Requirements Of Section 91.151(b) ................................. 4 

GALE L. STONER Seeks Exemption From The Requirement Of Section 91.405{a) ................................... 4 

GALE L. STONER Seeks Exemption From The Requirements Of Section 91.407(a){l) ............................. 4 

GALE L. STONER Seeks Exemption From The Requirements Of Sections 91.409{a)(l) 

And 91.409(a)(2) ...................................................................................................................................... 4 

GALE L. STONER Seeks Exemption From The Requirements Of Sections 91.417{a) And 91.417{b) ........ 5 

THE EXTENT OF RELIEF GALE L. STONER SEEKS AND THE REASON GALE L. STONER SEEKS THE RELIEF .. 6 

Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief From Section 

61.113(a) And (b) ..................................................................................................................................... 6 

Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief 

From Section 91.7{a) ............................................................................................................................... 7 

Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief 

From Section 91.121 ............................................................................................................................... 7 

Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief 

From Section 91.151(b) ........................................................................................................................... 8 

Extent Of Relief GALE L. STONER Seeks And The Reason GALE L. STONER Seeks Relief 

From Sections 91.405(a), 91.407{a)(l), 91.409(a){l) & (a)(2), And 91.417{a) & (b) ................................ 8 

The Reasons Why Granting GALE L. STONER Request Would Be In The Public Interest; That Is, 

How It Would Benefit The Public As A Whole ............................................................................................. 8 

The Public Will Benefit From Decreased Congestion Of The NAS ........................................................... 9 

The Public Will Benefit From The Safety And Efficiency Of The DJI UAS Aircraft .................................... 9 

Performing Aerial Video and Photography Operations With The DJI UAS Aircraft will 

Benefit The Economy .............................................................................................................................. 10 

There Are No Privacy Issues .................................................................................................................... 10 

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 GALE L. 

STONER Seeks Exemption ............................................................................................................................ 11 
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Reasons Why The DJI UAS Aircraft Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333 .................................................................................................... 11 

The Specifications Of The DJI UAS Aircraft Demonstrate Its Save Characteristics ....................................... 12 

Technical Specifications of DJI UAS Aircraft ................................................................................................. 12 

DJI UAS Aircraft GCS Operation ................................................................................................................... 12 

Flight Operations of DJI UAS Aircraft are limited To The line Of Sight Of A Certificated Pilot 

in Command With A Safety Observer .......................................................................................................... 12 

Flights of DJI UAS Aircraft Will Be Conducted Pursuant To Specific Operating limitations .................................. 12 

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

Adversely Affect Safety ......................................................................................................................................... 16 

Reasons Why An Exemption From The Requirements Of Section 91. 7(a) Would Not Adversely 

Affect Safety .......................................................................................................................................................... 18 

Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely 

Affect Safety .......................................................................................................................................................... 18 

Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely 

Affect Safety .......................................................................................................................................................... 18 

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 ........................................................................ 19 

The FAA May Prescribe Any Other Conditions For Safe Operation ...................................................................... 20 

A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

GALE L. STONER Seeks Exemption: ....................................................................................................................... 21 

Brief Description Of The Nature Of The Exemption GALE L. STONER Seeks: ........................................................ 21 

Any Additional Information, Views, Or Arguments Available To Support GALE L. STONER Request .................... 21 

CONCLUSION ......................................................................................................................................................... 22 

Phantom 3 Specifications and Description: .................................................................................................. 23 

ii 
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GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

Dll UAS Aircraft 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UAV 

UAS 

VFR 

VLOS 

VMC 

VTOL 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofFederal Regulations 

Certificate of Authorization 

Dll Phantom 3 subject of this Petition. 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss ofLink 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Mod and Reform Act of 2012 (FMRA) Section 333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft Vehicle 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

iii 
SUMMARY 

GALE L. STONER seeks exemption from the requirements of 14 C.F.R §§61.113(a} & (b), 91.7(a}, 

91.121, 91.151(b}, 91.40S(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 GALE L. STONER to operate an Unmanned Aircraft System 

(UAS} for the commercial purpose of conducting aerial video and photography in support of small 

business, community and charitable activities in and around the State of Tennessee. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

GALE L. STONER's primary occupation is a sole proprietor of a photography business. From time to 

time he is asked to support local community, small business, and charitable activities by providing 

commercial aerial photography or videography. In the absence of the exemption, GALE L. STONER 

must decline to support these interests. The objective of GALE L. STONER and his aerial operations 

is to provide high quality imaging for a variety of commercial, public, and residential uses that are 

incidental to his primary occupation, specifically targeting 

• Golf Courses 

• Church Properties 

• Real Estate Marketing 

BACKGROUND 

Unmanned Aircraft Systems: OJI Phantom 3 (Hereafter the OJI UAS 

Aircraft) 

GALE L. STONER seeks an exemption to operate OJI Phantom 3 UAS systems for compensation or 

hire within the NAS. The DJI Phantom 3 is a vertical takeoff and landing (VTOL} Unmanned 

Aircraft (UA} with a Ground Control Station (GCS} utilizing electronic tablet or smart phone 

systems. OJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 

inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 30 

knots. The OJI Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors. 

BASIS FOR PETITION 

Petitioner, GALE L. STONER, 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 OJI UAS Aircraft in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§61.113(a} & (b), 91.7(a}, 91.121, 91.151(b}, 91.40S(a}, 91.407(a}(1}, 

91.409(a)(1} & (a}(2}, and 91.417(a} & (b). 

1 
9 • 

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

unmanned aircraft and its operation, GALE L. STONER operation DJI UAS Aircraft meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

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

Accordingly, GALE L. STONER 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. 

GALE L. STONER submits that the requested relief is proper since an equivalent level of safety will 

be ensured. GALE L. STONER 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. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command, is requested by GALE L. STONER to the extent necessary to allow a 

Pilot in Command (PIC) with significant experience in the field of UAV's, and who has 

demonstrated, by meeting minimum flight--hour and currency requirements, that the PIC is able 

to safely operate the OJI UAS Aircraft in a manner consistent with this exemption, including 

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

vehicles and structures. 

GALE L. STONER seeks relieffrom Section 91.7(a), entitled Civil aircraft airworthiness, because the 

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

Subpart H. As such, GALE L. STONER submits that he will ensure the DJI UAS Aircraft are in an 

airworthy condition, prior to every flight, by determining that the UASs are in compliance with the 

operating documents and that the aircraft are in a condition for safe flight. 

GALE L. STONER also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings; OJI UAS aircraft will not have a typical barometric altimeter on board. However, 

altitude information of the OJI UAS Aircraft 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 GALE L. 

STONER operation of the DJI UAS Aircraft within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Additionally, GALE L. STONER seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. GALE L. STONER submits that safety will not 

be affected by operation of the DJI UAS Aircraft 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 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. 

2 
In accordance with 14 C.F.R. § 11.81, GALE L. STONER provides the following information in support 

of its petition for exemption: 

Name And Address Of The Petitioner 

The name and address of the Petitioner and point of contact is: 

GALE L. STONER 

744 Stonetrace Drive 

Murfreesboro, TN 37128 

615-473-7674 (Mobile) 

gale@galestoner.com 

The Specific Sections Of 14 C.F.R. From Which GALE L. STONER Seeks 

Exemption. 

GALE L. STONER Seeks Exemption From The Requirements Of Section 61.113(a) 

And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: No person who holds a 

private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying 

passengers or property for compensation or hire; nor may that person, for compensation 

or hire, act as PIC of an aircraft. A private pilot may, for compensation or hire, act, as PIC 

of an aircraft in connection with any business or employment if- The flight is only 

incidental to that business or employment; and the aircraft does not carry passengers or 

property for compensation or hire. 

GALE L. STONER 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. 

GALE L. STONER Seeks Exemption From The Requirements Of Section 91.121. 

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

3 
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- Below 

18,000 feet MSL, to--The current reported altimeter setting of a station along the route and 

within 100nautical miles of the aircraft; 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 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. 

GALE L. STONER 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. 

GALE L. STONER 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- 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 [.] 

GALE L. STONER 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: No person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless--It has been 

approved for return to service by a person authorized under §43. 7 of this chapter [.] 

GALE L. STONER 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: 

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 --

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 

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

Part 21 of this chapter. 

4 
GALE L. STONER 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: 

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: 

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--A description (or reference to data acceptable to the Administrator) 

of the work performed; and the date of completion of the work performed; and 

The signature and certificate number of the person approving the aircraft for return to 

service. 

Records containing the following information: 

The total time in service of the airframe, each engine, each propeller, and each rotor. 

The current status of life--limited parts of each airframe, engine, propeller, rotor, and 

appliance. 

The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

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. 

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. 

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. 

5 
The owner or operator shall retain the following records for the periods prescribed: The 

records specified in paragraph {a)(l) 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. 

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. 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 GALE L. STONER Seeks and The Reason GALE L. STONER 

Seeks the Relief. 

Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER 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 

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, GALE L. STONER submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the OJI Phantom 3 UAS unless that PIC 

has met certain flight hour and currency requirements, demonstrating that the PIC is able to 

safely operate the OJI Phantom 3 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, GALE L. STONER submits that all flights of OJI UAS aircraft, conducted by the PIC 

pursuant to the grant of this Petition: {1) will be incidental to GALE L. STONER business; and {2) 

will not carry passengers or property for compensation or hire. 

6 
Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER 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 GALE L. STONER to determine that the DJI UAS Aircraft are in airworthy 

condition prior to every flight by ensuring that the UAS is in compliance with the operating 

documents (i.e., the GALE L. STONER Aerial Operations Manual, Monthly Maintenance Log, 

and OJI UAS Aircraft Instruction Manual). 

GALE L. STONER seeks the requested relief because the OJI UAS Aircraft do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GALE L. 

STONER will ensure that the OJI UAS Aircraft are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and OJI UAS Aircraft 

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. 

Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER Seeks Relief from 

Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the OJI UAS Aircraft, which utilize a barometric pressure sensor, GPS equipment, 

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), GALE L. STONER seeks the requested relief because the OJI UAS Aircraft 

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 OJI UAS Aircraft are equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that aground level pressure setting will be established 

prior to each flight, and provides the PIC with altitude information of the UA on the heads--up 

display of the GCS. 

7 
Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER 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 UAS Aircraft during 

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

total duration of 15 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 5 minutes. GALE l. STONER seeks the requested relief 

because without an exemption from Section 91.15l(b), the flight time duration of the battery 

powered DJI UAS Aircraft will severely constrain the practicality of any aerial video or still photo 

flight operations that GALE l. STONER proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI UAS Aircraft operating 

documents, and GALE l. STONER proposed operating limitations, ensure that GALE l. STONER 

will safely operate the battery powered DJI UAS Aircraft during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to 

fly for a total duration of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 

Extent of Relief GALE L. STONER Seeks and The Reason GALE L. STONER Seeks Relief from 

Sections 91.40S(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, GALE l. STONER requests relief from these 

Sections because the DJI UAS Aircraft do not require airworthiness certificates. As set forth 

more fully below, DJI UAS Aircraft meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. 

Accordingly, GALE l. STONER will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the GALE l. STONER Aerial 

Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual). 

Furthermore, GALE l. STONER will document and maintain all maintenance records for the DJI 

UAS Aircraft. 

The Reasons Why Granting GALE L. STONER 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 GALE l. STONER to 

safely, efficiently, and economically perform aerial video and photography of construction sites, 

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

8 
' 

Additionally, use of the OJI UAS Aircraft will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of GALE L. STONER 

proposed operation of the OJI UAS Aircraft would be realized without implicating any privacy 

issues. 

The Public Will Benefit from Decreased Congestion of The NAS. 

DJI UAS Aircraft 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 

OJI UAS Aircraft 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 OJI UAS Aircraft 

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. 

The Public Will Benefit from The Safety and Efficiency of The DJI UAS Aircraft 

Conducting aerial acquisitions with the OJI UAS Aircraft, 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 OJI UAS Aircraft 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 OJI UAS aircraft, 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 OJI UAS Aircraft 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. 

9 
Aside from the lack of flight crew members located on board the aircraft, the OJI UAS Aircraft 

(weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 

inches and 17.7 inches respectively, 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). 

Performing Aerial Video and Photography Operations with The DJI UAS Aircraft Will Benefit the 

Economy. 

In addition to being safe and efficient, the OJI UAS Aircraft are also an economical alternative to 

using manned aircraft to conduct similar aerial operations. As such, operation of the OJI UAS 

Aircraft will allow United States based companies, like GALE L. STONER, 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 OJI UAS Aircraft 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 OJI UAS aircraft, petitioners such as GALE L. STONER 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 OJI UAS 

Aircraft, 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. 

There Are No Privacy Issues. 

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

decades, GALE L. STONER proposed operation of the OJI UAS Aircraft will not implicate any 

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

operating documents (i.e., the GALE L. STONER Aerial Operations Manual, Monthly 

Maintenance Log, and OJI UAS Aircraft 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. 

10 
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 GALE L. STONER Seeks Exemption. 

Reasons Why The OJI UAS Aircraft Meet the Conditions of The FAA Modernization and Reform 

Act of 2012 (FMRA) Section 333. 

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

unmanned aircraft and its operation, GALE L. STONER operation of the OJI UAS Aircraft meet 

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

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

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

sets forth requirements for considering whether a UAS will create a hazard to users of the NAS 

or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 

states the following, in part: 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. 

Assessment of Unmanned Aircraft Systems. ----In making the determination under subsection 

(ate Secretary shall determine, at a minimumWhich 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 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). Requirements for 

Safe Operation. -

If the Secretary determines under this section that certain u), 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, GALE L. STONER submits that the OJI UAS Aircraft can operate safely 

in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the OJI 

UAS aircraft; (b) the pilot certification requirement; and (c) the specific operating limitations. 

11 
The Specifications of The DJI UAS Aircraft Demonstrate Its Safe Characteristics. 

The DJI UAS Aircraft do 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. 

Technical Specifications of DJI UAS Aircraft. 

The technical specifications of the DJI UAS Aircraft are set forth by the DJI UAS aircraft 

User Manuals, attached hereto as Appendix A and B. 

The DJI UAS Aircraft Autonomous Flight and Navigation Modes Enable The UASs to Remain 

Within a Defined Operational Area. 

The DJI UAS Aircraft may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI UAS Aircraft provided in the 

User Manuals, attached hereto as Appendix A and B. 

The DJI UAS Aircraft 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 UAS Aircraft will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI UAS Aircraft do not reacquire control link data from the GCS, the 

UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., 

failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI UAS aircraft are described in 

the User Manuals, attached hereto as Appendix A and B. 

DJI UAS Aircraft GCS Operation. 

Phantom 3 GCS and flight control software is provided in the User Manual for the DJI UAS 

aircraft attached hereto as Appendix A and B. 

Flight Operations of DJI UAS Aircraft are Limited to The Line of Sight of a Certificated 

Pilot in Command with A Safety Observer. 

GALE L. STONER will be the only person to act as a pilot in command (PIC) of DJI UAS Aircraft 

Flights of DJI UAS Aircraft Will Be Conducted Pursuant to Specific Operating Limitations. 

12 
In seeking this exemption, GALE L. STONER proposes to commercially operate OJI UAS Aircraft for 

the special purpose of conducting aerial video and photography over certain areas of United States, 

pursuant to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft 

described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum 

gross weight: OJI UAS AIRCRAFT. 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 45 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 lenses, as 

specified on the PIC's FAA--issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO} is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to 

communicate verbally at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer his or her designation 

for the duration of the flight. The PIC must ensure that the SO can perform the functions prescribed 

in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding 

other air traffic and other ground based obstacles/obstructions and is not permitted to operate the 

camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations 

and made available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the grant of exemption take 

precedence and must be followed. Otherwise, the operator must follow the procedures as outlined 

in its operating documents. The operator may update or revise its operating documents. It is the 

operator's responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator determines that 

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

operator must petition for amendment to its grant of exemption. The FAA's UAS Integration Office 

(AFS80} may be contacted if questions arise regarding updates or revisions to the operating 

documents. 

13 
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. 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. 

17. UAS operations may not be conducted during night, as defined in 14 C.F.R. 

18. §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. 

19. The UAV 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. 

14 
20. The UAV 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. 

21. If the UAV loses communications or loses its GPS signal, it must return to a pre-determined 

location within the planned operating area and land or be recovered in accordance with the 

operating documents. 

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

accordance with the operating documents. 

23. 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 UAV with 25% battery power remaining. 

24. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will 

also require the operator to request a Notice to Airman (NOT AM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in 

accordance with airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements. 

25. 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. 

26. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UAV must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

27. 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. 

28. The UAV must remain clear and yield the right of way to all manned aviation operations and 

activities at all times. 

29. The UAV may not be operated by the PIC from any moving device or vehicle. 

30. 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: 

31. Barriers or structures are present that sufficiently protect nonparticipating persons from the 

UAV and/or debris in the event of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where nonparticipating persons leave 

such protection and are within 500 feet of the UA, flight operations must cease immediately 

and/or; 

32. 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; 

15 
33. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an 

undue hazard to those persons per§ 91.119(a). 

34. 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. 

35. 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. 

36. 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. 

GALE L. STONER 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 UAS Aircraft 

unless that PIC has demonstrated, by meeting minimum flight--hour and currency 

requirements, that the PIC is able to safely operate the OJI UAS Aircraft in a manner 

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

appropriate distances from people, vessels, vehicles and structures. 

Considering GALE L. STONER proposed area of operations, and the operating limitations set 

forth--above; the parallel nature of private pilot aeronautical knowledge requirements to those 

of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills 

necessary to safely operate the DJI UAS aircraft, GALE L. STONER submits that the training, 

preparation, practice, and experience of the Petitioner is sufficient to meet the requirements of 

the proposed use. 

The FAA has previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in 

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,11112,11136, 

11138,11150,11153,11156,11158,11159,11160,11161). 

GALE L. STONER will not allow any PIC to operate the DJI UAS Aircraft unless the PIC has 

demonstrated, by meeting minimum flight--hour requirements or the OJI UAS Aircraft training and 

currency requirements, that the PIC is able to safely operate the DJI UAS Aircraft in a manner 

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

appropriate distances from people, vessels, vehicles and structures. 

16 
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 

hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

GALE L. STONER proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of 

motion picture filming (or similar operations), the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi--rotor UAS. Prior to operations under Exemption 

No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive rather than 

additive; i.e. 5 hours make and model time may be included in the 10 hours of multi--rotor time and 

the 10 hours may be included in the total 25 hours of UAS rotorcraft time. 

In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the 

preceding 90 days (for currency purposes). The FAA finds that at minimum, the flight--hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills 

necessary to safely conduct the petitioner's proposed operations. The FAA also finds that prior 

documented flight experience that was obtained in compliance with applicable regulations would 

satisfy this requirement. Training, proficiency, and experience--building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. During training, 

proficiency, and experience building flights the PIC is required to operate the UAS with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 16. 

Accordingly, GALE L. STONER will ensure safe operations by not allowing any PIC to operate OJI 

UAS Aircraft unless that PIC has demonstrated, by meeting minimum flight--hour and currency 

requirements, that the PIC is able to safely operate the DJI UAS Aircraft in a manner consistent 

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

distances from people, vessels, vehicles and structures. 

17 
Reasons Why an Exemption from The Requirements of Section 91. 7(a) Would Not Adversely 

Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior 

to every flight, GALE L. STONER will ensure that OJI UAS Aircraft is in an airworthy condition 

based upon the UAS's compliance with its operating documents and as stated in the conditions 

and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110,11112,11136, 11138,11150,11153,11156,11157,11158,11159,11160,11161). 

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 OJI UAS Aircraft will be provided to the PIC via GPS equipment and a 

radio communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path and altitude. This altitude information, combined with GALE L. 

STONER operation of the OJI UAS Aircraft within visual line of sight, at or below 400 feet AGL, 

will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude 

initiation point is automatically established by the UASs at ground level. 

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

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 11150, 

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

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 ofthe OJI UAS Aircraft; (2) the 

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

operations. Accordingly, GALE L. STONER will ensure that it will safely operate the battery 

powered OJI UAS Aircraft during daylight hours in VFR conditions, with enough battery power 

to fly for a total duration of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 

18 
Here, as in Exemption No. 11109, the technical specifications of the OJI UAS Aircraft UASs; 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 Aircraft provide 

audible and visual warnings to the PIC at the GCS when the UAs experiences low battery 

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

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

Vision+ and OJI Phantom 3UASs 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). 

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, GALE L. STONER 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 GALE L. 

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

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., the GALE L. STONER Aerial Operations Manual, Monthly Maintenance 

Log, and DJI UAS Aircraft Instruction Manual). 

Furthermore, GALE L. STONER will document and maintain all maintenance records for 

the DJI UAS Aircraft UASs. 

Since the OJI UAS Aircraft will be inspected as prescribed by the operating documents, GALE L. 

STONER will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the OJI UAS Aircraft User Manuals are attached 

hereto as Appendix A and B; a copy of the OJI UAS Aircraft Maintenance LOG is attached 

hereto as Appendix C. 

19 
Likewise, the exemption sought will not adversely affect safety because GALE L. STONER 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 ofthe DJI UAS Aircraft 

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 GALE L. STONER proposed operating limitations, the operating documents, 

and the technical aspects of the OJI UAS Aircraft, GALE L. STONER 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). 

The FAA May Prescribe Any Other Conditions for Safe Operation. 

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

and 14 C.F.R. § 21.16 entitled Special Conditions, GALE L. STONER requests that the FAA 

prescribe special conditions for the intended operation of the DJI UAS Aircraft UASs, which 

contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R §§61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for 

the limited purpose of conducting aerial video and photography over certain areas of the 

United States for compensation or hire. FMRA Section 333 sets forth the requirements for 

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. §21.16, for 

operation of the OJI UAS Aircraft UASs, since the airworthiness regulations of 14 C.F.R. Part 21 

do not contain adequate or appropriate safety standards, due to the novel or unusual design 

features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

20 
If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for the aircraft, 

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. See 14 C.F.R. § 21.16. 

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe 

special conditions for leading Edge's intended operation of the OJI UAS Aircraft, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113{a) & 

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

{b). 

A Summary That Can Be Published in The Federal Register, stating: The Rules from Which 

GALE L. STONER Seeks Exemption: 

GALE l. STONER seeks exemption from the requirements of 14 C.F.R Sections 61.113{a)&(b), 

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

A Brief Description of the Nature of the Exemption GALE L. STONER Seeks: 

This exemption will permit GALE l. STONER to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography over 

certain areas of the United States. 

Any Additional Information, Views, Or Arguments Available to Support GALE L. STONER 

Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

{FMRA) Section 333, which direct the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, GALE l. STONER request for exemption may 

be granted pursuant to the authority of FMRA Section 333 and 14 

C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; 

and further, provides the authority for such UAS to operate without airworthiness 

certification. 

21 
As discussed in detail above, GALE L. STONER will operate DJI UAS aircraft safely in the 

NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security. 

CONCLUSION 

As set forth herein, GALE L. STONER 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 OJI UAS Aircraft 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 GALE L. STONER to safely, 

efficiently, and economically operate the DJI UAS Aircraft commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, GALE L. STONER 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), 91.40S(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI UAS 

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

certain areas of the United States. 

Gale Stoner 

22 

Very respectfully, 

GALE L. STONER 

744 STONETRACE DRIVE 

MURFREESBORO, TN 37128 

615-473-7674 

7-8-/~ 

Date 
DJI Phantom 3 Manual 

http:/ /download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professionai_User_Manu 

al_vl.O_e n.pdf 

Gilnbal 

Model 

ZENMUSEX3 

Output Power (With Camera) 

Static: 9 W In Motion: 11 W 

Operating Current 

Station: 750 rnA Motion: 900 rnA 

Angular Vibration Range 

±0.03° 

Mounting 

Detachable 

Controllable Range 

Pitch: -90° to +30° Pan: ±320° 

Mechanical Range 

Pitch: -125° to +45° Pan: ±330° 

Max Controllable Speed 

Pitch: 120°/sPan: 180°/s 

Camera 

Name 

X3 

Model 

FC350 

Total Pixels 

12.76M 

Effective Pixels 

l2.4M 

Image Max Size 

4000x3000 

lso Range 

100-3200 (video) 100-1600 (photo) 

Electronic Shutter Speed 

8s - l/8000s 

Fov (Field Of View) 

94° 

Cmos 

23 
Sony EXMOR 1/2.3" 

Lens 

20mm (35mm format equivalent)f/2.8 focus at oo 9 Elements in 9 groups Anti-distortion 

Still Photography Modes 

Single shoot-burst shooting: 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5 

bracketed frames Time-lapse 

Video Recording Modes 

UHD ( 4K): 4096x2160p24/25, 3840x2160p24/25/30FHD: 

1920x I 080p24/25/30/48/50/60HD: l280x720p24/25/30/48/50/60 

Max Bitrate Of Video Storage 

60 Mbps 

Supported File Formats 

FAT32/exFAT Photo: JPEG, DNG Video: MP4/MOV (MPEG-4AVC/H.264) 

Supported Sd Card Types 

Micro SD Max capacity: 64GB. Class 10 or UHS-1 rating required. 

Operating Temperature Range 

0° to 40° C 

Remote Controller 

Cl 

Operating Frequency 

922.7-927.7 MHz (Japan Only)5.725-5.825 GHz 2.400,..,2.483 GHz 

Transmitting Distance (Outdoor And Unobstruct) 

2km 

Eirp 

10dBm@900m, 13dBm®5.8G, 20dBm@2.4G 

Video Output Port 

USB, mini-HDMI 

Power Supply 

Built-in battery 

Charging 

DJI charger 

Dual User Capability 

Host-and-Slave connection 

Mobile Device Holder 

Tablet or Phone 

Max Mobile Device Width 

170mm 

Output Power 

9W 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

24 
Less than 3 months: -20° to 45° C More than 3 months: 22° to 28° C 

Charging Temperature Range 

0-40° c 

Battery 

6000 mAh LiPo 2S 

Charger 

Model 

Al4-IOOPIA 

Voltage 

26.3 v 

Rated Power 

IOOW 

Battery (Standard) 

Intelligent Flight Battery 

Model 

TB47 

Capacity 

4500mAh 

Voltage 

22.2 v 

Battery Type 

LiPo 6S High voltage battery 

Energy 

99.9Wh 

Net Weight 

570 g 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20° to 45° C More than 3 months: 22° C to 28° C 

Charging Temperature Range 

0° to 40° C 

Max Charging Power 

180W 

Battery (Optional) 

Intelligent Flight Battery 

Model 

TB48 

Capacity 

5700 mAh 

Voltage 

25 
22.8 v 

Battery Type 

LiPo 6S 

Energy 

129.96 Wh 

Net Weight 

670 g 

Operating Temperature Range 

-10° to 40° C 

Storage Temperature Range 

Less than 3 months: -20 to 45° C More than 3 months: 22° to 28° C 

Charging Temperature Range 

oo to 40° C 

Max Charging Power 

180 w 

Vision Positioning 

Below 8 m/s (2 m above ground) 

Altitude Range 

5-500 em 

Operating Environment 

Brightly lit (lux> 15) patterned surfaces 

Operating Range 

0-250 em 

DJI Pilot App 

Mobile Device System Requirements 

lOS 8.0 or later Android 4.1.2 or later 

Supported Mobile Devices 

• Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, mini 3, and iPad mini 3 WiFi +Cellular. This app is opt 

• Samsung S5, Note 3, Sony Xperia Z3, Google Nexus *Support for additional 

Android devices available as test 

26 
Phantom 3 Professional 

The Phantom 3 Professional's flight controller features several important upgrades, 

including a new flight mode. Safety modes include Failsafe and Return-to-Home. These 

features ensure the safe return of your aircraft if the control signal is lost. The flight 

controller can also save critical flight data from each flight to the on-board storage device. 

The new flight controller also provides increased stability and a new air-braking feature. 

GENERAL FEATURES 

• Epic Aerial Video 

• Live HD View 

• Complete Control 

• Powerful Mobile App • Vision Positioning 

• Easy to Fly 

• Worry-free Autopilot 

• Intelligent Battery 

• Supports Adobe DNG RAW 

• Unmatched Propulsion 

• SDK Development 

VISION POSITIONING 

• Max Velocity: Less than 8 m/s (when 2 m above ground) 

• Altitude Range: 30 cm-300 em 

• Operating Range: 30 cm-300 cm<ltd><ltr> 

• Transmitter Power: CE: 25mw; FCC: 1 OOmw 

• Operating Environment: Surface with clear pattern and adequate lighting (lux > 15) 

CAMERA 

• Sensor: Sony EXMOR 1/2.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

• Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo 

• ISO Range: 100-3200 (video) 100-1600 (photo) 

• Max Bitrate Of Video Storage: 60 Mbps 

• Operating Temperature: ooc to 40°C 

REMOTE CONTROLLER 

• Operating Frequency: 2.400 GHz-2.483 GHz 

• Max Distance: 2000m (outdoors and unobstructed) 

• Receiver Sensitivity (1 %PER): -101 dBm ±2 dBm 

• Transmitter Power (EIRP): FCC: 20 dBm CE: 16 dBm 

• Working Voltage: 1.2 A @7 .4 V 

27 
.. • • 

DJI VISION APP 

• EIRP: 1 OOmW 

• Live View Working Frequency: 2.4GHz ISM 

• Live View Quality: 720P@ 30fps (depending on conditions and mobile device) 

• Required Operating Systems: lOS 8.0 or later, Android 4.1.2 or later 

• Recommended Devices: lOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + 

Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad 

mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for iPhone 5s, iPhone 6, and 

iPhone 6 Plus Android: Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 II, Google 

Nexus 9, Mi 3, Nubia Z7 mini 

28