UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

U.S. Department of Transportation, Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590

Regulatory Docket No. _________________________________

IN THE MATTER OF THE PETITION FOR EXEMPTION AND RELIEF 

Andrew S. Coccari, Inc.

d.b.a. Long Island Gymnasium Equipment Company

PETITIONS FOR EXEMPTION AND SEEKING RELIEF AND FROM 

THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS CONCERNING 

COMMERCIAL OPERATION OF

SMALL UNMANNED AERIAL SYSTEMS PURSUANT TO 

SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012

PUBLIC LAW 112-95

PETITIONER: Philip J. Coccari, President

Andrew S. Coccari, Inc.

d.b.a. Long Island Gymnasium Equipment Company

1400 Penataquit Avenue

Bay Shore, NY 11706

(631) 666-9513 ・pcoccari@ligym.com

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Table of Contents

Introduction 3 .....................................................................................................

Interests of the Petitioner 3 ...............................................................................

Relief from Specific Applicable Regulations 4 ...................................................

Impact to Safety 7 .............................................................................................

Proposed Operations and Limitations 13 ..........................................................

Public Interest 18 ...............................................................................................

Conclusion 20 ....................................................................................................

Exhibits 21 .........................................................................................................

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Introduction

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 

112-95 FEB. 14, 2012, Section 333 (herein referred to as “FMRA of 2012”), I, Philip J. Coccari, 

owner and operator of small unmanned aerial systems (sUAS), and employed by Andrew 

S. Coccari, Inc. d.b.a. Long Island Gymnasium Equipment Company (herein referred to as 

“LI Gym”), respectfully petition the FAA, on behalf of LI Gym, for an exemption from the 

herein listed Federal Aviation Regulations (FARs) so as to commence commercial 

operations of sUAS in the National Airspace System (NAS). Said operations shall be 

conducted within and under the conditions stipulated herein or as may be established by 

the FAA and/or as required by the FMRA of 2012, Section 333.

LI Gym hereby petitions and requests exemption from the following FARs under Title 14 

CFR:

§§ 21(h), 61.113(a) & (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.105, 91.109, 91.119, 91.121, 

91.151(b), 91.215, 91.405(a), 91.407(a)(1), 91.409(a)(1)(a)(2), 91.417(a)(1)

Interests of the Petitioner

LI Gym is a small business that was established back in 1980. LI Gym sells, installs, and 

services professional grade scoreboards, message boards, sporting equipment and sports 

apparatuses. Clientele ranges from private entities, schools and colleges, to owners of large 

sporting arenas.

It is the intent of LI Gym to utilize sUAS in order to facilitate the following activities that 

are in furtherance of the business, for hire, and for direct compensation:

1) Aerial Photography and Videography

Create and record high-resolution digital video and still imagery to be used in 

demonstrating, marketing and selling services or products.

2) Aerial Surveying

Create and record high-resolution digital video and still imagery to be used to survey 

geographical locations of new and existing installation sites.

3) Aerial Inspections

Create and record high-resolution digital video and still imagery to be used to aid in the 

inspection of existing scoreboards, message boards, sporting equipment and 

apparatuses.

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Relief from Specific Applicable Regulations

Pursuant to 14 CFR §11.61(b) and the FMRA of 2012, Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, LI Gym hereby petitions the Administrator for the 

engagement of commercial operations utilizing the DJI Inspire 1 and DJI Phantom 3 

Professional sUAS in the National Airspace System (NAS), and seeks relief and or 

exemption from the following FARs under Title 14 CFR:

§21, Subpart H Airworthiness Certificates

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

unmanned aircraft (UA) and its operation, the DJI Inspire 1 and DJI Phantom 3 Professional 

sUAS meet the conditions of FMRA of 2012, Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 CFR Part 21, Subpart H.

§61.113(a)(b) Private pilot privileges and limitations: Pilot in command

Exemption from certain requirements of §61.113(a) and (b), entitled, “Private pilot 

privileges and limitations: Pilot in command”, is requested by LI Gym, 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 

a minimum of 10 flight-hours of the designated UAVs, along the ability to safely operate 

and fly the DJI Inspire 1 and/or, the DJI Phantom 3 Professional sUAS in a manner 

consistent with this exemption; including but not limited to standard takeoff and landing 

procedures, flight attitudes consistent with the safe envelope of flight for the given UA, 

evasive maneuvers, emergency maneuvers and procedures as well as the ability to 

maintain safe distances from people, property, buildings, structures, and restricted 

airspace.

§91.7(a) Civil aircraft airworthiness

LI Gym seeks exemption from the requirement of §91.7(a), entitled, “Civil aircraft 

airworthiness”, because the DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not 

require an airworthiness certificate in accordance with Part 21, Subpart H. Furthermore, LI 

Gym will ensure, to the best of their knowledge and ability, that said UA are in airworthy 

condition and capable of safe flight by implementing a designated checklist. A preflight 

checklist shall be utilized in order to determine a “go” or “no-go” decision prior to each 

and every flight. The items on this list are based upon the operating limitations for that 

version of UA as specified in the manufacturer manual and operating software. sUAS 

checklist for the the DJI Inspire 1 and DJI Phantom 3 Professional sUAS is annexed hereto 

as Exhibit A and Exhibit B respectively.

rev A1.1 Page 4 of 23
§91.9(b)(2) Civil Aircraft Flight Manual, Marking, and Placard 

Requirements

LI Gym seeks exemption from the requirement of §91.9(b)(2), entitled, “Civil aircraft flight 

manual, marking, and placard requirements”, because the the DJI Inspire 1 and DJI 

Phantom 3 Professional sUAS do not possess current approved Airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination 

thereof.

§91.105 Flight Crew Members at Stations

LI Gym seeks exemption from the requirement of §91.105, entitled, “Flight crew members 

at stations”, because the the DJI Inspire 1 and DJI Phantom 3 Professional sUAS are by 

definition unmanned and therefore do not possess crew members.

§91.103(b) Preflight Action

LI Gym seeks exemption from the requirement of §91.103(b), entitled, “Preflight action” 

“For any flight, runway lengths at airports of intended use, and the following takeoff and 

landing distance information:”, because the DJI Inspire 1 and DJI Phantom 3 Professional 

sUAS will, at no time, be operating from an airport and do not require the use of a runway. 

Therefore, this regulation simply does not apply to the operation of the DJI Inspire 1 and 

DJI Phantom 3 Professional sUAS.

§91.109 Flight Instruction; Simulated Instrument Flight and Certain Flight 

Tests.

LI Gym seeks exemption from the requirement of §91.109, entitled, “ Flight instruction; 

Simulated instrument flight and certain flight tests”, in its entirety, because the the DJI 

Inspire 1 and DJI Phantom 3 Professional sUAS are by definition unmanned and possess a 

Ground Control Station (GCS) consisting of two gimbal sticks in order to maneuver the 

UAV. Furthermore, there will no flight instruction or flight tests administered under this 

exemption.

§91.119 Minimum Safe Altitudes

LI Gym seeks exemption from the requirement of §91.119, entitled “Minimum Safe 

Altitudes”. As contained in AC91.57A, §6 item (e), entitled, “Model Aircraft Operations”, 

as follows: “Model aircraft operators should follow best practices including limiting 

operations to 400 feet above ground level (AGL).” Furthermore, under the provisions set 

forth by this exemption, operations of the herein specified UA’s shall be limited to 200 feet 

AGL or below. The basis of this exemption is due to the nature of the intended sUAS tasks 

specified herein, flights over sparsely populated areas could occur on a regular basis.

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§91.121 Altimeter Settings

LI Gym seeks exemption from the requirement of §91.121, entitled “Altimeter Settings” 

because the DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not possess a traditional 

barometric altimeter. However, altitude information of said UA’s is provided to the pilot in 

command (PIC) via the Global Positioning System (GPS) equipment and radio telemetry 

data link of the respective sUAS. Realtime telemetry conveys altitude information from the 

UA to the ground control station (GCS) for active monitoring during the flight. This 

altitude information, together with visual line of sight (VLOS) by the PIC and/or the 

spotter, at or below 500 feet AGL, will ensure a level of safety equivalent to §91.121.

§91.151(b) Fuel requirements for flight in VFR conditions

LI Gym seeks exemption from the requirement of §91.151(b), entitled “Fuel requirements 

for flight in VFR conditions”. Safety will not be affected by operation of the DJI Inspire 1 

and DJI Phantom 3 UA while maintaining visual line of sight (VLOS), during daylight 

hours in visual meteorological conditions (VMC) under visual flight rules (VFR), as there 

exists, by design, enough battery power under a no-wind condition, for a total flight 

duration of approximately 18 and 20 minutes respectively, to the first intended GPS 

waypoint and then the first point of intended landing, and assuming normal cruising 

speed, to fly thereafter for at least 4 minutes.

§91.215 ATC Transponder and Altitude Reporting Equipment and Use

LI Gym seeks exemption from the requirement of §91.215, entitled “ATC transponder and 

altitude reporting equipment and use”. Due to the small size, limited lifting capacity, and 

limited power reserves, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS cannot be 

configured with, and operate, a traditional transponder and automatic altitude reporting 

equipment as specified in §91.215 (a) and (b).

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

Accordingly, upon exemption from Part 21, Subpart H, these sections stated above stipulate 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Therefore, the petitioner hereby requests exemption from these sections as well. LI Gym 

submits that the requested exemption is proper since an equivalent level of safety will be 

ensured due to the fact that LI Gym will only use experienced technicians to perform 

maintenance, alterations, and upgrades or updates to either hardware or software on all 

sUAS components in accordance with the manufacturer’s guidelines. Furthermore, LI 

Gym will only procure DJI approved manufactured parts for all maintenance, repairs, 

alterations, and/or upgrades or updates to the herein stated UA. Records of any and all 

maintenance, alterations, and upgrades or updates to either hardware or software on all 

sUAS components shall be maintained by LI Gym in a separate electronic, computer 

readable, maintenance log. An example is annexed hereto as Exhibit C.

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Impact to Safety

The following states the reasons why granting this exemption would not adversely affect 

safety. In addition, it is further stated how LI Gym believes this exemption would provide 

a level of safety at least equal to that provided by the existing rule from which LI Gym 

seeks exemption.

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

DJI Inspire 1 and DJI Phantom 3 Professional sUAS, LI Gym’s operation of these sUAS 

meet the conditions of FMRA Section 333, and will not require an airworthiness certificate 

in accordance with 14 CFR Part 21, Subpart H.

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

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. Specifically, FMRA 

Section 333 states, in part, the following:

(a) In General. — Notwithstanding any other requirement of this subtitle, and not later than 180 

days after the date of enactment of this Act, the Secretary of Transportation shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the plan and rule making required by section 332 of this Act or the guidance 

required by section 334 of this Act.

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

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

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

operational capability, proximity to airports and populated areas, and operation within 

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

public or pose a threat to national security; and 

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

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

unmanned aircraft systems identified under paragraph (1). 

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

certain unmanned aircraft systems may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft systems in the 

national airspace system.

In seeking this exemption, LI Gym submits that the DJI Inspire 1 and DJI Phantom 3 

Professional sUAS can operate safely in the NAS pursuant to FMRA of 2012, Section 333, as 

demonstrated by: (a) the safe characteristics of said UAVs; (b) the pilot certification 

requirement; and (c) the proposed operations and limitations stated herein.

rev A1.1 Page 7 of 23
DJI Inspire 1 and DJI Phantom 3 Professional sUAS Safe Characteristics

The DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not create a hazard to users of 

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

weight, speed, and operational capabilities.

The DJI Inspire 1 and DJI Phantom 3 Professional sUAS may be operated in either manual 

mode or GPS flight mode. When GPS flight mode is enabled the UAV can be programmed 

to remain within a defined operational area that is defined by waypoints in the operating 

software and thus limiting it’s operation to a prescribed geographic location that has been 

properly vetted for safety prior to flight.

The DJI Inspire 1 and DJI Phantom 3 Professional sUAS is designed to automatically return 

to the designated point of departure or “home point” or begin a hovering maneuver in the 

event of a loss of signal to the ground control station. When the signal to the ground 

control station is lost for a period exceeding 3 seconds, the UAV will begin a hovering 

maneuver at it’s given altitude. If the UAV does not reacquire a signal back to the ground 

control station, it will enter a failsafe condition whereby it will commence flight on it’s own 

and return to the designated home point at it’s present altitude. Once reaching the home 

point it will hover for 15 seconds, then begin an automated descent and commence a safe 

landing. Immediately following this controlled landing, the UAV will shutdown it’s 

motors and propellers.

The technical specifications of the DJI Inspire 1 and DJI Phantom 3 Professional sUAS are 

conveyed in the manufacturer’s user manual and are duplicated herein for reference. They 

include the operating radio frequencies that the UAS utilizes as well as maximum velocity 

limitations. For example, the documented maximum lateral velocity of the DJI Phantom 3 

Professional is 16 m/s or 35.79 mph in a no-wind atmosphere; the documented maximum 

lateral velocity of the DJI Inspire 1 is 16 m/s or 49.21 mph in a no-wind atmosphere.

rev A1.1 Page 8 of 23
TECHNICAL SPECIFICATIONS OF THE DJI PHANTOM 3 PROFESSIONAL SUAS

AIRCRAFT

Weight (including battery and propellers) 1280g ...........

Diagonal size (including propellers) 590mm ..................

Max Ascent Speed 5m/s ....................................................

Max Descent Speed 3m/s .................................................

Hover Accuracy

• Vertical: +/- 0.1 m (when VPS active) or +/- 0.5 m

• Horizontal: +/- 1.5 m

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

Max Service Ceiling (MSL)

6000 m (Default altitude limit: 120 m above 

takeoff point)

Operating Temperature ................................0°C to 40°C

GPS MODE

Constellation ..........................................GPS/GLONASS

GIMBAL

Controllable Range .............................Pitch -90° to +30°

Stabilization................................3-axis (pitch, roll, yaw)

REMOTE CONTROLLER

Operating Frequency

2.400GHz - 2.483GHz

Max Distance

Up to 5 km or 3.1 miles (unobstructed, free of 

interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of 

interference) when CE compliant

Video Output Port USB .....................................................

Operating Temperature....................................0°C- 40°C

Battery................................................6000 mAh LiPo 2S

Mobile Device Holder ......................For tablet or phone

Receiver Sensitivity (1%PER) .............-101dBm ±2dBm

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

Working Voltage ..........................................1.2 A @7.4 V

INTELLIGENT FLIGHT BATTERY

Capacity / Voltage / Battery Type / Energy / Weight

4480 mAh, 15.2 V, 4S LiPo, 68 Wh, 365 g

Max Flight Time Approx. 23 mins ....................................

Operating Temperature .............................-10°C to 40°C

Max Charging Power ..............................................100W

CAMERA

Sensor....Sony EXMOR 1/2.3” Effective pixels: 12.4 M 

(total pixels: 12.76 M)

Lens.FOV 94° 20 mm (35 mm format equivalent) f/2.8, 

focus at ∞

ISO Range................100-3200 (video) 100-1600 (photo)

Shutter Speed................................................8s -1/8000s

Image Max Size.............................................4000 x 3000

Still Photography Modes

• Single Shot

• Burst Shooting: 3/5/7 shots

• Auto Exposure Bracketing (AEB): 3/5

• Bracketed Frames at 0.7EV Bias

• Time-lapse

VIDEO RECORDING MODES

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

• FHD: 1920x1080p 24/25/30/48/50/60

• HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types................................Micro SD

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

required

Max Bitrate of Video Storage ............................60 Mbps

Supported File Formats

• FAT32/exFAT

• Photo: JPEG, DNG

• Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature ................................0°C to 40°C

VISION POSITIONING

Max Velocity............Less than 8 m/s (when 2 m above 

ground)

Altitude Range / Operating Range ..........50 cm-300 cm

Operating Environment

Surface with clear pattern and adequate lighting 

(Lux > 15)

BATTERY CHARGER

Voltage ....................................................................17.4 V

Rated Power 100W ............................................................

rev A1.1 Page 9 of 23
APP/LIVE VIEW

Mobile App............................................................DJI GO

EIRP ......................................................................100mW

Power Spectral Density ...............................6.9mW/MHz

Live View Working Frequency

2.4GHz ISM

Live View Quality

720P @ 30fps (depending on conditions and mobile device)

Latency

220ms (depending on conditions and mobile device)

Required Operating Systems

• iOS 8.0 or later

• Android 4.1.2 or later

RECOMMENDED DEVICES

iOS

iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, 

iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular.

This app is optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

Android

Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google Nexus 9, Google 

Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini, Sony Xperia Z3, MI 3, MI PAD, Smartisan T1.

*Support for additional Android devices available as testing and development continues.

DJI PHANTOM 3 PROFESSIONAL IMAGE REFERENCE

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TECHNICAL SPECIFICATIONS OF THE DJI INSPIRE 1 SUAS

AIRCRAFT

Model.........................................................................T600

Weight (Battery Included)......................................2935g

Hovering Accuracy (GPS mode)

Vertical: 0.5 m, Horizontal: 2.5 m

Max Angular Velocity Pitch: 300°/s, ............ Yaw: 150°/s

Max Tilt Angle..............................................................35°

Max Ascent Speed...................................................5 m/s

Max Descent Speed ................................................4 m/s

Max Speed ........................22 m/s (ATTI mode, no wind)

Max Service Ceiling Above Sea Level

4500 m (Default altitude limit: 120 m above 

takeoff point)

Max Wind Speed Resistance................................10 m/s

Max Flight Time Approx. .................................... 18 mins

Motor Model.....................................................DJI 3510H

Propeller Model................................................DJI 1345T

Indoor Hovering................................Enabled by default

Operating Temperature Range....................-10° to 40°C

Diagonal Distance ...................................559 to 581 mm

Dimensions..........................................438x451x301 mm

Power Spectral Density 9.06mW/MHz .............................

VISION POSITIONING SYSTEM

Velocity Range...........Below 8 m/s (2 m above ground)

Altitude Range...................................................5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range ...............................................0-250 cm

GIMBAL

Model..........................................................ZENMUSE X3

Operating Current Station: 750 mA, ..... Motion: 900 mA

Angular Vibration Range.......................................±0.03°

Mounting ........................................................Detachable

Controllable Range Pitch: -90° to +30°, ........ Pan: ±320°

Mechanical Range Pitch: -125° to +45°, ....... Pan: ±330°

Max Controllable Speed Pitch: 120°/s, ........ Pan: 180°/s

CAMERA

Name .............................................................................X3

Model ......................................................................FC350

Total Pixels............................................................12.76M

Effective Pixels.......................................................12.4M

Image Max Size...............................................4000x3000

ISO Range 100-3200 (video), ............... 100-1600 (photo)

Electronic Shutter Speed 8s .......................... ҆ 1/8000s

FOV (Field of View) .....................................................94°

CMOS...............................................Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

STILL PHOTOGRAPHY MODES

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed 

frames at 0.7EV Bias

Time-lapse

VIDEO RECORDING MODES

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

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

Max Bitrate of Video Storage ............................60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

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

Supported SD Card Types................................Micro SD

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

required.

Operating Temperature Range......................0° to 40° C

rev A1.1 Page 11 of 23
BATTERY (STANDARD)

Name ........................................Intelligent Flight Battery

Model ........................................................................TB47

Capacity ...........................................................4500 mAh

Voltage .....................................................................22.2V

Battery Type.....................LiPo 6S High voltage battery

Energy..................................................................99.9 Wh

Net Weight.................................................................570g

Operating Temperature Range....................-10° to 40°C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range ........................0° to 40°C

Max Charging Power ..............................................180W

BATTERY (OPTIONAL)

Name ........................................Intelligent Flight Battery

Model ........................................................................TB48

Capacity ...........................................................5700 mAh

Voltage .....................................................................22.8V

Battery Type.........................................................LiPo 6S

Energy..............................................................129.96 Wh

Net Weight.................................................................670g

Operating Temperature Range....................-10° to 40°C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range ........................0° to 40°C

Max Charging Power 180W ..............................................

CHARGER

Model ............................................................A14-100P1A

Voltage .....................................................................26.3V

Rated Power............................................................100W

REMOTE CONTROLLER

Name .............................................................................C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Maximum Transmitting Distance

Up to 5 km or 3.1 miles (unobstructed, free of 

interference) when FCC compliant

Up to 3.5 km or 2.1 miles (unobstructed, free of 

interference) when CE compliant

EIRP........10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port .................................USB, mini-HDMI

Power Supply ..........................................Built-in battery

Charging........................................................DJI charger

Dual User Capability ..........Host-and-Slave connection

Mobile Device Holder ............................Tablet or Phone

Max Mobile Device Width ....................................170mm

Output Power .............................................................9 W

Operating Temperature Range....................-10° to 40°C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range..............................0-40°C

Battery................................................6000 mAh LiPo 2S

DJI GO APP

Mobile Device System RequirementsiOS 8.0 or later, Android 4.1.2 or later

Supported Mobile Devices

iOS

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, iPad mini 2, iPad mini 2 

Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is 

optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus.

Android

* Compatible with Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, Samsung NOTE3, Google 

Nexus 9, Google Nexus 7 II, Ascend Mate7, Huawei P8 Max, Nubia Z7 mini,Sony Xperia Z3, MI 3, MI PAD, 

Smartisan T1.

*Support for additional Android devices available as testing and development continues.

rev A1.1 Page 12 of 23
DJI INSPIRE 1 IMAGE REFERENCE

Proposed Operations and Limitations

In seeking this exemption, LI Gym proposes to operate the DJI Inspire 1 and DJI Phantom 3 

Professional sUAS for the commercial purpose of conducting aerial video and 

photography, aerial surveying, and aerial inspections of equipment, over certain areas of 

United States, pursuant to the following specific operating limitations.

1. sUAS that are owned and operated by LI Gym shall be flown only by certificated pilots 

hired directly by LI Gym, possessing at least a private pilot certificate and valid airman 

medical certificate; and are competent in piloting and operating sUAS.

2. LI Gym shall not permit any pilot in command (PIC) to operate sUAS unless the PIC 

meets the operator’s qualification criteria and demonstrates the ability to safely operate 

the sUAS in a manner consistent with operations stated under this exemption, 

including but not limited to, evasive and emergency maneuvers. PIC qualification 

flight hours must be logged in a manner consistent with 14 CFR §61.51(b). PIC training 

flights shall be permitted under the terms of the exemption with the condition that 

training operations be only conducted during dedicated training sessions.

3. All flight operations shall be conducted in the presence of an additional individual who 

will act as an safety observer or “spotter”. The spotter will be responsible for observing 

flight operations as well as the operating environment and will aid in ensuring safe 

operations. The spotter may also be utilized to satisfy the visual line-of-sight (VLOS) 

requirement as per Section 333(b)(1), as long as the PIC maintains VLOS capability. The 

spotter and the PIC must be able to verbally communicate at all times.

rev A1.1 Page 13 of 23
4. All flights will be conducted during daylight hours only and under visual 

meteorological conditions (VMC). sUAS operations will not be conducted during 

night, as defined in 14 CFR §1.1. If night operations is required, a special request shall 

be made at the FAA Standards District Office (FSDO) closest to proposed area of 

operations.

5. The UAV shall remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

6. The UAV 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.

7. The UAV shall only be flown while maintaining VLOS at all times as per Section 333(b)

(1). At no time shall the pilot-in-command (PIC) rely solely on electronic visual 

telemetry as to constitute the use of “first person view” (FPV) during any flight 

operations. 

8. The location where sUAS will be flown shall be vetted for safety prior to the 

commencement of any UAV flight. sUAS safety considerations include, but are not 

limited to, weather conditions, airspace, obstructions, people, property, UAV 

limitations, and loss-link of radio signal to ground control station equipment. 

9. In accordance with 14 CFR §91.7(b), the appropriate sUAS checklist shall be utilized in 

order to convey the necessary procedures for conducting a preflight safety risk 

assessment in order to determine that the sUAS is in a condition for safe flight. The 

result of the tasks outlined on the checklist shall be used to determine a “go” or “no-go” 

decision for each and every flight. sUAS checklists for the DJI Inspire 1 and DJI 

Phantom 3 Professional is annexed hereto as Exhibit A and Exhibit B respectively.

10. Prior to the commencement of each flight operation, the designated PIC shall conduct a 

preflight inspection utilizing the appropriate checklist for the sUAS. The checklist shall 

insure that each component that comprises the sUAS meets the criteria for safe 

operation as set forth by the manufacturers operating manual and for the conditions in 

which the UAV is to be flown. If the preflight inspection reveals a condition that could 

affect the safe operation of the sUAS, the UAV is prohibited from flying until the 

necessary remedy can be affected to restore safe operation to the system. If 

maintenance is required in order to supply a remedy for an unsafe condition, then said 

maintenance must be logged appropriately.

11. The UAV shall be programmed to return it’s designated point of takeoff within the 

prescribed operating flight area and commence a safe landing should it loses 

communication with the ground control station. If during this failsafe condition, the 

PIC determines that communication to the ground control station has been restored, the 

rev A1.1 Page 14 of 23
PIC shall take command of the UAV and commence a safe landing as soon as 

practicable.

12. The DJI sUAS software provides a realtime battery capacity indicator, expressed in 

units of time, that informs the PIC how much power is left in the battery in order to 

supply sufficient power for the UA to sustain flight. The PIC will be able to quickly 

determine if enroute operations are to be terminated and a safe landing should 

commence. The PIC will make every effort to fly the UA back to the point at which the 

flight commenced and perform a safe landing. In addition, the software implements a 

“LOW” and "CRITICAL" battery level warning indication. If inconsistent drain on the 

battery occurs due to flight conditions or maneuvers, the UA shall be programmed to 

intervene normal flight operations and initiate an automated direct flight path back to 

it’s point of origin and commence a landing. The PIC will monitor battery capacity 

during all phases of flight in order to avoid this condition.

13. Commencement of sUAS operations is prohibited unless (considering forecasted 

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

intended landing point and land the UAV with at least 20% battery power remaining.

14. All UAVs operated in accordance with this exemption shall be identified by serial 

number, registered in accordance with 14 CFR §47, and have the appropriate 

identification (N-Number) markings in accordance with 14 CFR §45 (c). Markings shall 

be as large as practicable.

15. All sUAS operations shall be conducted on and over private or controlled-access 

property with expressed permission from the land owner/controller or authorized 

representative and shall be obtained prior to the commencement of any and all stated 

operations.

16. When able, locations of operation shall be subdivided in to specific areas in order to 

facilitate safe operation. These areas are to be identified as a sUAS Preflight Area, sUAS 

Operations Area, sUAS Crew Support Area.

1. A sUAS Preflight Area will be identified and properly delineated from all other 

areas. This area shall contain all sUAS equipment and will remain under positive 

control and supervision by authorized personnel at all times, and have restricted 

access to authorized personnel only.

2. A UAV Operations Area will be identified prior to the commencement of any flight. 

It shall include a take-off spot, a given flight path, and a landing spot. All flight 

paths of the designated flight area shall remain within visual line-of-sight (VLOS); 

the take-off and landing spot might not be colocated. The pilot-in-command (PIC) 

shall also identify emergency or abort procedures prior to every flight, along with 

an associated emergency landing spot should the flight need to be aborted or a 

failsafe condition occur during the flight. These procedures shall be conveyed to the 

designated spotter prior to every flight. All flights will be verbally announced by 

rev A1.1 Page 15 of 23
the PIC prior to commencement and shall only take place in the identified sUAS 

Operations Area.

3. A sUAS Crew Support Area will be identified and delineated from every other 

defined area of operation. This area shall contain all elements necessary in 

supporting the crew associated with sUAS operations. At no time shall the Crew 

Support Area be colocated with the sUAS Preflight Area or sUAS Operations Area. 

The sanctity of each area shall be preserved in order to maintain safety of the 

equipment and support crew.

17. Under no circumstance shall flights commence in airspace that prohibits sUAS 

operations. Every flight will be in accordance with current FARs, advisory circulars, 

and NOTAMS, and in conjunction with local, state and federal law.

18. The documents required fewer than 14 CFR §91.9(b)(2) and §91.203 must be available to 

the PIC at the Ground Control Station of the UAS any time the UAV is in operation. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

19. All pertinent operating documents as well as the grant of exemption must be accessible 

during any sUAS 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 shall take precedence. Otherwise, the 

operator shall follow the procedures outlined in the specified operating documents. 

The operator may update or revise the operating documents as necessary in order to 

maintain safe operations. 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) shall be contacted if questions arise regarding updates or 

revisions to the operating documents to the extent that they could pertain to the 

exemption under which they were granted.

20. Any sUAS that has undergone maintenance or alteration that could affect the operation 

or flight characteristics of the UAV or one of it’s components, must undergo a 

functional test flight. The test flight may be limited to the extent of the operation or 

flight characteristics related to the maintenance or alteration that was made to the 

sUAS. An entry for each test flight shall be made in the aircraft maintenance log.

21. The owner shall adhere to the sUAS manufacturer’s UAV component maintenance, 

replacement, inspection, overhaul, and life-limited requirements if so published by said 

manufacturer. Any and all maintenance or alterations to the sUAS must be logged in 

rev A1.1 Page 16 of 23
the appropriate maintenance log and be accompanied by the signature of the 

authorized person returning the sUAS to service.

22. Each sUAS operated under this exemption shall comply with all manufacturer safety 

bulletins if so published by said manufacturer.

23. 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 at http://www.ntsb.gov.

rev A1.1 Page 17 of 23
Public Interest

Granting this exemption will further the public interest by allowing LI Gym to safely, 

efficiently, and economically perform aerial video and photography, aerial surveying, and 

aerial inspections over certain areas of the United States.

In addition, the use of the DJI Inspire 1 and DJI Phantom 3 Professional sUAS will decrease 

congestion of the National Airspace (NAS), reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of LI Gym’s proposed operation of said 

sUAS will be realized without implicating any privacy issues.

The Public Will Benefit From Decreased Congestion Of The NAS

The DJI Inspire 1 and DJI Phantom 3 Professional sUAS are battery-powered and provide a 

safe, efficient, and economical alternative to manned aircraft that are traditionally utilized 

in obtaining aerial imagery. The DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not 

require an airport for takeoff or landing. By reducing the amount of manned aircraft in the 

NAS needed to perform low-altitude aerial imagery by way of this exemption, thus 

allowing the use of said sUAS, a reduction in noise pollution and carbon-based emissions 

pollution would occur. And most importantly, the safety of people and property in the air 

and on the ground would increase dramatically.

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

around airports caused by arriving and departing aircraft will be reduced. And, this 

reduction of manned aircraft will result in fewer aircraft that must be handled by air traffic 

control during the ground, departure, enroute, arrival, and landing phases of flight 

operations in the NAS.

The Public Will Benefit From The Safety And Efficiency Of sUAS

Conducting aerial imagery utilizing the DJI Inspire 1 and DJI Phantom 3 Professional sUAS 

instead of manned aircraft, will greatly benefit the public by drastically reducing the levels 

of air and noise pollution as compared to that generated during traditional low-altitude 

aerial imagery flight operations. Moreover, by using battery-powered electric motors, the 

DJI Inspire 1 and DJI Phantom 3 Professional sUAS produce zero air pollution. This is in 

stark contrast to the pollution generated by the approximately 20-30 gallons per hour of 

leaded aviation fuel that is burned by traditional cabin class, 6-cylinder, internal 

combustion aircraft engines during low-altitude aerial video and photography operations. 

In addition, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS also greatly reduce 

noise pollution due to the fact that they utilize relatively quiet, battery-powered electric 

motors rather than an internal combustion engine.

By using the DJI Inspire 1 and DJI Phantom 3 Professional sUAS for the acquisition of aerial 

imagery, the risk to life and property in the air and on the ground will be substantially 

reduced or in some cases, completely eliminated when compared to traditional manned 

rev A1.1 Page 18 of 23
aircraft flight operations. Risk to life is immediately eliminated due to the fact that sUAS, 

by definition, do not possess a flight crew onboard.

In addition, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS weigh 6.47 pounds and 

2.82 pounds respectively and therefore possess less mass than traditional manned aircraft 

weighing approximately 6,000 pounds. Since the amount of force produced by an object is 

it’s mass multiplied by it’s acceleration, the DJI Inspire 1 and DJI Phantom 3 Professional 

sUAS, by the laws of physics, possess less force and therefore less potential for physical 

damage to life and property on the ground and in the air.

Performing Aerial Video and Photography Operations Utilizing sUAS Will 

Benefit The Economy

In addition to being safe and efficient, the DJI Inspire 1 and DJI Phantom 3 Professional 

sUAS are also an economical alternative to using manned aircraft to conduct aerial imagery 

flights operations. It follows that companies based in the United States, like LI Gym, which 

are allowed to utilized sUAS, will remain competitive and contribute to the overall growth 

of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (EPA) regulatory actions that are phasing out leaded 

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

technologies in order to remain competitive in a global market. Operating the batterypowered DJI Inspire 1 and DJI Phantom 3 Professional sUAS is one such technology that 

not only allows companies greater operational flexibility compared to traditional manned 

aircraft, but provides this flexibility without the high operational costs associated with 

traditional manned aircraft.

By operating the DJI Inspire 1 and DJI Phantom 3 Professional sUAS, LI Gym can remain 

competitive and profitable, and therefore provide greater job stability to employees and 

contractors - which will ultimately contribute to the overall growth of the U.S. economy.

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

provides a stable workforce that increases consumer spending, improves local, state, and 

federal tax revenues, and allows companies to invest in research and development in order 

to remain competitive both in the United States and abroad.

There Are No Privacy Issues

Similar to traditional manned aircraft flight operations that have been implemented for 

decades to acquire aerial imagery, LI Gym’s proposed operation of the DJI Inspire 1 and DJI 

Phantom 3 Professional sUAS will not impose any privacy issues.

No sUAS flight operations will commence without the expressed permission of the 

property owner. Furthermore, all sUAS flight operations will be in compliance with local, 

state and federal laws when applicable and in accordance with the terms and stipulations 

set forth in this exemption and the FAA.

rev A1.1 Page 19 of 23
Conclusion

As set forth herein, LI Gym respectfully seeks an exemption pursuant to 14 CFR §11.61 and 

Section 333 of the FMRA of 2012, which will permit safe operation of the DJI Inspire 1 and 

DJI Phantom 3 Professional sUAS commercially, without an airworthiness certificate, for 

the limited purpose of conducting aerial video and photography, aerial surveying, and 

aerial inspections of equipment over certain areas of the United States. By granting this 

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

of 2012, while also advancing the interests of the public by allowing LI Gym to safely, 

efficiently, and economically operate the DJI Inspire 1 and DJI Phantom 3 Professional 

sUAS commercially within the NAS.

Respectfully,

submitted this 30th day of December 2015

Philip J. Coccari, President

Andrew S. Coccari, Inc.

d.b.a. Long Island Gymnasium Equipment Company

1400 Penataquit Avenue

Bay Shore, NY 11706

(631) 666-9513 ・pcoccari@ligym.com

rev A1.1 Page 20 of 23
Exhibits

Exhibit A - DJI Inspire 1 sUAS Checklist

rev A1.1 Page 21 of 23

Checklist DJI - Inspire 1

PreFlight

➡ Landing Gear Extended

➡ Install Props - Check Position/Secured

➡ Install Gimbal/Camera - Secured

➡ Motors - Secured

➡ VPS - Clear

➡ Gimbal Dampeners - Secured

➡ SD Card - Installed

➡ Lens Cover - Remove

➡ Gimbal Lock - Remove

➡ Battery - Installed/Charged

➡ Tablet Computer - Installed/Secured

➡ USB - Connected

➡ Tablet On - Charged

➡ TX On - Charged

➡ TX Antennas - Erect/Parallel

➡ DJI App - Invoked

➡ Neck Strap - On/Attached

Before Take-off

➡ Power - On

➡ Battery -Charged

➡ Camera - Live

➡ State - Validate

➡ Compass - Calibrated

➡ Camera Settings -Verified

➡ Satellites - Acquired

➡ Home Point - Recorded

Take-off

๏ Environment - Cleared & 

Secured

๏ Obstructions - None

๏ Flight Plan - Reviewed

CLEARED FOR DEPARTURE

Before Landing

๏ Environment - Secured

๏ Obstructions - None

๏ Landing Gear - Extended

After Landing

➡ PH3 Power - Off

➡ TX - Off

➡ DJI APP - Closed

➡ Tablet - Off
Exhibit B - DJI Phantom 3 Professional sUAS Checklist

rev A1.1 Page 22 of 23

Checklist DJI - Phantom 3 Professional

PreFlight

➡ Install Props - Check Position/Secured

➡ Gimbal/Camera - Secured

➡ Motors - Secured

➡ VPS - Clear

➡ Gimbal Dampeners - Secured

➡ SD Card - Installed

➡ Lens Cover - Remove

➡ Gimbal Lock - Remove

➡ Battery - Installed/Charged

➡ Tablet Computer - Installed/Secured

➡ USB - Connected

➡ Tablet On - Charged

➡ TX On - Charged

➡ TX Antennas - Erect/Parallel

➡ DJI App - Invoked

➡ Neck Strap - On/Attached

Before Take-off

➡ Power - On

➡ Battery -Charged

➡ Camera - Live

➡ State - Validate

➡ Compass - Calibrated

➡ Camera Settings -Verified

➡ Satellites - Acquired

➡ Home Point - Recorded

Take-off

๏ Environment - Cleared & 

Secured

๏ Obstructions - None

๏ Flight Plan - Reviewed

CLEARED FOR DEPARTURE

Before Landing

๏ Environment - Secured

๏ Obstructions - None

๏ Landing Gear - Extended

After Landing

➡ PH3 Power - Off

➡ TX - Off

➡ DJI APP - Closed

➡ Tablet - Off
Exhibit C - Example sUAS Maintenance Log

rev A1.1 Page 23 of 23

DJI Phantom 3 Professional Service Log [N-Number]

Service and Maintenance Record

Date Total Time Maintenance Performed