UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

800 Federal Aviation Administration

WASHINGTON, DC 20591

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Chesapeake Drone Service

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 

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

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIALOPERATION OF DJI Phantom 3 Professional 

UNMANNED AIRCRAFT SYSTEM SPURSUANT TO SECTION 333 OF THE FAA 

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

Submitted on August 13, 2015

George S Prince

dba/Chesapeake Drone Service

111 Burton Air Drive

Centreville, MD 21617

Gsprince16@yahoo.com

410-739-4370

SUMMARY

Chesapeake Drone Service 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), and91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit Chesapeake Drone Service to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography to be used 

primarily in

1. Farm land surveys, crop health, and pesticide use to reduce the amount of 

chemicals needed in order to reduce Nitrogen and Phosphorous entering the 

Bay. The largest source of pollution to the Bay comes from agricultural 

runoff, which contributes roughly 40 percent of the nitrogen and 50 percent of 

the phosphorus.

2. Industrial Inspection purposes

3. Real estate

4. General photography & video services

...over certain areas of the United States.
BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional

Chesapeake Drone Service seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 3 Professional is a vertical

takeoff and landing (VTOL) Unmanned Aircraft (UA) utilizing electronic tablet or smart 

phone systems. 

The DJI Phantom 3 Professional has a maximum gross weight of approximately 2 

pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 

inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 

Professional is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

The DJI Phantom 3 Professional will be operated by a licensed pilot as required, and 

will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well 

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

Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Chesapeake Drone Service, 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 

Professional 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, the operation of DJI Phantom 3 

Professional 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, Chesapeake Drone Service 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.

Chesapeake Drone Service submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Chesapeake Drone Service will use 

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

maintenance on the UASs using the methods, techniques, and practices prescribed in 
the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 

Professional Instruction Manual). 

Furthermore, Chesapeake Drone Service will document and maintain all maintenance

records for the DJI Phantom 3 Professional UAS.

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

pilot privileges and limitations: Pilot in command, is requested by Chesapeake Drone 

Service 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, and who 

will receive multi-rotor training by us that the PIC is able to safely operate the DJI 

Phantom 3 Professional UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Chesapeake Drone Service seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 3 Professional UAS does not require an 

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

such, Chesapeake Drone Service submits that he will ensure that the DJI Phantom 3 

Professional is in an airworthy condition, prior to every flight, by determining

that the UAS is in compliance with the operating documents (i.e., Monthly Maintenance 

Log, and DJI Phantom 3 Professional Instruction Manual), and that the aircraft is in a 

condition for safe flight.

Chesapeake Drone Service also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional does

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

Phantom 3 Professional 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 Transmitter for active monitoring of the flight path.

This altitude information, combined with visual line of sight, at or below 500 feet

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

Additionally, Chesapeake Drone Service seeks an exemption from the requirements of

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

Drone Service submits that safety will not be affected by operation of the DJI Phantom 3 

Professional during daylight hours in visual meteorological conditions (VMC) under 

visual flight rules (VFR), with enough battery power to fly for a total duration of 

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

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

In accordance with 14 C.F.R. § 11.81, Chesapeake Drone Service 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:

George S Prince

dba/Chesapeake Drone Service

111 Burton Air Drive

Centreville, MD 21617

410-739-4370

Gsprince16@yahoo.com

B. The Specific Sections Of 14 C.F.R. From Which Chesapeake Drone Service

Seeks Exemption.

1. Chesapeake Drone Service 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. Chesapeake Drone Service 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. Chesapeake Drone Service Seeks Exemption From The Requirements Of 

Section 91.121.

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

part:

(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. Chesapeake Drone Service 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. Chesapeake Drone Service 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. Chesapeake Drone Service 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. Chesapeake Drone Service Seeks Exemption From The Requirements Of 

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

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

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

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has

been approved for return to service by a person authorized by § 43.7 of this chapter; or

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

with part 21 of this chapter.
8. Chesapeake Drone Service 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:

(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 Chesapeake Drone Service Seeks And The Reason 

Chesapeake Drone Service Seeks The Relief.

1. Extent Of Relief Chesapeake Drone Service Seeks And The Reason 

Chesapeake Drone Service 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, Chesapeake Drone Service submits that an equivalent 

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

Phantom 3 Professional UAS unless that PIC has met certain flight-hour and

currency requirements, demonstrating that the PIC is able to safely operate either the 

DJI Phantom 3 Professional 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, Chesapeake Drone Service submits that all flights of the DJI Phantom 3 

Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1)

will be incidental to Chesapeake Drone Service’s business; and (2) will not carry 

passengers or property for compensation or hire.

2. Extent Of Relief Chesapeake Drone Service Seeks And The Reason 

Chesapeake Drone Service Seeks Relief From Section 91.7(a).

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

the extent required to allow Chesapeake Drone Service to determine that the DJI 

Phantom 3 Professional and is in airworthy condition prior to every flight by

ensuring that the UAS is in compliance with the operating documents (i.e., the Monthly 

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

Chesapeake Drone Service seeks the requested relief because the DJI Phantom 3 

Professional does not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Chesapeake Drone Service will ensure that the 

DJI Phantom 3 Professional is in airworthy condition based upon its compliance with the
operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Professional

user Manual) prior to every flight, and further, determine that the aircraft is in condition 

for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief Chesapeake Drone Service Seeks And The Reason 

Chesapeake Drone Service 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 Professional, 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 on the Ipad or Iphone

Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control (ATC) in feet above ground level (AGL), Chesapeake 

Drone Service seeks the requested relief because the DJI Phantom 3 Professional 

altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR

91.121 is sought to the extent necessary to comply with the applicable conditions and

limitations stated below. As more fully set forth herein, an equivalent level of safety will

be maintained since the DJI Phantom 3 Professional is 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.

4. Extent Of Relief Chesapeake Drone Service Seeks And The Reason 

Chesapeake Drone Service Seeks Relief From Section 91.151(b).

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

conditions, is requested to the extent required to allow flights of the battery powered DJI

Phantom 3 Professional during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first 

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

least 4.5 minutes.

Chesapeake Drone Service seeks the requested relief because

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

powered DJI Phantom 3 Professional will severely constrain the practicality of any aerial 

video or still photo flight operations that Chesapeake Drone Service proposes to 

conduct pursuant to this Petition.

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

Professional operating documents, and Chesapeake Drone Service proposed operating 

limitations, ensure that Chesapeake Drone Service will safely operate the battery 
powered DJI Phantom 3 Professional during daylight hours in visual meteorological 

conditions (VMC),

under visual flight rules (VFR), with enough battery power to fly for a total duration of

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

to fly after that for at least 4.5 minutes.

5. Extent Of Relief Chesapeake Drone Service Seeks And The Reason 

Chesapeake Drone Service 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, Chesapeake Drone Service

requests relief from these Sections because the DJI Phantom 3 Professional does

not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3

Professional meets the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, Chesapeake Drone Service 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 Chesapeake Drone Service Aerial Operations Manual, Monthly 

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

Furthermore, Chesapeake Drone Service will document and maintain all maintenance 

records for the DJI Phantom 3 Professional UAS.

D. The Reasons Why Granting Chesapeake Drone Service 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 Chesapeake 

Drone Service to safely, efficiently, and economically perform aerial video and 

photography of farm land, chicken houses with sediment ponds, real estate, and 

landscape, over certain areas of the United States.

Additionally, use of the DJI Phantom 3 Professional and will decrease congestion of the 

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

benefits of Chesapeake Drone Service’s proposed operation of the DJI

Phantom 3 Professional and will be realized without implicating any privacy issues.

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

The DJI Phantom 3 Professional is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional UAS 
would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, 

as well as increase the safety of life and property in the air and on the ground.

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

congestion around airports caused by arriving and departing aircraft will be reduced. 

The DJI Phantom 3 Professional does not require an airport to takeoff or land. Likewise, 

a reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations.

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

Professional.

Conducting aerial acquisitions with the DJI Phantom 3 Professional 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 Professional produces

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 Professional, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAs is propelled by battery powered 

electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 Professional to perform aerial acquisitions, the substantial 

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

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

eliminated. 

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

Phantom 3 Professional (weighing approximately 2 pounds 11 ounces respectively, at 

it’s maximum gross weights with lengths of 16 inches and 17.3 inches respectively, and 

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

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

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

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

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 3 Professional and Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 
such, operation of the DJI Phantom 3 Professional will allow United States based 

companies, like mine, to remain competitive and contribute to growth of the U.S. 

economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection 

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

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

competitive. Operating the battery powered DJI Phantom 3 Professional and is one 

such technology that not only allows companies greater operational flexibility compared 

to manned aircraft, but provides such flexibility without the high operational cost of a

traditional manned aircraft.

By operating the DJI Phantom 3 Professional, small companies can remain competitive 

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

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

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

Phantom 3 Professional and DJI Inspire 1 UASs, provides a stable workforce that 

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

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

competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, Chesapeake Drone Service’s proposed operation of the DJI Phantom 3 

Professional will not implicate any privacy issues. Specifically, the DJI Phantom 3

Professional and will be operated only in compliance with operating

documents (i.e., the Monthly Maintenance Log, and DJI

Phantom 3 Professional instruction Manual) which requires property owner involvement 

as well as local law enforcement notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 

91.119.

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

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

Provided By The Rule From Which Chesapeake Drone Service Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional Meets 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, Chesapeake Drone Service’s operation of 

the DJI Phantom 3 Professional meets the conditions of FMRA Section 333, and will not 

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
Section 333 provides authority for a UAS to operate without airworthiness

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

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

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

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

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

Transportation shall determine if certain unmanned aircraft systems may

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

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

by section 334 of this Act.

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

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

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

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

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

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

a threat to national security; and

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

airworthiness certification under section 44704 of title 49, United

States Code, is required for the operation of unmanned aircraft

systems identified under paragraph (1).

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

section that certain unmanned aircraft systems may operate safely in the

national airspace system, the Secretary shall establish requirements for the

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

In seeking this exemption, Chesapeake Drone Service submits that the DJI Phantom 3

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

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional (b) the pilot 

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

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

Characteristics.

The DJI Phantom 3 Professional 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.
i. Technical Specifications Of The DJI Phantom 3 Professional UAS.

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

Phantom 3 Professional Specifications and Data Sheet, attached.

ii. The DJI Phantom 3 Professional Does Not Allow Autonomous Flight 

The DJI Phantom 3 Professional may currently only be operated in manual flight mode 

from the factory which improves the area of safe operation. A complete description of 

the flight and navigational modes of the DJI Phantom 3 Professional is provided at 

pages 25-35 of the DJI Phantom 3 Professional User Manual, attached.

iii. The DJI Phantom 3 Professional is 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 Professional will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional does 

not reacquire control link data from the GCS, the UAs will assume that the Control Link 

is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will 

descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3 Professional 

UAS are set forth at pages 27 through 29 of the DJI Phantom 3 Professional User 

Manuals, attached hereto as Exhibit C.

iv. The DJI Phantom 3 Professional and Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3

Professional flight control software is provided at pages 32 through 43 of the DJI 

Phantom 3 Professional User Manual. A DJI Phantom 3 Professional User Manual is

attached.

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

Sight Of A Certificated Pilot in Command With A Safety Observer.

Chesapeake Drone Service will only utilize certificated pilots who possess a current and 

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

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

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

Operating Limitations.

In seeking this exemption, Chesapeake Drone Service proposes to commercially 

operate DJI
Phantom 3 Professional for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations:

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 

pounds maximum gross weight: DJI Phantom 3 Professional Unmanned Aircraft 

Systems. Proposed operations of any other aircraft will require a new petition or a 

petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 500 feet above ground

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

a special request is made and approved by ATC. All altitudes reported to ATC must be 

in feet AGL.

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

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

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate.

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

permitted.

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

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

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

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

PIC must be 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. 

All maintenance and alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conducts the

functional test flight must make an entry in the aircraft records.

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

inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.

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

maintenance, overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance,

inspection, alterations, and status of replacement/overhaul component parts

must be noted in the aircraft records, including total time in service,

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

returning the UAS to service.

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

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

third- class medical certificate.
18. The operator may not permit any PIC to operate unless the PIC meets the

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

the UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

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

qualification flight hours must be logged in a manner consistent with 14

C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are

permitted under the terms of the exemption. 

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

During training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

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

office closest to proposed area of operations. Flights under special visual

flight rules (SVFR) are not authorized.

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

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

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

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

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

to the Administrator upon request.

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

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

the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a

pre- determined location within the planned operating area and land or be

recovered in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

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

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

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate
of Waiver or Authorization (COA) prior to conducting any operations under

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

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

than 48 hours prior to the operation. 

All operations shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential transponder 

requirements.

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

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

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

Subpart C. Markings must be as large as practicable.

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

operation and control of the UA must comply with the Federal

Communications Commission (FCC) or other appropriate government oversight agency 

requirements.

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

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

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

Administrator or any law enforcement official upon request.

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

operations and activities at all times.

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

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

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:

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

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

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

nonparticipating persons leave such protection and are within 500 feet

of the UA, flight operations must cease immediately and/or;

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

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

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

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

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

present an undue hazard to those persons per § 91.119(a).
32. All operations shall be conducted over private or controlled-access property with 

permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be obtained for 

each flight to be conducted.

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

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

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

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

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

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

And (b) Would Not Adversely Affect Safety.

Chesapeake Drone Service 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 DJIPhantom 3 Professional 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 Professional or DJI Inspire 1 UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Considering Chesapeake Drone Service’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); andthe airmanship skills necessary to safely operate the DJI Phantom 3 

Professional UAS, Chesapeake Drone Service submits that the additional manned 

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

airmanship skills necessary for Chesapeake Drone Service’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).

Chesapeake Drone Service will not allow any PIC to operate the DJI Phantom 3 

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

requirements or the DJI Phantom 3 Professional UAS training and currency 

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

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 Chesapeake Drone Service’s proposed operations. The

Administrator has held that prior documented flight experience that was obtained in

compliance with applicable regulations would ensure safe operations, stating as follows:

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

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

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

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

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

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

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

exemption. For clarification, the FAA considers these minimum hour

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

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

included in the total 25 hours of UAS rotorcraft time. In addition to the hour

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

90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour

requirements in Exemption No. 11062 are appropriate to practice and build

proficiency in the skills necessary to safely conduct the petitioner’s proposed

operations. The FAA also finds that prior documented flight experience that was

obtained in compliance with applicable regulations would satisfy this

requirement. Training, proficiency, and experience-building flights can also be

conducted under the grant of exemption to accomplish the required flight time.

During training, proficiency, and 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, Chesapeake Drone Service will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 3 Professional 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 Professional 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, Chesapeake Drone Service will ensure that the DJI 

Phantom 3 Professional 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 Professional will be provided to 

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

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

This altitude information, combined with Chesapeake Drone Service’s operation of the 

DJI Phantom 3 Professional within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section

91.121. The altitude information will be generated by GPS equipment installed onboard

the aircraft. Prior to each flight, a zero altitude initiation point is automatically

established by the UASs at ground level.

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

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 

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

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

Would Not Adversely Affect Safety.

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

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

Phantom 3 Professional (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations.

Accordingly, Chesapeake Drone Service will ensure that he will safely operate the 

battery powered DJI Phantom 3 Professional during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes.

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

warnings to the PIC 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, DJI Phantom 3 

Professional will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

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

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

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

Not Adversely Affect Safety.

In seeking this exemption, Chesapeake Drone Service 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 Chesapeake Drone Service will use trained technicians to 

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

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

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

Furthermore, Chesapeake Drone Service will document and maintain all maintenance 

records for the DJI Phantom 3 Professional.

Since the DJI Phantom 3 Professional and will be inspected as prescribed by the 

operating documents, Chesapeake Drone Service 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 Professional User Manual is attached.

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

Drone Service will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety
established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of 

the DJI Phantom 3 Professional and 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 Chesapeake Drone Service’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3 Professional, 

Chesapeake Drone Service 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, Chesapeake Drone 

Service requests that the FAA prescribe special conditions for the intended operation of 

the DJI Phantom 3 Professional 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 Professional UAS, since

the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not

contain adequate or appropriate safety standards for an aircraft, aircraft engine, or
propeller because of a novel or unusual design feature of the aircraft, aircraft

engine or propeller, he prescribes special conditions and amendments thereto for

the product. 

The special conditions are issued in accordance with Part 11 of this

chapter and contain such safety standards for the aircraft, aircraft engine or

propeller as the FAA finds necessary to establish a level of safety equivalent to

that established in the regulations. See 14 C.F.R. § 21.16.

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

may prescribe special conditions for the intended operation of the DJI Phantom 3 

Professional 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).

A Summary That Can Be Published in the Federal Register, stating: The

Rules From Which Chesapeake Drone Service Seeks Exemption:

Chesapeake Drone Service 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 Chesapeake Drone Service

Seeks:

This exemption will permit Chesapeake Drone Service to commercially operate an 

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

photography over certain areas of the United States.

Any Additional Information, Views, Or Arguments Available To Support

Chesapeake Drone Service’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, Chesapeake Drone Service’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, a licensed pilot will operate the DJI Phantom 3

Professional 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, Chesapeake Drone Service seeks an exemption pursuant to 14 

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

(FMRA), which will permit safe operation of the DJI Phantom 3 Professional 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 a licensed pilot to safely, efficiently, and economically operate the DJI 

Phantom 3 Professional commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, Chesapeake Drone Service

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 

Chesapeake Drone Service to operate the DJI Phantom 3 Professional and 

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

areas of the United States.

Dated: August 1, 2015

Respectfully submitted,

George S Prince

dba/Chesapeake Drone Service

111 Burton Air Drive

Centreville, MD 21617

410-739-4370

gsprince16@yahoo.com

Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

APPENDIX – A

DJI Phantom 3 Professional TECHNICAL SPECIFICATIONS

Chesapeake Drone Service only utilizes safe and reliable UASs. DJI is an industry 

leader in small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. 

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

altitude as well as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices)
1.1 DJI Phantom 3 Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

Reserved N Number - N2942