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Kenneth J. Crawford

Executive Director Facilities Services

Killeen Independent School District

200 North W.S. Young Drive, 

Killeen, Texas 76540-0967

kenneth.crawford@killeenisd.org

Dear Sir or Madam:

This petition is being submitted on behalf of the Killeen Independent 

School District, a government entity comprised of 6,600 employees and 

greater than 43,000 students across a 219 square mile area.

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 

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

and 14 C.F.R. Part 11, Kenneth J. Crawford, Facilities Executive Director for 

Killeen Independent School District, hereby petitions the Administrator to 

permit me to commercially operate the DJI Phantom 2, & 3 Series and the 

DJI Inspire-1 sUASs in the National Airspace System (NAS), and for an 

exemption from the six 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). 

This exemption will allow operation of Small Unmanned Aircraft Systems

(sUAS) commercially in airspace regulated by the Federal Aviation 

Administration (FAA) so long as we conduct such operations with and 

under the conditions outlined herein or as may be established by the FAA 

as required by Section 333.

The requested exemption would permit trained Killeen Independent 

School District Facilities Inspectors and Program Managers to conduct 

“commercial” sUAS flight operations over Killeen Independent School 

District owned property and prospective property interests in support of

the following areas: 

1. School District Real Estate Documentation.

2. Land Management (specifically all land owned by the School 

District).

3. Land Surveying.

4. Geographic Referencing.

5. Rooftop imaging, inspections, and documentation.

6. Response to or Document any physical external structural damage.

7. Campus documentation for Emergency Response Planning.
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Killeen Independent School District states that all sUAS flights will occur 

over private or controlled access property and will do so with the property 

owner's consent and knowledge and that only people who have 

consented or otherwise have agreed to be within the sUAS’ radius during 

filming and photography applications.

I, Kenneth J. Crawford, and my team of sUAS pilots and Visual Observers, 

have successfully demonstrated the ability to safely and effectively fly the 

DJI Phantom Series 2, & 3 systems with a combined total of more than 150 

sUAS flight hours for which I request authorization to use for all commercial

in the interest of the Killeen Independent School District. We will comply 

with local ordinances and laws regarding the operation of sUAS, and shall 

adhere to all weather and environmental restrictions or limitations in 

reference to the operations of sUAS.

All flights will comply with federal, state, and local laws or ordinances 

regarding privacy.

The Killeen Independent School District is seeking the exemption as we are

committed to complying with all of the rules, guidelines, limitations, and 

future legislation set forth by the FAA. We agree to and will operate the 

sUAS in the manner and for the purpose described. Without the 

exemption request granted, we will be limited to paying exorbitant costs 

which exceed $1,600 for manned flight operations over an already 

congested airspace. As stated in the Notice of Proposed Rulemaking 

Evaluation for Small Unmanned Aircraft Systems (sUAS) “drones pose a low 

level of pubic risk and that imposing all of those requirements would be 

unduly burdensome.” By allowing the School District to operate its own 

sUASs over District Property, the public, our local community, and our fiscal 

resources will directly benefit.

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

associated with the sUAS and its operation, my operations meets the 

conditions of FMRA Section 333 and therefore, should not require an 

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

Accordingly, I request 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.

We will document and maintain all maintenance records for the DJI 

Phantom 2, & 3 sUASs. Relief from certain requirements of Section 

61.113(a) and (b), entitled Sport pilot privileges and limitations: Pilot in 

command, is requested by the Killeen Independent School District to the 
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extent necessary to allow trained, knowledgeable, skilled, with 

demonstrated proficiency to serve as a Pilot in Command (PIC) as 

demonstrated, by meeting air knowledge and skills requirements for small 

sUAS platforms and having safely conducted over 150 hours of 

recreational flights over the past eighteen months with no mishaps. As the 

School District will operate the sUAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and 

structures.

1. Name And Address Of The Petitioner. The name and address of the 

Petitioner and point of contact is: 

Kenneth J. Crawford

Executive Director Facilities Services

Killeen Independent School District

200 North W.S. Young Drive

Killeen, Texas 76540-0967

2. The Specific Sections Of 14 C.F.R. From Which Killeen Independent 

School District Seeks Exemption. 

a. Killeen Independent School District Seeks Exemption from the 

Requirements Of Section 61.113(a) And (b). Section 61.113, 

entitled Sport pilot privileges and limitations: Pilot in command, 

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

i. No person who holds a sport 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.

ii. A sport 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.
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b. Killeen Independent School District Seeks Exemption From The 

Requirements Of Section 91.7(a). Section 91.7, entitled Civil 

aircraft airworthiness, subsection (a), states the following: 

c. Killeen Independent School District Seeks Exemption From The 

Requirements Of Section 91.121.Section 91.121, entitled Altimeter 

settings, subsection (a), states the following, in part:

d. Killeen Independent School District 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:

9(a) No person may operate a civil aircraft unless it is in an 

airworthy condition.

iii. 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--

2. The current reported altimeter setting of a station

along the route and within 100 nautical miles of the 

aircraft;

3. 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

4. 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.

v. No person may operate any aircraft that has undergone 

maintenance, preventive maintenance, rebuilding, or 

alteration unless—

1. (1) It has been approved for return to service by a 

person authorized under § 43.7 of this chapter[.]
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e. Killeen Independent School District Seeks Exemption From The 

Requirement Of Section 91.405(a). Section 91.405, entitled 

Maintenance required, subsection (a), states the following: 

f. Killeen Independent School District 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:

g. Killeen Independent School District 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:

(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.

Each owner or operator of an aircraft—

iv. 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[.]

vi. 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.
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h. Killeen Independent School District 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:

vii. Except for work performed in accordance with §§ 91.411 

and 91.413, each registered owner or operator shall keep 

the following records for the periods specified in 

paragraph (b) of this section: (1) Records of the 

maintenance, preventive maintenance, and alteration 

and records of the 100-hour, annual, progressive, and 

other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The 

records must include:

1. A description (or reference to data acceptable to the 

Administrator) of the work performed; and

2. The date of completion of the work performed; and

3. The signature, and certificate number of the person 

approving the aircraft for return to service. (2) Records 

containing the following information:

a. The total time in service of the airframe, each 

engine, each propeller, and each rotor.

b. The current status of life-limited parts of each 

airframe, engine, propeller, rotor, and appliance.

c. The time since last overhaul of all items installed on 

the aircraft which are required to be overhauled 

on a specified time basis.

(continued on next page)
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3. The Extent Of Relief Killeen Independent School District Seeks And The 

Reason Killeen Independent School District Seeks The Relief.

a. Extent Of Relief Killeen Independent School District Seeks And 

The Reason Killeen Independent School District Seeks Relief From 

Section 61.113(a) And (b).

i. Relief from Section 61.113(a) and (b) entitled Sport pilot 

privileges and limitations: Pilot in command, is requested to 

the extent necessary to allow a PIC holding a sport 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 sUAS flight operations for compensation or hire. 

(continued from previous page)

d. 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.

e. 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.

f. 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.

viii. The owner or operator shall retain the following records 

for the periods prescribed:

1. The records specified in paragraph (a)(1) of this section 

shall be retained until the work is repeated or 

superseded by other work or for 1 year after the work is 

performed.

2. The records specified in paragraph (a)(2) of this section 

shall be retained and transferred with the aircraft at the 

time the aircraft is sold.

3. A list of defects furnished to a registered owner or 

operator under § 43.11 of this chapter shall be retained 

until the defects are repaired and the aircraft is 

approved for return to service.
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ii. This relief is requested since the limitations set forth in 

Section 61.113(a) and (b) state that a sport 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. 

iii. As set forth more fully below, Killeen Independent School 

District submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate

the DJI Phantom 2 & 3 sUAS 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 

& 3 sUAS 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.

iv. Further, Killeen Independent School District submits that all 

flights of the DJI Phantom 2 & 3 sUASs, conducted by the 

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

incidental to the best interests of the Killeen Independent 

School District; and (2) will not carry passengers or property 

for compensation or hire.

b. Extent Of Relief Killeen Independent School District Seeks And 

The Reason Killeen Independent School District Seeks Relief From 

Section 91.7(a).

i. Relief from Section 91.7(a) entitled Civil aircraft 

airworthiness, is requested to the extent required to allow 

Killeen Independent School District to determine that the 

DJI Phantom 2 & 3 sUASs are in airworthy condition prior to 

every flight by ensuring that the sUAS is in compliance with 

the operating documents (i.e., the Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 & 

3 Instruction Manual).

ii. Killeen Independent School District seeks the requested 

relief because the DJI Phantom 2 & 3 sUASs do not require 

an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. Therefore, Killeen Independent School 

District will ensure that the DJI Phantom 2 & 3 sUASs are in

airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, 

and DJI Phantom 2 & 3 Instruction Manual) prior to every 

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

limitations below.

c. Extent Of Relief Killeen Independent School District Seeks And 

The Reason Killeen Independent School District Seeks Relief From 

Section 91.121.

i. Relief from Section 91.121, entitled Altimeter settings, may 

be required to allow flight operations of the DJI Phantom 2 

& 3 sUASs, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data 

link to downlink altitude information from the sUAS to the 

PIC at the ground control station (GCS). 

ii. Since the FAA requires that any altitude information 

concerning sUAS operations be reported to air traffic 

control (ATC) in feet above ground level (AGL), Killeen 

Independent School District seeks the requested relief 

because the DJI Phantom 2 & 3 sUAS’s altimeter may be 

set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.

iii. 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. 

iv. As more fully set forth herein, an equivalent level of safety 

will be maintained since the DJI Phantom 2 & 3 sUASs 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 sUAS

on the heads-up display of the GCS.

d. Extent Of Relief Killeen Independent School District Seeks And 

The Reason Killeen Independent School District Seeks Relief From 

Section 91.151(b).

i. 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 2 & 3

sUASs 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. 

ii. Killeen Independent School District seeks the requested 

relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered 

DJI Phantom 2 & 3 sUASs will severely constrain the 
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practicality of any aerial video or still photo flight

operations that Killeen Independent School District 

proposes to conduct pursuant to this Petition. 

iii. Significantly, as set forth below, the technical 

specifications of the DJI Phantom 2 & 3 sUASs, the DJI 

Phantom 2 & 3 operating documents, and Killeen 

Independent School District’s proposed operating

limitations, ensure that Killeen Independent School District 

will safely operate the battery powered DJI Phantom 2 & 3

sUASs during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), 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.

e. Extent Of Relief Killeen Independent School District Seeks And 

The Reason Killeen Independent School District Seeks Relief From 

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

91.417(a) & (b).

i. 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, Killeen Independent School 

District requests relief from these Sections because the DJI 

Phantom 2 & 3 sUASs do not require airworthiness

certificates. 

ii. As set forth more fully below, the DJI Phantom 2 & 3 sUASs 

meet the conditions of FMRA Section 333 for operation

without an airworthiness certificate. 

iii. Accordingly, Killeen Independent School District will use

trained or manufacture recognized technicians to perform 

maintenance, alterations, or preventive maintenance on 

the sUASs using the methods, techniques, and practices

prescribed in the sUAS operating documents (i.e., the 

Monthly Maintenance Log, and DJI Phantom 2 & 3

Instruction Manuals). 

iv. Furthermore, Killeen Independent School District will 

document and maintain all maintenance records for the 

DJI Phantom 2 & 3 sUASs.

4. The Reasons Why Granting Killeen Independent School District’s 

Request Would Be In The Public Interest; That Is, How It Would Benefit 

The Public As A Whole.

a. Granting the present Petition will further the public interest by 

allowing Killeen Independent School District to safely, efficiently, 

and economically perform aerial video and photography of 
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District-owned Real Estate, Vacant Land, subdivisions, and

Industrial property over certain areas of the United States, and 

readily available to conduct any District-owned property or 

facility disaster survey. 

b. Additionally, use of the DJI Phantom 2 & 3 sUASs will decrease 

congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. 

c. Notably, the benefits of Killeen Independent School District’s 

proposed operation of the DJI Phantom 2 & 3 sUASs will be 

realized without implicating any privacy issues.

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

The DJI Phantom 2 & 3 sUASs 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 2 

& 3 sUAS 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.

e. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Phantom 2 & 3 sUASs. Conducting aerial acquisitions with the DJI 

Phantom 2 & 3 sUASs, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the substantial risk to 

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

associated with traditional manned aircraft flight operations. 

Aside from the lack of flight crew members located onboard the 

aircraft, the DJI Phantom 2 & 3 sUASs (weighing approximately 2 

pounds 11 ounces, at their maximum gross weights with lengths 

of 16 inches, and a width of 16 inches, and with no fuel on 

board), has less physical potential for collateral damage to life 

and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations 

(weighing approximately 4,450 pounds with a wingspan of

approximately 37 feet, a length of 42 feet, and a fuel capacity 

of 110 gallons, (these are the specifications of a Bell Jet Ranger 

206)).

f. Performing Aerial Video and Photography Operations With The

DJI Phantom 2 & 3 sUASs Will Benefit The Economy. In addition to 

being safe and efficient, the DJI Phantom 2 & 3 sUASs are also an 

economical alternative to using manned aircraft to conduct 

similar aerial operations. As such, operation of the DJI Phantom 2 

& 3 sUASs will allow the School District to preserve limited fiscal 

resources for educational purposes rather than pay for manned 

flight in a congested airspace.
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g. No Privacy Issues. Similar to the manned aerial acquisition flight 

operations that have been conducted for decades, Killeen 

Independent School District’s proposed operation of the DJI 

Phantom 2 & 3 sUASs will not implicate any privacy issues.

Specifically, the DJI Phantom 2 & 3 sUASs will be operated only in 

compliance with operating documents (i.e., DJI Phantom 2 & 3

Instruction Manual), which requires property owner involvement,

and in accordance with the Federal Aviation Regulations,

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

91.119.

5. 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 Killeen Independent

School District Seeks Exemption.

a. Reasons Why The DJI Phantom 2 & 3 sUASs Meet The Conditions 

Of The FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333.

i. In consideration of the size, weight, speed, and limited 

operating area associated with the unmanned aircraft 

and its operation, Killeen Independent School District’s 

operation of the DJI Phantom 2 & 3 sUASs 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 that provides authority for a 

sUAS to operate without airworthiness certification and sets 

forth requirements for considering whether a sUAS will 

create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security. 
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ii. Specifically, FMRA Section 333 states the following, in part:

(a)In General.--Notwithstanding any other requirement of 

this subtitle, and not later than 180 days after the date 

of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems 

may operate safely in the national airspace system 

before completion of the plan and rulemaking required 

by section 332 of this Act or the guidance required by 

section 334 of this Act.

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

the determination under subsection (a), the Secretary 

shall determine, at a minimum—

(1) which types of unmanned aircraft systems, if 

any, as a result of their size, weight, speed, 

operational capability, proximity to airports and 

populated areas, and operation within visual line 

of sight do not create a hazard to users of the 

national airspace system or the public or pose a 

threat to national security; and 

(2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under 

section 44704 of title 49, United States Code, is 

required for the operation of unmanned aircraft 

systems identified under paragraph (1).

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

determines under this section that certain unmanned 

aircraft systems may operate safely in the national 

airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft 

systems in the national airspace system.
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b. In seeking this exemption, Killeen Independent School District 

submits that the DJI Phantom 2 & 3 sUASs can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: 

i. the characteristics of the DJI Phantom 2 & 3 sUASs

ii. the sUAS pilot certification requirement

iii. the specific operating limitations over School Districtowned property.

c. The Specifications Of The DJI Phantom 2 & 3 sUASs Demonstrate 

Its Safe Characteristics.

i. The DJI Phantom 2 & 3 sUASs 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.

1. Web links to the Technical Specifications Of The DJI 

Phantom 2 & 3 sUASs are set forth by the DJI 

Phantom 2 & 3 Specifications and Data Sheet, are 

provided at the end of this document.

2. The DJI Phantom 2 & 3 sUASs Autonomous Flight And 

Navigation Modes Enable The sUASs To Remain 

Within A Defined Operational Area. The DJI 

Phantom 2 & 3 sUASs may be operated in both

manual and fully autonomous flight modes. A 

complete description of the flight and navigational 

modes of the DJI Phantom 2 & 3 sUASs is provided in 

the DJI Phantom 2 & 3 and the DJI Inspire User

Manuals (web links provided at the end of this 

document).

3. The DJI Phantom 2 & 3 sUASs 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 2 & 3 sUASs

will remain stationary, in flight, for 3 seconds or more. 

If, after 3 seconds, the DJI Phantom 2 & 3 sUASs do 

not reacquire control link data from the GCS, the 

sUASs will assume that the Control Link is lost and the 

sUASs 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 2 & 3 sUAS

and the DJI Inspire User Manuals respectively, can 

be found at the referenced links at the end of this 

document.
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4. The DJI Phantom 2 & 3 Safety Zones.

a. A recent firmware update provides Safety 

Zones whereby restrictions are self-imposed by 

the software in the sUAS. The restricted areas 

are divided into Category A, and Category B. 

Category A is around larger airports like DFW 

and Love Field. Within 1.5 miles of this zone, 

the sUAS will not take off. Between 1.5 miles 

and 5 miles, the maximum altitude is 35 feet. If 

flying within 320 feet this safety zone, a 

warning message will appear on the DJI Vision 

app. Category B safety zone is around smaller 

airports. Within .6 miles of this zone, the sUAS

will not take off. If flying within .6 miles this 

safety zone, a warning message will appear 

on the DJI Vision application.

b. A complete description of the “Flight 

Restriction of Restricted Areas” of the DJI 

Phantom 2 & 3 GCS and flight control 

software is provided in the DJI Phantom 2 & 3

User Manual (web links provided at the end of 

this document).

5. Flight operations of DJI Phantom 2 & 3 sUASs are

limited to the line of sight of a certificated pilot in 

command with a safety observer. 

a. Killeen Independent School District requests 

the exemption to the required use of

certificated pilots who possess a current and 

valid airman medical certificate to act as a 

pilot in command (PIC) of the DJI Phantom 2 

& 3 sUASs. 

b. Additionally, a safety observer will assist all 

pilots during flight time. 

c. Flights Of DJI Phantom 2 & 3 sUASs Will Be 

Conducted Pursuant To Specific Operating 

Limitations. 

6. In seeking this exemption, Killeen Independent 

School District proposes to commercially operate DJI 

Phantom 2 & 3 sUASs for the special purpose of

conducting aerial video and photography over 

certain areas of United States, pursuant to the 

following specific operating limitations:
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a. Operations authorized by this grant of 

exemption will be limited to the following 

aircraft described in the operating 

documents, rotorcraft sUASs weighing less 

than 55 pounds maximum gross weight: DJI 

Phantom 2 & 3 Unmanned Aircraft Systems. 

b. Proposed operations of any other aircraft will 

require a new petition or a petition to amend 

this grant.

c. sUAS operations under this exemption will be 

limited to conducting operations for the 

purpose of aerial video and photography.

d. The sUASs may not be flown at an indicated 

airspeed exceeding 20 knots.

e. The sUASs 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.

f. The sUASs must be operated within visual line 

of sight (VLOS) of the PIC at all times.

g. The use of first person view (FPV) by the PIC or 

safety observer (SO) is not permitted.

h. 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.

i. 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.
17

j. The operating documents and the grant of 

exemption must be accessible during sUAS

operations and made available to the

Administrator upon request. If a discrepancy 

exists between the conditions and limitations 

contained in the grant of exemption and the

procedures outlined in the operating 

documents, the conditions and limitations 

contained in the grant of exemption 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 sUAS

Integration Office (AFS-80) may be contacted 

if questions arise regarding updates or 

revisions to the operating documents.

k. Prior to each flight the PIC must inspect the 

sUAS to ensure that it is in a condition for safe 

flight. If the inspection reveals a condition that

affects the safe operation of the sUAS, the 

aircraft is prohibited from operating until the 

necessary maintenance has been performed 

and the sUAS 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.
18

l. Any sUAS that has undergone maintenance or 

alterations that affect the sUAS 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.

m. 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.

n. The operator must follow the sUAS

manufacturer’s aircraft/ component, 

maintenance, overhaul, replacement, 

inspection, and life limit requirements.

o. 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 sUAS to 

service.

p. Each sUASs operated under this exemption 

must comply with all manufacturer Safety 

Bulletins.

q. The authorized person must make an entry in 

the aircraft record of the corrective action 

taken against discrepancies discovered 

between inspections.

r. The PIC must possess at least a sport pilot 

certificate and at least a current third- class 

medical certificate or valid driver’s license 

issued by a state.
19

s. 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 sUAS in a manner 

consistent with how the sUAS 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 experiencebuilding flights, all persons not essential for 

flight operations are considered 

nonparticipants, and the PIC must operate 

the sUAS with appropriate distance from 

nonparticipants in accordance with 14 C.F.R.

§ 91.119.

t. sUAS 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.

u. The sUAS 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.

v. The sUAS 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.
20

w. If the sUAS 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.

x. The PIC must abort the flight in the event of 

unpredicted obstacles or emergencies in 

accordance with the operating documents.

y. 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 sUAS with 25% 

battery power remaining.

z. 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.

aa. 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.

bb. Before conducting operations, the radio 

frequency spectrum used for operation and 

control of the sUAS must comply with the 

Federal Communications Commission (FCC) 

or other appropriate government oversight 

agency requirements.
21

cc. 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 

sUAS any time the sUAS is operating. These 

documents must be made available to the 

Administrator or any law enforcement official 

upon request.

dd. The sUAS must remain clear and yield the 

right of way to all manned aviation operations 

and activities at all times.

ee. The sUAS may not be operated by the PIC 

from any moving device or vehicle.

ff. 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:

i. Barriers or structures are present that 

sufficiently protect nonparticipating 

persons from the sUAS 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 sUAS, flight operations must cease 

immediately and/or;

ii. 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;

iii. Operations nearer to the PIC, SO, 

operator trainees or essential persons 

do not present an undue hazard to 

those persons per § 91.119(a).
22

gg. All operations shall be conducted over 

sport 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.

hh.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 sUAS Integration Office

(AFS-80) within 24 hours. 

ii. Accidents must be reported to the National

Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: 

www.ntsb.gov.

ii. Reasons Why An Exemption From The Requirements Of 

Section 61.113(a) And (b) Would Not Adversely Affect 

Safety.

1. Killeen Independent School District 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 2 & 

3 sUASs unless that PIC has demonstrated, by 

meeting minimum sUAS flight-knowledge and skills

requirements, that the PIC is able to safely operate 

the DJI Phantom 2 & 3 sUASs in a manner consistent 

with the exemption, including evasive and 

emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles 

and structures.

2. Considering Killeen Independent School District’s 

proposed area of operations, and the operating 

limitations set forth- above; the parallel nature of 

sport 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 2 & 3

sUAS, Killeen Independent School District submits 

that the additional manned airmanship experience 

of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Killeen 

Independent School District’s specific proposed 
23

micro sUAS or small sUAS flight operations. The FAA 

has previously granted relief from Section 61.113(a) 

and (b) specific to sUAS, 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).

3. Killeen Independent School District will not allow any 

PIC to operate the DJI Phantom 2 & 3 sUAS unless 

that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the DJI Phantom 2 & 3

sUAS training and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 2 & 3

sUAS 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 sUAS rotorcraft pilot (with a minimum of 5 

hours of those hours as a sUAS pilot operating the 

same make and model of sUAS 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). 

4. 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 Killeen 

Independent School District’s proposed operations. 

The Administrator has held that prior documented 

flight experience that was obtained in compliance 

with applicable regulations would ensure safe 

operations, stating as follows: In Exemption No. 

11062, the FAA required that prior to conducting

operations for the purpose of motion picture filming 

(or similar operations), the PIC must have 

accumulated and logged, in a manner consistent 

with 14 CFR 61.51(b), 25 hours of total time as a sUAS

rotorcraft pilot including at least 10 hours logged as 

a sUAS pilot with a multi-rotor sUAS. Prior to 

operations under Exemption No. 11062, the PIC must 

also have accumulated and logged a minimum of 5 
24

hours as a sUAS pilot operating the same make and 

model of sUAS 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 sUAS rotorcraft time. 

5. 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 

sUAS with appropriate distances in accordance with 

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

6. Accordingly, Killeen Independent School District will 

ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 2 & 3 sUAS unless that PIC 

has demonstrated, by meeting minimum flight- hour 

and currency requirements, that the PIC is able to 

safely operate the DJI Phantom 2 & 3 sUAS in a

manner consistent with the exemption, including

evasive and emergency maneuvers and 

maintaining appropriate distances from people, 

vessels, vehicles and structures.

iii. 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, Killeen 

Independent School District will ensure that the DJI 

Phantom 2 & 3 sUAS is in an airworthy condition based 

upon the sUAS’s compliance with its operating documents 

and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from 
25

Section 91.7(a) specific to sUAS, 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).

iv. 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 2 & 3 sUASs will be provided to the PIC via GPS 

equipment and a radio communications telemetry data 

link, which downlinks from the sUAS to the GCS for active 

monitoring of the flight path and altitude. This altitude 

information, combined with Killeen Independent School 

District’s operation of the DJI Phantom 2 & 3 sUASs within 

visual line of sight, at or below 500 feet AGL, will ensure a 

level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude 

initiation point is automatically established by the sUASs at

ground level. The FAA has previously granted relief from 

Section 91.121 specific to sUAS, 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).

v. 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 

2 & 3 sUASs; (2) the limitations on the proposed flight 

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

operations. 

1. Accordingly, Killeen Independent School District will 

ensure that it will safely operate the battery 

powered DJI Phantom 2 & 3 sUASs 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. 

2. Here, as in Exemption No. 11109, the technical 

specifications of the DJI Phantom 2 & 3 sUASs; the 

limitations on the proposed flight operations; and 
26

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 2 & 3 sUASs provide 

audible and visual warnings to the PIC at the GCS

when the sUASs 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 Vision+ 

sUASs 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 sUAS

are considered. 

3. 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 sUAS, 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).

vi. 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. 

1. In seeking this exemption, Killeen Independent 

School District 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 Killeen 

Independent School District will use trained 

technicians to perform maintenance, alterations, or

preventive maintenance on the sUASs using the 

methods, techniques, and practices prescribed in 

the operating documents (i.e., the Aerial Operations 

Manual, Monthly Maintenance Log, and DJI 

Phantom 2 & 3 Instruction Manual). 
27

2. Furthermore, Killeen Independent School District will

document and maintain all maintenance records 

for the DJI Phantom 2 & 3 sUASs. Since the DJI 

Phantom 2 & 3 sUASs will be inspected as prescribed 

by the operating documents, Killeen Independent 

School District will maintain the equivalent level of 

safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the DJI 

Phantom 2 & 3 User Manual links are provided at the 

end of this document for reference.

3. Likewise, the exemption sought will not adversely 

affect safety because Killeen Independent School 

District will use trained technicians to perform 

maintenance, alterations or preventive 

maintenance on the sUAS 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 2 & 3 sUASs 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 sUAS are considered. In consideration of Killeen 

Independent School District’s proposed operating 

limitations, the operating documents, and the 

technical aspects of the DJI Phantom 2 & 3 sUASs, 

Killeen Independent School District 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 sUAS 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).
28

vii. 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, Killeen 

Independent School District requests that the FAA 

prescribe special conditions for the intended operation of 

the DJI Phantom 2 & 3 sUASs, 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 sUAS for the 

limited purpose of conducting aerial video and 

photography over certain areas of the United States for 

compensation or hire. 

1. FMRA Section 333 sets forth the requirements for 

considering whether a sUAS 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 sUAS to operate without 

airworthiness certification in accordance with any 

requirements that must be established for the safe 

operation of the sUAS in the NAS. Likewise, the 

Administrator may prescribe special conditions 

pursuant to 14 C.F.R. § 21.16, for operation of the DJI 

Phantom 2 & 3 sUASs, 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.
29

2. 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 Phantom 2 & 3 sUASs, 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).

6. A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which Killeen Independent School District Seeks Exemption: 

Killeen Independent School District 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. A Brief Description Of The Nature Of The Exemption Killeen 

Independent School District Seeks: This exemption will permit 

Killeen Independent School District to commercially operate an

Small Unmanned Aircraft System (sUAS) for the purpose of 

capturing video and/or photographs of the following activities:

i. School District Real Estate Documentation.

ii. Land Management (specifically all land owned by the 

School District).

iii. Land Surveying.

iv. Geographic Referencing.

v. Rooftop imaging, inspections, and documentation.

vi. Response to or Document any physical external structural 

damage.

vii. Campus documentation for Emergency Response 

Planning.

b. Any Additional Information, Views, Or Arguments Available To

Support Killeen Independent School District’s Request.

i. 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 sUAS

may operate safely in the NAS. As such, Killeen 

Independent School District’s request for exemption may 

be granted pursuant to the authority of FMRA Section 333 

and 14 C.F.R. Part 11, as set forth above. 

ii. FMRA Section 333 sets forth the requirements for 

considering whether a sUAS will create a hazard to users of 

the NAS or the public, or otherwise pose a threat to 
30

national security; and further, provides the authority for

such sUAS to operate without airworthiness certification. 

iii. As discussed in detail above, Killeen Independent School 

District will operate the DJI Phantom 2 & 3 sUASs safely in 

the NAS, without creating a hazard to users of the NAS, or 

the public, or otherwise pose a threat to national security.

7. CONCLUSION

a. As set forth herein, and based on the proposed Department of 

Transportation, Federal Aviation Administration, Notice of 

Proposed Rulemaking Regulatory Evaluation, Small Unmanned 

Aircraft Systems, 14 CFR Part 107 dated February 2015, Killeen 

Independent School District 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 2 & 3 sUASs commercially, without an

airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United 

States. 

b. 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 Killeen Independent School District to safely, efficiently, 

and economically operate the DJI Phantom 2 & 3 sUASs 

commercially within the NAS.

8. WHEREFORE, in accordance with the Federal Aviation Regulations and 

the FAA Modernization and Reform Act of 2012, Section 333, Killeen 

Independent School District 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 Phantom 2 & 3 sUASs commercially 

for the purpose of conducting aerial video and photography over 

certain areas of the United States.

Dated: October 1, 2015

Respectfully submitted, Kenneth J. Crawford

Executive Director Facilities Services Killeen Independent School District

200 North W.S. Young Drive

Killeen, Texas 76540-0967

Mobile: (254) 366-0074

Email: kenneth.crawford@killeenisd.org
31

References:

A. DJI Phantom 2 Specifications User Manual Link:

http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Man

ual_v1.4_en.pdf

B. DJI Phantom 2 Specifications Data Sheet Link:

http://www.dji.com/product/phantom-2-vision/spec

C. DJI Phantom 3 Specifications User Manual Link:

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Profession

al_User_Manual_v1.4_en_0915.pdf

D. DJI Phantom 3 Specifications Data Sheet Link:

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

Appendices:

A. Killeen Independent School District, small sUAS Flight Guidelines, 

Procedures, and Operational Checks

B. DJI Phantom Knowledge and Skills Test Score Results
32

Killeen	Independent	School	District

Appendix	A

small	sUAS Flight	Guidelines,	Procedures,	and	Operational	Checks

Pre-Flight

1. Weather:	Carefully	check	the	latest	weather	and	wind	forecasts	for	the	area	

that	will	be	surveyed	prior	to	submission	of	flight	request	and	NOTAM,	upon	

ATC	pre-flight	coordination,	and	visually	immediately	prior	to	flight.	Be	aware	

and	mindful	of	the	effects	terrain	and	altitude	may	have	on	wind	direction,	

speed,	or	flight	operations.	Windfinder provides	a	great	resource	for	wind	speed	

forecasts	of	many	locations	near	which	flight	operations	may	occur.

2. Hazards: Prior	to	flight,	the	PIC	will	make	every effort	to	ensure	that	flight	

operations	will	not	pose	any	undue	risk	to	the	personnel	directly	involved	with	

the	effort	and	to	members	of	the	public	who	are	not	directly	involved.	Likewise,	

make	every	effort	to	ensure	that	operations	will	not	pose	any	undue	risk	to	any	

property	in	the	area.

a. Controlled	Airspace flights	shall	be	performed	only	with	permission	of	-

RA- and	in	constant	communication	with	all	required	parties	and	

agencies	and	the	controlling	authority	of	the	airspace.	The	controlling	

authority	maintains	the	right	to	abort	any	sUAS/sUAS flights	regardless	

of	the	stage	the	operation	is	in.	Comply	with	all	federal,	state,	and	local	

laws,	ordinances,	covenants,	and	restrictions	as	they	relate	to	

sUAS/sUAS operations.	Formally	request	permission	from	local	

government	and	local	communities	before	flying	over	their	airspace	

whenever	possible	or	required.	Likewise,	request	permission	from	both	

local	government	and	local	communities	to	take	aerial	

photographs/videos.	For	high-quality,	professional	mapping, flying	at	

300	meters	is	often	necessary.	If	these	levels	exceed	the	legal	altitude	

limits	in	the	country	of	operation,	seek	formal	permission	whenever	

possible	and	notify	the	nearest	airport	operator	of	the	intended	flight	

plan

b. Airspace: Ensure	that	all	operations	take	place	at	least	three (3)	miles	

(or	the	minimum	distance	required	by	local	regulations)	from	any	

controlled	airspace	such	as	an	airport	or	active	airfield.	Prior	to	taking	

off,	be	sure	to	scan	the	skies	for	any	signs	&	sounds	of	aircraft.	 When	

flying,	apply	the	“see	and	avoid”	as	you	continue	to	look	for	aircraft. If	

you	spot	or	hear	any, immediately	land	your	sUAS/sUAS.		Referencing	

the	“Don’t	Fly	Drones	Here”	web	page	(link:		
33

https://www.mapbox.com/drone/no-fly/)	provides	initial	location	checks	

for	areas	that	require	a	COA	or	prohibit	commercial	drone	flight	

operations.

c. Launch	&	Landing	Sites: The	selection	of	launch	and	landing	sites	is	

based	first	and	foremost	on	safety	and	thus	dependent	on	the	following:

i. Site	is	away	from	nonessential	participants,	utility	wires,	and	

poles;

ii. Ability	to	maintain	adequate	buffer	zones	between	aircraft	and	

personnel;

iii. Minimize	departures	and	landings	over	populated	areas;

iv. Take-off	site	should	be	chosen	to take	into	account	local	

topography,	ensuring	a	visible	line	of	sight	towards	the	sUAS at	

all	times.

v. Typically	the	landing	site	is	the	same	as	the	launch	site.	However,	

an	alternative	landing	site	should	be	identified	if	the	primary	

landing	site	becomes	unusable	or	unsafe.	To	this	end	

launch/landing	sites	should	be	selected	based	on	the	availability	

of	an	alternative	landing	site;

vi. The	availability	of	a	mission	“abort	site”	is	not	required	but	

recommended.

vii. An	abort	site	is	one	where	the	sUAS may	be	“dumped”	in	the	

event	of	an	emergency	situation.

viii. If	landing	site	includes	other	flight	staff	announce	out	loud	“Clear	

Prop”	before	starting	aircraft	power.

d. Safety	Software: sUASs	increasingly	have	a	number	of	failsafe	options	

in	case	of	failures	or	unexpected	situations.	These	often	include	using	

methods	of	stabilization	and	an	automated	Return/Home	option.	Other	

features	include	fail- recovery	software	and	sUAS parachute. Make	sure	

to	test	these	fail-safe	mechanisms	before	you	start	flying.	Do	not	fly	

without	these	failsafe	mechanisms.

e. Mission	Flight	Plan: The	mission	plan	shall	contain	all	actions	and	

contingencies	for	the	mission	planned.	Any	limiting	factors	in	the	flight	

environment	may	alter	the	intended	operation	and	modify	the	mission	

plan	accordingly.	Contingency	planning	should	include	safe	routes	in	the	

event	of	a	system	failure,	degraded	performance,	or	lost	communication	

link,	if	such	a	failsafe	exists. Mission	plans	will	also	include	a	flight	plan	

when	flying	large	sUASs	and/or	when	flying	complex	missions.	Complex	

missions	include	areas	that	have	several	ongoing	sUAS projects;	are	in	

dense	urban	areas	and	or	close	to	airports.	Small	sUASs,	especially	when	

flown	line-of-site,	do	not	require	formal	flight	plans.	Mission	plans	and	

flight	plans	should	be	shared	with	other	operators	when	flying	complex	

missions.

f. Public	Awareness:	Pro-actively	raise	public	awareness	about	intended	
34

flight	plans/paths	so	as	to	avoid	scaring	local	communities	and	

passersby.	Consider	using	flyers,	local	radio	and	newspapers	for	

disseminating	this	information,	particularly	when	flying	complex	

missions.	Meet	with	the	local	community	to	propose	and	discuss	the	

flight	plan	whenever	possible.	In	addition,	explain	the	technology	and	

ask	for	their	authorization	before	flying.	Ideally,	give	something	back	to	

the	community	whenever	possible	(training,	printed	maps,	etc). Teamup	a	local	operator	who	has	experience	in	the	country,	speaks	the	

language	and	understands	the	culture.

g. Camera	&	Settings: Ensure	that	the	camera	settings	are	appropriate	to	

your	mission.	Make	sure	the	camera	batteries	are	fully	re-charged	and	

that	there	is	sufficient	memory	on	the	proper	speed	SD	card	to	record	

the	footage	for	your	mission.	Remember	to	start	the	video	or	photos	

before	launching	your	sUAS (you’d	be	surprised	how	easy	that	step	is	to	

overlook).

h. Insurance: Make	every	effort	to	secure	individual	insurance	and	assume	

all	liability	for	your	actions.	sUAS NGOs	and	companies	who	collaborate	

with	our	network	are	also	required	to	secure	insurance.

i. Obvious	but	for	the	Record: Do	not	operate	sUASs	while	under	the	

influence	of	alcohol	or	while	using	any	drug	that	could	adversely	affect	

the	ability	to	safely	control	the	model.

3. Aircraft	Checks:		Conduct a	thorough	inspection	of	the	sUAS airframe	before	

flight:

a. Transmitter	firmware	up	to	date?

b. Check	condition	of	props	(run	finger	along	leading	and	trailing	edges,	flex	

both	blades	to	check	for	hairline	cracks,	chips,	looseness	and	any	

deformation)	and	ensure	prop	nuts	are	tight.

c. Check all	control	surfaces	for	signs	of	damage,	loose	hinges,	and	overall	

condition;	Looking	over	the	wing/rotors	to	ensure	they	are	in	good	

structural	condition	and	properly	secured

d. Check	motor	shafts	have	no	free	play	(missing	E	clip?	Loose	bell	housing	

screw?	Bad	bearings?). Check the	motor/engine	and	mounting	system	

to	make	sure	it	is	firmly	attached	to	the	airframe.

e. Checking	the	landing	legs for	damage and secure	attachment(s) as	

required.

f. Check	motors	move	freely	when	spun	by	hand.

g. Check	all	electrical	connections

i. plugged	in	and	secured	to	the	airframe

ii. Check	condition	of	battery	spade	connectors	and	data	pins	(level,	

free	movement,	clean).

iii. Confirm	full	battery charge	(on-board	battery	indicator	=	full	

green). Verify	all	full	charge	of	transmitter,	on-board	aircraft	and	
35

camera	batteries.

h. Check	camera	mounts	are	secure	(and	any	other	attachments)	and	SD	

card	is	inserted.

i. Transmitter sticks	positioned full	up	(GPS	on	- IOC	off).

j. Turn	on	transmitter.

k. Turn	on	sUAS.

l. DJI	Vision	Application:

i. Battery	indicator	reflects	time	of	available	flight	(green	bar)	–

return	to	point	of	origin	at	yellow	indicator	bar).

ii. Flight	timer	warning	alarm	ON	and	volume	set	to	maximum

iii. Monitor	brightness	set	to	maximum.

m. Compass	cable	tightly	connected.

n. Calibrate	DJI	GPS	each	change	of	point	of	origin	location (Critical	Task)	–

set	return	to	home.

o. When	powered	up	and	idling	confirm	no	unusual	noise	or	vibration	from	

motors.

p. Confirm	visual	display	in	DJA	Application	indicates:

i. Battery	Level	Reading

ii. Location	of	sUAS to	GCS

iii. Altitude	reads	“0”	at	ground	level.

iv. Indicated	Air	Speed	reads	“0”	when	stationary	on	ground.

v. Camera	elevation	and	depression	fully	functions	and	

communicates	with	the	camera	gimbal	control	by	moving	the	

camera.

q. Confirm	surrounding	area	is	clear	of:

i. Persons	at	ground	level

ii. Horizontal	hazards	(vegetation,	power	lines,	structures)

iii. Other	aircraft	(manned	or	unmanned)

r. Take	off	and	hover-check	all	stick	controls	in	stabilization	mode	to	

ensure the	control	surfaces	move	towards	the	correct	positions and	

mitigate	potential	“fly	away.”

i. Rotate	on	“X”	axis	360°

ii. Check	yaw	“Y”	axis	360°

iii. Check	“Z”	axis	(up	and	down).

s. Conduct	flight	per	flight	plan.

In-Flight

1. Basics:

a. If	flying	manually,	always	keep	your	fingers	on	the	controller/transmitter.

b. Always	fly	the	sUAS in	Line	Of	Sight	(LOS)	from	the	Ground	Control	

Station.
36

c. Climb	to	a	safe	altitude	away	from	potential	hazards	and	to	reduce	noise	

pollution.	Keep	aircraft	at	a	safe	operating	distance	from	people,	electric	

utility	lines	and	buildings.	If	the	sUAS must	be	flown	over	buildings	or	

people,	use	a	lightweight	sUAS and	maintain	a	safe	altitude	for	recovery	

and	make	every	effort	to	minimize	exposure.

2. Spotter: Use	a	spotter	or	visual	observer	whenever	possible	and	appropriate.

3. Laws:

a. The	PIC	will	maintain	a	see	and	avoid	manned	aircraft	operations	at	all	

times	prior	to	and	during	flight.

b. Do	not	fly	sUASs	within	five	miles	(or	whatever	is	defined	by	local	laws)	

of	any	private/commercial	airport/helipad	or	a	pre-existing	sUAS flying	

site	without	a	frequency-management	agreement.

c. Do	not	interfere	with	operations	and	traffic	patterns at	any	airport,	

heliport	or	seaplane	base	except	where	there	is	a	written	mixed-use	

agreement.	

d. Respect	altitude	limits	as	stated	by	local/national	laws.

4. Landing:

a. Regardless	of	whether	of	a	manual	or	automated	sUAS landing,	scan	

landing	area	for	potential	obstruction	hazards.	

b. Announce	out	loud	“Preparing	to	Land!”

c. Carefully	land	the	aircraft	away	from	obstructions	and	people.

Post-Flight

1. Shutting	Down:

a. Turn	the power	off	to	the	aircraft	and/or	disconnect/remove	the	

battery(ies).

b. Turn	off	the	transmitter and	range	extender	system.	

c. Turn	the	power	off	to	the	photo	equipment.	

d. Visually	check	aircraft	for	signs	of	damage	and/or	excessive	wear.	

e. Secure	the	aircraft.

2. Check	pictures: Verify	that	the	sUAS camera	actually	took	the	pictures.	If	not,	or	

of	bad	quality,	consider	redoing	the	mission	with	a	spare	set	of	batteries.

3. Logs: Keep	a	detailed	logbook	of	all	flights.

4. Information	Sharing: Request	permission	from	local	communities	to	share	the	

resulting	imagery,	either	privately	or	publicly	for	humanitarian	purposes.	Freely	

share	imagery	with	local	communities	whenever	possible.	Consider	printing	the	

imagery	on	banners	as	these	are	much	more	durable	than	paper.

5. Aircraft	Checklist:

a. Weekly	or	every	ten	(10)	flights	(whichever	occurs	sooner):

i. Visual	inspection	of	shell	and	other	plastic	components	for	

cracking/damage	(landing	skids, camera	mounting	plates,	etc.);
37

ii. Check	tightness	of	motor	retaining	screws	and	shell	retaining	

screws	(both	2.0mm	hex);

iii. Clean	data	spring	pins	and	battery	contact	pads	with	alcohol	and	

swab or	proprietary	electrical	contact	cleaner	and	cycle	spring	

pins	several	times	to	check	for	spring	weakness	and	full	

unimpeded	travel;

iv. Plug	in	to	Vision	Assistant	and	check	tx	&	IMU	calibration	state	

and	all	battery	cells	have	good	balance	(repeat	for	all	batteries);

v. Check	batteries	for	number	of	cycles	and	discharge	per	DJI	

recommendations	if	required.

b. Monthly	or	every	forty	(40)	flights (whichever	occurs	sooner):

i. Remove	upper	shell	and	check	state	of	all	wiring	- plugs	fully	

seated,	condition	of	all	solder	joints,	condition	of	visible	circuit	

boards	and	wiring	runs,	internals	generally	clean	and	no	

debris/loose	items.

ii. Remove	motors	and	check	security	of	E	clips,	condition	of	bearings

and	general	visual	inspection.

iii. Remove	rubber cover	from	Vision	camera	servo-mounting	point	

and	check	tightness	of	the	small	cross-head	screw.

c. General	Maintenance:		To	ensure	that	your	aircraft	continues	to	offer	

optimal	performance	and	to	ensure	flight	safety,	it	is	recommended	that	

comprehensive	maintenance	be	performed	after	every	200	flights	or	50	

flight	hours.	This	manual	is	intended	to	help	users	maintain	their	aircraft	

and	maximize	its	continued	reliability.

i. Smart	Battery

1. Check	the	battery	for	damage	and	deformities.	If	there	are	

any	signs	of	damage	to	the	battery,	stop	using	it	and	

discharge	the	battery	to	10%	or	below	for	disposal.	Do	not	

disassemble	the	battery	for	any	reason.

2. Check	the	battery	pins	and	rub	them	clean	with	an	eraser	if	

any	residue	is	observed.	This	will	help	to	ensure	a	more	

reliable	connection.

3. Check	the	metal	battery	power	connectors	for	damage.	If	

the	connectors	appear	burnt,	try	to	clear	them.	This	can	be	

done	by	inserting	a	piece	of	sandpaper	(1mm	thick)	into	

the	connectors	to	polish	the	metal.

4. Check	the	contact	pins	in	the	battery	compartment	to	

ensure	that	the	pins	are	clear.	They	should	be	able	to	

establish	easy	contact	with	the	battery	connectors	and	

should	not	be	bent.

5. Check	the	electrodes	on	the	battery.	If	they	appear	burnt,	

polish	them	with	sandpaper.	If	there	is	serious	erosion,	

send	the	battery	in	for	repairs.

6. Check	the	plastic	components	of	the	battery	bracket	to	see	
38

it	is	in	good	condition	and	that	all	screws	are	secure.	This	

prevents	the	battery	from	becoming	loose	during	flight.

7. Check	the	power	cables	between	the	arms	and	the	center	

plate,	if	the	cables	are	worn,	contact	DJI	to	arrange	repairs.

8. For	long-term	storage,	please	refer	to	the	“Intelligent	

Flight	Battery	Safety	Guidelines”	and	check	the	battery	

once	a	month	to	prevent	the	battery	cell	from	being	

damaged.

9. Run	the	DJI	Pilot	App	to	confirm	that	all	battery	cells	are	at	

similar	voltage	levels	and	stay	at	the	same	level	when	the	

battery	is	fully	charged.	If	all	cells	maintain	voltage	levels	

above	3.7V	but	any	cell	is	0.2V	higher	or	lower	than	the	

others,	contact	DJI	for	analysis.	You	can	also	check	the	

battery	cell	warning	history.	If	any	warning	is	reported,	

contact	DJI.

ii. Aircraft

1. Confirm	that	all	the	screws	are	still	adequately	tightened.

2. Check	the	aircraft	for	breaks	or	damage.	If	there	is	any	

reason	to	believe	that	detectable	damage	might	affect	

flight	safety,	consult	with	DJI	Support.

3. Check	the	pads	on	the	bottom	of	landing	gears.	If	they	are	

loose,	replace	or	secure	them	with	502	glue.

4. Ensure	that	there	are	no	obstructions	on	or	around	the	

GPS	module	or	around	the	antennas	on	the	landing	gear.	

Remove	any	obstacles	(such	as	tapes,	decals	or	stickers	

with	conductive	material)	that	might	affect	or	block	the	

signal.

iii. Motors

1. Check	the	rotors	to	confirm	that	they	have	not	become	

loose.

2. Detach	the	propellers	and	start	the	motors.	Listen	

carefully.	If	there	is	any	abnormal	noise,	please	replace	the	

motors.	This	may	be	a	sign	that	the	bearings	have	been	

worn	out.

3. Detach	the	propellers	and	start	the	motors.	Carefully	

examine	the	edge	of	the	rotor	and	confirm	that	the	shaft	is	

perfectly	centered	on	the	motor.	Check	for	any	abnormal	

or	excessive	vibration.	If	any	problems	are	detected,	

contact	DJI	Support	to	order	replacement	motors.

4. Check	for	deformities	by	confirming	that	the	gap	between	

the	motor	and	motor	base	is	even.	If	not	contact	DJI	

Support	to	order	replacement	motors.

5. Ensure	that	the	screws	used	to	secure	the	motor	base	are	

tight	and	the	plastic	components	around	the	motors	are	in	
39

good	condition.	If	not	please	tighten	the	screws	and	

contact	DJI	to	repair	any	broken	plastic	components.

iv. Propellers

1. Check	the	propellers.	If	there	is	any	bending,	breakage	or	

cracking	on	a	propeller,	do	not	use	it.

2. Attach	the	propeller	to	the	motor,	turn	on	the	aircraft,	and	

place	it	on	the	ground.	Stand	1	meter	away	from	the	

aircraft	and	observe	the	rotating	propellers.	If	you	can	see	

two	distinct	propeller	outline	layers,	when	looking	at	a	

spinning	propeller	from	the	side,	this	propeller	is	damaged	

and	should	not	be	used.

v. IMU

1. Open	DJI	Pilot	app	to	check	the	condition	of	the	IMU	and	

perform	an	advanced	IMU	calibration.	Please	place	the	

aircraft	in	a	cool	environment	and	on	a	flat,	stable	surface	

(if	the	landing	gear	is	damaged,	support	the	aircraft	with	

four	objects	of	equal	height).	Do	not	touch	the	craft	during	

the	calibration.

2. Turn	on	the	aircraft	and	listen	for	any	abnormal	noise	or	

vibration	from	the	fan	located	on	the	front	of	the	aircraft.	

If	any	irregularity	is	detected,	replace	the	fan.

vi. Control	and	Video	Transmission	System

1. Check	the	4	antennas	on	the	landing	gear	to	ensure	that	

they	are	secure.	Also	check for	any	bending	or	damage.

2. Check	the	antennas	of	the	remote	controller	for	damage.

3. Check	the	neck	strap	for	damage	or	wear,	replace	if	

necessary.

vii. Gimbal	and	Camera

1. Confirm	that	the	gimbal	is	able	to	properly	stabilize	itself.	If	

its	stabilizing	performance	deteriorates,	contact	DJI	to	

arrange	repairs.

2. Listen	for	any	abnormal	noise	from	the	fan	when	the	

gimbal	is	turned	on.	This	may	indicate	unusual	vibration	

and	the	fan	should	be	replaced.

3. Check	rubber	vibration	dampers	for	positioning	and	tears.

4. Check	two plastic	security	pins	for	positioning	and	

placement

viii. Vision	Positioning	System

ix. Check	the	lens	of	the	camera.	If	any	dirt	or	residue	is	detected,	

gently	clean	the	lens.

x. Check	for	and	remove	objects	that	might	block	the	sensors.

xi. Ensure	that	the	Vision	Positioning	System	is	securely	installed	on	

the	aircraft.

xii. Detach	the	propellers	and	turn	on	the	aircraft.	Hold	the	aircraft	1-
40

2	meters	above	a	surface	with	rich	patterns,	under	good	lighting	

conditions.	Change	the	Flight	Mode	switch	to	P	Mode	on	the	

controller	and	check	the	DJI	Pilot	app.	If	the	app	displays	an	

altitude	value	and	indicates	that	P-OPTI	mode	is	active,	the	Vision	

Positioning	System	should	function	normally.
41

Endnotes

1. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:	

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement.	

http://www.sUASnews.com/first-to-deploy

2. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:	

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement.	

http://www.sUASnews.com/first-to-deploy

3. Ackerman,	Evan,	“Every	Quadrotor	Needs	This	Amazing	Failsafe	Software,”	

IEEE	Spectrum,	March	4,	2014,	

http://spectrum.ieee.org/automaton/robotics/aerial-robots/every-quadrotorneeds-this-amazing- failsafe-software#.UxdDHIzx33Y.hackernews.

4. “DIY	parachute	deploy	mechanism	for	Multicopter,”	DIY	

Drones,	August	11,	2013,	

http://diydrones.com/forum/topics/diy-parachutedeployment-mechanism-for-multicopter.

5. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:	

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement.	

http://www.sUASnews.com/first-to-deploy

6. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:	

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement.	

http://www.sUASnews.com/first-to-deploy

7. Drawn	from	DroneAdventures	best	practices.

8. Taken	from	DroneAdventures	best	practices.

9. Drawn	from	DroneAdventures	best	practices.

10. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:	

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement.	

http://www.sUASnews.com/first-to-deploy

11. Academy	of	Model	Aeronautics,	“	Document	#540-D	‘See	and	Avoid’	

Guidance,”	August	2012, http://www.modelaircraft.org/files/540-

D.pdf.

12. Academy	of	Model	Aeronautics,	“Document	#922	Procedure	for	RF	

Interference	Testing	between	Model	Sites,”	

http://www.modelaircraft.org/files/922.pdf;	Academy	of	Model	Aeronautics,	

“Document	#923	From	the	2011	Official	AMA	National	Model	Aircraft	Safety	

Code,”	http://www.modelaircraft.org/files/923.pdf

13. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:	

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement.	

http://www.sUASnews.com/first-to-deploy

14. This	text	is	sourced	directly	from	Gene	Robinson	(2012).	First	to	Deploy:	

Unmanned	Aircraft	for	Search	&	Rescue	and	Law	Enforcement.	

http://www.sUASnews.com/first-to-deploy
42

DJI Phantom

Ground School Test

This knowledge-based test reflects Kenneth J. Crawford

successfully exceeded the 80% correct answer criteria with a 

final resulting grade of 99%. Prior to flight operations, all 

operators will successfully pass this test.

The link to this test is: 

http://p3groundschool.s3.amazonaws.com/p3quiz/html5.html