UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

U.S. Department of Transportation, Docket Management System

1200 New Jersey Ave, SE Washington, DC 20590

Regulatory Docket No. _________________________________

ESTATE AERIAL, INC. 

PETITION FOR EXEMPTION AND RELIEF FROM THE REQUIREMENTS 

OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

CONCERNING COMMERCIAL OPERATION OF

SMALL UNMANNED AERIAL SYSTEMS PURSUANT TO 

SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012

PUBLIC LAW 112-95

PETITIONER

HAL M. STANILOFF, PRESIDENT

ESTATE AERIAL, INC.・P.O. BOX 702・SETAUKET, NY 11733

(631) 371-4676・HAL@ESTATEAERIAL.COM

Rev. A1.2 Page 1 of 22
Table of Contents

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

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

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

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

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

Public Interest 17 ...............................................................................................

Conclusion 19 ....................................................................................................

Exhibits 20 .........................................................................................................

Rev. A1.2 Page 2 of 22
Introduction

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 112-95 

FEB. 14, 2012, Section 333 (herein referred to as “FMRA of 2012”), I, Hal M. Staniloff, owner 

and operator of small unmanned aerial systems (sUAS), and owner of Estate Aerial, Inc. 

respectfully petition the FAA for an exemption from the herein listed Federal Aviation 

Regulations (FARs) so as to commence commercial operations of sUAS in the National Airspace 

System (NAS). Said operations shall be conducted under the conditions stipulated herein or as 

may be established by the FAA and, or, as required by the FMRA of 2012, Section 333.

Estate Aerial, Inc. hereby petitions and requests exemption from the following FARs under Title 

14 CFR:

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

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

Interests of the Petitioner

Estate Aerial, Inc. is a small business that was established in 2014. Estate Aerial, Inc. is a 

professional small unmanned aerial vehicles (sUAS) operations company that creates dramatic, 

low-altitude, HD aerial video and photography utilizing sUAS. Estate Aerial, Inc. also collates, 

and analyzes aerial video and photography telemetry in order to produce NVI maps, orthomosaic 

maps, 3-dimensional imagery, and photogrammetry data. All pertinent team members are 

OSHA-10 certified.

It is the intent of Estate Aerial, Inc. to utilize sUAS in order to facilitate the following activities 

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

1) Aerial Photography and Videography

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

marketing and selling services offered by Estate Aerial, Inc. or other companies.

2) Aerial Surveying

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

survey new or existing residential or commercial real estate locations or construction sites. 

Or used to produce video and photographic telemetry in order to produce NVI maps, 

orthomosaic maps, 3-dimensional imagery, and photogrammetry data.

3) Aerial Inspections

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

inspection of existing residential or commercial real estate buildings, structures, or 

construction sites.

Rev. A1.2 Page 3 of 22
Relief from Specific Applicable Regulations

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

Unmanned Aircraft Systems, Estate Aerial, Inc. hereby petitions the Administrator for the 

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

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

following FARs under Title 14 CFR:

§21, Subpart H Airworthiness Certificates

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

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

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

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

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

in Command

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

limitations: Pilot in command”, is requested by Estate Aerial, Inc., to the extent necessary to 

allow a pilot in command (PIC) holding a private pilot or higher level certificate, as well as an 

airman medical certificate, and who has demonstrated, by meeting a minimum of 10 flight-hours 

of the designated UAV, along with the ability to safely operate and fly the DJI Inspire 1 and/or, 

the DJI Phantom 3 Professional sUAS in a manner consistent with this exemption; including but 

not limited to standard takeoff and landing procedures, flight attitudes consistent with the safe 

envelope of flight for the given UA, evasive maneuvers, emergency maneuvers and procedures 

as well as the ability to maintain safe distances from people, property, buildings, structures, 

manned aircraft and restricted airspace.

§91.7(a) Civil aircraft airworthiness

Estate Aerial, Inc. seeks exemption from the requirement of §91.7(a), entitled, “Civil aircraft 

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

an airworthiness certificate in accordance with Part 21, Subpart H. Furthermore, Estate Aerial, 

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

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

shall be utilized in order to determine a “go” or “no-go” decision prior to each and every flight. 

The items on this list are based upon the operating limitations for that version of UA as specified 

in the manufacturers operation manual and system software. sUAS checklist for the the DJI 

Inspire 1 and DJI Phantom 3 Professional sUAS is annexed hereto as Exhibit A and Exhibit B 

respectively.

Rev. A1.2 Page 4 of 22
§91.9(b)(2) Civil Aircraft Flight Manual, Marking, and Placard 

Requirements

Estate Aerial, Inc. seeks exemption from the requirement of §91.9(b)(2), entitled, “Civil aircraft 

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

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

Manual, approved manual material, markings, and placards, or any combination thereof.

§91.105 Flight Crew Members at Stations

Estate Aerial, Inc. seeks exemption from the requirement of §91.105, entitled, “Flight crew 

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

definition, unmanned and therefore do not possess crew members.

§91.103(b) Preflight Action

Estate Aerial, Inc. seeks exemption from the requirement of §91.103(b), entitled, “Preflight 

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

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

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

this regulation simply does not apply to the operation of the DJI Inspire 1 and DJI Phantom 3 

Professional sUAS.

§91.109 Flight Instruction; Simulated Instrument Flight and 

Certain Flight Tests

Estate Aerial, Inc. seeks exemption from the requirement of §91.109, entitled, “ Flight 

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

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

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

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

§91.119 Minimum Safe Altitudes

Estate Aerial, Inc. seeks exemption from the requirement of §91.119, entitled “Minimum Safe 

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

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

400 feet above ground level (AGL).” Furthermore, under the provisions set forth by this 

exemption, operations of the herein specified UA’s shall be limited to 200 feet AGL or below in 

accordance with the blanket COA that is obtained at the time this exemption is granted. The 

basis of this exemption is due to the nature of the intended sUAS tasks specified herein, flights 

over sparsely populated areas could occur on a regular basis.

Rev. A1.2 Page 5 of 22
§91.121 Altimeter Settings

Estate Aerial, Inc. seeks exemption from the requirement of §91.121, entitled “Altimeter 

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

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

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

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

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

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

400 feet AGL, will ensure a level of safety equivalent to §91.121.

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

Estate Aerial, Inc. seeks exemption from the requirement of §91.151(b), entitled “Fuel 

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

Inspire 1 and DJI Phantom 3 UA while maintaining visual line of sight (VLOS), during daylight 

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

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

approximately 18 and 20 minutes respectively, to the first intended GPS waypoint and then the 

first point of intended landing, and assuming normal cruising speed, to fly thereafter for at least 4 

minutes.

§91.215 ATC Transponder and Altitude Reporting Equipment and 

Use

Estate Aerial, Inc. seeks exemption from the requirement of §91.215, entitled “ATC transponder 

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

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

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

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

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

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

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

Therefore, the petitioner hereby requests exemption from these sections as well. Estate Aerial, 

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

due to the fact that Estate Aerial, Inc. will only use experienced technicians to perform maintenance, 

alterations, and upgrades or updates to either hardware or system software on all sUAS components in 

accordance with the manufacturer’s guidelines. Furthermore, Estate Aerial, Inc. will only procure DJI 

approved manufactured parts for all maintenance, repairs, alterations, and/or upgrades or updates to the 

herein stated UA. Records of any and all maintenance, alterations, and upgrades or updates to either 

hardware or system software on all sUAS components shall be maintained by Estate Aerial, Inc. in a 

separate electronic, computer readable, maintenance log. An example output from said maintenance log 

is annexed hereto as Exhibit C.

Rev. A1.2 Page 6 of 22
Impact to Safety

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

In addition, it is further stated how Estate Aerial, Inc. believes this exemption would provide a 

level of safety at least equal to that provided by the existing rule from which Estate Aerial, Inc.

seeks exemption.

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

Inspire 1 and DJI Phantom 3 Professional sUAS, Estate Aerial, Inc.’s operation of these sUAS 

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

accordance with 14 CFR Part 21, Subpart H.

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

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

the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states, 

in part, the following:

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

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

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

the plan and rule making required by section 332 of this Act or the guidance required by section 334 

of this Act.

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

the Secretary shall determine, at a minimum — 

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

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

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

a threat to national security; and 

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

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

aircraft systems identified under paragraph (1). 

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

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

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

In seeking this exemption, Estate Aerial, Inc. submits that the DJI Inspire 1 and DJI Phantom 3 

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

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

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

Rev. A1.2 Page 7 of 22
DJI Inspire 1 and DJI Phantom 3 Professional sUAS Safe Characteristics 

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

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

velocity, and operational characteristics and capabilities.

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

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

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

software. This capability allows the operator to limit flight operations to a prescribed geographic 

area that has been properly vetted for safety.

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

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

loss of signal to the ground control station. When the signal to the ground control station is lost 

for a period exceeding 3 seconds, the UAV will begin a hovering maneuver at it’s given altitude. 

If the UAV does not reacquire a signal back to the ground control station, it will enter a failsafe 

condition whereby it will commence flight on it’s own and return to the designated home point at 

it’s present altitude. Once reaching the home point, it will hover for 15 seconds, then begin an 

automated descent and commence a safe landing. Immediately following this controlled landing, 

the UAV will shutdown it’s motors and propellers.

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

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

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

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

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

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

Rev. A1.2 Page 8 of 22
TECHNICAL SPECIFICATIONS OF THE DJI PHANTOM 3 PROFESSIONAL SUAS

AIRCRAFT

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

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

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

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

Hover Accuracy

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

• Horizontal: +/- 1.5 m

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

Max Service Ceiling (MSL)

6000 m (Default altitude limit: 120 m above 

takeoff point)

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

GPS MODE

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

GIMBAL

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

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

REMOTE CONTROLLER

Operating Frequency

2.400GHz - 2.483GHz

Max Distance

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

interference) when FCC compliant

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

interference) when CE compliant

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

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

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

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

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

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

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

INTELLIGENT FLIGHT BATTERY

Capacity / Voltage / Battery Type / Energy / Weight

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

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

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

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

CAMERA

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

(total pixels: 12.76 M)

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

focus at ∞

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

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

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

Still Photography Modes

• Single Shot

• Burst Shooting: 3/5/7 shots

• Auto Exposure Bracketing (AEB): 3/5

• Bracketed Frames at 0.7EV Bias

• Time-lapse

VIDEO RECORDING MODES

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

• FHD: 1920x1080p 24/25/30/48/50/60

• HD: 1280x720p 24/25/30/48/50/60

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

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

required

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

Supported File Formats

• FAT32/exFAT

• Photo: JPEG, DNG

• Video: MP4, MOV (MPEG-4 AVC/H.264)

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

VISION POSITIONING

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

ground)

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

Operating Environment

Surface with clear pattern and adequate lighting 

(Lux > 15)

BATTERY CHARGER

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

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

Rev. A1.2 Page 9 of 22
APP/LIVE VIEW

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

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

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

Live View Working Frequency

2.4GHz ISM

Live View Quality

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

Latency

220ms (depending on conditions and mobile device)

Required Operating Systems

• iOS 8.0 or later

• Android 4.1.2 or later

RECOMMENDED DEVICES

iOS

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

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

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

Android

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

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

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

DJI PHANTOM 3 PROFESSIONAL IMAGE REFERENCE

Rev. A1.2 Page 10 of 22
TECHNICAL SPECIFICATIONS OF THE DJI INSPIRE 1 SUAS

AIRCRAFT

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

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

Hovering Accuracy (GPS mode)

Vertical: 0.5 m, Horizontal: 2.5 m

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

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

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

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

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

Max Service Ceiling Above Sea Level

4500 m (Default altitude limit: 120 m above 

takeoff point)

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

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

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

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

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

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

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

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

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

VISION POSITIONING SYSTEM

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

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

Operating Environment

Brightly lit (lux > 15) patterned surfaces

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

GIMBAL

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

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

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

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

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

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

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

CAMERA

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

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

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

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

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

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

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

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

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

Lens

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

9 Elements in 9 groups

Anti-distortion

STILL PHOTOGRAPHY MODES

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed 

frames at 0.7EV Bias

Time-lapse

VIDEO RECORDING MODES

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

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

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

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

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

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

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

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

required.

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

Rev. A1.2 Page 11 of 22
BATTERY (STANDARD)

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

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

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

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

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

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

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

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

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

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

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

BATTERY (OPTIONAL)

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

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

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

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

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

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

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

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

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

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

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

CHARGER

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

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

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

REMOTE CONTROLLER

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

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Maximum Transmitting Distance

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

interference) when FCC compliant

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

interference) when CE compliant

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

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

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

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

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

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

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

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

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

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

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

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

DJI GO APP

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

Supported Mobile Devices

iOS

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

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

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

Android

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

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

Smartisan T1.

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

Rev. A1.2 Page 12 of 22
DJI INSPIRE 1 IMAGE REFERENCE

Proposed Operations and Limitations

In seeking this exemption, Estate Aerial, Inc. proposes to operate the DJI Inspire 1 and DJI 

Phantom 3 Professional sUAS over certain areas of United States for the commercial purpose of 

conducting aerial video and photography, aerial surveying, and aerial inspections, under to the 

following operating limitations.

1. sUAS that are owned and operated by Estate Aerial, Inc. shall be flown only by certificated 

pilots hired directly by Estate Aerial, Inc., possessing at least a private pilot certificate and 

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

2. Estate Aerial, Inc. shall not permit any pilot in command (PIC) to operate sUAS unless the 

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

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

not limited to, evasive and emergency maneuvers. PIC qualification flight hours must be 

logged in a manner consistent with 14 CFR §61.51(b). PIC training flights shall be permitted 

under the terms of the exemption with the condition that training operations be only 

conducted during dedicated training sessions.

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

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

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

spotter may also be utilized to satisfy the visual line-of-sight (VLOS) requirement as per 

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

must be able to verbally communicate at all times.

Rev. A1.2 Page 13 of 22
4. All flights will be conducted during daylight hours only and under visual meteorological 

conditions (VMC). sUAS operations will not be conducted during night, as defined in 14 

CFR §1.1. If night operations is required, a special request shall be made at the FAA 

Standards District Office (FSDO) closest to proposed area of operations.

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

activities at all times.

6. The UAV may not operate within 5 nautical miles of an airport reference point as denoted on 

a current FAA-published aeronautical chart unless a letter of agreement with that airport’s 

management is obtained, and the operation is conducted in accordance with a NOTAM as 

required by the operator’s COA. The letter of agreement with the airport management must 

be made available to the Administrator upon request.

7. The UAV shall only be flown while maintaining VLOS at all times as per Section 333(b)(1). 

At no time shall the pilot-in-command (PIC) rely solely on electronic visual telemetry as to 

constitute the use of “first person view” (FPV) during any flight operations. 

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

UAV flight. sUAS safety considerations include, but are not limited to, weather conditions, airspace, 

obstructions, people, property, UAV limitations, and loss-link of radio signal to ground control 

station equipment. 

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

convey the necessary tasks for conducting a preflight safety risk assessment in order to determine 

that the sUAS is in a condition for safe flight. The result of the tasks outlined on the checklist shall 

be used to determine a “go” or “no-go” decision for each and every flight. sUAS checklists for the 

DJI Inspire 1 and DJI Phantom 3 Professional is annexed hereto as Exhibit A and Exhibit B 

respectively.

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

inspection utilizing the appropriate checklist for the sUAS. The checklist shall insure that each 

component that comprises the sUAS meets the criteria for safe operation as set forth by the 

manufacturers operating manual and for the conditions in which the UAV is to be flown. If the 

preflight inspection reveals a condition that could affect the safe operation of the sUAS, the UAV is 

prohibited from flying until the necessary remedy can be affected in order to restore safe operation to 

the system. If maintenance is required in order to implement a remedy for an unsafe condition, then 

said maintenance must be logged appropriately and the remedy must be verified by the PIC prior to 

the next scheduled flight operation.

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

operating flight area and commence a safe landing should it loses communication with the ground 

control station. If during this “loss-link” failsafe condition, the PIC determines that 

communication to the ground control station has been restored, the PIC shall take command 

of the UAV and commence a safe landing as soon as practicable.

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

time as well as voltage, and informs the PIC how much power is left in the battery in order to 

supply sufficient power for the UAV to sustain flight. The PIC is able to quickly determine 

if enroute operations are to be terminated and a safe landing should commence. The PIC 

Rev. A1.2 Page 14 of 22
shall make every effort to fly the UAV back to the point at which the flight commenced and 

perform a safe landing. In addition, the software implements a “LOW” and "CRITICAL" 

battery level warning indication. If inconsistent drain on the battery occurs due to flight 

conditions or maneuvers, the UAV shall be programmed to intervene normal flight operations 

and initiate an automated direct flight path back to it’s point of origin and commence a 

landing. The PIC will monitor battery capacity during all phases of flight in order to avoid 

this condition.

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

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

point and land the UAV with at least 15% battery power remaining.

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

registered in accordance with 14 CFR §47, and possess the appropriate identifying NNumber markings in accordance with 14 CFR §45 (c). Markings shall be as large as 

practicable for the specific UAV.

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

with expressed permission from the land owner/controller or authorized representative and 

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

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

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

Crew Support Area.

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

shall contain all sUAS equipment and will remain under positive control and supervision by 

authorized personnel at all times. Access to the sUAS Preflight Area shall be restricted to 

authorized personnel only.

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

include a take-off spot, a given flight path, and a landing spot. All flight paths of the designated 

flight area shall remain within visual line-of-sight (VLOS); the take-off and landing spot might 

not be colocated. The pilot-in-command (PIC) shall also identify emergency or abort procedures 

prior to every flight, along with an associated emergency landing spot should flight operations 

need to be aborted or a failsafe condition occur during the flight. These procedures shall be 

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

the PIC prior to commencement and shall only take place in the identified UAV Operations 

Area.

3. A sUAS Crew Support Area will be identified and isolated from every other defined area of 

operation. This area shall contain all elements necessary in supporting the crew associated with 

sUAS operations. At no time shall the Crew Support Area be colocated with the sUAS Preflight 

Area or sUAS Operations Area. The sanctity of each area shall be preserved in order to maintain 

safety of the equipment and support crew.

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

flight operation shall be in accordance with current FARs, advisory circulars, and NOTAMS, and in 

accordance with local, state and federal law.

Rev. A1.2 Page 15 of 22
18. The documents required fewer than 14 CFR §91.9(b)(2) and §91.203 must be available to the 

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

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

request.

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

during any sUAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions and 

limitations contained in the grant of exemption shall take precedence. Otherwise, the 

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

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

operations. It is the operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must also present 

updated and revised documents if it petitions for extension or amendment to the grant of 

exemption. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted the exemption, then the operator must petition for amendment 

to its grant of exemption. The FAA’s UAS Integration Office (AFS-80) shall be contacted if 

questions arise regarding updates or revisions to the operating documents to the extent that 

they could pertain to the exemption under which they were granted.

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

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

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

related to the maintenance or alteration that was made to the sUAS. An entry for each test 

flight shall be made in the aircraft maintenance log.

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

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

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

appropriate maintenance log and be accompanied by the signature of the authorized person 

returning the sUAS to service.

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

bulletins if so published by said manufacturer.

23. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB web site at 

http://www.ntsb.gov.

Rev. A1.2 Page 16 of 22
Public Interest

Granting this exemption will further the public interest by allowing Estate Aerial, Inc. to safely, 

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

inspections over certain areas of the United States.

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

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

the economy. Notably, the benefits of Estate Aerial, Inc.’s proposed operation of said sUAS will 

be realized without implicating any privacy issues.

The Public Will Benefit From Decreased Congestion Of The NAS

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

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

aerial imagery. The DJI Inspire 1 and DJI Phantom 3 Professional sUAS do not require an 

airport for takeoff or landing. By reducing the amount of manned aircraft in the NAS needed to 

perform low-altitude aerial imagery by way of this exemption, thus allowing the use of said 

sUAS, a reduction in noise pollution and carbon-based emissions pollution would occur. And 

most importantly, the safety of people and property in the air and on the ground would increase 

dramatically.

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

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

manned aircraft will result in fewer aircraft that must be handled by air traffic control during the 

ground, departure, enroute, arrival, and landing phases of flight operations in the NAS.

The Public Will Benefit From The Safety And Efficiency Of sUAS

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

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

and noise pollution as compared to that generated during traditional low-altitude aerial imagery 

flight operations. Moreover, by using battery-powered electric motors, the DJI Inspire 1 and DJI 

Phantom 3 Professional sUAS produce zero air pollution. This is in stark contrast to the 

pollution generated by the approximately 20-30 gallons per hour of leaded aviation fuel that is 

burned by traditional cabin class, 6-cylinder, internal combustion aircraft engines during lowaltitude aerial video and photography operations. In addition, the DJI Inspire 1 and DJI Phantom 

3 Professional sUAS also greatly reduce noise pollution due to the fact that they utilize relatively 

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

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

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

in some cases, completely eliminated when compared to traditional manned aircraft flight 

operations. Risk to life is immediately eliminated due to the fact that sUAS, by definition, do not 

possess a flight crew onboard.

Rev. A1.2 Page 17 of 22
In addition, the DJI Inspire 1 and DJI Phantom 3 Professional sUAS weigh 6.47 pounds and 2.82 

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

approximately 6,000 pounds. Since the amount of force produced by an object is it’s mass 

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

laws of physics, possess less force and therefore less potential for physical damage to life and 

property on the ground and in the air.

Performing Aerial Video and Photography Operations Utilizing sUAS Will 

Benefit The Economy

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

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

operations. It follows that companies based in the United States, like Estate Aerial, Inc., that are 

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

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

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

owned and operated companies must adopt new and alternative technologies in order to remain 

competitive in a global market. Operating the battery-powered DJI Inspire 1 and DJI Phantom 3 

Professional sUAS is one such technology that not only allows companies greater operational 

flexibility compared to traditional manned aircraft, but provides this flexibility without the high 

operational costs associated with traditional manned aircraft.

By operating the DJI Inspire 1 and DJI Phantom 3 Professional sUAS, Estate Aerial, Inc. can 

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

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

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

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

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

competitive both in the United States of America and abroad.

There Are No Privacy Issues 

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

acquire aerial imagery, Estate Aerial, Inc.’s proposed operation of the DJI Inspire 1 and DJI 

Phantom 3 Professional sUAS will not impose any privacy issues.

No sUAS flight operations shall commence without the expressed permission of the property 

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

federal laws when applicable and in accordance with the terms and stipulations set forth in this 

exemption and the FAA.

Rev. A1.2 Page 18 of 22
Conclusion

As set forth herein, Estate Aerial, Inc. respectfully seeks an exemption pursuant to 14 CFR 

§11.61 and Section 333 of the FMRA of 2012. This exemption will allow the safe operation of 

the DJI Inspire 1 and DJI Phantom 3 Professional sUAS for commercial purposes - without an 

airworthiness certificate - for the limited purpose of conducting aerial video and photography, 

aerial surveying, and aerial inspections over certain areas of the United States. By granting this 

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

2012 while also advancing the interests of the public by allowing Estate Aerial, Inc. to safely, 

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

commercial purposes within the NAS.

Respectfully,

submitted this 5th day of February 2016

Hal M. Staniloff, President

Estate Aerial, Inc., Inc.

P.O. Box 702

Setauket, NY 11733

(631) 371-4676 ・hal@estateaerial.com

Rev. A1.2 Page 19 of 22
Exhibits

Exhibit A - DJI Inspire 1 sUAS Checklist 

Rev. A1.2 Page 20 of 22

Checklist DJI - Inspire 1

PreFlight

➡ Landing Gear Extended

➡ Install Props - Check Position/Secured

➡ Install Gimbal/Camera - Secured

➡ Motors - Secured

➡ VPS - Clear

➡ Gimbal Dampeners - Secured

➡ SD Card - Installed

➡ Lens Cover - Remove

➡ Gimbal Lock - Remove

➡ Battery - Installed/Charged

➡ Tablet Computer - Installed/Secured

➡ USB - Connected

➡ Tablet On - Charged

➡ TX On - Charged

➡ TX Antennas - Erect/Parallel

➡ DJI App - Invoked

➡ Neck Strap - On/Attached

Before Take-off

➡ Power - On

➡ Battery -Charged

➡ Camera - Live

➡ State - Validate

➡ Compass - Calibrated

➡ Camera Settings -Verified

➡ Satellites - Acquired

➡ Home Point - Recorded

Take-off

๏ Environment - Cleared & 

Secured

๏ Obstructions - None

๏ Flight Plan - Reviewed

CLEARED FOR DEPARTURE

Before Landing

๏ Environment - Secured

๏ Obstructions - None

๏ Landing Gear - Extended

After Landing

➡ PH3 Power - Off

➡ TX - Off

➡ DJI APP - Closed

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

Rev. A1.2 Page 21 of 22

Checklist DJI - Phantom 3 Professional

PreFlight

➡ Install Props - Check Position/Secured

➡ Gimbal/Camera - Secured

➡ Motors - Secured

➡ VPS - Clear

➡ Gimbal Dampeners - Secured

➡ SD Card - Installed

➡ Lens Cover - Remove

➡ Gimbal Lock - Remove

➡ Battery - Installed/Charged

➡ Tablet Computer - Installed/Secured

➡ USB - Connected

➡ Tablet On - Charged

➡ TX On - Charged

➡ TX Antennas - Erect/Parallel

➡ DJI App - Invoked

➡ Neck Strap - On/Attached

Before Take-off

➡ Power - On

➡ Battery -Charged

➡ Camera - Live

➡ State - Validate

➡ Compass - Calibrated

➡ Camera Settings -Verified

➡ Satellites - Acquired

➡ Home Point - Recorded

Take-off

๏ Environment - Cleared & 

Secured

๏ Obstructions - None

๏ Flight Plan - Reviewed

CLEARED FOR DEPARTURE

Before Landing

๏ Environment - Secured

๏ Obstructions - None

๏ Landing Gear - Extended

After Landing

➡ PH3 Power - Off

➡ TX - Off

➡ DJI APP - Closed

➡ Tablet - Off
Exhibit C - Example sUAS Maintenance Log 

Rev. A1.2 Page 22 of 22

DJI Phantom 3 Professional Service Log [N-Number]

Service and Maintenance Record

Date Total Time Maintenance Performed