UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON. D.C. 

IN THE MA TIER OF THE PETITION FOR EXEMPTION OF: ELLIS AERIAL PHOTOGRAPHY 

& IMAGING LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1} & (a)(2), AND 91 .417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 PROFESSIONAL AND DJI 

INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

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

SUBMITTED ON: 

SEPTEMBER 17, 2015 

NAME & ADDRESS OF PETITIONER: 

ELLIS AERIAL PHOTOGRAPHY & IMAGING LLC 

1775 E HOUSTON AVE 

FRESNO, CA 93720 

559-824-6942 

TAYLOR ELLIS (OWNER) 

TA YLORELLIS@ELLISAERIALS.COM 

Page 1 
TABLE OF CONTENTS 

Glossary of Abbreviations 

Summary 

Introduction & Interests of the Petitioner 

Backround 

Basis for Petition 

Name & Address of Petitioner 

The specific sections of 14 C.F.R. from which Ellis Aerial 

Photography & Imaging LLC seeks exemption. 

The extent of relief Ellis Aerial Photography & Imaging LLC 

seeks and the reason Ellis Aerial Photography & Imaging 

LLC seeks the relief. 

The reasons why granting Ellis Aerial Photography & Imaging 

LLC's request would be in the public interest. 

The reasons why granting the exemption would not adversely 

affect safety. 

Summary that can be published in the federal register. 

Any additional information, views, or arguments available to 

support Ellis Aerial Photography & Imaging LLC's request. 

Conclusion 

Appendices 

Page2 

Page# 

3 

4 

4 

4 

5 

6 

6 

10 

12 

14 

26 

26 

27 

28 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

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

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

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SUMMARY 

Ellis Aerial Photography & Imaging LLC seeks exemption from the requirements of 14 C.F.R 

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

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

Modernization and Reform Act of 2012 (FMRA). This exemption will permit Ellis Aerial Photography & 

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

conducting aerial videography & photography, precision agriculture, real estate promotion, 

inspection, 3d mapping/modeling, surveying, wildlife & forestry monitoring, and construction site 

management over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Ellis Aerial Photography & Imaging LLC provides its clients with expertise and knowledge in 

advanced technologies and solutions to increase efficiency, productivity and effectiveness. Ellis 

Aerial Photography & Imaging LLC also provides its clients with the highest quality digital content for 

use in their commercial, personal, and non-profit multimedia projects. Ellis Aerial Photography & 

Imaging LLC has over 4 years of experience in managing flight logs, flight data, and maintenance 

records. Ellis Aerial Photography & Imaging LLC has over 4 years of recreational/hobby experience 

in all aspects of aerial video and photography. The objective of Ellis Aerial Photography & Imaging 

LLC's aerial video and photography operations is to provide high quality imaging for a variety of 

private, commercial, public, and residential uses, specifically targeting: 

• Videography, Photography, & Filmmaking 

• Precision Agriculture 

• Real Estate Photography 

• Data Surveying 

• Pipeline, Petro/Oil Field, Solar, & Utility Inspection 

• 3d modeling & mapping 

• Wildlife & Forestry monitoring 

• Construction site management & imaging 

• Increase public knowledge of UAS and promote safe UAS operations in our local 

community. We believe education is the key to a safe airspace. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 Professional, DJI Inspire 1 UASs 

Ellis Aerial Photography & Imaging LLC seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The OJI Phantom 3 Professional and OJI Inspire 1 are vertical 

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

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

weight of approximately 2 pounds 13 ounces(1280g), measures 23 inches across, has a height of 8 

inches, and a maximum speed of approximately 31 knots. The DJIInspire 1 has a maximum gross 

weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, 

and a maximum speed of approximately 42 knots. The DJI Phantom 3 Professional and DJIInspire 1 

UASs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 

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The DJI Phantom 3 Professional and OJI Inspire 1 UASs that will be operated by Ellis Aerial 

Photography & Imaging LLC will be registered in accordance with 49 U.S.C. 44103, Registration of 

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

Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Ellis Aerial Photography & Imaging 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 OJI Phantom 3 Professional, OJI Inspire 1 UASs in the 

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

61 .113(a) & (b), 91.7(a), 91 .121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2}, and 

91.417(a) & (b). 

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

unmanned aircraft and its operation, Ellis Aerial Photography & Imaging LLC's operation of OJI 

Phantom 3 Professional and DJI Inspire 1 UASs 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,EIIis Aerial Photography & Imaging 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. 

Ellis Aerial Photography & Imaging LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Ellis Aerial Photography & Imaging LLC will use 

experienced personnel or technicians to perform maintenance, alterations, or preventive 

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

documents (i.e., Weekly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 

Instruction Manual). Furthermore, Ellis Aerial Photography & Imaging LLC will document and maintain 

all maintenance records for the OJI Phantom 3 Professional and OJI Inspire 1 UASs. 

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

and limitations: Pilot in command, is requested by Ellis Aerial Photography & Imaging LLC to the 

extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, 

as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour 

and currency requirements, that the PIC is able to safely operate the OJI Phantom 3 Professional 

and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive and emergency 

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

Ellis Aerial Photography & Imaging LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the OJI Phantom 3 Professional and DJI Inspire 1 UASs do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Ellis Aerial 

Photography & Imaging LLC submits that he will ensure that the OJI Phantom 3 Professional and DJI 

Inspire 1 UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in 

compliance with the operating documents (i.e., Weekly Maintenance Log, and OJI Phantom 3 

Professional and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe 

flight. 

Ellis Aerial Photography & Imaging LLC also seeks an exemption from the requirements of 

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Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional and DJIInspire 1 

UASs will not have a typical barometric altimeter onboard. However, altitude information of the DJI 

Phantom 3 Professional and DJI Inspire 1 UASs 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 Ellis Aerial 

Photography & Imaging LLC's operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs 

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

91.121. 

Additionally, Ellis Aerial Photography & Imaging LLC seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Ellis Aerial 

Photography & Imaging LLC submits that safety will not be affected by operation of the DJI Phantom 

3 Professional and DJI Inspire 1 UASs 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, Ellis Aerial Photography & Imaging LLC provides the 

following information in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

Ellis Aerial Photography & Imaging LLC 

1775 E Houston Ave 

Fresno, CA 93720 

Tel: (559) 824-6942 

Taylor Ellis (Owner) 

Email: TaylorEIIis@EIIisAerials.com 

B. The Specific Sections Of 14 C.F.R. from Which Ellis Aerial Photography & Imaging 

LLC Seeks Exemption. 

1. Ellis Aerial Photography & Imaging 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. 

Page6 
2. Ellis Aerial Photography & Imaging LLC Seeks Exemption From The 

Requirements Of Section 91. 7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Ellis Aerial Photography & Imaging LLC Seeks Exemption From The 

Requirements Of Section 91.121. 7 

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

part: 

(a) Each person operating an aircraft shall maintain the cruising attitude 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. 

4. Ellis Aerial Photography & Imaging LLC Seeks Exemption From The 

Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), 

states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

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

for at least 20 minutes. 

5. Ellis Aerial Photography & Imaging 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{.] 

Page 7 
6. Ellis Aerial Photography & Imaging 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 chapterf.] 

7. Ellis Aerial Photography & Imaging LLC Seeks Exemption From The 

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may 

operate an aircraft unless, within the preceding 12 calendar months, it has 

had-

{1) An annual inspection in accordance with part 43 of this chapter 

and has been approved for return to service by a person authorized 

by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

8. Ellis Aerial Photography & Imaging LLC Seeks Exemption From The 

Requirements Of Sections 91.417(a} And 91.417(b}. 

Section 91.417, entitled Maintenance records, subsections (a) and {b), state the 

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for the 

periods specified in paragraph {b) of this section: 

(1) Records of the maintenance, preventive maintenance, and 

alteration and records of the 100-hour, annual, progressive, and 

other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include-

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

Page8 
(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person 

approving the aircraft for retum to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified 

time basis. 

(iv) The current inspection status of the aircraft, including the 

time since the last inspection required by the inspection 

program under which the aircraft and its appliances are 

maintained. 

(v) The current status of applicable airworthiness directives 

(AD) and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision 

date. If the AD or safety directive involves recurring action, the 

time and date when the next action is required. 

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

for each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 

(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. 

Page9 
(3) A list of defects furnished to a registered owner or operator under 

§ 43.11 of this chapter shall be retained until the defects are repaired 

and the aircraft is approved for return to service. 

C. The Extent Of Relief Ellis Aerial Photography & Imaging LLC Seeks And The Reason 

Ellis Aerial Photography & Imaging LLC Seeks The Relief. 

1. Extent Of Relief Ellis Aerial Photography & Imaging LLC Seeks And The 

Reason Ellis Aerial Photography & Imaging 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 private pilot or higher level certificate, as well as a current and valid airman 

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

conduct the proposed UAS flight operations for compensation or hire. 

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

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

connection with any business or employment if: (1) The flight is only incidental to that 

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

for compensation or hire. 

As set forth more fully below, Ellis Aerial Photography & Imaging LLC submits 

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

operate the DJI Phantom 3 Professional UAS or DJI Inspire 1 UAS unless that PIC 

has met certain flight-hour and currency requirements. demonstrating that the PIC is 

able to safely operate either the DJI Phantom 3 Professional or DJI Inspire 1 UASs 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, Ellis Aerial Photography & Imaging LLC submits that all flights of the 

DJI Phantom 3 Professional and DJIInspire 1 UASs, conducted by the PIC pursuant 

to the grant of this Petition: (1) will be incidental to Ellis Aerial Photography & 

Imaging LLC's business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Ellis Aerial Photography & Imaging LLC Seeks And The 

Reason Ellis Aerial Photography & Imaging 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 Ellis Aerial Photography & Imaging LLC to determine that 

the DJI Phantom 3 Professional and DJI Inspire 1 UASs are in airworthy condition 

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

documents (i.e., the Ellis Aerial Photography & Imaging LLC Aerial Operations 

Page 10 
Manual, Weekly Maintenance Log, and DJI Phantom 3 Professional and DJIInspire 1 

Instruction Manual). 

Ellis Aerial Photography & Imaging seeks the requested relief because the 

OJI Phantom 3 Professional and OJI Inspire 1 UASs do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Ellis Aerial 

Photography & Imaging LLC will ensure that the DJI Phantom 3 Professional and OJI 

Inspire 1 UASs are in airworthy condition based upon its compliance with the 

operating documents (i.e., Weekly Maintenance Log, and DJI Phantom 3 

Professional and DJI Inspire 1 Instruction Manual) prior to every flight, and further, 

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

and limitations below. 

3. Extent Of Relief Ellis Aerial Photography & Imaging LLC Seeks And The 

Reason Ellis Aerial Photography & Imaging LLC Seeks Relief From Section 

91.121. 

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

allow flight operations of the OJI Phantom 3 Professional and DJI Inspire 1 UASs, 

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), Ellis Aerial Photography & Imaging LLC seeks the 

requested relief because the DJI Phantom 3 Professional and DJIInspire 1 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 and OJI 

Inspire 1 UAS are equipped with a barometric pressure sensor and GPS equipment, 

which automatically ensures that a ground level pressure setting will be established 

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

heads-up display of the GCS. 

4. Extent Of Relief Ellis Aerial Photography & Imaging LLC Seeks And The 

Reason Ellis Aerial Photography & Imaging 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 and DJI Inspire 1 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. Ellis Aerial Photography & Imaging 

LLC seeks the requested relief because without an exemption from Section 

Page 11 
91.151(b), the flight time duration of the battery powered OJI Phantom 3 Professional 

and OJI Inspire 1 UAS will severely constrain the practicality of any flight operations 

that Ellis Aerial Photography & Imaging LLC proposes to conduct pursuant to this 

Petition. 

Significantly, as set forth below, the technical specifications of the OJ I 

Phantom 3 Professional and DJI Inspire 1 UASs, the DJI Phantom 3 Professional 

and DJI Inspire 1 operating documents, and Ellis Aerial Photography & Imaging 

LLC's proposed operating limitations, ensure that Ellis Aerial Photography & Imaging 

LLC will safely operate the battery powered OJI Phantom 3 Professional and OJI 

Inspire 1 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. 

5. Extent Of Relief Ellis Aerial Photography & Imaging LLC Seeks And The 

Reason Ellis Aerial Photography & Imaging LLC Seeks Relief From Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(aX1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b) only apply to aircraft with an airworthiness certificate, Ellis Aerial Photography & 

Imaging LLC requests relief from these Sections because the OJI Phantom 3 

Professional and DJI Inspire 1 UASs do not require airworthiness certificates. As set 

forth more fully below, the OJI Phantom 3 Professional and OJI Inspire 1 UASs meet 

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

Accordingly, Ellis Aerial Photography & Imaging LLC will use trained technicians to 

perform maintenance, alterations, or preventive maintenance on the UASs using the 

methods, techniques, and practices prescribed in the UAS operating documents (i.e., 

the Ellis Aerial Photography & Imaging LLC Aerial Operations Manual, Weekly 

Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction 

Manual). Furthermore, Ellis Aerial Photography & Imaging LLC will document and 

maintain all maintenance records for the DJI Phantom 3 Professional and OJI Inspire 

1 UASs. 

D. The Reasons Why Granting Ellis Aerial Photography & Imaging LLC's Request Would 

Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing Ellis Aerial 

Photography & Imaging LLC to safely, efficiently, and economically perform flight operations 

conducting aerial videography & photography, precision agriculture, real estate promotion, 

inspection, 3d mapping/modeling, surveying, wildlife & forestry monitoring, and construction site 

management over certain areas of the United States. 

Additionally,. use of the DJI Phantom 3 Professional and OJI Inspire 1 UASs will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, 

the benefits of Ellis Aerial Photography & Imaging LLC's proposed operation of the DJI Phantom 3 

Professional and DJIInspire 1 UASs will be realized without implicating any privacy issues. 

Page 12 
1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Phantom 3 Professional and OJI Inspire 1 UAS are battery powered 

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

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

aircraft needed to perform aerial acquisitions, an exemption allowing the use of a OJI 

Phantom 3 Professional or OJI Inspire 1 UAS would reduce the amount of manned 

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

life and property in the air and on the ground. 

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

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

reduced. The DJI Phantom 3 Professional and OJI Inspire 1 UAS do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled 

by air traffic control during the ground, takeoff, departure, arrival, and landing phases 

of flight operations. 

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

Professional and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the OJI Phantom 3 Professional and OJI 

Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically 

reducing the levels of air and noise pollution generated during traditional manned 

flight operations. By using battery power and electric motors, the OJI Phantom 3 

Professional and OJI Inspire 1 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 2~30 gallons per hour of leaded aviation fuel. The OJI 

Phantom 3 Professional and OJI Inspire 1 UAS, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by 

battery powered electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 3 Professional and DJI Inspire 1 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 3 Professional and OJI 

Inspire 1 UAs (weighing approximately 2 pounds 13 ounces and 6 pounds 7.5 

ounces respectively, at their maximum gross weights with lengths of 16 inches and 

17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with 

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

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

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

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

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 

Professional and DJI Inspire 1 UASs Will Benefit The Economy. 

Page 13 
In addition to being safe and efficient, the DJI Phantom 3 Professional and 

DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the DJI Phantom 3 

Professional and DJI Inspire 1 UASs will allow United States based companies, like 

Ellis Aerial Photography & Imaging 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 and DJI Inspire 1 UASs 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 and DJI Inspire 1 UASs, 

companies such as Ellis Aerial Photography & Imaging 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 and DJI Inspire 1 UASs, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, Ellis Aerial Photography & Imaging LLC's proposed 

operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will not implicate 

any privacy issues. Specifically, the DJI Phantom 3 Professional and DJI Inspire 1 

UASs will be operated only in compliance with operating documents (i.e., the Ellis 

Aerial Photography & Imaging LLC's Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual) which requires 

property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119. 

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

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

Rule From Which Ellis Aerial Photography & Imaging LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 Professional and DJI Inspire 1 UASs Meet 

The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, Ellis Aerial Photography & Imaging LLC's 

operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs meet the conditions of 

Page 14 
FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. 

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

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

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

Section 333 states the following, in part: 

(a) In GeneraL- Notwithstanding any other requirement of this subtitle, and 

not later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan and rulemaking 

required by section 332 of this Act or the guidance required by section 334 of this 

Act. 

(b) Assessment of Unmanned Aircraft Systems.-ln 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, Ellis Aerial Photography & Imaging LLC submits that the DJI 

Phantom 3 Professional and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the OJI Phantom 3 Professional and DJI 

Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 Professional and DJI Inspire 1 UASs 

Demonstrate Its Safe Characteristics. 

The OJI Phantom 3 Professional and DJI Inspire 1 UASs do not create a hazard to 

users of tlie NAS or the public, or otherwise pose a threat to national security considering its 

size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 Professional 

and OJI Inspire 1 UASs. 

Page 15 
The technical specifications of the OJI Phantom 3 Professional and 

OJI Inspire 1 UASs are set forth by the DJI Phantom 3 Professional and DJI 

Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B. 

ii. The DJI Phantom 3 Profes.sional and DJI Inspire 1 UASs 

Autonomous Flight And Navigation Modes Enable The UASs To Remain 

Within A Defined Operational Area. 

The DJI Phantom 3 Professional and DJI Inspire 1 UASs may be 

operated in both manual and fully autonomous flight modes. A complete 

description of the flight and navigational modes of the OJ I Phantom 3 

Professional and OJI Inspire 1 UASs is provided at pages 11-12 and 40-43 

of the OJI Phantom 3 Professional and pages 12-16 and 45-50 of the OJI 

Inspire 1 User Manuals, attached hereto as Exhibit C and 0 

iii. The DJI Phantom 3 Professional and DJI Inspire 1 UASs Are 

Designed For Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the OJI Phantom 3 Professional and 

OJI Inspire 1 UASs will remain stationary, in flight, for 3 seconds or more. If, 

after 3 seconds, the OJI Phantom 3 Professional and OJI Inspire 1 UASs do 

not reacquire control link data from the GCS, the UASs will assume that the 

Control Link is lost and the UASs will retum to the home position (i.e., failsafe 

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

complete description of the Failsafe Functions of the OJI Phantom 3 

Professional UAS are set forth at pages 12 through 14 and for the DJIInspire 

1 at pages 12 through 15 of the DJI Phantom 3 Professional and OJI Inspire 

1 User Manuals, attached hereto as Exhibit C and D. 

iv. The DJI Phantom 3 Professional and DJI Inspire 1 GCS And Its 

Operation. 

A complete description of the operation and specifications of the OJ I 

Phantom 3 Professional and DJI Inspire 1 GCS and flight control software is 

provided at pages 34 through 38 of the OJI Phantom 3 Professional User 

Manual and pages 40 through 47 of the DJI Inspire 1 User Manual. OJI 

Phantom 3 Professional and OJI Inspire 1 User Manuals are attached hereto 

as Exhibits C and 0 . 

b. Flight Operations Of DJI Phantom 3 Professional and DJI Inspire 1 UASs Are Limited 

To The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. 

Ellis Aerial Photography & Imaging 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 OJI Phantom 3 Professional and OJI Inspire 1 

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

Page 16 
c. Flights Of DJI Phantom 3 Professional and DJI Inspire 1 UASs Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, Ellis Aerial Photography & Imaging LLC proposes to 

commercially operate DJI Phantom 3 Professional and DJI Inspire 1 UASs 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 3 Professional and DJI Inspire 

1 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 500 feet above 

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

documents unless a special request is made and approved by ATC. All 

altitudes reported to ATC must be in feet AGL. 

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

all times. This requires the PIC to be able to use human vision unaided by 

any device other than corrective lenses, as specified on the PIC's FAA-issued 

airman medical certificate. 

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

permitted. 

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The 

PIC must be 17 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 

Page 17 
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's Safety Bulletins. 

Page 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 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 NOT AM as required by the 

operator's COA. The letter of agreement with the airport management must 

be made available to the Administrator upon request. 

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. 

Page 19 
24. The PIC is prohibited from beginning a flight unless (considering wind and 

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

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

remaining. 

25. The operator must obtain an Air Traffic Organization (ATO} issued 

Certificate of Waiver or Authorization (COA) prior to conducting any 

operations under the grant of exemption. This COA will also require the 

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

advance, but not less than 48 hours prior to the operation. All operations 

shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential 

transponder requirements. 

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

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

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

Subpart C. Markings must be as large as practicable. 

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

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

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

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

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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

aviation operations and activities at all times. 

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

vehicle. 

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

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

or essential persons), vessels, vehicles, and structures unless: a. Barriers or 

structures are present that sufficiently protect nonparticipating persons from 

the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation 

arises where nonparticipating persons leave such protection and are within 

500 feet of the UA, flight operations must cease immediately and/or, 20 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 

Page 20 
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 .1 19(a). 

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

property with permission from the landowner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted. 

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

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

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

hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And 

(b) Would Not Adversely Affect Safety. 

Ellis Aerial Photography & Imaging 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 and DJI Inspire 1 UASs 

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

requirements, that the PIC is able to safely operate the OJI Phantom 3 Professional 

or OJI Inspire 1 UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering Ellis Aerial Photography & Imaging 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 or DJI Inspire 1 UAS, Ellis Aerial Photography & 

Imaging LLC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary 

for Ellis Aerial Photography & Imaging LLC's specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific 

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

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

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

. Ellis Aerial Photography & Imaging LLC will not allow any PIC to operate the 

DJI Phantom 3 Professional or OJI Inspire 1 UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the DJI Phantom 3 Professional or 

OJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely 

operate the OJI Phantom 3 Professional or OJI Inspire 1 UAS in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining 

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

Specifically, the PIC must have accumulated and logged, in a manner 

consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot 

(with a minimum of 5 hours of those hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption). In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 

90 days (for currency purposes). 

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

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Ellis Aerial Photography & Imaging LLC's proposed 

operations. The Administrator has held that prior documented flight experience that 

was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting 

operations for the purpose of motion picture filming (or similar operations), the PIC 

must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 

25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a 

UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

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

exemption. For clarification, the FAA considers these minimum hour requirements to 

be inclusive rather than additive; i.e. 5 hours make and model time may be included 

in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 

hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). 

The FAA finds that at a minimum, the flight-hour requirements in Exemption No. 

11062 are appropriate to practice and build proficiency in the skills necessary to 

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

documented flight experience that was obtained in compliance with applicable 

regulations would satisfy this requirement. Training, proficiency, and 

experience~building flights can also be conducted under the grant of exemption to 

accomplish the required flight time. During training, proficiency, and 

experienc~uilding flights the PIC is required to operate the UAS with appropriate 

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

Exemption No. 11138 at page 15. 

Accordingly, Ellis Aerial Photography & Imaging LLC will ensure safe 

operations by not allowing any PIC to operate the OJI Phantom 3 Professional or OJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the OJI Phantom 3 

Professional or OJI Inspire 1 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would 

Not Adversely Affect Safety. 

Page 22 
The equivalent level of safety established by Section 91. ?(a) will be 

maintained because prior to every flight, Ellis Aerial Photography & Imaging LLC will 

ensure that the DJI Phantom 3 Professional or DJI Inspire 1 UAS is in an airworthy 

condition based upon the UAS's compliance with its operating documents and as 

stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) 

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

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

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

11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would 

Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be 

maintained because the altitude information of the DJ I Phantom 3 Professional and 

DJIInspire 1 UASs will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UAS to the GCS for 

active monitoring of the flight path and altitude. This altitude information, combined 

with Ellis Aerial Photography & Imaging LLC's operation of the DJI Phantom 3 

Professional and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed onboard the aircraft. Prior 

to each flight, a zero altitude initiation point is automatically established by the UASs 

at ground level. 

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

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

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

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical 

specifications of the DJI Phantom 3 Professional and DJI Inspire 1 UASs; (2) the 

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

flight operations. Accordingly, Ellis Aerial Photography & Imaging LLC will ensure that 

it will safely operate the battery powered DJI Phantom 3 Professional and DJI Inspire 

1 UASs during daylight hours in VFR conditions, with enough battery power to fly for 

a t.otal 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 and DJI Inspire 1 UASs; the limitations on the proposed 

flight operations; and the location of the proposed operations, will ensure an 

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

Page 23 
safety will be ensured as the DJI Phantom 3 Professional and DJI Inspire 1 UASs 

provide audible and visual warnings to the PIC at the GCS when the UASs 

experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. 

At the critically low battery level, the DJI Phantom 3 Professional and DJI Inspire 1 

UASs will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical 

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

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

Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the 

FAA has previously granted relief from Section 91.151 specific to UAS, in 

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

Exemption Nos. 8811 , 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety. 

In seeking this exemption, Ellis Aerial Photography & Imaging 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 Ellis Aerial Photography & Imaging 

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

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

in the operating documents (i.e., the Ellis Aerial Photography & Imaging LLC Aerial 

Operations Manual, Weekly Maintenance Log, and DJI Phantom 3 Professional and 

DJIInspire 1 Instruction Manual). Furthermore, Ellis Aerial Photography & Imaging 

LLC will document and maintain all maintenance records for the OJI Phantom 3 

Professional and DJI Inspire 1 UASs. 

Since the OJI Phantom 3 Professional and DJI Inspire 1 UASs will be 

inspected as prescribed by the operating documents, Ellis Aerial Photography & 

Imaging 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 the OJ I Phantom 3 Professional 

and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy of 

the DJI Phantom 3 Professional and DJI Inspire 1 UAS Maintenance LOG is attached 

hereto as Exhibit E. A copy of the OJI Phantom 3 Professional and OJI Inspire 1 

Preflight and Postflight Checklist is attached hereto as Exhibit F. 

Likewise, the exemption sought will not adversely affect safety because Ellis 

Aerial Photography & Imaging 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 and OJI Inspire 1 UASs will be 

Page 24 
perfonned by trained technicians. Maintenance will be documented and maintained 

utilizing the weekly 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 Ellis Aerial Photography & Imaging LLC's proposed 

operating limitations, the operating documents, and the technical aspects of the DJI 

Phantom 3 Professional and DJI Inspire 1 UASs, Ellis Aerial Photography & Imaging 

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). 

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

In accordance with Section 333 of the FAA Modernization and Refonn Act of 

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Ellis Aerial 

Photography & Imaging LLC requests that the FAA prescribe special conditions for 

the intended operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, 

which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will 

pennit safe operation of the UAs for the limited purpose of conducting aerial 

videography & photography, precision agriculture, real estate promotion, inspection, 

3d mapping/modeling, surveying·, wildlife & forestry monitoring, and construction site 

management over certain areas of the United States for compensation or hire. FMRA 

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

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

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

airworthiness certification in accordance with any requirements that must be 

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

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R. § 21.16, for operation of the DJI Phantom 3 Professional and DJI Inspire 1 

UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain 

adequate or appropriate safety standards, due to the novel or unusual design 

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

following: 

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 

Page 25 
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 Ellis Aerial Photography & Imaging LLC's 

intended operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, which 

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

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

C.F.R 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). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Ellis Aerial Photography & Imaging LLC Seeks Exemption: 

Ellis Aerial Photography & Imaging LLC seeks exemption from the requirements of 14 

C.F.R Sections 61. 113(a)&(b), 91. ?(a), 91. 121, 91. 151(b), 91.405(a), 91.407(a)(1), 

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

A Brief Description Of The Nature Of The Exemption Ellis Aerial Photography & 

Imaging LLC Seeks: 

This exemption will permit Ellis Aerial Photography & Imaging LLC to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial 

videography & photography, precision agriculture, real estate promotion, inspection, 3d 

mapping/modeling, surveying, wildlife & forestry monitoring, and construction site 

management over certain areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support Ellis 

Aerial Photography & Imaging LLC's Request. 

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

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Ellis Aerial Photography & Imaging 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, Ellis Aerial Photography & Imaging LLC will operate the 

DJI Phantom 3 Professional and DJI Inspire 1 UASs safely in the NAS, without creating a 

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

Page 26 
CONCLUSION 

As set forth herein, Ellis Aerial Photography & Imaging 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 and OJ I Inspire 1 UASs commercially, 

without an airworthiness certificate, for the limited purpose of conducting aerial videography & 

photography, precision agriculture, real estate promotion, inspection, 3d mapping/modeling, 

surveying, wildlife & forestry monitoring, and construction site management 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 Ellis Aerial Photography & Imaging LLC to safely, efficiently, and economically 

operate the OJI Phantom 3 Professional and OJI Inspire 1 UASs commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Ellis Aerial Photography & Imaging 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 the petitioner to operate the OJI Phantom 3 

Professional and DJI Inspire 1 UASs commercially for the purpose of conducting aerial videography & 

photography, precision agriculture, real estate promotion, inspection, 3d mapping/modeling, 

surveying, wildlife & forestry monitoring, and construction site management over certain areas of the 

United States. 

Page 27 

Respectfully submitted, 

~iiji?/ ~ Taylor B. Ellis 

Ellis Aerial-Photography & Imaging LLC, Owner 

1775 E Houston Ave 

Fresno, CA 93720 

Tel: (559) 824-6942 
APPENDICES: 

A - DJI Phantom 3 Professional Specifications Data Sheet 

B- DJIInspire 1 Specifications Data Sheet 

C- DJI Phantom 3 Professional Manufacturer's User Manual 

D- DJI Inspire 1 Manufacturer's User Manual 

E- Weekly Maintenance Log 

F - Preflight and Postflight Checklists 

APPENDIX-A 

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS 

Ellis Aerial Photography & Imaging LLC only utilizes safe and reliable UASs. DJI is an industry leader 

in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to 

set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well 

as limit flight to a predetermined and set distance. In addition, DJI software provides real-time altitude 

and location information to the PIC via the linked monitor (smart phone/tablet devices) 

1. 1 DJ I Phantom 3 Professional 

1.1.1 Aircraft 

1. 1.1.1 Supported Battery - DJ I 6000mAH 2S UPo Battery 

1.1.1.2 Weight (Battery & Propellers Included)- 1280g 

1.1.1.3 Hover Accuracy (Ready to Fly)- Vertical:+/- .1m; Horizontal:+/- 1.5m 

1. 1. 1.4 Max Ascent Speed - Sm/s 

1.1.1.5 Max Descent Speed-3m/s 

1.1.1.6 Max Flight Speed -16m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

1.1.2.1 Controllable Range- Pitch: -90° to +30° 

1.1.3 Camera 

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

1.1.3.2 Sensor Size- 1/2.3" 

1.1.3.3 Effective Pixels - 12.4M 

1.1.3.4 Resolution - 4000X3000 

1.3.5 HD Video Recording -4K + 1080P 

1.3.6 Recording Field of View- 94° 

1.1.4 Transmitter 

1.1.4.1 Operating Frequency - 2.400GHz - 2.483GHz 

1.1.4.2 Communication Distance (unobstructed) - FCC Compliance: 2000m 

1.1.4.3 Receiver Sensitivity (1%PER)- -101dBm 

1.1.4.4 Transmitter Power- FCC Compliance: 100mW 

1.1.4.5 Working Voltage -120mA@7.4V 

Page 28 
APPENDIX-8 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Ellis Aerial Photography & Imaging 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) 

2.2 DJI Inspire 1 

2.2. 1 Aircraft 

2. 2.1. 1 Model - T600 

2.2.1.2 Weight (Battery Included)- 61bs 7.5291oz {2935g) 

2.2.1 .3 Hovering Accuracy {GPS Mode)- Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity- Pitch: 300°/s; Yaw: 150°/s 

2.2.1 . 5 Max Tilt Angle - 35° 

2.2.1.6 Max Ascent Speed - 5m/s 

2.2.1. 7 Max Descent Speed - 4m/s 

2.2.1 .8 Max Speed- 22m/s (A TTl mode, no wind- NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude- 4500m 

2.2.1.10 Max Wind Resistance -10m/s 

2.2.1.11 Max Flight Time - Approximately 18 minutes 

2.2.1 .12 Motor Model- DJI 3510 

2.2.1.13 Propeller Model - DJI 1345 

2.2.1.14 Operating Temperature Range - 14°F to 104°F {-1 0°C to 40°C) 

2.2.1 .15 Dimensions -17 %" x 17 %" x 12" 

2.2.2 Gimbal 

2.2.2.1 Model -ZEN MUSE X3 

2.2.2.2 Output Power {with camera)- Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current- Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range- ±0.03° 

2.2.2.5 Mounting - Detachable 

2.2.2.6 Controllable Range- Pitch: -90° to +30°; Pan: ±320° 

2.2.2.7 Mechanical Range - Pitch: -125° to 45°; Pan: ±330° 

2.2.2.8 Max Controllable Speed- Pitch: 120°/s; Pan: 180°/s 

2.2.3 Camera 

2.2.3.1 Name- X3 

2.2.3.2 Model- FC350 

2.2.3.3 Total Pixels - 12.76M 

2.2.3.4 Effective Pixels -12.4M 

2.2.3.5 Image Max Size- 4000x3000 

2.2.3.6 ISO Range- 100-3200 
2.2.3. 7 Field of View - 94° 

2.2.3.8 CMOS -Sony EXMOR 1/2.3" 30 

2.2.3.9 HD Video Recording- UHD(4K): 3840x2160p24/25/30; 

2.2.3.10 Operating Temperature Range- 32°F- 104°F (0°C- 40°C} 

2.2.4 Transmitter 

2.2.4.1 Name- C1 

2.2.4.2 Operating Frequency- 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) - 2000m 

2.2.4.4 Output Power- 9W 

2.2.4.5 Operating Temperature Range- 14°F to 104°F (-100C to 40°C) 

2.2.4.6 Battery - 600mAh LiPo 2S 
UAV SERIAL# : 

SOFTWARE/UPD 

ATES 

AIRFRAME 

MOTORS 

PROPELLERS 

CAMERA/GIMBAL 

LANDING GEAR 

VIBRATION 

DAMPENING 

WIRING 

HARNESS 

OTHER: 

DATE 

ISSUE 

APPENDIX E 

WEEKLY MAINTENANCE LOG EXAMPLE 

DATE 

ISSUE 

DESCRIPTIO 

N OF ISSUE 

,FOUND & 

MAINTENAN MONTH: 

DISCOVERE CORRECTE CE PERFORME _ __ _ 

D D CONDUCTED D BY : 

WEEK 

#: 
APPENDIX F 

PREFLIGHT AND POSTFLIGHT CHECKLISTS 

PREFLIGHT 

1. Verify all transmitter, camera, and aircraft batteries are fully charged. 

2. Check all control surfaces for signs of damage, loose hinges, and overall condition. 

3. Check the control linkages are secured and the condition of the control hams and brackets. 

4. Check the frame and booms to confirm structural condition and proper alignment. 

5. check the motors and mounting system to make sure it is firmly attached to the airframe. 

6. Check the propellers for chips, cracks, looseness, and any deformation. 

7. Check the landing gear for damage, proper mobility, and secure attachment. 

8. Check that the servos are attached properly and in working condition, all receivers are 

secure. 

9. Check all electrical connections making sure they are plugged in and secured to the airframe. 

10. Check that the photography equipment and mounting system are secure and operational. 

11. Perform an overall visual check of the aircraft prior to arming any power systems. 

12. Repair or replace any part found to be unairworthy in the preflight prior to takeoff. 

13. Perform assessment of operational area to identify hazards that may interfere with operation. 

14. Determine if barriers or crowd control personnel are needed to protect public from harm. 

15. Install barriers and/or assign duties to crowd control personnel as needed. 

CONTROL SYSTEMS CHECK 

1. Make every effort to assure that no one in the area is using your radios frequence before 

turning on your transmitter. 

2. Make sure that all of your body parts, clothing, other obstructions, and bystanders are well 

away from any propeller or rotor and its arc before turning power on to any stems. Make sure 

the aircraft is secure and will not move if the motor was suddenly powered up. 

3. Announce out loud- "CLEAR PROP" 

4. Tum on the transmitter. Check all GCS's alerts and warnings and confirm systems clear. 

5. Make sure that the throttle stick on the transmitter is in the power off position. 

6. Insert the aircraft battery and tum on the power to the aircraft. 

7. Test signal strength and confirm failsafe settings in the GCS. 

8. Check for proper operation of control surfaces. 

9. Check that all servos are steady and not chattering or making any other abnormal noise 

when in operation or idle. 

10. Check the motors for proper operation. Confirm the motors stop when the throttle stick is 

turned to "OFF" 

11 . Check that photo/video equipment power is on. Check to make sure the trigger function is 

working properly. 

BEFORE TAKE OFF 

1. Confirm transmitter antenna is fully extended and vertical. 

2. Check that the area is clear of obstructions and people. 

3. Double check the weather conditions and review potential emergency landing areas. 
4. Set flight timer alarms. 

5. Double check airspace around takeoff area scanning for any aircraft. 

6. Double check location & flight meets or exceeds all regulations in place by the FAA, and 

exceeds the protocol recommended by the insurance company. 

7. Announce out loud- "TAKE OFF" 

8. Launch aircraft 

IN FLIGHT 

1. Climb to a safe altitude away from potential hazards and check control systems. 

2. Confirm flight mode operations, satellite strength, and check for any drifting. 

3. Keep aircraft at a safe operating distance from people and buildings. 

4. Continually scan the flight and ground areas for potential hazards, utilizing your spotter for 

assessing for possible hazards. 

LAN PING 

1. Check the control systems and lower landing gear. 

2. Scan landing area for potential obstruction hazards and recheck weather conditions. 

3. Announce out loud- "LANDING" 

4. Always be prepared to go around to have an emergency landing location. 

5. Carefully land the aircraft away from obstructions and people. 

POST FLIGHT 

1. Tum the power off to the aircraft and remove the battery. 

2. Turn off the transmitter. 

3. Tum off the photo equipment. 

4. Visually check the aircraft for signs of damage and/or excessive wear. 

5. Secure the aircraft and lock all equipment cases.