UNITED STATES OF AMERICA 

 DEPARTMENT OF TRANSPORTATION 

 FEDERAL AVIATION ADMINISTRATION 

 WASHINGTON, DC 

 IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

 Alternative Digital Solutions, LLC (ADS, LLC)

 Submitted on October 15, 2015 

 Alternative Digital Solutions, LLC

 120 Peachtree East Shopping Center

 Peachtree City, Georgia. 30269

 (678)378-1871

 Operating Officer: Ronald C. Romuno

 Alternate Contact Information: Ronald.C.Romuno@FAA.gov

 A80, Atlanta TRACON Safety Office

 Federal Aviation Administration

 (678)364-6114
 TABLE OF CONTENTS 

 Page 

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

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

INTRODUCTION.....................................................................................................4 

LIST OF REGULATIONS FOR EXEMPTION......................................................................5 

PROCESSES, PROCEDURES, AND RESPONSIBILITIES................................................5 

PUBLIC BENEIFT..........................................................................................................9 

PRIVACY CONCERNS.................................................................................................10 

SAFETY CONCERNS...................................................................................................10 

CONCLUSION........................................................................................................................15 

CHECKLISTS............................................................................................................16 

DJI Phantom 2 SPEC SHEET .........................................................................................17 
 GLOSSARY OF ABBREVIATIONS 

ADS Alternative Digital Solutions, LLC

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 

DJI UAV manufacturer 

ESC Electronic speed control 

FPV First Person View 

LI-PO Lithium Polymer battery 

RCV Radio Controlled vehicle 
 INTRODUCTION 

Alternative Digital Solutions, LLC (ADS) is a Real Estate Support Company with the focus on 

providing video and still photography, both interior and exterior, to clients throughout the Atlanta 

Metro area. 

The objective of ADS aerial video and photography operations is to provide high quality imaging for 

a variety of commercial, public, and residential uses.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 

14 C.F.R. Part 11, Alternative Digital Solutions, LLC, hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of a Small Unmanned Aircraft 

System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so 

long as such operations are conducted with and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

The requested exemption would permit ADS to pursue commercial interests in providing services to 

clients using a small advanced sUAV in the following areas: Real Estate, Marketing, Land 

Management/Surveying, and Special Events. ADS states that all sUAS flights will occur over private 

or controlled access property and will do so with the property owner's consent and knowledge and 

that only people who have consented or otherwise have agreed to be within the UAS’ radius during 

filming and photography applications. 

Ronald C Romuno, Operating Officer and sUAV Pilot (Pilot Certificate # 69545978), has 

demonstrated the ability to safely and effectively fly the sUAS DJI Phantom 2 which will be used for 

all commercial and private purposes. Ronald C Romuno complies with local ordinances and laws 

regarding the operation of sUAS, and adheres to all weather and environmental restrictions or 

limitations in reference to the operations of sUAS. Additionally, ADS will ensure that any other 

individual who operates an sUAV for ADS will meet all pilot requirements with respect to license, 

medical clearance, etc. and complies with all Federal, State and Local regulations.

All flights will occur in ordinance with any state or local laws regarding privacy. 

We, Alternative Digital solutions, LLC, request the exemption because we are committed to 

complying with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. 

We agree to operate the sUAS in the manner that we have described, and for the purposes that we

have described. Without the exemption request granted, we would be unable to safely and effectively 

run our business, and it is our intention to comply with the FAA and obtain an exemption of the 

following regulations. 

The following contains a list of regulations from which we are seeking exemption, and a complete 

list of responsibilities we assume as operator; it also contains information regarding the aircraft, 

public benefit and safety features, and similar petitions requests granted. 
Regulations from which exemption is requested: 

14 C.F.R. Part 21 

14 C.F.R. 45.23(b) 

14 C.F.R. 61.113(a) & (b) 

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9(b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417 

PROCESSES, PROCEDURES, AND RESPONSIBILITIES 

We, Alternative Digital Solutions, LLC, WOULD ASSUME THE FOLLOWING 

RESPONSIBILITIES IF MY EXEMPTION IS APPROVED. 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 when weighing 

less than 55 pounds including payload. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption 

holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot 

speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer. 

4. The UA will be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. 

5. The UA will 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 or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The VO 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 VO can perform the duties required of the 

VO. 
7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during UAS 

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

conditions and 4 limitations in this exemption and the procedures outlined in the operating 

documents, the conditions and limitations herein 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 or any law enforcement official upon 

request. The operator must also present updated and revised documents if it petitions for extension or 

amendment to this grant of exemption. If the operator determines that any update or revision would 

affect the basis upon which the FAA granted this exemption, then the operator must petition for an 

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. 

8. 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 

prior to conducting further operations under this exemption. Functional test flights may only be 

conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional 

test flight must be conducted in such a manner so as to not pose an undue hazard to persons and 

property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection see attachment and determine 

the UAS is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. 5 
14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

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

vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a 

manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs 

and VOs (training, proficiency, and experience-building) and determining the PIC’s ability to safely 

operate the UAS in a manner consistent with how the UAS will be operated under this exemption are 

permitted under the terms of this 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 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations 

must be conducted under visual meteorological conditions (VMC). Flights under special visual flight 

rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in 

the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center 

of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of 

agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the 

exemption holder. The letter of agreement with the airport management must be made available to 

the Administrator or any law enforcement official upon request. 

17. 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined 

location within the private or controlled-access property. 

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

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a 

new or amended COA if it intends to conduct operations that cannot be conducted under the terms of 

the attached COA. 6 
22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at all 

times. 

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of nonparticipating persons; and b. The 

owner/controller of any vessels, vehicles or structures has granted permission for operating closer to 

those objects 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. The PIC, VO, operator trainees or 

essential persons are not considered nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. 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.
 PUBLIC BENEFIT 

1. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 UASs. 

Conducting aerial acquisitions with the DJI Phantom 2 UASs, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and electric 

motors, the DJI Phantom 2 UASs 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 2 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 2 UASs to perform aerial acquisitions, the substantial risk to life and 

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

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Phantom 2 UAs (weighing 5 pounds 7 

ounces, at its maximum gross weights with a diagonal length of 13.78 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). 

2. Performing Aerial Video and Photography Operations With The DJI Phantom 2 UASs Will 

Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 2 UAS is also an 

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

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

competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of 

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered DJI Phantom 2 UAS not 

only allows companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. By operating the DJI 

Phantom 2 UAS, companies such as ADS can remain competitive and profitable, and therefore, 

provide greater job stability to employees and contractors, which will ultimately contribute to growth 

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

the DJI Phantom 2 UAS, provides a stable workforce that increases consumer spending; improves 

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

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

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

proposed operation of the DJI Phantom 2 UAS would not implicate any privacy issues. Specifically, 

the DJI Phantom 2 UAS will be operated only in compliance with operating documents such as the 

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

 SAFETY CONCERNS 

In seeking this exemption, ADS submits that the DJI Phantom 2 UAS can operate safely in the NAS 

pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2

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

i. The Specifications Of The DJI Phantom 2 UAS Demonstrate Its Safe Characteristics. The DJI 

Phantom 2 UAS does not create a hazard to users of the NAS or the public, or otherwise pose a threat 

to national security considering its size, weight, speed, and operational capability. 

ii. Technical Specifications Of The DJI Phantom 2 UAS. The DJI Phantom 2 Specifications and 

Data Sheet, attached hereto as Appendix A and B, set the technical specifications of the DJI Phantom 

2 UAS forth. 

iii. The DJI Phantom 2 UAS Autonomous Flight And Navigation Modes Enable The UAS To 

Remain Within A Defined Operational Area. The DJI Phantom 2 UAS may be operated in both 

manual and fully autonomous flight modes. A complete description of the flight and navigational 

modes of the DJI Phantom 2 UAS is provided on pages 30 through 44 of the DJI Phantom 2 User 

Manuals. DJI Phantom 2 User Manual is attached.

iv. The DJI Phantom 2 UAS Is Designed For Automatic Return To Home Point Or Hover In 

The Event Of Loss Of The Control Link Or Navigation. When the Control Link is lost, the DJI 

Phantom 2 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 2 UA 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 shutdown. A complete description of the Failsafe Functions 

for the DJI Phantom 2 is provided on pages 27 and 28 of the DJI Phantom 2 User Manual. DJI 

Phantom 2 User Manual is attached.

v. The DJI Phantom 2 GCS And Its Operation. A complete description of the operation and 

specifications of the DJI Phantom 2 GCS and flight control software is provided on pages 30 through 

44 of the DJI Phantom 2 User Manual. DJI Phantom 2 User Manual is attached.
vi. Flight Operations Of DJI Phantom 2 UAS Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. ADS will only utilize certificated pilots 

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

DJI Phantom 2 UAS. Additionally, a safety observer will assist all pilots during flight time. 

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

Limitations. In seeking this exemption, ADS proposes to commercially operate the DJI Phantom 2

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

States, pursuant to the following specific operating limitations: 1. Operations authorized by this grant 

of exemption will be limited to the following aircraft described in the operating documents, rotorcraft 

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

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. 

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. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time in 

service, description of work accomplished, and the signature of the authorized person returning the 

UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins. 

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

against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third-class medical 

certificate. 

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

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

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

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

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

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

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

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

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

nonparticipants in accordance with 14 C.F.R. § 91.119. 

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 pre-determined 

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

documents. 

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

with the operating documents. 
24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough power to fly at normal cruising speed to the intended landing point and 

land the UA with 25% battery power remaining. 

25. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

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

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

government oversight agency requirements. 

27. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the 

Ground Control Station of the UAS any time the UAS is operating. These documents must be made 

available to the Administrator or any law enforcement official upon request. 

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

activities at all times. 

29. 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 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.

CONCLUSION 

Alternative Digital Solutions, LLC (ADS) seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe 

operation of the DJI Phantom 2 UAS commercially, without an airworthiness certificate, for the 

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

ADS respectfully requests that the Administrator grant this Petition for an exemption and allow ADS

to operate the DJI Phantom 2 UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Current Phantom 2 UAS to be flown has the FAA Registered N Number: N599YB
 CHECK LISTS 

Pre-flight 

· Reviewed targeted area through Google Earth for any obstructions 

· Reviewed area for any FAA restricted fly zones or other areas of concern 

· Reviewed safety requirements with sponsor / owner (sign-off required back of form) 

· Posted “Aerial Photography” in process sign at opening / curb 

· Visit each neighbor to announce that aerial photography will be taking place 

· Posted “Launch/Landing” zone sign calling for 50’ parameter 

· Walked the hover area or path of flight to check for any areas on concern 

Flight Set-up 

· Advise anyone within “Launch/Landing” area of safety and 50’ requirement 

· Unpack and check DJI Phantom 2 for any visible signs of damage 

· Turn on Remote Controller and observe that both power and Wi-Fi are green 

· Ensure launch zone is clear and turn on DJI Phantom 2 battery 

· Toggle S1 & S2 switches five times to set GPS recall & failsafe landing zone 

· Wait for solid GPS lights (Solid Green slow flashing) 

· Spin DJI Phantom 2 360 degrees both horizontally and vertically to ensure lock 

· Review Launch Site one last time before lift off 

· Engage motors and start straight horizontal lift to desired altitude 

Flight 

· Monitor both GPS Lock (# satellites) / Battery Level every minute 

· Watch for any changes to the “Launch/Landing” area of safety and advise as necessary 

· Watch for any irregular craft behavior and land immediately if necessary 

· Return the craft to the landing area within 20% of battery life 

Post-Flight 

· Announce that the craft is returning for landing 

· Visual check that the 50’ rule is observed, otherwise hover until 50’ is observed 

· Slowly bring the DJI Phantom 2 in for a landing 

· Turn off Battery on Craft first, then the Remote Controller 

· Store all equipment in their cases before allowing observers to approach
General Features

Lightweight, multi-functional integrated aircraft and

camera

Camera remote-control by DJI VISION APP

Range Extender increases Wi-Fi distance to 300m

Anti-vibration camera platform with single axis 

stabilization

Low-voltage protection

Virtual Radar aircraft locator on mobile device

Range of camera tilt options

Multiple, continuous and timed capture options

HD Video Recording (1080/p30 or 1080/60i)

RAW and JPEG picture formats

Aircraft

Battery

5200mAh LiPo

Weight (Battery & Propellers Included)

1160g

Hover Accuracy (Ready To Fly)

Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity

200°/s

Max Tilt Angle

35°

Max Ascent / Descent Speed

Ascent: 6m/s; Descent: 2m/s

Max Flight Speed

15m/s (Not Recommended)

Diagonal Length

350mm

Tilting Range Of Gimbal

0°-60°

Transmitter

Operating Frequency

5.728GHz-5.8GHz

Communication Distance (Open Area)

CE: 300m; FCC: 500m

Receiver Sensitivity (1%PER)

-93dBm

Transmitter Power

General Features
CE: 25mw; FCC: 125mw

Working Voltage

80 mA@6V

Battery

4 AA Batteries

Camera

Resolution

14 Megapixels

FOV

120°/ 110°/ 85°

Sensor Size

1/2.3"

Functionality

 Support of multi-capture, continuous capture and 

timed capture

 Support of HD Recording (1080/p30 or 1080/60i)

 Supports of both RAW and JPEG picture format

Range Extender

Operating Frequency

2412-2462MHz

Communication Distance (Open Area)

300m

Transmitter Power

<=17dBm

Power Consumption

1.5W

DJI VISION App

System Requirement Of Mobile Device

iOS version 6.1 or above/ Android system version 4.0 or 

above

Mobile Device Support

 iOS recommended: iPhone 4s, iPhone 5, iPhone 5s, 

iPhone 6, iPhone 6 Plus, iPod touch 5 (available but 

not recommended: iPad 3, iPad 4, iPad mini)

 Android recommended: Samsung Galaxy S3, S4, 

Note 2, Note 3 or phones of similar configuration