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July 30, 2015 

Attn: 

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 1200 New 

Jersey Ave, SE Washington, DC 20590 

RE: JOHN L. JOHNSTON OWNER, GARRAVA, LLC REQUEST AN EXEMPTION FROM THE 

REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

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

91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 3 Professional (S/N 

P76DCF18010027 N107BB) UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 

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

John L. Johnston President Garrava, LLC 3652 Dunigan Court Catharpin, VA 20143 

703.472.1711 email; trade@thejumpworks.com
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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 GARRAVA, LLC SEEKS EXEMPTION ...... 6

THE EXTENT OF RELIEF GARRAVA, LLC SEEKS AND THE REASON

GARRAVA, LLC SEEKS THE RELIEF...................................................................................................... 10 

THE REASONS WHY GRANTING GARRAVA, LLC’S REQUEST WOULD BE 

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

THE REASONS WHY GRANTING THE EXEMPTION TO GARRAVA, LLC 

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 GARRAVA, LLC’S REQUEST25 CONCLUSIONS ................................................................ 25 

APPENDICES ............................................................................................................................................... 26
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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) 

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 
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SUMMARY 

JOHN L. JOHNSTON as GARRAVA, LLC hereafter referred to as GARRAVA, LLC seeks exemption 

from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System (DJI 

Phantom 3) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This 

exemption will permit The GARRAVA, LLC to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of construction sites, residential and 

commercial real estate, civil landscapes and approved events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

JOHN L. JOHNSTON sole member of GARRAVA, LLC has been involved in commercial aviation 

since 1990 with an ATP certificate since 2004 and type ratings in both the HS-125 and G1159 aircraft. 

John L. Johnston has over 5000 hours of turbine aircraft experience including international experience 

in both part 91 and 135 operations. During an incident/accident free career JOHN L. JOHNSTON has 

been familiar with FAR regulations, airspace, aircraft maintenance manuals and logbooks, MEL’s, 

ground operations and record keeping in accordance with current regulations. 

The objective of GARRAVA, LLC and our Unmanned Aircraft System (DJI Phantom 3 professional) 

aerial operations is to provide a more affordable, high-quality production system for a variety of 

governmental, commercial, public, and residential uses, specifically targeting 

a. Construction sites before and after 

b. Appraisals 

c. Real-estate marketing 

d. Economic development 

e. Civic landmarks 

f. Special event coverage 

g. Support for various local agencies including police and fire and rescue operations

John L. Johnston has safely flown small RC aircraft for over 7 years including electric quadcopters 

recreationally for over a year without incident. 

BACKGROUND 

GARRAVA, LLC seeks an exemption to operate DJI Phantom 3 system for compensation or hire 

within the NAS. The DJI Phantom 3 is 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 2.8 lb. while having a diagonal dimension of 

23.2”, a maximum speed of approximately 16.4’fps and a maximum flying height of 400'. The DJI 

Phantom 3 is equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. 

The DJI Phantom 3 that will be operated by GARRAVA, LLC will be registered in accordance with 49 

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked 

in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 
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BASIS FOR PETITION 

Petitioner, GARRAVA, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. 

§ 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the 

DJI Phantom 3, UAS 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, GARRAVA, LLC operation of DJI Phantom 3 UAS meets the conditions of 

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

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

Accordingly, GARRAVA, LLC requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate. 

GARRAVA, LLC submits that the requested relief is proper since an equivalent level of safety will be 

ensured. GARRAVA, LLC will use experienced personnel or technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction 

Manual). Furthermore, GARRAVA, LLC will document and maintain all maintenance records for the 

DJI Phantom 3 UAS. 

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

limitations: Pilot in command, is requested by GARRAVA, LLC to the extent necessary to allow a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight-hour and currency requirements, 

that the PIC is able to safely operate the DJI Phantom UAS in a manner consistent with this exemption, 

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

vessels, vehicles and structures. 

GARRAVA, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI 

Phantom 3 UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

As such, GARRAVA, LLC submits that they will ensure that the DJI Phantom 3 UAS is in an airworthy 

condition, prior to every flight, by determining that the UAS are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft are 

in a condition for safe flight. 

GARRAVA, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom 3 UAS will not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Phantom 3 UAS 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 GARRAVA, LLC’s operation 

of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of 
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safety equivalent to Section 91.121. 

Additionally, GARRAVA, LLC seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. GARRAVA, LLC submits that safety will not 

be affected by operation of the DJI Phantom 3 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 23 minutes. Battery power indicators are also able to show exactly how much battery 

power is left, as well as how much time is needed to return safely back to point of take off. The DJI 

pilot App will display a notice when a low battery warning is triggered. The UAS will automatically 

return to the home point if no action is taken after a 10 second count down. Additional details of the 

RTH failsafe will be addressed in the section “technical specifications of DJI Phantom 3 UAS.

In accordance with 14 C.F.R. § 11.81, GARRAVA, LLC provides the following information in support 

of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

GARRAVA, LLC c/o JOHN L. JOHNSTON 3652 Dunigan Court Catharpin, VA 20143 

Mobile: 703.472.1711 Email: trade@thejumpworks.com 

B. The Specific Sections Of 14 C.F.R. From which GARRAVA, LLC Seeks Exemption. 

1. GARRAVA, LLC Seeks Exemption From The Requirements Of Section 61.113(a) 

And (b). 

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

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

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

of an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft. 

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

with any business or employment if—

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

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

2. GARRAVA, LLC Seeks Exemption From The Requirements Of Section 91.7(a). 

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

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

3. GARRAVA, LLC Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 
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(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. GARRAVA, LLC Seeks Exemption From The Requirements Of Section 91.151(b). 

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

(b), states the following: 

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

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

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

at least 20 minutes. 

5. GARRAVA, LLC Seeks Exemption From The Requirement Of Section 91.405(a). 

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

Each owner or operator of an aircraft—

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

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

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

6. GARRAVA, LLC Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless-

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

7. GARRAVA, LLC Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

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

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

unless, within the preceding 12 calendar months, it has had -
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(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. GARRAVA, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

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

following: 

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

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

paragraph (b) of this section:

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

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

appropriate, for each aircraft (including the airframe) and each engine, propeller, 

rotor, and appliance of an aircraft. The records must include-

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

work performed; and 

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

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

for return to service. 

(2) Records containing the following information: 

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

each rotor. 

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

rotor, and appliance. 

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

required to be overhauled on a specified time basis. 

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

inspection required by the inspection program under which the aircraft and its 

appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date 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: 
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(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 GARRAVA, LLC Seeks And The Reason GARRAVA, LLC 

Seeks The Relief. 

1. Extent Of Relief GARRAVA, LLC Seeks And The Reason GARRAVA, 

LLC Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a 

PIC holding a private pilot or higher level certificate, as well as a current and 

valid airman medical certificate, and who has met certain flight-hour and 

currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

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

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

aircraft in connection with any business or employment if: 

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

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

or hire. 

As set forth more fully below, GARRAVA, LLC submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the 

DJI Phantom 3 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 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, GARRAVA, LLC submits that all flights of the DJI Phantom 3 UAS, 

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

to GARRAVA, LLC’s business (2) will not carry passengers or property for 

compensation or hire; and (3) will maintain an appropriate PIC hourly flight log 

which will include flight time, location, weather conditions (VFR), type of 

flight, and reason for flight.

2. Extent Of Relief GARRAVA, LLC Seeks And The Reason GARRAVA, LLC Seeks 

Relief From Section 91.7(a). 
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Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow GARRAVA, LLC to determine that the DJI Phantom 3 UAS 

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

compliance with the operating documents (i.e., GARRAVA, LLC Aerial Operations 

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

GARRAVA, LLC seeks the requested relief because the DJI Phantom 3 UAS do not 

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

Therefore, GARRAVA, LLC will ensure that the DJI Phantom 3 UAS are in airworthy 

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

Maintenance Log, and DJI Phantom 3) 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 GARRAVA, LLC Seeks And The Reason GARRAVA, LLC Seeks 

Relief From Section 91.121. 

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

operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude 

information from the UA to the PIC at the ground control station (GCS). Since the FAA 

requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), GARRAVA, LLC seeks the 

requested relief because the DJI Phantom 3 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 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 GARRAVA, LLC Seeks And The Reason GARRAVA, LLC Seeks 

Relief From Section 91.151(b). 

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

is requested to the extent required to allow flights of the battery powered DJI Phantom 3 

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

flight rules (VFR), for a total duration of 23 minutes. GARRAVA, LLC seeks the 

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

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

practicality of any aerial video or still photo flight operations that GARRAVA, LLC 

proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 UAS, 
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the DJI Phantom 3 operating documents, and GARRAVA, LLC’s proposed operating 

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

Phantom 3 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 

23 minutes. 

5. Extent Of Relief GARRAVA, LLC Seeks And The Reason GARRAVA, LLC Seeks 

Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) 

& (b). 

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

apply to aircraft with an airworthiness certificate, GARRAVA, LLC requests relief from 

these Sections because the DJI Phantom 3 UAS do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 3 UAS meet the conditions 

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

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

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., the GARRAVA, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction 

Manual). Furthermore, GARRAVA, LLC will document and maintain all maintenance 

records for the DJI Phantom 3 UAS. 

D. The Reasons Why Granting GARRAVA, LLC 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 GARRAVA, LLC to 

safely, efficiently, and economically perform aerial video and photography of construction sites, 

real estate, events and civic landscape over certain areas of the United States. Additionally, 

using the UAS for agricultural crop diagnosis would increase safety by pinpointing areas 

needing pesticide application, reducing pesticide overuse. This would provide small to midsize 

farms compete at a lower cost. Providing assistance to people in need during disaster situations 

by identifying areas needing immediate relief thereby limiting resources spent in those areas not 

needing immediate assistance and saving lives with reduced response times.

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, reduce 

pollution, and provide significant benefits to the economy. Notably, the benefits of GARRAVA, 

LLC’s proposed operation of the DJI Phantom 3 UAS will be realized without implicating any 

privacy issues. 

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

The DJI Phantom 3 UAS are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 
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imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom 3 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 

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 

UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft, 

will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Phantom 3 UAS 

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 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 UAS to perform aerial acquisitions, the substantial risk to 

life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Phantom 3 UAS (weighing approximately 2.8 pounds at their maximum gross 

weight with diagonal dimension of 23.2 inches, and with no fuel on board), has less 

physical potential for collateral damage to life and property on the ground, and in the 

air, compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons). 

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

3 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical 

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

operation of the DJI Phantom 3 UAS will allow United States based companies, like 

GARRAVA, LLC, to remain competitive and contribute to growth of the U.S. 

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

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such 
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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 UAS, companies such as GARRAVA, LLC, can 

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

employees and contractors, which will ultimately contribute to growth of the U.S. 

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

of the DJI Phantom 3 UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United 

States and abroad

4. There Are No Privacy Issues. 

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

decades, GARRAVA, LLC’s proposed operation of the DJI Phantom 3 UAS will not 

implicate any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated 

only in compliance with operating documents (i.e., GARRAVA, LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) which 

requires property owner involvement, subject notification as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 CFR § 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 GARRAVA, LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 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, GARRAVA, LLC’s operation of the DJI 

Phantom 3 UAS 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 
14

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. 

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

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

demonstrated by: 

(a) the characteristics of the DJI Phantom 3 UAS; 

(b) the pilot certification requirement; and 

(c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe 

Characteristics. 

The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the 

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

weight, speed, and operational capability. The DJI Phantom three has 

established itself as a reliable and safe UAS, with multiple automatic safety 

features as described below.

i. Technical Specifications Of The DJI Phantom 3 UAS. 

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

the DJI Phantom 3 User Manual, attached hereto as Appendix A. 

ii. The DJI Phantom 3 UAS Global Positioning Modes Enable The 

UAS To Remain Within A Defined Operational Area. 

The DJI Phantom 3 UAS may be operated in both manual and global 
15

positioning flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 3 UAS is provided at pages 11 

of the DJI Phantom 3 User Manual attached hereto as Appendix A. 

iii. The DJI Phantom 3 UAS 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 UAS will remain 

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

Phantom 3 UAS does not reacquire control link data from the GCS, the 

UAS will assume that the Control Link is lost and the 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 Phantom 3 

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

Manual, attached hereto as Appendix A. 

iv. The DJI Phantom 3 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI 

Phantom 3 GCS and flight control software is provided at pages 23 

through 29 of the DJI Phantom 3 User Manual. DJI Phantom 3 User 

Manual is attached hereto as Appendix A. 

b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The 

Line Of Sight Of A Certificated Pilot in Command With A Safety

Observer. 

Currently as sole member of GARRAVA, LLC JOHN L. JOHNSTON will be 

the only person to act as a pilot in command (PIC) of the DJI Phantom 3 UAS. 

Additionally, a minimum of one trained safety observer (SO) will assist him at 

all times during flight time. 

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

1. In seeking this exemption, GARRAVA, LLC proposes to commercially operate DJI 

Phantom 3 UAS for the special purpose of conducting aerial video and photography over 

certain areas of United States, pursuant to the following specific operating limitations. 

1) Operations authorized by this grant of exemption will be limited to the following aircraft 
16

described in the operating documents, rotorcraft UAS weighing less than 55 pounds 

maximum gross weight: DJI Phantom 3 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 listed in the objectives section on page 3. 

3) The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

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

as indicated by the procedures specified in the operating documents unless a special request 

is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

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

requires the PIC to be able to use human vision unaided by any device other than corrective 

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

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

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

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

able to communicate verbally at all times. Electronic messaging or texting is not permitted 

during flight operations. The PIC must be designated before the flight and cannot transfer 

his or her designation for the duration of the flight. The PIC must ensure that the SO can 

perform the functions prescribed in the operating documents. 

8) The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not permitted 

to operate the camera or other instruments. 

9) The operating documents and the grant of exemption must be accessible during UAS 

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

between the conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and limitations contained in 

the grant of exemption take precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operating documents. The operator may update or 

revise its operating documents. It is the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The operator 

must also present updated and revised documents if it petitions for extension or amendment 

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

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

for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may 

be contacted if questions arise regarding updates or revisions to the operating documents. 

10) Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the 

aircraft is prohibited from operating until the necessary maintenance has been performed 

and the UAS is found to be in a condition for safe flight. The Ground Control Station must 

be included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

11) Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a 
17

functional test flight. The PIC who conducts the functional test flight must make an entry 

in the aircraft records. 

12) The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

13) The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

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

in accordance with the operating documents. Maintenance, inspection, alterations, and 

status of replacement/overhaul component parts must be noted in the aircraft records, 

including total time in service, description of work accomplished, and the signature of the 

authorized person returning the UAS to service. 

15) Each UAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

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). 

19) Flights for the purposes of training the operator’s PICs are permitted under the terms of the 

exemption. 

20) 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. 

21) UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed area 

of operations. Flights under special visual flight rules (SVFR) are not authorized. 

22) 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. 

23) The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 
18

24) 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. 

25) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

26) 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. 

27) 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. 

28) 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. 

29) 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. 

30) The documents required by parts 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. 

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

activities at all times. 

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

operations must be conducted at least 500 feet from all nonparticipating persons (persons 

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

structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

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

nonparticipating persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet of the UA, 

flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those objects 

and determined that it does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

33) All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative. Permission from 
19

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

conducted. 

34) 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. 

GARRAVA, LLC submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 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 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Considering GARRAVA, LLC’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary 

to safely operate the DJI Phantom 3 UAS, GARRAVA, LLC submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for GARRAVA, LLC’s specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11158, 11159, 11160, 11161). 

GARRAVA, LLC will not allow any PIC to operate the DJI Phantom 3 UAS in an any capacity 

other than training unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 3 UAS training and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. 

§ 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 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 GARRAVA, LLC’s proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations 

would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for the 
20

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, GARRAVA, LLC will ensure safe operations by not allowing any PIC to operate the 

DJI Phantom 3 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 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. 

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

every flight, GARRAVA, LLC will ensure that the DJI Phantom 3 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 UAS will be provided to the PIC via GPS equipment 
21

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 

GARRAVA, LLC’s operation of the DJI Phantom 3 UAS within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

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

flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

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

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

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161). 

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 UAS; (2) 

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

operations. Accordingly, GARRAVA, LLC will ensure that it will safely operate the battery 

powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of 23 minutes. 

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

limitations on the proposed flight operations; and the location of the proposed operations, will 

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

safety will be ensured as the DJI Phantom 3 UAS 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 UAS will descend and land 

automatically through the return to home failsafe.

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, GARRAVA, LLC submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because 

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

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in 

the operating documents (i.e., GARRAVA, LLC Aerial Operations Manual, Monthly 
22

Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, GARRAVA, LLC 

will document and maintain all maintenance records for the DJI Phantom 3 UAS. 

Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating documents, 

GARRAVA, LLC will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manual are 

attached hereto as Appendix A and a copy of the DJI Phantom 3 UAS Maintenance LOG is 

attached hereto as Appendix B. 

Likewise, the exemption sought will not adversely affect safety because GARRAVA, LLC will 

use trained technicians to perform maintenance, alterations or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS 

will be performed by trained technicians. Maintenance will be documented and maintained 

utilizing the monthly maintenance log. 

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

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

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

In consideration of GARRAVA, LLC’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 UAS, GARRAVA, LLC submits 

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

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

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

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

11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161). 

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

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

and 14 C.F.R. § 21.16 entitled Special Conditions, GARRAVA, LLC requests that the FAA 

prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, which 

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

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 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 UAS, since the airworthiness regulations of 14 
23

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 GARRAVA, LLC’s intended operation of the DJI Phantom 3 

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

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

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

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

Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

GARRAVA, LLC Seeks Exemption: 

The GARRAVA, LLC seeks exemption from the requirements of 14 C.F.R Sections 

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

91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption The GARRAVA, LLC Seeks: 

This exemption will permit The GARRAVA, LLC to commercially operate an Unmanned 

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

areas of the United States. 
24

Any Additional Information, Views, Or Arguments Available To Support GARRAVA, LLC’s 

Request. 

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

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

may operate safely in the NAS. As such, GARRAVA, LLC’s request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above. 

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

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

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, GARRAVA, LLC will operate the DJI Phantom 3 UAS safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security. 

CONCLUSION 

As set forth herein, GARRAVA, LLC seeks an exemption pursuant to 14 C.F.R. § 

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

safe operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the 

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

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

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

GARRAVA, LLC to safely, efficiently, and economically operate the DJI Phantom 3 UAS 

commercially within the NAS. 
25

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

and Reform Act of 2012, Section 333, GARRAVA, LLC respectfully requests that the Administrator 

grant this Petition for an exemption from the requirements of 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b), and permit GARRAVA, LLC to operate the DJI Phantom 3 UAS 

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

United States. 

Dated: July 29, 2015 

Respectfully submitted, 

JOHN L. JOHNSTON GARRAVA, LLC 3652 Dunigan Court Catharpin, VA 20143 

703.472.1711 

trade@thejumpworks.com 

Appendices: 

A – Link to DJI Phantom 3 Manual: Click on link below 

http://www.dji.com/product/phantom-3/download

B – Attached Garrava, LLC Aircraft Inspection and Monthly Maintenance Log

C – Attached Garrava, LLC Aircraft Preflight Inspection Log