UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Windermere Drone, LLC

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 OF A DJI INSPIRE 1 & DJI Phantom 3 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on January 1, 2016

Jeremy Mammen

Windermere Drone, LLC

11531 Wakeworth St

Orlando, FL 32836

(407) 790-6477

Email: jeremycmammen@gmail.com
2

TABLE OF CONTENTS Page 

GLOSSARY OF ABBREVIATIONS........................................................................................3 

SUMMARY................................................................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER........................................................4

BACKGROUND.......................................................................................................................5

BASIS FOR PETITION.............................................................................................................5 

NAME AND ADDRESS OF PETITIONER.............................................................................6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WINDERMERE 

DRONE, LLC SEEKS EXEMPTION.......................................................................................7 

THE EXTENT OF RELIEF WINDERMERE DRONE, LLC SEEKS AND THE 

REASON WINDERMERE DRONE, LLC SEEKS THE RELIEF.........................................10

THE REASONS WHY GRANTING WINDERMERE DRONE, LLC REQUEST 

WOULD BE IN THE PUBLIC INTEREST ..........................................................................10 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................................12 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......................26

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT WINDERMERE DRONE LLC's REQUEST.........................26

CONCLUSION........................................................................................................................27

APPENDICES..........................................................................................................................28
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

DJI UAV manufacturer 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

FPV First Person View 

ESC Electronic speed control 

GCS Ground Control Station 

GPS Global Positioning System 

LI-PO Lithium Polymer battery 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

RCV Radio Controlled vehicle 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
4

SUMMARY

WINDERMERE DRONE, LLC seeks exemption from the requirements of 14 C.F.R §§ 

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

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit WINDERMERE 

DRONE, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography high-quality aerial photography and videography of 

special events, sporting events, resorts and hotels, tourism destinations, weddings, landscapes,

real estate listings, residential and commercial building sites, civic landmarks, film making, 

economic development, golf courses, UAS operator training and other building or structural 

inspections over certain areas of the United States and increase public knowledge of UAS and 

promote safe UAS operations.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Jeremy Mammen, owner and president of WINDERMERE DRONE, LLC. I 

have more than 15 years of aviation experience and a strong background in aviation safety. I’m 

currently a licensed commercial pilot with knowledge of all FAA regulations. I have flight 

experience as PIC of numerous aircraft, including Cessna Skyhawk, Cirrus SR20, Piper Arrow 

and the Piper Seminole. 

The objective of WINDERMERE DRONE, LLC is to provide high-quality aerial 

photography and videography of special events, sporting events, resorts and hotels, tourism 

destinations, weddings, landscapes, real estate listings, residential and commercial building sites, 

civic landmarks, film making, economic development, golf courses, UAS operator training and 

other building or structural inspections. WINDERMERE DRONE, LLC will also provide 

knowledge of UAS and promote safe UAS operations. 
5

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 and DJI Inspire 1 UASs

WINDERMERE DRONE, LLC seeks an exemption to operate DJI systems for compensation 

or hire within the National Airspace System (NAS). The DJI Phantom 3 and DJI Inspire 1 are 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station 

(GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum 

gross weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 

16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 

1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 

inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI 

Phantom 3 and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors. 

The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by WINDERMERE 

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

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

45, Identification and Registration Markings. 

BASIS FOR PETITION

Petitioner, WINDERMERE DRONE, LLC, pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions 

the Administrator to commercially operate the DJI Phantom 3, DJI Inspire 1 UASs 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, WINDERMERE DRONE, LLC operation of DJI Phantom 3 

and DJI Inspire 1 UASs 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, WINDERMERE DRONE, LLC requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements 

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

WINDERMERE DRONE, LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. WINDERMERE DRONE, LLC will use experienced 

personnel or technicians to perform maintenance, alterations, or preventive maintenance on the 

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

Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 User Manual). Furthermore, 

WINDERMERE DRONE, LLC will document and maintain all maintenance records for the DJI 

Phantom 3 and DJI Inspire 1 UASs (as described under appendix D). 
6

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

privileges and limitations: Pilot in command, is requested by WINDERMERE DRONE, LLC to 

the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 3 and DJI Inspire 1 UASs in a manner consistent with this exemption, including 

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

vehicles and structures. 

WINDERMERE DRONE, LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 and DJI Inspire 1 UASs do not require an 

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

WINDERMERE DRONE, LLC submits that he will ensure that the DJI Phantom 3 and DJI 

Inspire 1UASs are in an airworthy condition, prior to every flight, by determining that the UASs 

are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Phantom 3 and DJI Inspire 1 User Manual), and that the aircraft are in a condition for safe flight. 

WINDERMERE DRONE, LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 and 

DJI Inspire 1UAs 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 WINDERMERE 

DRONE, LLC operation of the DJI Phantom 3 and DJI Inspire 1 UASs within visual line of 

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

Additionally, WINDERMERE DRONE, LLC seeks an exemption from the requirements of 

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

DRONE, LLC submits that safety will not be affected by operation of the DJI Phantom 3 and 

DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC) under visual 

flight rules (VFR), with enough battery power to fly for a total duration of approximately 15.5 

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

that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, WINDERMERE DRONE, LLC provides the 

following information in support of its petition for exemption: 

A. Name and Address of the Petitioner.

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

JEREMY MAMMEN

WINDERMERE DRONE, LLC

11531 WAKEWORTH ST

ORLANDO, FL 32836

Email: jeremycmammen@gmail.com
7

B. The Specific Sections of 14 C.F.R. from Which WINDERMERE DRONE, LLC

Seeks Exemption.

1. WINDERMERE DRONE, LLC Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and 

limitations: Pilot in command, Subsections (a) and (b) prescribe the following, in relevant 

part: 

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

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

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

connection with any business or employment if—

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

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

hire. 

2. WINDERMERE DRONE, LLC Seeks Exemption From The Requirements Of 

Section 91.7(a). Section 91.7, entitled Civil Aircraft Airworthiness, subsection (a), states 

the following: 

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

3. WINDERMERE DRONE, LLC Seeks Exemption From The Requirements Of 

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

following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

level of that aircraft, as the case may be, by reference to an altimeter that is 

set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; 

(iii) In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available 

before departure. 
8

4. WINDERMERE DRONE, LLC Seeks Exemption From The Requirements Of 

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

conditions, subsection (b), states the following: 

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

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

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

fly after that for at least 20 minutes. 

5. WINDERMERE DRONE, LLC Seeks Exemption From The Requirement Of 

Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states 

the following: Each owner or operator of an aircraft—

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

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

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

6. WINDERMERE DRONE, LLC Seeks Exemption From The Requirements Of 

Section 91.407(a) Section 91.407, entitled Operation after maintenance, preventive 

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

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

preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 

43.7 of this chapter.

7. WINDERMERE DRONE, LLC Seeks Exemption From The Requirements Of 

Sections 91.409(a)(1) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection 

(a), states the following: 

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

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

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

been approved for return to service by a person authorized by § 43.7 of 

this chapter; or 

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

with part 21 of this chapter. 

8. WINDERMERE DRONE, LLC Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, 

subsections (a) and (b), state the following: 

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

registered owner or operator shall keep the following records for the periods 
9

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 (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include—

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

the work performed; and 

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

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

aircraft for return to service. 

(b) Records containing the following information: 

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

and each rotor. 

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

propeller, rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 

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

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

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

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

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

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(c) The owner or operator shall retain the following records for the periods 

prescribed: 

(i) 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. 
10

(ii) 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. 

(iii) A list of defects furnished to a registered owner or operator under § 

43.11 of this chapter shall be retained until the defects are repaired 

and the aircraft is approved for return to service. 

C. The Extent Of Relief WINDERMERE DRONE, LLC Seeks And The Reason 

WINDERMERE DRONE, LLC Seeks The Relief. 

1. Extent Of Relief WINDERMERE DRONE, LLC Seeks And The Reason 

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

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

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

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

medical certificate, and who has met certain flight-hour and currency requirements, to 

conduct the proposed UAS flight operations for compensation or hire. 

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

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to 

that business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. 

As set forth more fully below, WINDERMERE DRONE, LLC submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to 

operate the DJI Phantom 3 UAS or DJI Inspire 1 UAS unless that PIC has met certain 

flight-hour and currency requirements, demonstrating that the PIC is able to safely 

operate either the DJI Phantom 3 or DJI Inspire 1 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, WINDERMERE DRONE, LLC submits that 

all flights of the DJI Phantom 3 and DJI Inspire 1 UASs, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to WINDERMERE 

DRONE, LLC business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief WINDERMERE DRONE, LLC Seeks And The Reason 

WINDERMERE DRONE, LLC 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 WINDERMERE DRONE, LLC to determine that the DJI 

Phantom 3 and DJI Inspire 1 UASs are in airworthy condition prior to every flight by 

ensuring that the UAS is in compliance with the operating documents (i.e., 
11

WINDERMERE DRONE, LLC Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). 

WINDERMERE DRONE, LLC seeks the requested relief because the DJI 

Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, WINDERMERE DRONE, 

LLC will ensure that the DJI Phantom 3 and DJI Inspire 1 UASs are in airworthy 

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

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 User 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. 

3. Extent Of Relief WINDERMERE DRONE, LLC Seeks And The Reason 

WINDERMERE DRONE, LLC Seeks Relief From Section 91.121. 

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

flight operations of the DJI Phantom 3 and DJI Inspire 1 UASs, 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), WINDERMERE DRONE, LLC seeks the requested relief 

because the DJI Phantom 3 and DJI Inspire 1 UA’s altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or field altitude, 

before each flight. 

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

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

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

will be maintained since the DJI Phantom 3 and DJI Inspire 1 UAs are equipped with 

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

ground level pressure setting will be established prior to each flight, and provides the 

PIC with altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief WINDERMERE DRONE, LLC Seeks And The Reason 

WINDERMERE DRONE, LLC Seeks Relief From Section 91.151(b).

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

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

DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total duration of 15.5 

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

fly after that for at least 4.5 minutes. WINDERMERE DRONE, LLC seeks the 

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

duration of the battery powered DJI Phantom 3 and DJI Inspire 1 UAs will severely 
12

constrain the practicality of any aerial video or still photo flight operations that 

WINDERMERE DRONE, LLC proposes to conduct pursuant to this Petition. 

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

and DJI Inspire 1 UASs, the DJI Phantom 3 and DJI Inspire 1 operating documents, 

and WINDERMERE DRONE, LLC proposed operating limitations, ensure that 

WINDERMERE DRONE, LLC will safely operate the battery powered DJI Phantom 

3 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions 

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

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

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

5. Extent Of Relief WINDERMERE DRONE, LLC Seeks And The Reason 

WINDERMERE DRONE, LLC Seeks Relief From Sections 91.405(a), 

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

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

(b) only apply to aircraft with an airworthiness certificate, WINDERMERE DRONE, 

LLC requests relief from these Sections because the DJI Phantom 3 and DJI Inspire 1 

UASs do not require airworthiness certificates. As set forth more fully below, the DJI 

Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for

operation without an airworthiness certificate. Accordingly, WINDERMERE

DRONE, LLC 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., WINDERMERE DRONE, LLC

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

Inspire 1 User Manual). Furthermore, WINDERMERE DRONE, LLC will document 

and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs. 

D. The Reasons Why Granting WINDERMERE DRONE, LLC Request Would Be In 

The Public Interest: That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing WINDERMERE 

DRONE, LLC to safely, efficiently, and economically perform high-quality aerial 

photography and videography of special events, sporting events, resorts and hotels, tourism 

destinations, weddings, landscapes, real estate listings, residential and commercial building 

sites, civic landmarks, film making, economic development, golf courses, UAS operator 

training and other building or structural inspections over certain areas of the United States. 

Additionally, use of the DJI Phantom 3 and DJI Inspire 1 UASs will decrease congestion 

of the NAS, reduce pollution, crashes and accidents caused by pilot error and provide 

significant benefits to the economy. Notably, the benefits of WINDERMERE DRONE, LLC

proposed operation of the DJI Phantom 3 and DJI Inspire 1 UASs will be realized without 

implicating any privacy issues. 
13

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

The DJI Phantom 3 and DJI Inspire 1 UAs 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 Phantom 3 or DJI Inspire 1 UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, 

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

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

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

DJI Phantom 3 and DJI Inspire 1 UAs do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during 

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

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

and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UASs, 

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

levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the DJI 

Phantom 3 and DJI Inspire 1 UASs produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and photography, while burning 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 and 

DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAs are propelled by battery powered electric motors, 

rather than an internal combustion engine. 

By using the DJI Phantom 3 and DJI Inspire 1 UASs to perform aerial acquisitions, 

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

associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Phantom 3 and DJI Inspire 1 UAs (weighing approximately 2 pounds 

14 ounces and 6 pounds 7.5 ounces 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). 

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

and DJI Inspire 1 UASs Will Benefit The Economy.
14

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

also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 and DJI Inspire 1 UASs will allow 

United States based companies, like WINDERMERE DRONE, LLC to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the rising 

cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new 

and alternative technology in order to remain competitive. Operating the battery powered 

DJI Phantom 3 and DJI Inspire 1 UASs is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 3 and DJI Inspire 1 UASs, companies such as 

WINDERMERE DRONE, LLC can remain competitive and profitable, and therefore, 

provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the DJI Phantom 3 and DJI Inspire 1 UASs, 

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

federal tax revenues; and allows companies to invest in research and development in 

order to remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

for decades, WINDERMERE DRONE, LLC proposed operation of the DJI Phantom 3 

and DJI Inspire 1 UASs would not implicate any privacy issues. Specifically, the DJI 

Phantom 3 and DJI Inspire 1 UASs will be operated only in compliance with operating 

documents (i.e., WINDERMERE DRONE, LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 User 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. 
15

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

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

Provided By The Rule From Which WINDERMERE DRONE, LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 UAs Meet The Conditions Of 

The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 

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

the unmanned aircraft and its operation, WINDERMERE DRONE, LLC operation of the 

DJI Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and 

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. 

Section 333 provides authority for a UAS to operate without airworthiness 

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

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

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

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

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

Transportation shall determine if certain unmanned aircraft systems may operate 

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

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

334 of this Act. (b) Assessment of Unmanned Aircraft Systems. --In making the 

determination under subsection (a), the Secretary shall determine, at a 

minimum—

(i) 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; 

(ii) 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). 

(b) 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. 
16

In seeking this exemption, WINDERMERE DRONE, LLC submits that the DJI 

Phantom 3 and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 and DJI 

Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 

(a) The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs 

Demonstrate Its Safe Characteristics. 

The DJI Phantom 3 and DJI Inspire 1 UASs 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. 

i. Technical Specifications Of The DJI Phantom 3 and DJI 

Inspire 1 UASs. The DJI Phantom 3 and DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Appendix A 

and B, set the technical specifications of the DJI Phantom 3 

and DJI Inspire 1 UASs forth. 

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous 

Flight And Navigation Modes Enable The UASs To Remain 

Within A Defined Operational Area. 

The DJI Phantom 3 and DJI Inspire 1 UASs may be operated in 

both manual and fully autonomous flight modes. A complete 

description of the flight and navigational modes of the DJI 

Phantom 3 and DJI Inspire 1 UASs is provided at pages 25-35 of 

the DJI Phantom 3 and pages 12-16 and 45-50 of the DJI Inspire 1 

User Manuals, attached hereto as Exhibit A and B. 

iii. The DJI Phantom 3 and DJI Inspire 1 UASs Are Designed 

For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 3 and DJI 

Inspire 1 UAs will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Phantom 3 and DJI Inspire 1 UAs 

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 Phantom 3 UAS are set forth at pages 

27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of 

the DJI Phantom 3 and DJI Inspire 1 User Manuals, attached 

hereto as Exhibit A and B.
17

iv. The DJI Phantom 3 and DJI Inspire 1 GCS And It’s 

Operation. 

A complete description of the operation and specifications of 

the DJI Phantom 3 and DJI Inspire 1 GCS and flight control 

software is provided at pages 32 through 43 of the DJI Phantom 3 

User Manual and pages 40 through 47 of the DJI Inspire 1 User 

Manual. DJI Phantom 3 and DJI Inspire 1 User Manuals are 

attached hereto as Exhibits A and B. 

(b) Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UASs Are 

Limited To The Line Of Sight Of A Certificated Pilot in Command 

With A Safety Observer. 

WINDERMERE DRONE, LLC will only utilize certificated pilots 

who possess a current and valid airman medical certificate to act as a 

pilot in command (PIC) of the DJI Phantom 3 and DJI Inspire 1 UASs. 

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

(c) Flights Of DJI Phantom 3 and DJI Inspire 1 UASs Will Be 

Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, WINDERMERE DRONE, LLC proposes to commercially 

operate DJI Phantom 3 and DJI Inspire 1 UASs for the special purpose of conducting aerial 

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

operating limitations: 

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

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

maximum gross weight: DJI Phantom 3 and DJI Inspire 1 Unmanned Aircraft Systems. 

Proposed operations of any other aircraft will require a new petition or a petition to amend 

this grant. 

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

of aerial video and photography. 

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

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), 

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

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

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

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

lenses, as specified on the PIC’s FAA-issued airman medical certificate. 
18

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

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

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

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

flight operations. The PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

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

other air traffic and other ground based obstacles/obstructions and is not permitted to operate the 

camera or other instruments. 

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

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

the conditions and limitations contained in the grant of exemption and the procedures outlined in 

the operating documents, the conditions and limitations contained in the grant of exemption take 

precedence and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its operating documents. 

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

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

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

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

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

The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

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

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

is prohibited from operating until the necessary maintenance has been performed and the UAS is 

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

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

records. 

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

flight characteristics, e.g. replacement of a flight critical component, must undergo a 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. 
19

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

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

replacement/overhaul component parts must be noted in the aircraft records, including total time 

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

returning the UAS to service. 

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

Bulletins. 

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

against discrepancies discovered between inspections. 

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

medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of 

the exemption. However, training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience building flights, all persons not essential 

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

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

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

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

required, a special request will be made at the FAA office closest to proposed area of operations. 

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

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

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

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

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

made available to the Administrator upon request. 

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

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

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

location within the planned operating area and land or be recovered in accordance with the 

operating documents. 

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

accordance with the operating documents. 
20

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

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

and land the UA with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or 

Authorization (COA) prior to conducting any operations under the grant of exemption. This 

COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. All operations shall be 

conducted in accordance with airspace requirements in the ATO issued COA including class of 

airspace, altitude level and potential transponder requirements.

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

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings 

in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of 

the UA must comply with the Federal Communications Commission (FCC) or other appropriate 

government oversight agency requirements. 

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

at the Ground Control Station of the UAS any time the UAS is operating. These documents must 

be made available to the Administrator or any law enforcement official upon request. 

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

activities at all times. 

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

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

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

structures unless: 

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

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

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

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

flight operations must cease immediately and/or; 

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

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and; 

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

an undue hazard to those persons per § 91.119(a). 
21

32. All operations shall be conducted over private or controlled-access property with permission 

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

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

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

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

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

Transportation Safety Board (NTSB) per instructions contained on the NTSB Website: 

www.ntsb.gov. 

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

Would Not Adversely Affect Safety. 

WINDERMERE DRONE, LLC submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI 

Phantom 3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 

or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive and 

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

structures. 

Considering WINDERMERE DRONE, LLC proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS, 

WINDERMERE DRONE, LLC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for 

WINDERMERE DRONE, LLC specific proposed flight operations. 

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

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

WINDERMERE DRONE, LLC will not allow any PIC to operate the DJI Phantom 3 or DJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements 

or the DJI Phantom 3 or DJI Inspire 1 UAS training and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS to be used for operations 

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs 

and landings in the preceding 90 days (for currency purposes). 
22

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 WINDERMERE DRONE, LLC proposed operations. The Administrator has held that 

prior documented flight experience that was obtained in compliance with applicable regulations 

would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that 

prior to conducting operations for the purpose of motion picture filming (or similar operations), 

the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 

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

with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and 

model of UAS to be used for operations under the exemption. For clarification, the FAA 

considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours 

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

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

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). 

The FAA finds that at a minimum, the flight hour requirements in Exemption No. 11062 are 

appropriate to practice and build proficiency in the skills necessary to safely conduct the 

petitioner’s proposed operations. The FAA also finds that prior documented flight experience 

that was obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience building flights can also be conducted under the grant of 

exemption to accomplish the required flight time. During training, proficiency, and experiencebuilding flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119. Exemption No. 11138 at page 15. 

Accordingly, WINDERMERE DRONE, LLC will ensure safe operations by not allowing 

any PIC to operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has demonstrated, 

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

operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the exemption, 

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

vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would

Not Adversely Affect Safety.

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

because prior to every flight, WINDERMERE DRONE, LLC will ensure that the DJI Phantom 3

or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with its

operating documents and as stated in the conditions and limitations herein. Additionally, the 

FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances 

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

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).
23

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained

because the altitude information of the DJI Phantom 3 and DJI Inspire 1 UAS will be provided to 

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

from the UAS to the GCS for active monitoring of the flight path and altitude. This altitude 

information combined with WINDERMERE DRONE, LLC’s operation of the DJI Phantom 3 

and DJI Inspire 1 UAS within visual line of sight, at or below 400 feet AGL, will ensure a level 

of safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed on board the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UAS's 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. 28 Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

Would Not Adversely Affect Safety.

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

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

Phantom 3 and DJI Inspire 1 UAS 's; (2) the limitations on the proposed flight operations; and 

(3) the location of the proposed flight operations. Accordingly, WINDERMERE DRONE,

LLC will ensure that he will safely operate the battery powered DJI Phantom 3 and DJI Inspire 1

UA's during daylight hours in VFR conditions, with enough battery power to fly for a total

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

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

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

3 and DJI Inspire 1 UAS the limitations on the proposed flight operations and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section

91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 and DJI Inspire 1 UAS 

provides audible and visual warnings to the PIC at the controller when the UA's experiences low

battery voltage, the first warning occurring at approximately 33% remaining battery

power, and again at approximately 10% remaining battery power. At the critically low

battery level, the DJI Phantom 3 and DJI Inspire 1 UAS 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).
24

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) &(b) Would Not Adversely Affect 

Safety.

In seeking this exemption, WINDERMERE DRONE, LLC submits that the

equivalent level of safety with regard to the regulatory maintenance and alteration requirements

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will

be met because WINDERMERE DRONE, LLC will use trained technicians to perform

maintenance, alterations, or preventive maintenance on the UAS's using the methods,

techniques, and practices prescribed in the operating documents i.e., the Operations Manual,

Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 User Manual. Furthermore, 

WINDERMERE DRONE, LLC will document and maintain all maintenance records for the DJI

Phantom 3 and DJI Inspire 1 UAS.

Since the DJI Phantom 3 and DJI Inspire 1 UAS will be inspected as prescribed by the 

operating documents, WINDERMERE DRONE, LLC will maintain the equivalent level of 

safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). Copies of the DJI 

Phantom 3 and DJI Inspire 1 User Manuals are attached hereto as Exhibit A and B; a copy of the 

DJI Phantom 3 and DJI Inspire 1 UAS Maintenance LOG is located under appendix D.

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

DRONE, LLC will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents.

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

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

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

utilizing the monthly maintenance log described under appendix D.

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 WINDERMERE DRONE, LLC’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3 and DJI Inspire 1 UAS,

WINDERMERE DRONE, LLC submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a) (2), and 

91.417(a) and (b). The FAA has previously granted relief specific to UAS in

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

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

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).
25

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, WINDERMERE DRONE,

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

Phantom 3 and DJI Inspire 1 UAS, which contains 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 UA for the limited purpose of conducting aerial video and photography 

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

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

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

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

must be established for the safe operation of the UAS in the NAS.

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

§21.16, for operation of the DJI Phantom 3 and DJI Inspire 1 UAS, since the airworthiness 

regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to 

the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, 

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

contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, it may 

prescribe 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 WINDERMERE DRONE, LLC’s intended operation of the DJI 

Phantom 3 and DJI Inspire 1 UAS , which contains 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).
26

F. A Summary That Can Be Published In The Federal Register stating: The Rules

From Which WINDERMERE DRONE, LLC seeks Exemption:

WINDERMERE DRONE, LLC seeks exemption from the requirements of 14 C.F.R

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

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

A Brief Description Of The Nature Of The Exemption WINDERMERE DRONE, LLC 

Seeks:

This exemption will permit WINDERMERE DRONE, LLC to commercially

operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial

video and photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support 

WINDERMERE DRONE, LLC’s Request.

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

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

UAS may operate safely in the NAS. As such, WINDERMERE DRONE, LLC 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 poses a threat to national

security and further, provides the authority for such UAS to operate without airworthiness

certification.
27

CONCLUSION

WINDERMERE DRONE, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

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

operation of the DJI Phantom 3 and DJI Inspire 1 UASs commercially, without an airworthiness 

certificate, for the limited purpose of conducting coverage of events, film sets, special events,

sporting events, resorts and hotels, tourism destinations, weddings, landscapes, real estate 

listings, residential and commercial building sites, civic landmarks, film making, economic 

development, golf courses, UAS operator training and other building or structural inspections 

over certain areas of the United States and increase public knowledge of UAS and promote safe 

UAS operations. By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing WINDERMERE DRONE, LLC to safely, 

efficiently, and economically operate the DJI Phantom 3 and DJI Inspire 1 UASs commercially 

within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, WINDERMERE DRONE, LLC

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

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit WINDERMERE DRONE, 

LLC to operate the DJI Phantom 3 and DJI Inspire 1 UASs commercially for the purpose of 

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

Dated: January 1, 2016 Submitted by:

Jeremy Mammen

Owner/President

WINDERMERE DRONE, LLC
28

APPENDICES:

A – DJI Phantom 3 Technical Specifications

B – DJI Inspire 1 Technical Specifications

C – On-Site Safety Checklist

D – Monthly Maintenance Log
29

APPENDIX – A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

WINDERMERE DRONE, LLC only utilizes safe and reliable UASs. DJI is an industry 

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

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

also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight 

to a predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices).

DJI Phantom 3 

1.1 Aircraft 

1.1.1 Supported Battery – DJI 6000AH LiPo Battery 

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

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

1.1.4 Max Yaw Angular Velocity - 200/s 

1.1.5 Max Tilt Angel - 35 

1.1.6 Max Ascent Speed – 6m/s 

1.1.7 Max Descent Speed – 2m/s 

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

1.2 Gimbal 

1.2.1Working Current – Static: 750mA; Dynamic: 900mA 

1.2.2 Control Accuracy - ±0.03 

1.2.3 Controllable Range – Pitch: -90 - 0 

1.2.4 Maximum Angular Speed – Pitch: 90/s 

1.3 Camera 

1.3.1 Operating Temperature Range - 32F - 104F (0C - 40C) 

1.3.2 Sensor Size – 1/2.3” 

1.3.3 Effective Pixels – 14M 

1.3.4 Resolution – 4384x3288 

1.3.5 HD Video Recording – 1080p30 & 720p 

1.3.6 Recording Field of View - 110/85 
30

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

WINDERMERE DRONE, LLC only utilizes safe and reliable UASs. DJI is an industry 

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

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

also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight 

to a predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices).

DJI Inspire 

1 1.1 Aircraft 

1.1.1 Model – T600 

1.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

1.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

1.1.4 Max Angular Velocity – Pitch: 300/s; Yaw: 150/s 

1.1.5 Max Tilt Angle - 35 

1.1.6 Max Ascent Speed – 5m/s 

1.1.7 Max Descent Speed – 4m/s 

1.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

1.1.9 Max Flight Altitude – 4500m 

1.1.10 Max Wind Resistance – 10m/s 

1.1.11 Max Flight Time – Approximately 18 minutes 

1.1.12 Motor Model – DJI 3510 

1.1.13 Propeller Model – DJI 1345 

1.1.14 Operating Temperature Range – 14F to 104F (-10C to 40C) 

1.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

1.2 Gimbal 

1.2.1 Model – ZENMUSE X3 

1.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

1.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

1.2.4 Angular Vibration Range - ±0.03 

1.2.5 Mounting – Detachable 

1.2.6 Controllable Range – Pitch: -90 to +30; Pan: ±320 

1.2.7 Mechanical Range – Pitch: -125 to 45; Pan: ±330 

1.2.8 Max Controllable Speed – Pitch: 120/s; Pan: 180/s 

1.3 Transmitter 

1.3.1 Name – C1 

1.3.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

1.3.3 Communicating Distance (unobstructed) – 2000m 

1.3.4 Output Power – 9W 

1.3.5 Operating Temperature Range - 14F to 104F (-10C to 40C) 
31

1.3.6 Battery – 600mAh LiPo 2SF All specifications can be found in the attached user manual or 

at http://www.dji.com/product/inspire-1/spec
32

APPENDIX – C

Windermere Drone, LLC

On-Site Safety Checklist

Pre-flight

√ Reviewed targeted area through Google Earth for any obstructions 

√ Reviewed area for any FAA restricted fly zones or other areas of concern 

√ Reviewed safety requirements with sponsor / owner (sign-off required back of form) 

√ Posted “Aerial Photography” in process sign at opening / curb 

√ Visit each neighbor to announce that aerial photography will be taking place 

√ Posted “Launch/Landing” zone sign calling for 50’ parameter 

√ Walked the hover area or path of flight to check for any areas on concern 

Flight Set-up 

√ Advise anyone within “Launch/Landing” area of safety and 50’ requirement 

√ Unpack and check DJI Phantom 3 for any visible signs of damage 

√ Turn on Remote Controller and observe that both power and Wi-Fi are green 

√ Ensure launch zone is clear and turn on DJI Phantom 3 battery 

√ Toggle S1 & S2 switches five times to set GPS recalc & failsafe landing zone 

√ Wait for solid GPS lights (Solid Green slow flashing) 

√ Spin DJI Phantom 3 360° both Horizontal and Vertically to ensure lock 

√ Review Launch Site one last time before liftoff 

√ Engage motors and start straight horizontal lift to desired altitude 

Flight 

√ Monitor both GPS Lock (# satellites) / Battery Level every minute 

√ Watch for any changes to the “Launch/Landing” area of safety and advise as necessary 

√ Watch for any irregular craft behavior and land immediately if necessary 

√ Return the craft to the landing area within 20% of battery life 

Post-Flight 

√ Announce that the craft is returning for landing 

√ Visual check that the 50’ rule is observed / Otherwise hover until 50’ is observed 

√ Slowly bring the DJI Phantom 3 in for a landing 

√ Turn off Battery on Craft first, then the Remote Controller 

√ Store all equipment in their cases before allowing observes to approach 
33

On-Site Safety Checklist

Sponsor / Owner Sign-off 

As the sponsor or owner of this engagement you understand that Windermere Drone LLC operates under 

the following rules and obligation to ensure the public safety and privacy, and that we follow all FAA 

rules and guidelines. 

As the sponsor / owner of this engagement you agree to the following through your initial of each item 

and signature at the bottom of this page. 

Windermere Drone LLC has advised you as to the following: Initial: _____ 

√ We will not fly within 1 mile of FAA Restricted Zones ______ 

√ We will not fly over 00’ of the current launch elevation ______ 

√ We will not fly if a 50” Launch/Landing parameter cannot be established ______ 

√ We will land the craft immediately of any technical issues occur ______ 

√ We will land the craft if on-site activity occurs that presents a security concern ______ 

Privacy Concerns: 

If neighbors have a privacy concern, we will not fly until it is resolved ______ 

If pictures taken has a privacy concern, it will not be made available ______ 

Safety: 

You agree to assist in the limiting of people within the launch/landing area ______ 

You agree to assist in the support of all other identified safety areas 

Safety Checklist Signatures 

Sponsor/Owner 

<Name and address is normally listed below__________________________________ 

Windermere Drone, LLC 

Jeremy Mammen

Owner/President _______________________________
34

APPENDIX – D

Windermere Drone, LLC

Monthly Maintenance and Repair Log

Aircraft:

Hours:

Date:

Date	Issue

Discovered

Date	Issue

Resolved

Issue	Description/	Maintenance

Conducted

Repair/Maintenance

Performed	By

Airframe

Motors

Propellers

Flight	Control	

Update

Gimbal

Misc