General Comment:Attn: U. S. Department of Transportation Docket Operations West Building Ground 

Floor, Room w12-140 1200 New Jersey Ave, SE Washington, DC 20590 

RE: AMBER/WARREN INC dba. ALTEK MEDIA GROUP REQUEST AN EXEMPTION 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 OF DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS PURSUANT 

TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Dwight Cromie President Amber/Warren Inc, dba. Altek Media Group 231 E. Alessandro Blvd. Ste A-363 

Riverside CA 92508 951-697-3098 F-951-653-3201
June, 11 2015 Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor, 

Room w12-140 1200 New Jersey Ave, SE Washington, DC 20590 RE: AMBER/WARREN INC dba. ALTEK 

MEDIA GROUP REQUEST AN EXEMPTION 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 OF DJI Phantom 3 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND 

REFORM ACT OF 2012 (PUBLIC LAW 112-95) Dwight Cromie President Amber/Warren Inc, dba. Altek 

Media Group 231 E. Alessandro Blvd. Ste A-363 Riverside CA 92508 951-697-3098 F-951-653-3201 

dsc@altekmedia.com 2 TABLE OF CONTENTS Page GLOSSARY OF 

ABBREVIATIONS...................................................................................3 

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

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

BACKGROUND....................................................................................................................4 BASIS FOR 

PETITION.........................................................................................................5 NAME AND ADDRESS OF 

PETITIONER.........................................................................6 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM 

WHICH THE ALTEK MEDIA GROUP SEEKS 

EXEMPTION............................................................................................................7 THE EXTENT OF RELIEF 

THE ALTEK MEDIA GROUP SEEKS AND THE REASON THE ALTEK MEDIA GROUP SEEKS THE 

RELIEF..............................................................10 THE REASONS WHY GRANTING THE ALTEK MEDIA 

GROUP’S REQUEST WOULD BE IN THE PUBLIC INTEREST 

............................................................................................12 THE REASONS WHY GRANTING THE 

EXEMPTION TO THE ALTEK MEDIA GROUP WOULD NOT ADVERSELY AFFECT 

SAFETY..............................................................14 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL 

REGISTER...................25 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT THE ALTEK MEDIA GROUP’S REQUEST..................................................25 

CONCLUSION.....................................................................................................................25 

APPENDICES......................................................................................... 26 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 Authorization 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 Site VMC Visual Meteorological Conditions VTOL Vertical Takeoff and Landing 4 

SUMMARY Amber/Warren Inc, dba. Altek Media Group hereafter referred to as The ALTEK MEDIA 

GROUP 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 (DJI Phantom 3) pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit The ALTEK MEDIA GROUP to operate an Unmanned Aircraft 

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

sites, residential and commercial real estate, civil landscapes and events over certain areas of the United 

States. INTRODUCTION AND INTERESTS OF THE PETITIONER The ALTEK MEDIA GROUP has for over 

thirty-five years provided their clients (which include private sector businesses and non-profits, along 

with local state and federal agencies) with expertise and knowledge in video and multimedia marketing, 

advertising, public relations and training using advanced technologies and solutions. The ALTEK MEDIA 

GROUP has worked on thousands of productions over the past 35 years in all types of locations with a 

perfect client and employee safety record. In the past we have supplied our clients aerial video and 

photography using commercial aircraft. The objective of The ALTEK MEDIA GROUP and our Unmanned 
Aircraft System (DJI Phantom 3) aerial operations is to provide a more affordable, high-quality 

production system for a variety of governmental, commercial, public, and residential uses, specifically 

targeting • Construction sites before and after • Appraisals • Real-estate marketing • Economic 

development • Civic landmarks • Special event coverage • Private and governmental training My staff 

has safely flown small RC electric quadcopters recreationally for approximately 2 years without incident. 

BACKGROUND Unmanned Aircraft Systems: DJI Phantom 3, UAS The ALTEK MEDIA GROUP seeks an 

exemption to operate DJI Phantom 3 system for compensation or hire within the NAS. The DJI Phantom 

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

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

approximately 2.8 lb. while having a diagonal dimension of 23.2”, a maximum speed of approximately 

16.4’fps and a maximum flying height of 400'. The DJI Phantom 3 is equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. 5 The DJI Phantom 3 that will be operated 

by The ALTEK MEDIA GROUP will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 

45, Identification and Registration Marking. BASIS FOR PETITION Petitioner, The ALTEK MEDIA GROUP, 

pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned 

Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 3, 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, The ALTEK MEDIA GROUP operation of DJI Phantom 3 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, The ALTEK MEDIA GROUP 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. The ALTEK 

MEDIA GROUP submits that the requested relief is proper since an equivalent level of safety will be 

ensured. The ALTEK MEDIA GROUP 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 3 

Instruction Manual). Furthermore, The ALTEK MEDIA GROUP will document and maintain all 

maintenance records for the DJI Phantom 3 UAS. Relief from certain requirements of Section 61.113(a) 

and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by The ALTEK 

MEDIA GROUP 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 flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 

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

maintaining appropriate distances from people, vessels, vehicles and structures. The ALTEK MEDIA 

GROUP seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 3 

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

The ALTEK MEDIA GROUP submits that they will ensure that the DJI Phantom 3 UAS is in an airworthy 

condition, prior to every flight, by determining that the UAS are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft 

are in a condition for safe flight. 6 The ALTEK MEDIA GROUP also seeks an exemption from the 

requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 UAS will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 UAS 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 The ALTEK MEDIA GROUP’s operation of the DJI Phantom 3 UAS within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, The ALTEK MEDIA GROUP seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. The ALTEK MEDIA GROUP submits that safety will 

not be affected by operation of the DJI Phantom 3 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 23 minutes. Battery power indicators are also able to show exactly how much battery 

power is left, as well as how much time is needed to return safely back to point of take off. In 

accordance with 14 C.F.R. § 11.81, The ALTEK MEDIA GROUP 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: Dwight Cromie President Amber/Warren Inc, dba. Altek Media 

Group 231 E. Alessandro Blvd. Ste A-363 Riverside CA 92508 951-697-3098 F-951-653-3201 

dsc@altekmedia.com 7 B. The Specific Sections Of 14 C.F.R. From Which The ALTEK MEDIA GROUP Seeks 

Exemption. 1. The ALTEK MEDIA GROUP 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. The ALTEK MEDIA GROUP 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. The ALTEK MEDIA GROUP Seeks Exemption From The Requirements Of Section 91.121. 

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

operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may 

be, by reference to an altimeter that is set, when operating-- (1) Below 18,000 feet MSL, to-- (i) The 

current reported altimeter setting of a station along the route and within 100 nautical miles of the 

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

current reported altimeter setting of an appropriate available station; or (iii) In the case of an aircraft 

not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting 

available before departure. 8 4. The ALTEK MEDIA GROUP 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. 5. The 

ALTEK MEDIA GROUP 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. The ALTEK MEDIA GROUP 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. The ALTEK MEDIA GROUP 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. 9 8. The ALTEK MEDIA GROUP Seeks Exemption From The Requirements Of Sections 

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

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

owner or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: (1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of 

the person approving the aircraft for return to service. (2) Records containing the following information: 

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

status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since 

last overhaul of all items installed on the aircraft which are required to be overhauled on a specified 

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

required by the inspection program under which the aircraft and its appliances are maintained. (v) The 

current status of applicable airworthiness directives (AD) and safety directives including, for each, the 

method of compliance, the AD or safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is required. (vi) Copies of the forms 

prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 10 (b) The owner or operator shall retain the following 

records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be 

retained until the work is repeated or superseded by other work or for 1 year after the work is 

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

with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or 

operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. C. The Extent Of Relief The ALTEK MEDIA GROUP Seeks And The Reason 

The ALTEK MEDIA GROUP Seeks The Relief. 1. Extent Of Relief The ALTEK MEDIA GROUP Seeks And The 

Reason The ALTEK MEDIA GROUP Seeks Relief From Section 61.113(a) And (b). Relief from Section 

61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the 

extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and 

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

conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the 

limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, 

act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental 

to that business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. As set forth more fully below, The ALTEK MEDIA GROUP submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 

3 UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC 

is able to safely operate either the DJI 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, The ALTEK 

MEDIA GROUP submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC pursuant to the 

grant of this Petition: (1) will be incidental to The ALTEK MEDIA GROUP’s business; and (2) will not carry 

passengers or property for compensation or hire. 11 2. Extent Of Relief The ALTEK MEDIA GROUP Seeks 

And The Reason The ALTEK MEDIA GROUP 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 The ALTEK MEDIA 

GROUP to determine that the DJI Phantom 3 UAS are in airworthy condition prior to every flight by 

ensuring that the UAS is in compliance with the operating documents (i.e., the ALTEK MEDIA GROUP 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). The 

ALTEK MEDIA GROUP seeks the requested relief because the DJI Phantom 3 UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, The ALTEK MEDIA 

GROUP will ensure that the DJI Phantom 3 UAS are in airworthy condition based upon its compliance 

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3) prior to every flight, 

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

limitations below. 3. Extent Of Relief The ALTEK MEDIA GROUP Seeks And The Reason The ALTEK MEDIA 

GROUP Seeks Relief From Section 91.121. Relief from Section 91.121, entitled Altimeter settings, may be 

required to allow flight operations of the DJI Phantom 3 UAS, 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), The ALTEK MEDIA GROUP seeks the requested relief because the DJI Phantom 3 UA’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 3 UAS are 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 The ALTEK MEDIA GROUP Seeks And The Reason The ALTEK MEDIA GROUP Seeks Relief From 

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

is requested to the extent required to allow flights of the battery powered DJI Phantom 3 UAS during 

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

duration of 23 minutes. The ALTEK MEDIA GROUP seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the 12 battery powered DJI Phantom 3 

UAS will severely constrain the practicality of any aerial video or still photo flight operations that The 

ALTEK MEDIA GROUP proposes to conduct pursuant to this Petition. Significantly, as set forth below, the 

technical specifications of the DJI Phantom 3 UAS, the DJI Phantom 3 operating documents, and The 

ALTEK MEDIA GROUP’s proposed operating limitations, ensure that The ALTEK MEDIA GROUP will safely 

operate the battery powered DJI Phantom 3 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 

23 minutes. 5. Extent Of Relief The ALTEK MEDIA GROUP Seeks And The Reason The ALTEK MEDIA 

GROUP 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, The ALTEK MEDIA GROUP requests relief from these Sections because 

the DJI Phantom 3 UAS do not require airworthiness certificates. As set forth more fully below, the DJI 

Phantom 3 UAS meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, The ALTEK MEDIA GROUP will use trained technicians to perform maintenance, 

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

prescribed in the UAS operating documents (i.e., the The ALTEK MEDIA GROUP Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, The ALTEK 

MEDIA GROUP will document and maintain all maintenance records for the DJI Phantom 3 UAS. D. The 

Reasons Why Granting The ALTEK MEDIA GROUP 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 The ALTEK MEDIA GROUP to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, events and civic landscape over certain areas of the 

United States. Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce 

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

GROUP’s proposed operation of the DJI Phantom 3 UAS will be realized without implicating any privacy 

issues. 1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 3 UAS are 

battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the 13 amount of manned aircraft needed to 

perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS would reduce the 

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

life and property in the air and on the ground. Furthermore, by reducing the number of manned aircraft 

operating in the NAS, congestion around airports caused by arriving and departing aircraft will be 

reduced. The DJI Phantom 3 UAS do 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 3 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 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 3 UAS produce no air pollution, and is the most viable environmentally 

conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically 

utilized for aerial video and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an 

internal combustion engine. By using the DJI Phantom 3 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 3 UAS 

(weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 

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 3 UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 UAS 

are also an economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Phantom 3 UAS will allow United States based companies, like The ALTEK 

MEDIA GROUP, 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 3 UAS is one 

such technology that not only allows companies greater operational 14 flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 3 UAS, companies such as The ALTEK MEDIA GROUP, 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 3 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, The ALTEK MEDIA GROUP’s proposed operation of the DJI Phantom 3 

UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in 

compliance with operating documents (i.e., the ALTEK MEDIA GROUP Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. E. The Reasons Why 

Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A 

Level Of Safety At Least Equal To That Provided By The Rule From Which The ALTEK MEDIA GROUP Seeks 

Exemption. 1. Reasons Why The DJI Phantom 3 UAS 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, The ALTEK MEDIA GROUP’s 

operation of the DJI Phantom 3 UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 provides authority 

for a UAS to operate without airworthiness certification and sets forth requirements for considering 

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

national security. 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. 15 (b) 

Assessment of Unmanned Aircraft Systems.--In making the determination under subsection (a), the 

Secretary shall determine, at a minimum-- (1) which types of unmanned aircraft systems, if any, as a 

result of their size, weight, speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national airspace system or 

the public or pose a threat to national security; and (2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under section 44704 of title 49, United States Code, is 

required for the operation of unmanned aircraft systems identified under paragraph (1). (c) 

Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned 

aircraft systems may operate safely in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft systems in the national airspace system. In seeking 

this exemption, The ALTEK MEDIA GROUP submits that the DJI Phantom 3 UAS can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 

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

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

DJI Phantom 3 UAS. The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI 

Phantom 3 User Manual, attached hereto as Appendix A. ii. The DJI Phantom 3 UAS Global Positioning 

Modes Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom 3 UAS may be 

operated in both manual and global positioning flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 3 UAS is provided at pages 11 of the DJI Phantom 3 User Manual 

attached hereto as Appendix A. iii. The DJI Phantom 3 UAS Are Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the 

DJI Phantom 3 UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 3 UAS does not reacquire control link data from the GCS, the UAS will assume that the Control 

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

takeoff position and shutdown. 16 A complete description of the Failsafe Functions of the DJI Phantom 3 
UAS are set forth at pages 12 through 14 of the DJI Phantom 3 User Manual, attached hereto as 

Appendix A. iv. The DJI Phantom 3 GCS And Its Operation. A complete description of the operation and 

specifications of the DJI Phantom 3 GCS and flight control software is provided at pages 23 through 29 of 

the DJI Phantom 3 User Manual. DJI Phantom 3 User Manual is attached hereto as Appendix A. b. Flight 

Operations Of DJI Phantom 3 UAS Is Limited To The Line Of Sight Of A Certificated Pilot in Command 

With A Safety Observer. The ALTEK MEDIA GROUP video production staff will be the only persons to act 

as a pilot in command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist him at 

all times during flight time. c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations. In seeking this exemption, The ALTEK MEDIA GROUP proposes to commercially 

operate DJI Phantom 3 UAS 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 UAS weighing less than 55 pounds maximum gross weight: DJI Phantom 3 

Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a 

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

operations for the purpose of aerial video and photography. 3. The UAS may not be flown at an 

indicated airspeed exceeding 20 knots. 4. The UA must be operated at an altitude of no more than 400 

feet above ground level (AGL), as indicated by the procedures specified in the operating documents 

unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the 

PIC to be able to use human vision unaided by any device other than corrective 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. 17 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 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. 18 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 thirdclass medical 

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

qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with 

how the UAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight 

hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of 

training the operator’s PICs are permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, proficiency, and 

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

and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 

C.F.R. § 91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at night is 

required, a special request will be made at the FAA office closest to proposed area of operations. Flights 

under special visual flight rules (SVFR) are not authorized. 20. The UA may not operate within 5 nautical 

miles of an airport reference point as denoted on a current FAA-published aeronautical chart unless a 

letter of agreement with that airport’s management is obtained, and the operation is conducted in 

accordance with a 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 UA may not be 

operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is 

less than 3 statute miles from the PIC. 22. If the UA loses communications or loses its GPS signal, it must 

return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 19 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 28. The documents required fewer than 

14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time 
the UAS is operating. These documents must be made available to the Administrator or any law 

enforcement official upon request. 29. The UA must remain clear and yield the right of way to all 

manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from 

any moving device or vehicle. 31. Flight operations must be conducted at least 500 feet from all 

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

vessels, vehicles, and structures unless: 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; 20 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. The ALTEK MEDIA GROUP submits that the equivalent level of safety 

established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate 

the DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with 

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

from people, vessels, vehicles and structures. Considering The ALTEK MEDIA GROUP’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 3 UAS, The ALTEK MEDIA 

GROUP submits that the additional manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for The ALTEK MEDIA GROUP’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). The ALTEK MEDIA GROUP will not allow any PIC to operate the DJI 

Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 

DJI Phantom 3 UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 3 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 21 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 The ALTEK MEDIA GROUP’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, The ALTEK MEDIA GROUP will ensure safe 

operations by not allowing any PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the 

DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 3. 

Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect 

Safety. 22 The equivalent level of safety established by Section 91.7(a) will be maintained because prior 

to every flight, The ALTEK MEDIA GROUP will ensure that the DJI Phantom 3 UAS 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). 4. Reasons Why An Exemption From The 

Requirements Of Section 91.121 Would Not Adversely Affect Safety. The equivalent level of safety 

established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 3 

UAS 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 The ALTEK MEDIA GROUP’s operation of the DJI Phantom 3 UAS 

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

91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. 

Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground 

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

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 

11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161). 5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. A grant of this exemption would ensure an equivalent level of safety established 

by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) 

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

Accordingly, The ALTEK MEDIA GROUP will ensure that it will safely operate the battery powered DJI 

Phantom 3 UAS during daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 23 minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 
3 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, 

will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety 

will be ensured as the DJI Phantom 3 UAS 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 23 power. At the critically 

low battery level, the DJI Phantom 3 UAS will descend and land automatically. Significantly, previous 

exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected 

when the technical characteristics and operating limitations of the UAS are considered. Relief has been 

granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, 

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

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

herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 6. 

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, The ALTEK 

MEDIA GROUP 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 The ALTEK MEDIA GROUP will use trained technicians to perform 

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

practices prescribed in the operating documents (i.e., the ALTEK MEDIA GROUP Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, The ALTEK 

MEDIA GROUP will document and maintain all maintenance records for the DJI Phantom 3 UAS. Since 

the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, The ALTEK MEDIA 

GROUP 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 DJI Phantom 3 User Manuals are attached hereto as Appendix A and B; a 

copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as Appendix C. Likewise, the 

exemption sought will not adversely affect safety because The ALTEK MEDIA GROUP will use trained 

technicians to perform maintenance, alterations or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed by the operating documents. Furthermore, the 

exemption sought would maintain an equivalent level of safety established by Sections 91.407, 

91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS will be performed by 

trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log. Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected 

when the technical characteristics and operating limitations of the UAS are considered. 24 In 

consideration of The ALTEK MEDIA GROUP’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Phantom 3 UAS, The ALTEK MEDIA GROUP 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). 7. 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, The ALTEK MEDIA GROUP requests that the FAA 

prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, 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 DJI Phantom 3 UAS, 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: 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 DJI Phantom 3 UAS, 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 25 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 The ALTEK 

MEDIA GROUP Seeks Exemption: The ALTEK MEDIA GROUP 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 The ALTEK MEDIA 

GROUP Seeks: This exemption will permit The ALTEK MEDIA GROUP 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 The ALTEK MEDIA GROUP’s Request. This Petition is made pursuant to the FAA Modernization 

and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine 

if certain UAS may operate safely in the NAS. As such, The ALTEK MEDIA GROUP’s 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. As discussed in detail above, The 

ALTEK MEDIA GROUP will operate the DJI Phantom 3 UAS 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, The ALTEK MEDIA GROUP 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 3 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 The ALTEK MEDIA 

GROUP to safely, efficiently, and economically operate the DJI Phantom 3 UAS commercially within the 

NAS. 26 WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, The ALTEK MEDIA GROUP 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 Leading Edge to operate the DJI Phantom 3 UAS commercially for the purpose of conducting 
aerial video and photography over certain areas of the United States. Dated: June 10, 2015 Respectfully 

submitted, Dwight Cromie President Amber/Warren Inc, dba. Altek Media Group 231 E. Alessandro Blvd. 

Ste A-363 Riverside CA 92508 951-697-3098 F-951-653-3201 dsc@altekmedia.com Appendices: A – Link 

to DJI Phantom 3 Manual: Click on link below 

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manua

l_v1.2_en.pdf