FROM: 

Donald A. Trowell 

Coeus

544 Flint Street

Rock Hill, SC 29730

Tel: 843-637-9029

Email: datrowell@yahoo.com

TO:

DOCKET OPERATIONS

ROOM W12-140 OF THE WEST BUILDING GROUND FLOOR

1200 NEW JERSEY AVENUE, SE. WASHINGTON, DC, 20590

Regulatory Docket No. _____________

PETITION FOR EXEMPTION OF:

Coeus

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

PART 21, SUBPART H AND SECTIONS §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121,

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

CONCERNING COMMERCIALOPERATION OF DJI PHANTOM 2 VISION+ AND DJI PHANTOM 3 

PROFESSIONAL UNMANNED AIRCRAFT SYSTEMSPURSUANT TO SECTION 333 OF

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

Coeus (Donald A. Trowell) seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

(b), 91.109, 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 Coeus to operate an 

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

photography of Real Estate Properties (for homeowners, realtors, home builders, home 

contractors and / or home inspectors for real estate marketing and inspection of home 

exteriors) as well as filming of special events, film sets, scripted and unscripted television sets 

and landscape, conducting power line inspection, aerial mapping, surveying and search and 

rescue over certain areas of the United States.
INTRODUCTION AND INTERESTS OF THE PETITIONER 

Coeus is a production company based in South Carolina specializing in real estate videography, 

photography, music video production, special event production and film and television 

production. Coeus’s objective is to conduct aerial photography and videography in order to

provide high quality digital imaging and video content to its clients, in particular to 

homeowners, real estate agents, realtors, home builders, home contractors, and/or home 

inspectors for real estate marketing and inspections of home exteriors as well as filming of 

special events, film sets, scripted and unscripted television sets and landscape, conducting 

power line inspection, aerial mapping, surveying and search and rescue utilizing DJI Phantom 2 

Vision+ and/or DJI Phantom 3 UAS. More specifically, Over Exposure aerial video and 

photography operations will serve in the following areas: 

• Aerial photography of houses / residential and commercial buildings and power lines 

• Aerial videography of houses / residential and commercial buildings and power lines 

• Aerial event photography 

• Aerial event filming 

• Aerial Film & Television production

• Aerial search and rescue and safety inspections 

• Increase public knowledge of UAS and promote safe UAS operations.

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, Phantom 3 Professional UAS

Coeus seeks an exemption to operate DJI systems DRONES for compensation or hire within the 

NAS. The DJI Phantom 2 Vision+, DJI Phantom 3 Professional are vertical takeoff and landing 

(VTOL) Unmanned Aircrafts (UAS) with a Ground Control Station (GCS) utilizing electronic tablet 

or smart phone systems. The DJI Phantom 2+, DJI Phantom 3 Professional have a maximum 
gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 

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

Phantom 2 Vision+, DJI Phantom 3 Professional UAS are equipped with four main rotors; driven 

by Lithium Polymer battery powered electric motors. The DJI Phantom 2 Vision+, DJI Phantom 3 

Professional UAS that will be operated by Coeus (trained professional), will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking.

BASIS FOR PETITION

Petitioner, Coeus, 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 2 Vision+, DJI Phantom 3 Professional UAS in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.109, 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, Coeus operation of DJI Phantom 2 Vision+, DJI Phantom 3 

Professional UAS 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, Coeus

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. Coeus submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Coeus will use experienced personnel or 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., Monthly Maintenance 
Log, and DJI Phantom 2 Vision+, DJI Phantom 3 Professional Instruction Manual). Furthermore, 

Coeus will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and 

DJI Phantom 3 Professional UAS. 

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

and limitations: Pilot In Command, is requested by Coeus to the extent necessary to allow a 

Pilot in Command (PIC) holding a Commercial Pilots License, and who has demonstrated, by 

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

the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Coeus seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional UAS do not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. As such, Coeus submits that it will ensure that 

the Phantom 2 Vision+, DJI Phantom 3 Professional UAS are in an airworthy condition, prior to 

every flight, by determining that the UAS’s are in compliance with the operating documents 

(i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+, DJI Phantom 3 Professional 

Instruction Manual), and that the aircraft are in a condition for safe flight. Coeus also seeks an 

exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI 

Phantom 2 Vision+, DJI Phantom 3 Professional UAS will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Phantom 2 Vision+, DJI Phantom 3 

Professional UA 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 Coeus’s operation of the 

DJI Phantom 2 Vision+, DJI Phantom 3 Professional UAS within visual line of sight, at or below 

200 feet AGL, will ensure a level of safety equivalent to Section 91.121.
Additionally, Coeus seeks an exemption from the requirements of Section 91.151(b), entitled 

Fuel requirements for flight in VFR conditions. Coeus submits that safety will not be affected by 

operation of the DJI Phantom 2 Vision+, DJI Phantom 3 Professional UA during daylight hours in 

visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery 

power to fly for a total duration of approximately 13.5 minutes to the first point of intended 

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

In accordance with 14 C.F.R. § 11.81, Coeus 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:

Donald A. Trowell 

Coeus

544 Flint Street

Rock Hill, SC 68048

Tel: 843-637-9029

Email: datrowell@yahoo.com

B. The Specific Sections Of 14 C.F.R. From Which Coeus Seeks 

Exemption. 

1. (removed) 

2. Coeus 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. Coeus Seeks Exemption From The Requirements Of Section 91.121. Section 91.121, 

entitled Altimeter settings, subsection (a), states the following, in part: (a) Each person 

operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating--

(1) Below 18,000 feet MSL, to--
(i) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft; 

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

section, the current reported altimeter setting of an appropriate available 

station; or 

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

departure airport or an appropriate altimeter setting available before departure.

4. Coeus Seeks Exemption From The Requirements Of Section 91.151(b). 

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

states the following: 

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

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 20 

minutes. 

5. Coeus 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. Coeus Seeks Exemption From The Requirements Of Section 

91.407(a)(1) Section 91.407, entitled Operation after maintenance, preventive 

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

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

maintenance, rebuilding, or alteration unless--

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

chapter[.] 
7. Coeus 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. Coeus Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

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

owner or operator shall keep the following records for the periods specified in 

paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of 

the 100-hour, annual, progressive, and other required or approved inspections, as 

appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include--

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

work performed; and 

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

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

return to service. 

(2) Records containing the following information: 

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

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

rotor, and appliance. 

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

required to be overhauled on a specified time basis. 

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

inspection required by the inspection program under which the aircraft and its 

appliances are maintained.

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

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

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

recurring action, the time and date when the next action is required. (vi) Copies 

of the forms prescribed by § 43.9(d) of this chapter for each major alteration to 

the airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

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

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and 

transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 

C. The Extent Of Relief Coeus Seeks And The Reason Coeus Seeks The Relief. 

1. Extent Of Relief Coeus Seeks And The Reason UAV Aerial Video 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 Supplemental Pilot 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, Coeus submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Phantom 2 

Vision+, Phantom 3 Professional UA 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 Vision+, Phantom 3 Professional UAS in a manner 

consistent with the operations specifications as described in this exemption, 

including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures. Further, Coeus submits 

that all flights of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS, 

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

to Coeus business; and (2) will not carry passengers or property for 

compensation or hire. 

Coeus believes that though UAS are not traditional aircrafts, a PIC operating the 

UA must have knowledge of Airman rules, basic Airspace and comply with all the 

rules proposed by the FAA. However, considering the fact that a UA is almost like 

a toy, weighing less than a skinny person, the PIC may be except from obtaining 

a Private Pilot Certificate, a Sports Certificate, a Recreational Certificate 

considering these certificates require flight hours of several thousand tons 

weighing aircrafts. The operation of UAS by Coeus is strictly for entertainment / 

informational purposes, thus the operators of the UAS have a career and / or 

freelance employment as a Camera Operator and Cinematographer and will be 
not be entertaining a career as a pilot. Lastly, Coeus PICs will operate the UAS no 

higher than 400 feet, consequently causing no danger to any other aircraft in the 

NAS. However, Coeus Proposes PIC Certification as a Supplemental pilot and a 

minimum requirement of successfully completed private pilot ground school. 

Additionally, supplemental pilots without a current FAA private pilot certificate 

must have successfully passed the private pilot, commercial pilot, or airline 

transport pilot knowledge test within the past 24 calendar months. 

2. Extent Of Relief Coeus Seeks And The Reason UAV Aerial Video 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 Coeus to determine that the DJI Phantom 2 Vision+, 

Phantom 3 Professional UAS are in airworthy condition prior to every flight by 

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

Coeus Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+, Phantom 3 Professional Instruction Manual). Coeus seeks the requested 

relief because the DJI Phantom 2 Vision+, Phantom 3 Professional UAS do not 

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

H. Therefore, Coeus will ensure that the DJI Phantom 2 Vision+ UAS are in 

airworthy condition based upon its compliance with the operating documents 

(i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 

Professional Instruction Manual) prior to every flight, and further, determine 

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

limitations below. 

3. Extent Of Relief Coeus Seeks And The Reason UAV Aerial Video 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 2 Vision+, Phantom 3 Professional UAS, 

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), Coeus seeks the requested relief 

because the DJI Phantom 2 Vision+, Phantom 3 Professional UA’s altimeter may 

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

or field requested relief because the DJI Phantom 2 Vision+, Phantom 3 

Professional 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 2 Vision+, 

Phantom 3 Professional 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 Coeus Seeks And The Reason UAV Aerial 

Video 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 2 Vision+, Phantom 3 Professional UAS during daylight 

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

for a total duration of 13.5 minutes to the first point of intended landing and, 

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

seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 2 

Vision+, Phantom 3 UA will severely constrain the practicality of any aerial video 
or still photo flight operations that Coeus proposes to conduct pursuant to this 

Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 

Vision+, Phantom 3 Professional UAS operating documents, and Coeus proposed 

operating limitations, ensure that Coeus will safely operate the battery powered 

DJI Phantom 2 Vision+, Phantom 3 Professional 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 Coeus Seeks And The Reason Coeus Seeks Relief From Section 

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, Coues requests relief 

from these Sections because the DJI Phantom 2 Vision +, Phantom 

3 Professional UAS do not require airworthiness certificates. As set forth more 

fully below, the DJI Phantom 2 Vision+, Phantom 3 Professional UAS meet the 

conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Coeus will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UAS using the 

methods, techniques, and practices prescribed in the UAS operating documents 

(i.e., the Coeus Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 Vision+, Phantom 3 Professional Instruction Manual). Furthermore, 

Coeus will document and maintain all maintenance records for the DJI Phantom 

2 Vision+, Phantom 3 UAS. 

D. The Reasons Why Granting Coeus 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 Over 

Exposure to safely, efficiently, and economically perform aerial video and 

photography of real estate, special events, film sets, and landscape over certain 

areas of the United States. 

Additionally, use of the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will 

decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Coeus’s proposed operation of 

the DJI Phantom 2 Vision+, Phantom 3 UAS will be realized without implicating 

any privacy issues. 

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

Phantom 2 Vision+, Phantom 3 Professional UA 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 Vision+, Phantom 3 Professional UAS would reduce the amount 

of manned aircraft in the NAS, reduce noise and air pollution, as well as increase 

the safety of life and property in the air and on the ground. 

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

congestion around airports caused by arriving and departing aircraft will be 

reduced. The DJI Phantom 2 Vision+, Phantom 3 Professional UA 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 2 

Vision+, Phantom 3 UAS. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+, Phantom 3 

Professional UAS, 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 2 Vision+, Phantom 3 Professional 

UAS 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 2 

Vision+, Phantom 3 Professional UA, 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 2 Vision+, Phantom 3 Professional UAS 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 2 Vision+, 

Phantom 3 UAS (weighing approximately 2 pounds 11 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 2 

Vision+, Phantom 3 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 Vision+, Phantom 3 

Professional is also an economical alternative to using manned aircraft to 

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

Vision+, Phantom 3 Professional UAS will allow United States based companies, 

like Over Exposure, 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 2 

Vision+, Phantom 3 Professional UAS 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 2 Vision+, Phantom 3 

Professional UAS, companies such as Coeus, 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 2 Vision +, Phantom 3 Professional UAS, 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, Coeus proposed operation of the DJI Phantom 2 Vision+, 

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

Phantom 2 Vision+, Phantom 3 Professional UAS will be operated only in 

compliance with operating documents (i.e., the Coeus Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3 Professional 

Instruction Manual) which requires property owner involvement as well as local 

law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 

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

Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From 

Which Coeus Seeks Exemption. 
1. Reasons Why The DJI Phantom 2 Vision+, Phantom 3 Professional 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, Coeus operation of the DJI 

Phantom 2 Vision+, Phantom 3 Professional UAS 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 rule-making required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

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

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

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

weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create 

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

national security; and 

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

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 
section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Coeus submits that the DJI Phantom 2 

Vision+, Phantom 3 Professional UAS can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI 

Phantom 2 Vision+, Phantom 3 Professional UAS; 

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

a. The Specifications Of The DJI Phantom 2 Vision+, Phantom 3 Professional 

UAS Demonstrate Its Safe Characteristics. The DJI Phantom 2 Vision+, Phantom 

3 Professional UAS does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 2 Vision+, Phantom 3 Professional 

UAS. 

The technical specifications of the DJI Phantom 2 Vision+, Phantom 3 

Professional UAS is set forth by the DJI Phantom 2 Vision+, Phantom 3 

Professional Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS Autonomous Flight 

And Navigation Modes Enable The UAS To Remain Within A Defined Operational 

Area. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS 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 Vision+, Phantom 3 UAS 

is provided at pages 25-35 of the DJI Phantom 2 Vision+, User Manual, attached 

hereto as Exhibit B & D (Phantom 3 User Manual will be available after May 15, 

2015; however, is very similar to DJI Phantom 2 Vision+ User Manual). 

iii. The DJI Phantom 2 Vision+, Phantom 3 Professional UAS 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 Vision+ UA 
will remains stationary, in flight, for 3 seconds or more. If, after 3 seconds, the 

DJI Phantom 2 Vision+, Phantom 3 Professional UA does not reacquire control 

link data from the GCS, the UA will assume that the Control Link is lost and the 

UA 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 Vision+, Phantom 3 Professional UAS are set 

forth at pages 27 through 29 of the DJI Phantom 2 Vision+, (Phantom 3) 

Professional User Manual, attached hereto as B & D. 

iv. The DJI Phantom 2 Vision+, Phantom 3 Professional GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 2 

Vision+, Phantom 3 GCS and flight control software is provided at pages 32 

through 43 of the DJI Phantom 2 Vision+, (Phantom 3) Professional User Manual. 

DJI Phantom 2 Vision+ User Manual is attached hereto as Exhibit B & D.

b. Flight Operations Of DJI Phantom 2 Vision+, Phantom 3 Professional UAS Are 

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

Observer. 

Coeus 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 2 

Vision+, Phantom 3 Professional UAS. Additionally, a safety observer will assist 

all pilots during flight time. 

c. Flights Of DJI Phantom 2 Vision+, Phantom 3 Professional UAS Will Be 

Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, proposes to commercially operate DJI Phantom 2 

Vision+, Phantom 3 Professional UAS 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 2 Vision+, 

Phantom 3 Professional Unmanned Aircraft System. 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 for homeowners, Realtors, 

home builders, contractors, home inspectors for use in real estate marketing and 

real estate inspections. Additionally, aerial video and photography may be 

conducted on occasional basis for film and television sets, special events and 

landscape photography, conducting power line inspection, aerial mapping, 

surveying as deemed necessary. 

3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 

m/s). 

4. The UAS must be operated at an altitude of no more than 200 (500 per the 

User Manual) feet above ground level (AGL), as indicated by the procedures 

specified in the operating documents unless a special request is made and 

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

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

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

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

medical certificate. 

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

permitted. 

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

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

capability. 

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

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 
duration of the flight. The PIC must ensure that the SO can perform the functions 

prescribed in the operating documents.

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

seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments. 

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

during UAS operations and made available to the Administrator upon request. If 

a discrepancy exists between the conditions and limitations contained in the 

grant of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

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

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

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines 

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

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

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

questions arise regarding updates or revisions to the operating documents. 

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

condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

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

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 
11. Any UAS that has undergone maintenance or alterations that affect the UAS 

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

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

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

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

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

relevant sections of the operating documents. 

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

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

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

keeping requirements, in accordance with the operating documents. 

Maintenance, inspection, alterations, and status of replacement/overhaul 

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

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

person returning the UAS to service. 

15. Each UAS 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 Supplemental Pilot certificate and at least a 

current third- class medical certificate. Supplemental pilots must have, at a 

minimum, successfully completed private pilot ground school. Additionally, 

supplemental pilots without a current FAA private pilot certificate must have 

successfully passed the private pilot, commercial pilot, or airline transport pilot 

knowledge test within the past 24 calendar months. 

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 

predetermined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

forecast weather conditions) there is enough power to fly at normal cruising 
speed to the intended landing point and land the UA with 25% battery power 

remaining. 

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

of Waiver or Authorization (COA) prior to conducting any operations under the 

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

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements. 

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

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

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

Subpart C. Markings must be as large as practicable. 

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

operation and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

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

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

operating. These documents must be made available to the Administrator or any 

law enforcement official upon request.

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

operations and activities at all times. 

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

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

nonparticipating persons (persons other than the PIC, SO, operator trainees or 

essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 
must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or; 

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

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

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

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

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

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

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

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

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

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

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

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

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

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

And (b) Would Not Adversely Affect Safety. 

Coeus 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 Vision +, Phantom 3 Professional 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 2 Vision +, Phantom 3 

Professional UAS in a manner consistent with the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 
Considering Coeus 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 2 

Vision+, Phantom 3 Professional UAS, Coeus submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to 

the airmanship skills necessary for Coeus 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). 

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, Coeus will ensure that the DJI Phantom 2 

Vision+, Phantom 3 Professional UAS is in an airworthy condition based upon the 

UAS’s compliance with its operating documents and as stated in the conditions 

and limitations herein. Additionally, the FAA has previously granted relief from 

Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, 

to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

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

11157, 11158, 11159, 11160, 11161). 

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

Would Not Adversely Affect Safety. 

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

because the altitude information of the DJI Phantom 2 Vision+, Phantom 3 

Professional UA will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS 
for active monitoring of the flight path and altitude. This altitude information, 

combined with Coeus’s operation of the DJI Phantom 2 Vision+, Phantom 3 

Professional UAS within visual line of sight, at or below 500 feet AGL, will ensure 

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

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

zero altitude initiation point is automatically established by the UASs at ground 

level. 

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

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

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

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

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

Would Not Adversely Affect Safety. 

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

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

DJI Phantom 2 Vision+, Phantom 3 Professional UAS; (2) the limitations on the 

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

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

powered DJI Phantom 2 Vision+, Phantom 3 Professional UA 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 

2 Vision+, Phantom 3 Professional 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 2 Vision+, Phantom 3 

Professional UAS provide audible and visual warnings to the PIC at the GCS when 
the UAS experiences low battery voltage, the first warning occurring at 

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

remaining battery power. At the critically low battery level, the DJI Phantom 

Vision+, Phantom 3 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). 

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, Coeus 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 Coeus will use trained technicians to 

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

the methods, techniques, and practices prescribed in the operating documents 

(i.e., the Coeus Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 Vision+, Phantom 3 Professional Instruction Manual). Furthermore, 

Coeus will document and maintain all maintenance records for the DJI Phantom 

2 Vision+, Phantom 3 Professional UAS. 

Since the DJI Phantom 2 Vision+, Phantom 3 Professional UAS will be inspected 

as prescribed by the operating documents, Coeus 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 Vision+ User Manual is attached hereto as Exhibit B 

& D; a copy of the DJI Phantom 2 Vision+, Phantom 3 UAS Maintenance LOG is 

attached hereto as Exhibit C. Likewise, the exemption sought will not adversely 

affect safety because Coeus 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 2 Vision+, Phantom 3 Professional UAS will be performed by trained 

technicians. Maintenance will be documented and maintained utilizing the 

monthly maintenance log. Significantly, previous exemptions granted by the FAA 

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

& (b) establish that safety is not adversely affected when the technical 

characteristics and operating limitations of the UAS are considered. 

In consideration of Coeus proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 Vision +, Phantom 3 

Professional UAS, Coeus submits that safety will not be adversely affected by 

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

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief 

specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

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

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

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Coeus requests 

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

Phantom 2 Vision+, Phantom 3 Professional UAS, which contain such safety 
standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

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

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

of the UAS for the limited purpose of conducting aerial video and photography 

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

333 sets forth the requirements for considering whether a UAS will create a 

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

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

airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. Likewise, the 

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

§ 21.16, for operation of the DJI Phantom 2 Vision+, Phantom 3 Professional 

UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain 

adequate or appropriate safety standards, due to the novel or unusual design 

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

following: 

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

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

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

engine or propeller, he prescribes special conditions and amendments thereto 

for the product. The special conditions are issued in accordance with Part 11 of 

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

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

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

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

may prescribe special conditions for Coeus’s intended operation of the DJI 

Phantom 2 Vision+, Phantom 3 UAS, which contain such safety standards that 

the Administrator finds necessary to establish a level of safety equivalent to that 
established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 

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

91.417(a) & (b). 

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

From Which Coeus Seeks Exemption: 

Coeus 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 Coeus Seeks: This 

exemption will permit Coeus 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 UAV 

Aerial Video 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, Coeus request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 

14 C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the 

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

NAS or the public, or otherwise pose a threat to national security; and further, 

provides the authority for such UAS to operate without airworthiness 

certification. As discussed in detail above, Coeus will operate the DJI Phantom 2 

Vision +, Phantom 3 Professional UAS safely in the NAS, without creating a 

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

security. 

CONCLUSION

As set forth herein, Coeus 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 Vision+, Phantom 3 Professional UAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial video and photography over certain 

areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the 

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

the interests of the public, by allowing UAV Aerial Video to safely, efficiently, and economically 

operate the DJI Phantom 2 Vision+, Phantom 3 Professional UAS commercially within the NAS. 

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

and Reform Act of 2012, Section 333, Coeus 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 Coeus to operate the DJI Phantom 2 Vision +, Phantom 3 Professional UAS 

commercially for the purpose of conducting aerial video and photography of Real Estate 

Properties (for homeowners, realtors, home builders, home contractors and / or home 

inspectors for real estate marketing and inspection of home exteriors) as well as filming of 

special events, film sets, scripted and unscripted television sets and landscape as well as 

conducting power line inspection, aerial mapping, surveying and search and rescue over certain 

areas of the United States. 

Respectfully submitted by, Donald A. Trowell

Donald A. Trowell

Coeus

544 Flint Street

Rock Hill, SC 29730

843-637-9029

datrowell@yahoo.com 
Appendixes:

A – DJI Phantom 2 Vision+ Specifications Data Sheet 

B – DJI Phantom 2 Vision+ Manufacturer’s User Manual 

C – DJI Phantom 3 Professional Specifications Data Sheet 

D – DJI Phantom 3 Manufacturer’s User Manual 

E – Monthly Maintenance Log 
APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS 

Coeus only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI 

UASs are loaded with ground breaking software enabling the user to set parameters which will 

not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher 

than a predetermined and set altitude as well as limit flight to a predetermined and set 

distance. In addition, DJI software provides real-time altitude and location information to the 

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

1.1 DJI Phantom 2 Vision+ 

1.1.1 Aircraft 

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 

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

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

1.1.1.4 Max Yaw Angular Velocity - 2000/s 

1.1.1.5 Max Tilt Angel - 350 

1.1.1.6 Max Ascent Speed – 6m/s 

1.1.1.7 Max Descent Speed – 2m/s 

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

1.1.2 Gimbal 

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

1.1.2.2 Control Accuracy - ±0.030 

1.1.2.3 Controllable Range – Pitch: -900 - 00 

1.1.2.4 Maximum Angular Speed – Pitch: 900/s 

1.1.3 Camera 

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

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288 

4.1.3.5 HD Video Recording – 1080p30 & 720p 

4.1.3.6 Recording Field of View - 1100/850 

1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW 
1.1.4.5 Working Voltage – 120mA@3.7V 

1.1.5 Range Extender 

1.1.5.1 Operating Frequency – 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed) – 500-700m 

1.1.5.3 Transmitter Power – 20dBm 

1.1.5.4 Power Consumption – 2W
APPENDIX-B 

DJI Phantom 2 Vision+ Manufacturer's User Manual 

(uploaded in a separate attachment, a 72-page document)
APPENDIX – C

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

AIRCRAFT

Weight (Including Battery And Propellers) 1280 g

Diagonal Size (Including Propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy 

• Vertical: +/- 10cm 

• Horizontal: +/- 1m 

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

Max Altitude Above Sea Level 6000 m

Operating Temperature 0°C to 40°C

Gps Mode GPS/GLONASS

GIMBAL 

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

REMOTE CONTROLLER 

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance 2000m (outdoors/unobstructed) 

Video Output Port USB 

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder For tablet or phone Receiver

Sensitivity (1%Per) -101 dBm ±2 dBm

Transmitter Power (Eirp) 

• FCC: 20 dBm 

• CE: 16 dBm 

Working Voltage 1.2 A @7.4 V
BATTERY CHARGER 

Voltage 17.4 V Rated Power

Phantom 3 Professional 100 W

INTELLIGENT FLIGHT BATTERY 

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W
APPENDIX – D 

DJI Phantom 3 Professional Manufacturer’s User Manual 

(uploaded in a separate attachment, a 58-page document)
APPENDIX – E

MONTHLY MAINTENANCE LOG

UAS 

# 

Date Issue

Discovered

Date Issue

Addressed

Issue Description 

& Maintenance 

Conducted

Maintenance 

Performed By: Print & 

Sign

Software Updates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 

Vibration 

Dampening 

Other: