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Daniela Trujillo 

10030 sw tigard st Tigard, OR 97223 

Tel: 503-510-1733 

Email: Danielatrujillo1993@gmail.com

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: DANIELA. TRUJILLO

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

(a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION

DJI Phantom2 UNMANNED AIRCRAFT SYSTEMS FOR THE COMMERCIAL PURPOSE OF 

CONDUCTING AERIAL VIDEO AND PHOTOGRAPHY OF CONSTRUCTION SITES, REAL ESTATE, 

SPECIAL EVENTS, FILM SETS , AND LANDSCAPE OVER CERTAIN AREAS OF THE UNITED STATES.

AGL.

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95) 

GLOSSARY OF ABBREVIATIONS 
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AGL Above Ground Level 

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

DJI Dji Phantom 2 subject of petition 

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM National Airspace System Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UAV Unmanned Aircraft Vehicle

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing 

INTRODUCTION AND INTERESTS OF THE PETITIONER 
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DANIELA TRUJILLO’S primary occupation is member of multiple media Companies and 

has hundreds of hours as a UAS hobbyist. From time to time she is asked to support 

local community, small businesses and charitable activities by providing aerial 

photography or videography. with no exemption,DANIELA TRUJILLO must decline to support to 

support these interest. The objective of Daniela Trujillo and her Unmanned Aircraft 

System (DJI Phantom 2) aerial operations is to provide a more affordable, high-quality 

production system for a variety of governmental, commercial, public, and residential 

uses, specifically targeting 

● Construction sites before and after

● Appraisals

● Real-estate marketing

● Economic development

● Civic landmarks

● Special event coverage

● Aerial photography/videography of houses / residential and commercial buildings 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 (Hereafter the DJI UAS Aircraft)

Daniela Trujillo seeks an exemption to operate a DJI Phantom 2 UAS systems for 

compensation or hire within the NAS. The Phantom 2 is vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. 

DJI Phantom 2 has a maximum gross weight of approximately 3 pounds, a length of 17.3 inches, 

width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 30 knots. 

The Phantom 2 is equipped with four main rotors; driven by Lithium Polymer battery powered 

electric motors. 

BASIS FOR PETITION
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Petitioner, DANIELA TRUJILLO, 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 UAS Aircraft 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, DANIELA TRUJILLO operation DJI UAS Aircraft 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, DANIELA TRUJILLO 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.

DANIELA TRUJILLO submits that the requested relief is proper since an equivalent level of safety 

will be ensured. DANIELA TRUJILLO 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.

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

and limitations: Pilot in command, is requested by DANIELA TRUJILLO to the extent necessary to 

allow a Pilot in Command (PIC) with significant experience in the field of UAV’s, and who has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able 

to safely operate the DJI UAS Aircraft in a manner consistent with this exemption, including 

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

vehicles and structures.

DANIELA TRUJILLO seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI UAS Aircraft do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, DANIELA TRUJILLO submits that he will ensure the DJI
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UAS Aircraft are in an airworthy condition, prior to every flight, by determining that the UASs 

are in compliance with the operating documents and that the aircraft are in a condition for safe 

flight.

DANIELA TRUJILLO also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, DJI UAS aircraft will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI UAS Aircraft will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, which 

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

information, combined with DANIELA TRUJILLO operation of the DJI UAS Aircraft within visual 

line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, DANIELA TRUJILLO seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. DANIELA TRUJILLO submits 

that safety will not be affected by operation of the DJI UAS Aircraft 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 15 minutes to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 5 minutes.

In accordance with 14 C.F.R. § 11.81, DANIELA TRUJILLO provides the following information in 

support of its petition for exemption:

Name And Address Of The Petitioner.

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

DANIELA TRUJILLO

10030 sw Tigard st 

Tigard, OR 97223

503-510-1733

Danielatrujillo1993@gmail.com

The Specific Sections Of 14 C.F.R. From Which DANIELA TRUJILLO Seeks 

Exemption.

 DANIELA TRUJILLO 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:

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

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

connection with any business or employment if—

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

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

DANIELA TRUJILLO 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.

DANIELA TRUJILLO Seeks Exemption From The Requirements Of Section 91.121.

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

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—

Below 18,000 feet MSL, to--

The current reported altimeter setting of a station along the route and within 100 nautical miles 

of the aircraft;

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

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.

DANIELA TRUJILLO 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.

DANIELA TRUJILLO Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:
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Each owner or operator of an aircraft—

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[.]

DANIELA TRUJILLO 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:

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

maintenance, rebuilding, or alteration unless--

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

chapter[.]

DANIELA TRUJILLO 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:

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 --

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

An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.

DANIELA TRUJILLO 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:

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:

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 
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(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

includeA description (or reference to data acceptable to the Administrator) of the work performed; 

and

The date of completion of the work performed; and

The signature and certificate number of the person approving the aircraft for return to service.

Records containing the following information:

The total time in service of the airframe, each engine, each propeller, and each rotor.

The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis.

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.

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.

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. The owner or 

operator shall retain the following records for the periods prescribed: 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.

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.

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.

The Extent of Relief DANIELA TRUJILLO Seeks and The Reason DANIELA TRUJILLO Seeks the 

Relief.
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Extent of Relief DANIELA TRUJILLO Seeks and The Reason DANIELA TRUJILLO 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, DANIELA TRUJILLO submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Phantom 2 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 2 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, DANIELA TRUJILLO submits that all flights of DJI UAS aircraft, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to DANIELA TRUJILLO business; and 

(2) will not carry passengers or property for compensation or hire.

Extent of Relief DANIELA TRUJILLO Seeks and The Reason DANIELA TRUJILLO 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 DANIELA TRUJILLO to determine that the DJI UAS Aircraft are in 

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

the operating documents (i.e., the DANIELA TRUJILLO Aerial Operations Manual, 

Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual).

DANIELA TRUJILLO seeks the requested relief because the DJI UAS Aircraft do not 

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

Therefore, DANIELA TRUJILLO will ensure that the DJI UAS Aircraft are in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly
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Maintenance Log, and DJI UAS Aircraft Instruction Manual) prior to every flight, and 

further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below.

Extent of Relief DANIELA TRUJILLO Seeks and The Reason DANIELA TRUJILLO Seeks Relief 

from Section 91.121.

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

DJI UAS Aircraft, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the 

ground control station (GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), DANIELA TRUJILLO 

seeks the requested relief because the DJI UAS Aircraft 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 UAS Aircraft are equipped 

with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level 

pressure setting will be established prior to each flight, and provides the PIC with altitude information of 

the UA on the heads-up display of the GCS.

Extent of Relief DANIELA TRUJILLO Seeks and The Reason DANIELA TRUJILLO 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 UAS Aircraft during 

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. MICHAEL E. OLSEN seeks the requested 

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

battery powered DJI UAS Aircraft will severely constrain the practicality of any aerial video or 

still photo flight operations that DANIELA TRUJILLO proposes to conduct pursuant to this 

Petition.

Significantly, as set forth below, the technical specifications of the DJI UAS Aircraft operating 

documents, and DANIELA TRUJILLO proposed operating limitations, ensure that DANIELA 

TRUJILLO will safely operate the battery powered DJI UAS Aircraft during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery 
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power to fly for a total duration of 15 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 5 minutes.

Extent of Relief DANIELA TRUJILLO Seeks and The Reason DANIELA TRUJILLO 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, DANIELA TRUJILLO requests relief from these

Sections because the DJI UAS Aircraft do not require airworthiness certificates. As set forth 

more fully below, DJI UAS Aircraft meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate.

Accordingly, DANIELA TRUJILLO will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, techniques, and 

practices prescribed in the UAS operating documents (i.e., the DANIELA TRUJILLO Aerial 

Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction Manual). 

Furthermore, DANIELA TRUJILLO will document and maintain all maintenance records for the 

DJI UAS Aircraft.

The Reasons Why Granting DANIELA TRUJILLO 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 DANIELA TRUJILLO to 

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

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

Additionally, use of the DJI UAS Aircraft will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of DANIELA TRUJILLO 

proposed operation of the DJI UAS Aircraft will be realized without implicating any privacy 

issues.

The Public Will Benefit from Decreased Congestion of The NAS.

DJI UAS Aircraft are battery powered and serve as a safe, efficient, and economical

alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a DJI UAS Aircraft would reduce the amount of manned 
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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 UAS Aircraft do not require an airport to takeoff or land. Likewise,

a reduction of manned aircraft conducting aerial video

and photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

The Public Will Benefit from The Safety and Efficiency of The DJI UAS Aircraft

Conducting aerial acquisitions with the DJI UAS Aircraft, 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 UAS Aircraft produce no air pollution, 

and is the most viable environmentally conscious alternative to the cabin class, six 

cylinder internal combustion engine aircraft that are typically utilized for aerial video 

and photography, while burning approximately 20-30 gallons per hour of leaded 

aviation fuel. The DJI UAS aircraft, while reducing the carbon footprint of aerial 

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

powered electric motors, rather than an internal combustion engine.

By using the DJI UAS Aircraft 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 UAS Aircraft(weighing 

approximately 3 pounds respectively, at their maximum gross weights with lengths of 16 inches 

and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel 

on board), has less physical potential for collateral damage to life and property on the ground, 

and in the air, compared to the manned aircraft that typically conduct similar operations 

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

feet, and a fuel capacity of 180 gallons).

Performing Aerial Video and Photography Operations with The DJI UAS Aircraft Will Benefit 

the Economy.

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

alternative to using manned aircraft to conduct similar aerial operations. As such, 
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operation of the DJI UAS Aircraft will allow United States based companies, like DANIELA 

TRUJILLO 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 UAS Aircraft 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 UAS aircraft, petitioners such as DANIELA TRUJILLO 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 UAS Aircraft, provides a stable workforce 

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

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

United States and abroad.

There Are No Privacy Issues.

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

decades, DANIELA TRUJILLO proposed operation of the DJI UAS Aircraft will not 

implicate any privacy issues. Specifically, the DJI UAS Aircraft will be operated only in 

compliance with operating documents (i.e., the DANIELA TRUJILLO Aerial Operations 

Manual, Monthly Maintenance Log, and DJI UAS Aircraft 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.

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 DANIELA TRUJILLO Seeks Exemption.

Reasons Why The DJI UAS Aircraft Meet the Conditions of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333.

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

the unmanned aircraft and its operation, DANIELA TRUJILLO operation of the DJI UAS 

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

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

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.

Assessment of Unmanned Aircraft Systems. --In making the determination under subsection 

(ate Secretary shall determine, at a minimum—

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

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). Requirements for Safe Operation. —

If the Secretary determines under this section that certain u), nmanned 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, DANIELA TRUJILLO submits that the DJI UAS Aircraft can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of 

the DJI UAS aircraft; (b) the pilot certification requirement; and (c) the specific operating 

limitations.

The Specifications of The DJI UAS Aircraft Demonstrate Its Safe Characteristics.

The DJI UAS Aircraft do not create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security considering its size, weight, speed, and operational capability.

Technical Specifications of DJI UAS Aircraft.
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The technical specifications of the DJI UAS Aircraft are set forth by the DJI UAS aircraft User 

Manuals, attached hereto as Appendix A and B.

The DJI UAS Aircraft Autonomous Flight and Navigation Modes Enable The UASs to Remain 

Within a Defined Operational Area.

The DJI UAS Aircraft may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the DJI UAS Aircraft 

provided in the User Manuals, attached hereto as Appendix A and B.

The DJI UAS Aircraft 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 UAS Aircraft will remain stationary, in flight, for 3 seconds 

or more. If, after 3 seconds, the DJI UAS Aircraft do not reacquire control link data from the 

GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home 

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

A complete description of the Failsafe Functions of the DJI UAS aircraft are described in the 

User Manuals, attached hereto as Appendix A and B.

DJI UAS Aircraft GCS Operation.

Phantom 2 GCS and flight control software is provided in the User Manual for the DJI UAS 

aircraft attached hereto as Appendix A and B.

Flight Operations of DJI UAS Aircraft are Limited to The Line of Sight of a Certificated Pilot in 

Command with A Safety Observer.

DANIELA TRUJILLO will be the only person to act as a pilot in command (PIC) of DJI UAS Aircraft.

Flights of DJI UAS Aircraft Will Be Conducted Pursuant to Specific Operating Limitations.

In seeking this exemption, DANIELA TRUJILLO proposes to commercially operate DJI UAS 

Aircraft 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 
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maximum gross weight: DJI UAS AIRCRAFT. 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 45 knots.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

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

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

feet AGL. 

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

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

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

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

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

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

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

permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perform the functions prescribed in the operating documents. 

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

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

permitted to operate the camera or other instruments. 

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

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

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

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

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

the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to the grant of exemption. If the 

operator determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the operator must petition for amendment to its grant 

of exemption. The FAA’s UAS Integration Office (AFS- 80) may be contacted if questions 

arise regarding updates or revisions to the operating documents. 
17

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

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

UAS, the aircraft is prohibited from operating until the necessary maintenance has been 

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

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

must be properly documented in the aircraft records. 

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

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

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

in the aircraft records.

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

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

operating documents.

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

overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description 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. 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. 

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

18. § 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 
18

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

authorized.

19. 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. 

20. The UAV 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. 

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

accordance with the operating documents.

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

accordance with the operating documents.

23. 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 UAV with 25% battery power remaining.

24. 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.

25. 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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable.

26. Before conducting operations, the radio frequency spectrum used for operation and 

control of the UAV must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements.

27. 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.

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

and activities at all times.
19

29. The UAV may not be operated by the PIC from any moving device or vehicle.

30. 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:

31. Barriers or structures are present that sufficiently protect nonparticipating persons from 

the UAV 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;

32. 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;

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

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

34. 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.

35. 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.

36. Accidents must be reported to the National Transportation Safety Board (NTSB) per 

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

Reasons Why an Exemption from The Requirements of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety.

DANIELA TRUJILLO submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the DJI UAS Aircraft unless 

that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that 

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

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering DANIELA TRUJILLO proposed area of operations, and the operating limitations set 

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

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

necessary to safely operate the DJI UAS aircraft, DANIELA TRUJILLO submits that the training, 
20

preparation, practice, and experience of the Petitioner is sufficient to meet the requirements of 

the proposed use. 

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).

DANIELA TRUJILLO will not allow any PIC to operate the DJI UAS Aircraft unless the PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI UAS Aircraft training 

and currency requirements, that the PIC is able to safely operate the DJI UAS Aircraft 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 MICHAEL E. OLSEN 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 
21

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 experiencebuilding 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 UAS with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, DANIELA TRUJILLO will ensure safe operations by not allowing any PIC to operate 

DJI UAS Aircraft unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI UAS Aircraft in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

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, MICHAEL E. OLSEN will ensure that DJI UAS Aircraft 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).

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 UAS Aircraft 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 DANIELA 
22

TRUJILLO operation of the DJI UAS Aircraft within visual line of sight, at or below 400 feet AGL, 

will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude 

initiation point is automatically established by the 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).

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 UAS Aircraft; (2) the 

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

operations. Accordingly, DANIELA TRUJILLO will ensure that it will safely operate the battery 

powered DJI UAS Aircraft during daylight hours in VFR conditions, with enough battery power 

to fly for a total duration of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI UAS Aircraft UASs; the 

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

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

safety will be ensured as the DJI UAS Aircraft provide audible and visual warnings to the PIC at 

the GCS when the UAs experiences low battery voltage, the first warning occurring at 

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

battery power. At the critically low battery level, the DJI Phantom 2 UASs 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).
23

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, DANIELA TRUJILLO 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 DANIELA 

TRUJILLO will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

operating documents (i.e., the DANIELA TRUJILLO Aerial Operations Manual, Monthly 

Maintenance Log, and DJI UAS Aircraft Instruction Manual).

Furthermore, DANIELA TRUJILLO will document and maintain all maintenance records for the 

DJI UAS Aircraft UASs.

Since the DJI UAS Aircraft will be inspected as prescribed by the operating documents, DANIELA 

TRUJILLO 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 UAS Aircraft User Manuals are attached hereto 

as Appendix A and B; a copy of the DJI UAS Aircraft Maintenance LOG is attached hereto as 

Appendix C.

Likewise, the exemption sought will not adversely affect safety because DANIELA TRUJILLO

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 UAS Aircraft 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 DANIELA TRUJILLO proposed operating limitations, the operating 

documents, and the technical aspects of the DJI UAS Aircraft, DANIELA TRUJILLO 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 
24

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

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

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, DANIELA TRUJILLO

requests that the FAA prescribe special conditions for the intended operation of the DJI UAS 

Aircraft UASs, which contain such safety standards that the Administrator finds necessary to 

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

C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

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

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

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

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

such UAS to operate without airworthiness certification in accordance with any requirements 

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

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the DJI UAS Aircraft UASs, since the airworthiness regulations of 14 C.F.R. Part 21 

do not contain adequate or appropriate safety standards, due to the novel or unusual design 

features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

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

or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel 

or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for the aircraft, 

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

to that established in the regulations.

See 14 C.F.R. § 21.16.

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

special conditions for Leading Edge’s intended operation of the DJI UAS Aircraft, 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).
25

A Summary That Can Be Published in The Federal Register, stating: The Rules from Which 

DANIELA TRUJILLO Seeks Exemption:

DANIELA TRUJILLO 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 DANIELA TRUJILLO Seeks:

This exemption will permit DANIELA TRUJILLO 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 DANIELA TRUJILLO 

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, DANIELA TRUJILLO 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, DANIELA TRUJILLO will operate DJI UAS aircraft 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,DANIELA TRUJILLO 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 UAS Aircraft 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 
26

2012, while also advancing the interests of the public, by allowing DANIELA TRUJILLO to 

safely, efficiently, and economically operate the DJI UAS Aircraft commercially within 

the NAS.

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

Modernization and Reform Act of 2012, Section 333, DANIELA TRUJILLO respectfully 

requests that the Administrator grant this Petition for an exemption from the 

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to 

operate the DJI UAS Aircraft commercially for the purpose of conducting aerial video 

and photography over certain areas of the United States. 

Dated September 28, 2015 

Thank you,

Daniela Trujillo 

10030 sw Tigard St 

Tigard Or 97223

503-510-1733 

Danielatrujillo1993@gmail.com
27

Aircraft

Weight (Battery & Propellers Included)

1000g

Hover Accuracy (Ready To Fly)

Vertical: 0.8m;

Horizontal: 2.5m

Max Yaw Angular Velocity

200°/s

Max Tilt Angle

35°

Max Ascent / Descent Speed

Ascent: 6m/s; Descent: 2m/s

Max Flight Speed

15m/s(Not Recommended)

Diagonal Length

350mm

Flight Time

25mins

Take-Off Weight

≤1300g

Operating Temperature -10°C ~ 50°C

Supported Battery

DJI Smart Battery

DJI Smart Battery

Type
28

3S LiPo

Capacity

5200mAh, 11.1V

Charging Environment Range

0 to 40

Discharging Environment Range

-20 to 50

Gimbal

Model

ZENMUSE X3

Output Power (With Camera

Static: 9 W

In Motion: 11 W

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 
29