UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PAPER PLANE PRODUCTIONS, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS SECTIONS 45.23 (b), 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 OF THE DJI PHANTOM 2 UNMANNED AIRCRAFT SYSTEM, AND 

THE DJI INSPIRE 1 PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on January 15, 2016

PAPER PLANE PRODUCTIONS

9480 SOUTH UNION SQUARE

SUITE 204

SANDY, UT. 84070

(801) 946-0522
2

TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS .............................................................. 3

SUMMARY ............................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER ...................................... 4

BACKGROUND ...................................................................................... 5

BASIS FOR PETITION .............................................................................. 5

NAME AND ADDRESS OF PETITIONER .................................. 6

THE SPECIFIC SECTIONS OF 14 C.F.R FROM

WHICH PAPER PLANE PRODUCTIONS 

SEEKS RELIEF ....................................................................7

THE EXTENT OF RELIEF PAPER PLANE

PRODUCTIONS SEEKS AND THE REASON

PAPER PLANE PRODUCTIONS SEEKS

THE RELIEF ....................................................................... 9

THE REASONS WHY GRANTING PAPER

PLANE PRODUCTIONS’ REQUEST WOULD

BE IN THE PUBLIC INTEREST .................................................. 12

THE REASON WHY GRANTING THE

EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY ................................................................. 14

CONCLUSION ........................................................................................21
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorizations

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VOTL Vertical Takeoff and Landing

DJI UAV manufacturer

ESC Electronic Speed Control

FPV First Person View

LI-PO Lithium Polymer Battery

RCV Radio Controlled Vehicle
4

SUMMARY

Paper Plane Productions, LLC seeks exemption from the requirements of 14 C.F.R. §§61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(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). The exemption will permit Paper Plane Productions, LLC to operate an Unmanned 

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

Marketing, film sets, real estate photography, commercials, special events, wedding cinematography, 

marine photography, roofing inspection, and landscape imaging over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Dan Hill will handle all operation of the UAS for Paper Plane Productions. He is an Aerial RCV 

enthusiast with over 20 years of experience operating various types of Aerial RCV’s as well as 1 year 

operating quad copter UAS’s. Paper Plane Productions also provides customers with high quality 

photography and videography for a wide range of applications. Dan Hill is considered an advanced level 

RCV pilot who has even taught beginners how to pilot RCV’s. 

The objective of Paper Plane Productions, LLC is to provide superior aerial imaging for a wide range of 

industries and events while promoting safe UAS operations and promoting public knowledge of UAS’s as 

well as providing a high level of knowledge about UAS’s.
5

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 UAS

Paper Plane Productions, LLC seeks an exemption to operate the DJI systems for compensation or hire within the 

NAS. The DJI Phantom 2 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground 

Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 has a maximum 

gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, height 

of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 2 UAS is equipped with four 

main rotors; driven by a Lithium Polymer battery powered electric motor.

The DJI Phantom 2 UAS that will be operated by Dan Hill of Paper Plane Productions, LLC 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 

Markings.

BASIS FOR PETITION

Petitioner, Paper Plane Productions, LLC, 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 2 UAS 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), 91.405(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, Paper Plane Productions, LLC’s operation of DJI Phantom 2 UAS 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, Paper Plane Productions, LLC 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. 

Paper Plane Productions, LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Paper Plane Productions, LLC 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 Phantom 2

Manual). Furthermore, Paper Plane Productions, LLC will document and maintain all maintenance 

records for the DJI Phantom 2. 

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

limitations: Pilot in command, is requested by Paper Plane Productions, LLC to the extent necessary to 

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman 

medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 2 UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 
6

Paper Plane Productions, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 2 UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, Paper Plane Productions, LLC submits that they will ensure that the 

DJI Phantom 2 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 Phantom 2 Instruction 

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

Paper Plane Productions, LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Phantom 2 UAS will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Phantom 2 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 Dan Hill of Paper Plane Productions, LLC’s operation of the DJI Phantom UAS within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Paper Plane Productions, LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Paper Plane Productions, LLC submits 

that safety will not be affected by operation of the DJI Phantom 2 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 15.5 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, Paper Plane Productions, LLC provides the following information 

in support of its petition for exemption: 

A. Name And Address Of The Petitioner.

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

DAN HILL

PAPER PLANE PRODUCTIONS, LLC

9480 SOUTH UNION SQUARE

SUITE 204

SANDY, UT 84070

(801) 673-3987

Email: DAN@PAPERPLANEPROD.COM
7

A. The Specific Sections Of 14 C.F.R. From Which Paper Plane Productions, LLC Seeks 

Exemption. 

1. Paper Plane Productions, LLC 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: 

(a) 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. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Paper Plane Productions, LLC 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. 

3. Paper Plane Productions, LLC 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--

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. 

4. Paper Plane Productions, LLC 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. 
8

5. Paper Plane Productions, LLC 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[.] 

6. Paper Plane Productions, LLC 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[.] 

7. Paper Plane Productions, LLC 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. 

8. Paper Plane Productions, LLC 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
9

(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. 

3. The owner or operator shall retain the following records for the periods 

prescribed: 

(i) 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.

(ii) 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.

(iii) 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. 

B. The Extent Of Relief Paper Plane Productions, LLC Seeks And The Reason Paper Plane 

Productions, LLC Seeks The Relief.

1. Extent Of Relief Paper Plane Productions, LLC Seeks And The Reason Paper Plane 

Productions, LLC Seeks Relief From Section 61.113(a) And (b). 
10

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a private pilot or higher level certificate, as well as a current and valid 

airman medical certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or 

hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: 

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation 

or hire. 

As set forth more fully below, Paper Plane Productions, LLC submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to 

operate the DJI Phantom 2 UAS unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate the 

DJI Phantom 2 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. 

Furthermore, Paper Plane Productions, LLC submits that all flights of the DJI 

Phantom 2 UAS, conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to Paper Plane Productions, LLC's business; and 

(2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Paper Plane Productions, LLC Seeks And The Reason Paper Plane Productions, 

LLC 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 Paper Plane Productions, LLC to determine that the DJI Phantom 2 UAS is in 

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

operating documents (i.e., Paper Plane Productions, LLC’s Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 2 Instruction Manual, Pre-Flight Checklist). 

Paper Plane Productions, LLC seeks the requested relief because the DJI Phantom 2 UAS does 

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

Therefore, Paper Plane Productions, LLC will ensure that the DJI Phantom 2 UAS is in airworthy 

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

Log, and DJI Phantom 2 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. 
11

3. Extent Of Relief Paper Plane Productions, LLC Seeks And The Reason Paper Plane Productions, 

LLC 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 UAS, which utilizes 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), Paper Plane Productions, LLC seeks the requested relief because the DJI Phantom 2

UAS’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 

2 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 UA on the heads-up display of the GCS. 

4. Extent Of Relief Paper Plane Productions, LLC Seeks And The Reason Paper Plane Productions, 

LLC 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 2 UAS 

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

(VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. Paper Plane Productions, LLC

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

duration of the battery powered DJI Phantom 2 UAS will severely constrain the practicality of 

any aerial video or still photo flight operations that Paper Plane Productions, LLC proposes to 

conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 UAS, the DJI 

Phantom 2 UAS’s operating documents, and proposed operating limitations, ensure that Paper 

Plane Productions, LLC will safely operate the battery powered DJI Phantom 2 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 15.5 minutes to the first point of intended 

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

5. Extent Of Relief Paper Plane Productions, LLC Seeks And The Reason Paper Plane Productions, 

LLC 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, Paper Plane Productions, LLC requests relief from these 

Sections because the DJI Phantom 2 UAS does not require airworthiness certificates. As set forth 

more fully below, the DJI Phantom 2 UAS meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, Paper Plane Productions, LLC will 
12

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., Paper Plane Productions, LLC Aerial Operations Manual, Monthly Maintenance Log, DJI 

Phantom 2 Instruction Manual, Pre-Flight Checklist). Furthermore, Paper Plane Productions, 

LLC will document and maintain all maintenance records for the DJI Phantom 2 UAS. 

C. The Reasons Why Granting Paper Plane Productions, LLC’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 Paper Plane Productions, 

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

construction sites, real estate, and landscape, boats, and events over certain areas of the United 

States. 

Additionally, use of the DJI Phantom 2 UAS will decrease congestion of the NAS, reduce 

pollution, crashes and accidents caused by pilot error and provide significant benefits to the 

economy. Notably, the benefits of Paper Plane Productions, LLC’s proposed operation of the DJI 

Phantom 2 UAS will be realized without implicating any privacy issues. 

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

The DJI Phantom 2 UAS is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom 2 UAS would reduce the 

amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase 

the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom 2 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 Phantom 2 

UAS. 

Conducting aerial acquisitions with the DJI Phantom 2 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 Phantom 2 UAS produces 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 2 UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS is propelled by battery powered electric motors, 

rather than an internal combustion engine. 
13

By using the DJI Phantom 2 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 

Phantom 2 (weighing approximately 2 pounds 14 ounces at its maximum gross weight, 

with a length of 16 inches, and a width 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 Phantom 2 

UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 UAS is also an economical 

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

operation of the DJI Phantom 2 UAS will allow United States based companies, like 

Paper Plane Productions, LLC, 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 Phantom 2 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 2 UAS, companies such as Paper Plane Productions, LLC, 

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 Phantom 2 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, Paper Plane Productions, LLC’s proposed operation of the DJI Phantom 2 UAS 

will not implicate any privacy issues. Specifically, the DJI Phantom 2 UAS will be 

operated only in compliance with operating documents (i.e., Paper Plane Productions, 

LLC Aerial Operations Manual, Monthly Maintenance Log, DJI Phantom 2 and 

Instruction Manual, Pre-Flight Checklist) 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. 
14

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The 

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which Paper Plane Productions, LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 2 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, Paper Plane Productions, LLC’s operation of the DJI 

Phantom 2 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 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, Paper Plane Productions, LLC submits that the DJI 

Phantom 2 UAS can operate safely in the NAS pursuant to FMRA Section 333, 

as demonstrated by: (a) the characteristics of the DJI Phantom 2 UAS; (b) the 

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

a. The Specifications Of The DJI Phantom 2 UAS Demonstrates Its Safe 

Characteristics. 

The DJI Phantom 2 UAS does not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability. 
15

i. Technical Specifications Of The DJI Phantom 2 UAS. 

The technical specifications of the DJI Phantom 2 UAS is set forth by the 

DJI Phantom 2 Specifications and Data Sheet, attached hereto as Exhibit 

A. 

ii. The DJI Phantom 2 UAS’ Autonomous Flight And Navigation 

Modes Enable The UAS To Remain Within A Defined Operational 

Area. 

The DJI Phantom 2 UAS may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 2 UAS is provided at pages 25-

35 of the DJI Phantom 2 User Manual, attached hereto as Exhibit B. 

iii. The DJI Phantom 2 UAS is Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link 

Or Navigation. 

When the Control Link is lost, the DJI Phantom 2 UAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 2 UAS does not reacquire control link data from the GCS, the 

UAS will assume that the Control Link is lost and the UAS will return to 

the home position (i.e., failsafe mode) via GPS, and will descend to the 

takeoff position and shutdown. A complete description of the Failsafe 

Functions of the DJI Phantom 2 UAS are set forth at pages 27 through 29 

of the DJI Phantom User Manual, attached hereto as Exhibit B. iv. The 

DJI Phantom 2 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI 

Phantom 2 GCS and flight control software is provided at pages 32 

through 43 of the DJI Phantom 2 User Manual. DJI Phantom 2 User 

Manual is attached hereto as Exhibit B. 

b. Flight Operations Of DJI Phantom 2 UAS is Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer. 

Paper Plane Productions, LLC will only utilize certificated pilots who possess a 

current and valid airman medical certificate to act as a pilot in command (PIC) of 

the DJI Phantom 2 UAS. Additionally, a safety observer will assist all pilots 

during flight time.

c. Flights Of DJI Phantom 2 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, Paper Plane Productions, LLC proposes to 

commercially operate the DJI Phantom 2 UAS for the special purpose of 

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

pursuant to the following specific operating limitations: 
16

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

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Phantom 2 Unmanned 

Aircraft System. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UAS must be operated at an altitude of no more than 500 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 (AFS-80) may be contacted if 
17

questions arise regarding updates or revisions to the operating documents. 

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 UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current 

third-class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

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

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted 

under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience- building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 
18

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

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the FAA 

office closest to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The UAS 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 NOTAM as required by the operator’s COA. The 

letter of agreement with the airport management must be made available to the 

Administrator upon request. 

21. The UAS may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC. 

22. If the UAS 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. 

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

emergencies in accordance with the operating documents. 

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

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

25. The operator 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 (NOTAM) 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. 

26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N-Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the UAS 

is operating. These documents must be made available to the Administrator or 

any law enforcement official upon request. 
19

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

vehicle. 

31. Flight operations must be conducted at least 500 feet from all 

nonparticipating persons (persons other than the PIC, SO, operator trainees or 

essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating 

persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or; 

b. 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; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

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

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. 

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

Adversely Affect Safety. 

Paper Plane Productions, LLC submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 

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

requirements, that the PIC is able to safely operate the DJI Phantom 2 UAS in a manner 

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

appropriate distances from people, vessels, vehicles and structures. 

Considering Paper Plane Productions, LLC’s 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 Phantom 2 UAS, Paper Plane Productions, 
20

LLC submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for Paper Plane Productions, LLC’s 

specific proposed flight operations. 

The FAA has previously granted relief from 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). Paper Plane Productions, LLC will not allow any 

PIC to operate the DJI Phantom 2 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements and the DJI Phantom 2 UAS training and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 2 UAS in a manner consistent with this exemption, 

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

vessels, vehicles and structures. 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 Paper Plane Productions, LLC’s 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 a 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 UA with appropriate distances in 

accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. 

Accordingly, Paper Plane Productions, LLC will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 2 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2

UAS in a manner consistent with the exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from people, vessels, vehicles and structures. 
21

CONCLUSION

Paper Plane Productions, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI 

Phantom 2 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 Paper Plane Productions, LLC to 

safely, efficiently, and economically operate the DJI Phantom 2 UAS commercially within the NAS. 

Therefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform

Act of 2012, Section 333, Paper Plane Productions, LLC respectfully requests that the Administrator 

grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

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

Plane Productions, LLC to operate the DJI Phantom 2 UAS commercially for the purpose of conducting 

aerial video and photography over certain areas of the United States.

Dated: January 15, 2016

Submitted by 

Paper Plane Productions, LLC
22

APPENDIX – A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

Paper Plane Productions, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters 

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher 

than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In 

addition, DJI software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices) 

1.1 DJI Phantom 2

1.2 1.1.1Aircraft 

1.1.1.1 Supported Battery – DJI 6000AH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 

1.1.1.4 Max Yaw Angular Velocity - 200/s

1.1.1.5 Max Tilt Angel - 35 

1.1.1.6 Max Ascent Speed – 6m/s 

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 

1.1.2.2 Control Accuracy - ±0.03 

1.1.2.3 Controllable Range – Pitch: -90 - 0 

1.1.2.4 Maximum Angular Speed – Pitch: 90/s 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 32F - 104F (0C - 40C) 

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M 

1.1.3.4 Resolution – 4384x3288 

4.1.3.5 HD Video Recording – 1080p30 & 720p 

4.1.3.6 Recording Field of View - 110/85 

APPENDIX-BDJI 

PHANTOM 2 USER MANUAL

http://www.dji.com/product/phantom-2/download