pg. 1

FROM: 

Versa Solutions, LLC 

517 Wayland Drive 

Hockessin, DE 19707 

Tel: 440-225-6158 

Email: Christopher.Kuhman@flyversa.com 

TO: 

US DEPARTMENT OF TRANSPORTATION 

DOCKET OPERATIONS 

ROOM W12-140 OF THE WEST 

BUILDING GROUND FLOOR 

1200 NEW JERSEY AVENUE, 

SE. WASHINGTON, DC, 20590 

Regulatory Docket No. _______________ 

PETITION FOR EXEMPTION OF: 

Versa Solutions, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 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 PROFESSIONAL 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 
pg. 2

TABLE OF CONTENTS 

GLOSSARY OF ABREVIATIONS........................................................................ 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 VERSA SOLUTIONS, LLC SEEKS 

EXEMPTION................................................................................................. 7 

THE EXTENT OF RELIEF VERSA SOLUTIONS, LLC SEEKS AND THE REASON VERSA 

SOLUTIONS, LLC SEEKS THE RELIEF.............................................................. 10 

THE REASONS WHY GRANTING VERSA SOLUTIONS, LLC RELIEF WOULD BE IN 

THE PUBLIC INTEREST................................................................................. 12 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT PUBLIC SAFETY, OR HOW THE EXEMPTION WOULD PROVIDE A LEVEL OF 

SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH 

VERSA SOLUTIONS, LLC SEEKS EXEMPTION.................................................... 14 

THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR SAFE OPERATION...... 23 

A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER, STATING: 

THE RULES FROM WHICH VERSA SOLUTIONS, LLC SEEKS EXEMPTION.............. 24

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT VERSA SOLUTIONS, LLC REQUEST................................................... 25 

REQUEST FOR BLANKET APPROVAL.............................................................. 25 

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

APPENDIX A – DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS........... 27 

APPENDIX B – DJI PHANTOM 3 PROFESSIONAL USERS MANUAL............................. 29 

APPENDIX C – MONTHLY MAINTENANCE LOG..................................................... 30 
pg. 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) Section 333 

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 
pg. 4

SUMMARY 

Versa Solutions, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Versa Solutions, 

LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and photography for aerial surveying, building and monetizing YouTube channels, 

competitive intelligence, conservation, environmental regulation and compliance, delivery, 

disaster relief, feature filmmaking, news footage, pipeline and electrical line inspection, 

precision agriculture, real estate videos, resort and hotel advertising, search and rescue, security, 

sports and events, structural inspection and construction site data, surveillance, and wedding 

videos over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF PETITIONER 

Versa Solutions, LLC is a Delaware based company specializing in aerial videography 

and photography. The founders of Versa Solutions, LLC all hold engineering degrees from 

accredited universities and have professional experience with all health, safety and 

environmental standards. Versa Solutions, LLC has recreational/hobby experience in all aspects 

of aerial videography and photography. The objective of Versa Solutions, LLC video operations 

is to provide high-quality imaging for a variety of commercial and nonprofit productions, 

specifically targeting: home builders, home contractors, and/or home inspectors for real estate 

marketing and inspections of home exteriors as well as filming of special events, film sets, 

scripted and unscripted television sets, landscape, conducting pipeline and electrical line 

inspections, and aerial mapping and surveying utilizing a DJI Phantom 3 Professional UAS. 

More specifically, Versa Solutions, LLC aerial video and photography operations will serve in 

the following areas: 

• Aerial photography of landscapes / residential and commercial 

• Aerial videography of estates / residential and commercial buildings and power lines 

• Aerial photography and videography of pipelines and electrical lines 

• Aerial event photography 

• Aerial event filming 

• Increase public knowledge of UAS and promote safe UAS operations 

The proposed aerial filming will be conducted over private property with controlled access in the 

NAS and with the knowledge and permission of the private property’s owner. 
pg. 5

BACKGROUND 

Unmanned Aircraft System: DJI Phantom 3 Professional UAS 

Versa Solutions, LLC seeks an exemption to operate DJI systems DRONES for 

compensation or hire within the NAS. The DJI Phantom 3 Professional UAS are vertical takeoff 

and landing (VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing 

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

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

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

Professional UAS are equipped with four main rotors driven by Lithium Polymer battery 

powered electric motors. 

The DJI Phantom 3 Professional UAS that will be operated by Versa Solutions, LLC 

(trained professional, Douglas Artze) 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, Versa Solutions, 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 3 Professional UAS in the National 

Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) 

& (b), 91.109, 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, Versa Solutions, LLC operation of DJI Phantom 3 

Professional 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, Versa Solutions, 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. Versa Solutions, LLC 

submits that the requested relief is proper since an equivalent level of safety will be ensured. 

Versa Solutions, 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 3 

Professional Instruction Manual). Furthermore, Versa Solutions, LLC will document and 

maintain all maintenance records for the DJI Phantom 3 Professional UAS. 

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

privileges and limitations: Pilot In Command, is requested by Versa Solutions, LLC to the extent 

necessary to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate, and who 

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

able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this 
pg. 6

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Versa Solutions, LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Professional UAS does not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Versa Solutions, LLC 

submits that it will ensure that the DJI Phantom 3 Professional 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 3 Professional Instruction Manual), and that 

the aircraft is in a condition for safe flight. 

Versa Solutions, LLC also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 Pro 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 Versa Solutions, LLC’s operation of the DJI 

Phantom 3 Professional UAS within visual line of sight, at or below 200 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. 

Additionally, Versa Solutions, LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Versa Solutions, LLC 

submits that safety will not be affected by operation of the DJI Phantom 3 Professional UA 

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

(VFR), with enough battery power to fly for a total duration of approximately 13.5 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, Versa Solutions, LLC provides the following information 

in support of its petition for exemption: 

NAME AND ADDRESS OF PETITIONER 

Versa Solutions, LLC 

517 Wayland Drive 

Hockessin, DE 19707 

Tel: 440-225-6158 

Email: Christopher.Kuhman@flyversa.com
pg. 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH VERSA SOLUTIONS, LLC 

SEEKS EXEMPTION 

Versa Solutions, 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. 

Versa Solutions, 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. 

Versa Solutions, 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-- 

(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. 

Versa Solutions, 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: 
pg. 8

(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. 

Versa Solutions, 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[.] 

Versa Solutions, 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[.] 

Versa Solutions, 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. 

Versa Solutions, 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: 
pg. 9

(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 of the next action is required. 

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

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

propellers, and appliances. 

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

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

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

work is performed. 

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

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

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 
pg. 10

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

approved for return to service. 

THE EXTENT OF RELIEF VERSA SOLUTIONS, LLC SEEKS AND THE REASON 

VERSA SOLUTIONS, LLC SEEKS THE RELIEF 

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, LLC 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 Supplemental 

Pilot 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, Versa Solutions, LLC submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the Phantom 3 Professional 

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

the PIC is able to safely operate the DJI Phantom 3 Professional 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, Versa Solutions, LLC submits that all flights of the DJI Phantom 3 Professional 

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

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

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, 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 Versa Solutions, LLC to determine that the DJI Phantom 3 Professional UAS is 

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

operating documents (i.e., the Versa Solutions, LLC Aerial Operations Manual, Monthly 

Maintenance Log, and Phantom 3 Professional Instruction Manual). 

Versa Solutions, LLC seeks the requested relief because the DJI Phantom 3 Professional 

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

H. Therefore, Versa Solutions, LLC will ensure that the DJI Phantom 3 Professional UAS is in 

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

Maintenance Log, and DJI Phantom 3 Professional Instruction Manual) prior to every flight, and 
pg. 11

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

limitations below. 

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, 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 3 Professional 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). 

Versa Solutions, LLC seeks the requested relief because the DJI Phantom 3 Professional 

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 Professional 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. 

Extent Of Relief Versa Solutions, LLC Seeks And The Reason Versa Solutions, 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 3 

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

flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. Versa Solutions, LLC 

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

duration of the battery powered DJI Phantom 3 Professional UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that Versa Solutions, LLC proposes 

to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 

Professional UAS operating documents, and Versa Solutions, LLC proposed operating 

limitations, ensure that Versa Solutions, LLC will safely operate the battery powered DJI 

Phantom 3 Professional 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 13.5 

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

that for at least 4.5 minutes. 
pg. 12

Extent Of Relief Versa Solutions, LLC Seeks Relief And The Reason Versa Solutions, LLC 

Seeks Relief From Section 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, Versa Solutions, LLC requests relief from 

these Sections because the DJI Phantom 3 Professional UAS does not require airworthiness 

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

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

Versa Solutions, LLC 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 Versa Solutions, LLC Aerial Operations Manual, 

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

Versa Solutions, LLC will document and maintain all maintenance records for the DJI Phantom 

3 Professional UAS. 

THE REASONS WHY GRANTING VERSA SOLUTIONS, LLC RELIEF WOULD 

BE IN THE PUBLIC INTEREST 

The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Phantom 3 Professional 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 3 Professional 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 

Phantom 3 Professional UAS does not require an airport to take off or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would result in 

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

arrival, and landing phases of flight operations. 

The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 

Professional UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 Professional 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 Professional 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 

Phantom 3 Professional UAS, while reducing the carbon footprint of aerial acquisitions, also 
pg. 13

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 Professional 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 Professional UAS (weighing approximately 2 pounds 11 ounces respectively, at its 

maximum gross weights with length of 17.3 inches respectively, width of 17.3 inches 

respectively, and with no fuel on board), has less physical potential for collateral damage to life 

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

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

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

Performing Aerial Video and Photography Operations With The DJI Phantom 3 

Professional UAS Will Benefit The Economy. 

In addition to being safe and efficient, the Phantom 3 Professional is also an economical 

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

the DJI Phantom 3 Professional UAS will allow United States based companies, like Versa 

Solutions, 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 3 Professional 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 3 Professional UAS, companies such as Versa Solutions, 

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 

3 Professional 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. 

There Are No Privacy Issues. 

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

decades, Versa Solutions, LLC proposed operation of the DJI Phantom 3 Professional UAS will 

not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be 

operated only in compliance with operating documents (i.e., the Versa Solutions, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional 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. 
pg. 14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT PUBLIC SAFETY, OR HOW THE EXEMPTION WOULD PROVIDE A 

LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM 

WHICH VERSA SOLUTIONS, LLC SEEKS EXEMPTION. 

Reasons Why The DJI Phantom 3 Professional 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, Versa Solutions, LLC operation of the DJI Phantom 3 

Professional 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 rule-making required by section 332 

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

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

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

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

weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the 

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

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

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

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

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

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

airspace system, the Secretary shall establish requirements for the safe operation 

of such aircraft systems in the national airspace system. 

In seeking this exemption, Versa Solutions, LLC submits that the DJI Phantom 3 

Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS; (b) the pilot 

certification requirement; and (c) the specific operating limitations. 
pg. 15

The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate Its Safe 

Characteristics 

The DJI Phantom 3 Professional 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. 

Technical Specifications Of The DJI Phantom 3 Professional UAS 

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

DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as Appendix A. 

The DJI Phantom 3 Professional UAS Autonomous Flight And Navigation Modes Enable 

The UAS To Remain Within A Defined Operational Area. 

The DJI Phantom 3 Professional 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 3 Professional UAS is provided at page 26 of the DJI Phantom 3 Professional User 

Manual, attached hereto as Appendix B. 

The DJI Phantom 3 Professional 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 3 Professional UAS will remain 

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

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

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

descend to the takeoff position and shut down. 

A complete description of the Failsafe Functions of the DJI Phantom 3 Professional UAS 

are set forth at pages 12 through 14 of the DJI Phantom 3 Professional UAS User Manual, 

attached hereto as Exhibit B. 

The Phantom 3 Professional GCS And Its Operation 

A complete description of the operation and specifications of the DJI Phantom 3 

Professional GCS and flight control software is provided at pages 23 through 29 of the Phantom 

3 Professional User Manual. DJI Phantom 3 Professional User Manual is attached hereto as 

Exhibit B. 

Flight Operations Of DJI Phantom 3 Professional UAS Are Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer. 
pg. 16

Versa Solutions, 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 3 Professional 

UAS. Additionally, a safety observer will assist all pilots during flight time. 

Flights Of DJI Phantom 3 Professional UAS Will Be Conducted Pursuant To Specific 

Operating Limitations 

In seeking this exemption, Versa Solutions, LLC proposes to commercially operate the 

DJI Phantom 3 Professional UAS for the special purpose of conducting aerial video and 

photography over certain areas of the United States, pursuant to the following operating 

limitations: 

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

aircraft described in the operating documents, rotorcraft UAS's weighing less than 55 

pounds maximum gross weight: DJI Phantom 3 Professional 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 for homeowners, Realtors, home builders, 

contractors, home inspectors for use in real estate marketing and real estate inspections. 

Additionally, aerial video and photography may be conducted on occasional basis for 

film and television sets, special events and landscape photography, conducting power line 

inspection, aerial mapping, and surveying as deemed necessary. 

3. The UAS may not be flown at an indicated airspeed exceeding 30 knots (16 m/s). 

4. The UAS must be operated at an altitude of no more than 400 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents, unless a 

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

feet AGL. 

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

times. This requires the PIC to be able to use human vision unaided by any device other 

than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

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

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

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and 

PIC must be able to communicate verbally at all times. 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. 
pg. 17

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 the 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. 

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. 
pg. 18

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 Supplemental Pilot certificate and at least a current 

third-class medical certificate. Supplemental pilots must have, at a minimum, 

successfully completed private pilot ground school. Additionally, supplemental pilots 

without a current FAA private pilot certificate must have successfully passed the private 

pilot, commercial pilot, or airline transport pilot knowledge test within the past 24 

calendar months. 

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. 

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. 
pg. 19

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 Airmen 

(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 UAS must remain clear and yield the right of way to all manned aviation 

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

moving device or vehicle. 

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

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

vehicles, and structures unless: 

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). 

31. All operations shall be conducted over private or controlled-access property 
pg. 20

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. 

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

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

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

be reported to the National Transportation Safety Board (NTSB) per instructions 

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

Reasons Why An Exemption From The Requirements Of Section 61.113(a)And (b) Would 

Not Adversely Affect Safety. 

Versa Solutions, 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 

3 Professional 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 Professional 

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

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

Considering Versa Solutions, 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 3 Professional UAS, Versa Solutions, LLC submits 

that the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Versa Solutions, LLC 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, 1109, 11110, 11112, 11136, 11138, 11150, 

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

Versa Solutions, LLC will not allow any PIC to operate the DJI Phantom 3 Professional 

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

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

operate the DJI Phantom 3 Professional 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 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 Versa Solutions, LLC's proposed operations. The Administrator has held that prior 
pg. 21

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. 

 

Accordingly, Versa Solutions, LLC will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 3 Professional 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 Pro UAS in a manner consistent with the exemption, including evasive and 

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

structures. 

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

Adversely Affect Safety 

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

prior to every flight, Versa Solutions, LLC will ensure that the DJI Phantom 3 Professional 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, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 
pg. 22

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 Phantom 3 Professional UA 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 Versa Solutions, LLC’s operation of the DJI Phantom 3 Professional UAS within 

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

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

aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the 

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). 

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 

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

the proposed flight operations. Accordingly, Versa Solutions, LLC will ensure that it will safely 

operate the battery powered DJI Phantom 3 Professional UAS during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point 

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

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 

Professional 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 Professional UAS provides 

audible and visual warnings to the PIC at the GCS when the UA experiences low battery voltage, 

the first warning occurring at approximately 30% remaining battery power, and again at 

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

3 Professional 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). 
pg. 23

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, Versa Solutions, LLC 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 

Versa Solutions, LLC 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 Versa Solutions, LLC Aerial Operations Manual, Monthly 

Maintenance Log, and Phantom 3 Professional Instruction Manual). Furthermore, Versa 

Solutions, LLC will document and maintain all maintenance records for the DJI Phantom 3 

Professional UAS. 

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the 

operating documents, Versa Solutions, LLC 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 DJI Phantom 3 

Professional User Manual is attached hereto as Appendix B; a copy of the DJI Phantom 3 

Professional UAS Maintenance LOG is attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because Versa Solutions, 

LLC 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 

Professional UAS will be performed by trained technicians. Maintenance will be documented 

and maintained utilizing the monthly maintenance log. 

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

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

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

In consideration of Versa Solutions, LLC proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 Professional UAS, Versa Solutions, 

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

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

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

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR SAFE OPERATION. 

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Versa Solutions, LLC requests that 

the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

Professional 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 
pg. 24

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 for the limited 

purpose of conducting aerial and video photography over certain areas of the United Sates for 

compensation or hire. FMRA 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 Professional 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 Versa Solutions, LLC’s intended operation of the DJI Phantom 3 

Professional 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 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 VERSA SOLUTIONS, LLC SEEKS EXEMPTION 

Versa Solutions, LLC 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). 

Brief Description Of The Nature Of The Exemption Versa Solutions, LLC Seeks: 

This exemption will permit Versa Solutions, LLC to commercially operate an Unmanned 

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

areas of the United States. 
pg. 25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT VERSA SOLUTIONS, LLC 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, Versa Solutions, LLC'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, Versa Solutions, LLC will operate the DJI Phantom 3 Professional 

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. 

REQUEST FOR BLANKET COA APPROVAL 

On March 24, 2015, the FAA announced that it has implemented a new policy of 

granting "blanket" COAs to applicants requesting exemptions from the Federal Aviation 

Regulations under Section 333 of the FAA Modernization and Reform Act of 2012. The 

Applicant hereby requests a "blanket" COA that conforms to the terms set forth in 

https://www.faa.gov/news/updates/?newsId=82245 upon approval of Versa Solutions, LLC's 

exemption request. 

CONCLUSION 

As set forth herein, Versa Solutions, 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 3 Professional 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 UAV Aerial Video to safely, efficiently, 

and economically operate the DJI Phantom 3 Professional UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Versa Solutions, 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 Versa Solutions, LLC to operate the DJI Phantom 3 

Professional UAS commercially for the purpose of conducting aerial video and photography for 

aerial surveying, building and monetizing YouTube channels, competitive intelligence, 

conservation, environmental regulation and compliance, disaster relief, feature filmmaking, news 

footage, pipeline and electrical line inspection, precision agriculture, real estate videos, resort 

and hotel advertising, search and rescue, security, sports and events, structural inspection and 

construction site data, surveillance, and wedding videos over certain areas of the United States. 
pg. 26

Dated: December 16, 2015 

Respectfully submitted, 

Versa Solutions, LLC 

517 Wayland Drive 

Hockessin, DE 19707 

Tel: 440-225-6158 

Email: Christopher.Kuhman@flyversa.com 
pg. 27

APPENDIX – A 

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

Versa Solutions, 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) 

DJI Phantom 3 Pro 

 

Aircraft 

Weight (Battery & Propellers Included): 2.82 lbs (1280g) 

Hovering Accuracy (GPS Mode) Vertical: +/- 10cm, Horizontal: +/- 1m 

Max Ascent Speed: 5m/s 

Max Descent Speed: 3m/s 

Max Speed: 16m/s (ATTI mode, no wind) 

Max Flight Altitude: 6000m 

Max Flight Time: Approximately 23 minutes 

Operating Temperature Range: 32°F to 104°F (0°C to 40°C) 

Dimensions: 27 1/8" x 27 1/8" x 7.5" 

GPS Mode: GPS/GLONASS 

 

Gimbal 

Controllable Range Pitch: - 0°C to + 30°C 

Vision Positioning 

Velocity Range: < 8 m/s (2 m above the ground) 

Altitude Range: 30 cm-300 cm 

Operating Range: 30 cm-300 cm 

Operating Environment: Brightly lit (lux >15) patterned surfaces 

Camera 

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

Lens: FOV 94° 20 mm (35 mm format equivalent) 

ISO Range: 100-3200 (Video) 100-1600 (Photo) 

Electronic Shutter Speed: 8/s - 1/8000s 

Image Max Size: 4000x3000 

Single Shot 

Burst shooting 3/5/7 frames 

Still Photography Modes: 

Auto Exposure Bracketing (AEB): 3/5 

Bracketed frames at 0.7EV Bias 

Time Lapse 

Supported SD Card Types: 
pg. 28

Micro SD 

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

Video Recording Modes: 

UHD: 4096x2160p, 3840x2160p 24/25/30 

FHD: 1920x1080p 24/25/30/48/50/60 

HD: 1281x720p 24/25/30/48/50/60 

Max Bit Rate Of Video Storage: 60 Mbps 

Supported File Formats: FAT 32/exFAT 

Photo: JPEG, DNG 

Video: MP4/MOV (MPEG-4 AVC/H.264 

Operating Temperature Range: 0°C to 40°C 

Remove Controller 

Operating Frequency: 2.400 GHz-2.483 GHz 

Transmitting Distance: 2000 m (Outdoor And Unobstructed 

Video Output Port: USB 

Operating Temperature Range: 0°C to 40°C 

Battery: 6000 mAh LiPo 2s 

Mobile Device Holder: Tablets and smartphones 

Transmitter Power (EIRP): FCC: 20 dbm; CE: 16 dbm 

Working Voltage: 1.2 A @ 7.4 V 

Charger 

Voltage: 7.4 V 

Rated Power: 100 W 

Intelligent Flight Battery (PH3-4480 mAh-15.2 V) 

Capacity: 4481 mAh 

Voltage: 15.2 V 

Battery Type: LiPo 4S 

Energy: 68 W 

Net Weight: 365 g 

Operating Temperature: -10°C to 40°C 

Max Charging Power: 100 W 
pg. 29

APPENDIX – B 

DJI PHANTOM 3 PRO MANUFACTURER’S USER MANUAL 

Most current version of the user manual can be found at: 

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf
pg. 30

APPENDIX – C 

VERSA SOLUTIONS, LLC MONTHLY MAINTENANCE LOG 

Versa Solutions, LLC Monthly Maintenance Log 

Month: ______ Year: ________ 

 

Date Issue 

Discovered

Date Issue 

Addressed Issue Description & Maintenance Conducted

Maintenance 

Performed By: 

Print and Sign 

Software Updates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 

Batteries 

Other