UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, D.C.

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DAAN P. JASPERS

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 A DJI PHANTOM 3 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 November 18, 2015

Daan P. Jaspers

1690 Weeping Willow Way

Hollywood, FL 33019

Tel: 305-788-0291
2

TABLE OF CONTENTS

Page

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

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

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

BACKGROUND ...................................................................................................................4

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH DAAN P. JASPERS

SEEKS EXEMPTION...................................................................................................6

THE EXTENT OF RELIEF DAAN P. JASPERS SEEKS AND THE REASON

DAAN P. JASPERS SEEKS THE RELIEF .............................................................9

THE REASONS WHY GRANTING DAAN P. JASPERS REQUEST WOULD

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. .... 25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT DAAN P. JASPERS REQUEST.... .......................25

CONCLUSION......................................................................................................................... 25
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Daan P. Jaspers 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

Daan P. Jaspers to operate an Unmanned Aircraft System (UAS) for the commercial

purpose of conducting aerial video and photography for wedding videography, real estate

photography, mapping, inspections, special events, film sets, and landscape over certain

areas of the Unites States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Daan P. Jaspers provides its clients with expertise and knowledge in advanced

technologies and solutions to increase efficiency, productivity and effectiveness. Daan P. 

Jaspers also provides its clients with the highest quality digital content for use in their

commercial, personal, and non-profit multimedia projects. Daan P. Jaspers has professional

training as a TV and film director, professional experience as an event producer and 

professional experience as a trainer. Daan P. Jaspers has recreational/hobby experience in

all aspects of aerial video and photography. The objective of Daan P. Jaspers aerial video

and photography operations is to provide high quality imaging for a variety of commercial,

public, and residential uses, specifically targeting:

• Wedding Videography and Photography

• Motion Picture Filming

• Real Estate Videography and Photography

• Construction sites before and after

• Digital mapping and commercial/industrial inspections

• Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

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

Daan P. Jaspers seeks an exemption to operate DJI systems for compensation or

hire within the NAS. The DJI Phantom 3 and DJI 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 DJI Phantom 3 has a maximum gross weight

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

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

Inspire 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, and DJI Inspire 1 UAs are equipped with four

main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 3, and DJI Inspire 1 UAs that will be operated by Daan P. Jaspers

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.
5

BASIS FOR PETITION

Petitioner, Daan P. Jaspers, pursuant to the provisions of the Federal Aviation

Regulations (14

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate the DJI Phantom 3, DJI 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, Daan P. Jaspers operation of DJI Phantom 3,

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, Daan P. Jaspers 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.

Daan P. Jaspers submits that the requested relief is proper since an equivalent level

of safety will be ensured. Daan P. Jaspers 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., Monthly

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual).

Furthermore, Daan P. Jaspers will document and maintain all maintenance records for the

DJI Phantom 3 and DJI 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 Daan P. Jaspers to the extent

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

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting

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

DJI Phantom 3 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.

Daan P. Jaspers seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, DJI Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Daan P. Jaspers

submits that he will ensure that the DJI Phantom 3 and DJI Inspire 1UASs are in an 

airworthy condition, prior to every flight, by determining that the UASs are in compliance

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, and DJI

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

Daan P. Jaspers also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI Phantom 3, and DJI Inspire 1 UAs will not have a

typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3

and DJI Inspire 1UAs 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

Daan P. Jaspers operation of the DJI Phantom 3 and
6

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, Daan P. Jaspers seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Daan P. Jaspers submits

that safety will not be affected by operation of the DJI Phantom 3 and DJI 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 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, Daan P. Jaspers 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:

Daan P. Jaspers

1690 Weeping Willow Way

Hollywood, FL 33019

Tel: 305-788-0291

Email: info@littlestripedlion.com

B. The Specific Sections Of 14 C.F.R. from Which Daan P. Jaspers Seeks Exemption.

1. Daan P. Jaspers Seeks Exemption From The Requirements Of

Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

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

connection with any business or employment if—

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

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

2. Daan P. Jaspers 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. Daan P. Jaspers Seeks Exemption From The Requirements Of Section 91.121.

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

part:
7

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

(1) Below 18,000 feet MSL, to--

(I) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft;

(II) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available

station; or

(III)In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before departure.

4. Daan P. Jaspers 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. Daan P. Jaspers Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. Daan P. Jaspers 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--
8

(1) It has been approved for return to service by a person authorized under §43.7 of 

this chapter[.]

7. Daan P. Jaspers 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. Daan P. Jaspers Seeks Exemption From The Requirements Of

Sections 91.417(a) And 91.417(b).

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

following:

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

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

specified in paragraph (b) of this section:

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

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must

include--

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

work performed; and

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

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

for return to service.

(2) Records containing the following information:

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

each rotor.
9

(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.

(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 Daan P. Jaspers Seeks And The Reason Daan P. Jaspers Seeks

The Relief.

1. Extent Of Relief Daan P. Jaspers Seeks And The Reason Daan P. 

Jaspers 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
10

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, Daan P. Jaspers submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 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 or DJI Inspire 1

UAS in a manner consistent with the operations specifications as described in this

exemption, including evasive and emergency maneuvers, as well as maintaining appropriate

distances from people, vessels, vehicles and structures.

Further, Daan P. Jaspers submits that all flights of the DJI Phantom 3 and, DJI

Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to Daan P. Jaspers business; and (2) will not carry passengers or property for

compensation or hire.

2. Extent Of Relief Daan P. Jaspers Seeks And The Reason Daan P. 

Jaspers 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 Daan P. Jaspers to determine that the DJI Phantom 3 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 Daan P. Jaspers Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction

Manual).

Daan P. Jaspers seeks the requested relief because the DJI Phantom 3, and DJI

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part

21, Subpart H. Therefore, Daan P. Jaspers will ensure that the DJI Phantom 3 and DJI

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

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 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 Daan P. Jaspers Seeks And The Reason Daan P. 

Jaspers Seeks Relief From Section 91.121.

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

flight operations of the DJI Phantom 3 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),
11

Daan P. Jaspers seeks the requested relief because the DJI Phantom 3 and DJI

Inspire 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 and DJI 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 Daan P. Jaspers Seeks And The Reason Daan P. 

Jaspers 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 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. Daan P. Jaspers seeks the requested relief because

without an exemption from Section 91.151(b), the flight time duration of the battery

powered DJI Phantom 3 and DJI Inspire 1 UAs will severely constrain the practicality of

any aerial video or still photo flight operations that Daan P. Jaspers proposes to conduct

pursuant to this Petition.

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

and DJI Inspire 1 UASs, DJI Phantom 3 and DJI Inspire 1 operating documents, and Daan P. 

Jaspers proposed operating limitations, ensure that Daan P. Jaspers will safely operate the

battery powered DJI Phantom 3 and DJI 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 Daan P. Jaspers Seeks And The Reason Daan P. Jaspers

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),

And 91.417(a) & (b).

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

only apply to aircraft with an airworthiness certificate, Daan P. Jaspers requests relief from

these Sections because the, DJI Phantom 3 and DJI Inspire 1 UASs do not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 and DJI Inspire

1 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, Daan P. Jaspers 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
12

(i.e., the Daan P. Jaspers Aerial Operations Manual, Monthly Maintenance Log, and

DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, Daan P. Jaspers will

document and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1

UASs.

D.The Reasons Why Granting Daan P. Jaspers 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 Daan P. 

Jaspers to safely, efficiently, and economically perform aerial video and photography for

wedding films, real estate, special events, film sets, commercial & Industrial Inspections

and landscape over certain areas of the United States.

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

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

Notably, the benefits of Daan P. Jaspers proposed operation of the DJI Phantom 3 and DJI

Inspire 1 UASs will be realized without implicating any privacy issues.

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

The DJI Phantom 3 and DJI 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 DJI Phantom 3 or DJI 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 and DJI 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 and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 3 and DJI 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 aerial video and still photography flight

operations. By using battery power and electric motors, the DJI Phantom 3 and DJI 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 20-30 gallons per hour of

leaded aviation fuel. The DJI Phantom 3 and DJI 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 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
13

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 and DJI Inspire 1UAs (weighing approximately 2 pounds 11

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 and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 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 and DJI Inspire 1 UASs will allow

United States based companies, like Daan P. Jaspers, 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 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 and DJI Inspire 1 UASs, companies such as Daan P. 

Jaspers, 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 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, Daan P. Jaspers proposed operation of the DJI Phantom 3 and DJI Inspire 1 UASs

will not implicate any privacy issues. Specifically, the DJI Phantom 3 and DJI Inspire 1

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

Jaspers Aerial Operations Manual, Monthly Maintenance Log,
14

and DJI Phantom 3 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 Daan P. Jaspers Seeks Exemption.

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 UAs Meet The

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

Section 333.

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

with the unmanned aircraft and its operation, Daan P. Jaspers operation of the DJI Phantom

3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not require

an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a

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

Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by

section 334 of this Act.

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

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

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

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

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

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

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

that certain unmanned aircraft systems may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe

operation of such aircraft systems in the national airspace system.
15

In seeking this exemption, Daan P. Jaspers submits that the DJI Phantom 3 and DJI

Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 and DJI Inspire 1 UASs; (b)

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

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

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 3 and DJI Inspire 1 UASs do not create a hazard to users of the

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

weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1

UASs.

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 UASs are set

forth by the DJI Phantom 3 and DJI Inspire 1 Specifications and Data Sheet, attached

hereto as Exhibit A and B.

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous

Flight And Navigation Modes Enable The UASs To Remain

Within A Defined Operational Area.

The DJI Phantom 3 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 DJI Phantom 3 and DJI Inspire 1 UASs is provided at pages 12-16 and 45-

50 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit D and E.

iii.The DJI Phantom 3 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 DJI Phantom 3 and DJI Inspire 1 UAs will

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

and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will

assume that the Control Link is lost and the UAs will return to the home position (i.e.,

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

A complete description of the Failsafe Functions of the DJI Inspire 1 at pages 13

through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit B.

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

A complete description of the operation and specifications of the DJI Inspire 1

GCS and flight control software is provided at pages 40 through 47 of the DJI Inspire 1

User Manual. DJI Inspire 1 User Manuals are attached hereto as Exhibits B.

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

Limited To The Line Of Sight Of A Certificated Pilot in Command

With A Safety Observer.
16

Daan P. Jaspers will only utilize certificated pilots who possess a current and valid

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 and

DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.

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

Pursuant To Specific Operating Limitations.

In seeking this exemption, Daan P. Jaspers proposes to commercially operate DJI

Phantom 3 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 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 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
18

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. §

19.1. All operations must be conducted under visual meteorological

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

at the FAA office closest to proposed area of operations. Flights under special

visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. 

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

the Administrator upon request.

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

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

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents.
19

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

emergencies in accordance with the operating documents.

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

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

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

remaining.

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

of Waiver or Authorization (COA) prior to conducting any operations under the

grant of exemption. This COA will also require the operator to request a Notice

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements.

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

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

identification (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 

operating closer to those objects and determined that it does not present

an undue hazard, and;

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

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

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

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

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

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

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

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

hours. Accidents must be reported to the National Transportation Safety Board 

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

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

And (b) Would Not Adversely Affect Safety.

Daan P. Jaspers 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 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

DJI Phantom 3 or DJI 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 Daan P. Jaspers 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 or DJI Inspire 1 

UAS, Daan P. Jaspers submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for 

Daan P. Jaspers 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).

Daan P. Jaspers will not allow any PIC to operate the DJI Phantom 3 or DJI

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

requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI Inspire 1

UAS in a manner consistent with this exemption, including
21

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

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

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

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes).

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

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

equivalent level of safety during Daan P. Jaspers proposed operations. The Administrator

has held that prior documented flight experience that was obtained in compliance with

applicable regulations would ensure safe operations, stating as follows:

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

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

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

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

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

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

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

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

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

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

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

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

experience-building flights the PIC is required to operate the UA with appropriate

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

Exemption No. 11138 at page 15.

Accordingly, Daan P. Jaspers will ensure safe operations by not allowing any

PIC to operate the DJI Phantom 3or DJI 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 DJI Phantom 3 or DJI 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.
22

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

because prior to every flight, Daan P. Jaspers will ensure that the DJI Phantom 3 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 DJI Phantom 3 and DJI Inspire 1 UAs will be

provided to the PIC via GPS equipment and a radio communications telemetry data link,

which downlinks from the UA to the GCS for active monitoring of the flight path and

altitude. This altitude information, combined with Daan P. Jaspers operation of the DJI DJI

Phantom 3 and DJI Inspire 1 UAs within visual line of sight, at or below

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

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

each flight, a zero altitude initiation point is automatically established by the 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 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations;

and (3) the location of the proposed flight operations. Accordingly, Daan P. Jaspers will

ensure that it will safely operate the battery powered DJI Phantom 3 and DJI Inspire 1 UAs

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

duration of 13.5 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 4.5 minutes.

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

3 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, safety will be ensured as the DJI Phantom 3

and DJI Inspire 1 UASs provide audible and visual warnings to the PIC at the GCS when

the UAs experiences low battery voltage, the first warning occurring at approximately

33% remaining battery power, and again at approximately 10% remaining battery power.

At the critically low battery level, the DJI Phantom 3 and DJI Inspire 1 UASs will descend

and land automatically.
23

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, Daan P. Jaspers 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 Daan P. Jaspers 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 Daan P. Jaspers Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1

Instruction Manual).

Furthermore, Daan P. Jaspers will document and maintain all maintenance records for the

DJI Phantom 3 and DJI Inspire 1 UASs.

Since the DJI Phantom 3 and DJI Inspire 1 UASs will be inspected as prescribed by

the operating documents, Daan P. Jaspers will maintain the equivalent level of safety

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI DJI

Inspire 1 User Manual is attached hereto as Exhibit B; a copy of the DJI Phantom 3 and

DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit D.

Likewise, the exemption sought will not adversely affect safety because Daan P. 

Jaspers 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 and DJI Inspire 1 UASs will be performed by trained technicians.

Maintenance will be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Daan P. Jaspers proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 and DJI Inspire 1 UASs, Daan 

P. Jaspers 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,
24

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

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153,

11156, 11157, 11158, 11159, 11160, 11161).

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Daan P. Jaspers requests that the

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

safe operation of the UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

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

NAS or the public, or otherwise pose a threat to national security; and further, provides the

authority for such UAS to operate without airworthiness certification in accordance with any 

requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§21.16, for operation of the DJI Phantom 3 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 FAA

finds necessary to establish a level of safety equivalent to that established in the

regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Leading Edge’s intended operation of the DJI

Phantom 3 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 Daan P. Jaspers Seeks Exemption:
25

Daan P. Jaspers seeks exemption from the requirements of 14 C.F.R Sections

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

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

A Brief Description Of The Nature Of The Exemption Daan P. Jaspers Seeks:

This exemption will permit Daan P. Jaspers to commercially operate an

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

photography over certain areas of the United States.

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

P. Jaspers 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, Daan P. Jaspers 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, Daan P. Jaspers will operate the DJI

Phantom 3 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.

CONCLUSION

As set forth herein, Daan P. Jaspers 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 and DJI Inspire 1 UASs 

commercially, without an airworthiness certificate, for the limited purpose of conducting 

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

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public, 

by allowing Daan P. Jaspers to safely, efficiently, and economically operate the DJI 

Phantom 3 and DJI 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, Daan P. Jaspers respectfully requests

that

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 and

DJI Inspire 1 UASs commercially for the purpose of conducting aerial video and

photography over certain areas of the United States.

Dated: 11/18/2015
26

Respectfully submitted, 

Daan P. Jaspers

Daan P. Jaspers

 1690 Weeping Willow Way

Hollywood, FL 33019

Tel: (305) 788 0291

Appendices:

A – DJI Phantom 3 Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet

C – DJI Inspire 1 Manufacturer’s User Manual

D – Monthly Maintenance Log
27

APPENDIX – A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

Daan P. Jaspers 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)

2.1 DJI Phantom 3

2.1.1 Aircraft

2.1.1.1 Supported Battery – DJI 6000mAh LiPo 2S

2.1.1.2 Weight (Battery & Propellers Included) – 1280 g

2.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: 10cm; Horizontal: 1m

2.1.1.4 Max Ascent Speed – 5m/s

2.1.1.5 Max Descent Speed – 3m/s

2.1.1.6 Max Flight Speed – 16m/s (ATTI mode, no wind)

2.1.2 Gimbal

2.1.2.1 Controllable Range – Pitch: -90 + 30

2.1.2.2 Stabilization – 3-zxis (pitch, roll, yaw)

2.1.3 Camera

2.1.3.1 Sensor – Sony EXMOR

2.1.3.2 Sensor Size – 1/2.3”

2.1.3.3 Effective Pixels – 12.4M

2.1.3.4 Video Recording Mode – 4096x2160p, 3840x2160p, 1920x1080p, 

1280x720p

2.1.4 Remote Controller

2.1.4.1 Operating Frequency – 2.400GHz – 1.483GHz

2.1.4.2 Max Distance – 2000m

2.1.4.3 Receiver Sensitivity (1%PER) -101dBm+/-2dBm

2.1.4.4 Transmitter Power (EIRP) – FCC: 20dBm, CE: 16dBm

2.1.4.5 Working Voltage – 12A@7.4V
30

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Daan P. Jaspers 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)

3.2 DJI Inspire 1

3.2.1 Aircraft

3.2.1.1 Model – T600

3.2.1.2 Weight(Battery Included) – 6lbs 7.5291oz (2935g)

3.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m

3.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s

3.2.1.5 MaxTiltAngle --- 350

3.2.1.6 Max Ascent Speed – 5m/s

3.2.1.7 Max Descent Speed – 4m/s

3.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

3.2.1.9 Max Flight Altitude – 4500m

3.2.1.10 Max Wind Resistance – 10m/s

3.2.1.11 Max Flight Time – Approximately 18 minutes

3.2.1.12 Motor Model – DJI 3510

3.2.1.13 Propeller Model – DJI 1345

3.2.1.14 OperatingTemperatureRange – 140Fto 1040F(---100Cto400C)

3.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”

3.2.2 Gimbal

3.2.2.1 Model – ZENMUSE X3

3.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

3.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA

3.2.2.4 AngularVibrationRange--- ±0.030

3.2.2.5 Mounting – Detachable

3.2.2.6 ControllableRange–Pitch:---900 to+300;Pan:±3200

3.2.2.7 MechanicalRange –Pitch:---1250 to450;Pan:±3300

3.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s

3.2.3 Camera

3.2.3.1 Name – X3

3.2.3.2 Model – FC350

3.2.3.3 Total Pixels – 12.76M

3.2.3.4 Effective Pixels – 12.4M
31

3.2.3.5 Image Max Size – 4000x3000

3.2.3.6 ISO Range – 100---3200

3.2.3.7 FieldofView --- 940

3.2.3.8 CMOS – Sony EXMOR 1/2.3”

3.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25,

3840x2160p24/25/30;FHD:1920x1080p24/25/30/48/50/60;

HD:			 1280x720p24/25/30/48/50/60

3.2.3.10 Operating Temperature Range ---320F --- 1040F (00C --- 400C)

3.2.4Transmitter

3.2.4.1Name – C1

3.2.4.2 Operating Frequency –5.728---5.850GHz; 2.400---2.483GHz

3.2.4.3 Communicating Distance (unobstructed) – 2000m

3.2.4.4 Output Power	– 9W

3.2.4.5 OperatingTemperatureRange---140Fto1040F(---100Cto400C)

3.2.4.6 Battery – 600mAh LiPo 2S
32

APPENDIX – C

DJI INSPIRE 1 MANUFACTURER’S USER MANUAL

User manual can be found at:

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf
33

APPENDIX – D

MONTHLYMAINTENANCE LOG

month: year:

UAS #: Date Issue

Discovered

Date Issue

Addressed Issue Description & Maintenance Conducted

Maintenance Performed By:

Print & Sign

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration Dampening

Other: