Dear Exemption Manager,

Environmental Planning Group, LLC (EPG), seeks exemption from the requirements of 14 C.F.R

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

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

Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (FMRA). This

exemption will permit EPG to operate a small Unmanned Aircraft (UA) for the commercial

purpose of collecting photographs and video for planning and construction monitoring

purposes. EPG is an environmental planning services company whose anticipated UA services to

clients such as the United States Bureau of Land Management (BLM), United States Forest

Service (USFS), multiple utility companies, and local municipalities would include:

• Photo and video documentation for photo simulations of proposed projects

• Infrastructure inspection of utilities, pipelines, roadways, and built structures

• Photography of archeological and cultural sites

• Monitoring of erosion, air quality

• Construction site inspections and monitoring

• Oil and gas pipeline inspection/patrolling and oil‐field inspection

• Aerial surveying, mapping, and data collection

• Wildlife observance and monitoring

• Educational and research operations

Name of Applicant:

Environmental Planning Group, LLC (EPG)

4141 North 32nd Street, Suite 102

Phoenix, AZ 85018

Phone: 602.956.4370

Basis for Petition

EPG (Petitioner) seeks an exemption from the listed Federal Aviation Regulations (FARs) to

allow commercial operation of their UA, with full understanding that operations are conducted

within and under the conditions outlined and as established by the FAA as required by Section

333. The UA, as used by the Petitioner, would provide a safe means for conducting monitoring

and aerial photography while providing a higher quality of service to our clients and the public

in general.

As described more fully below, the requested exemption would permit the operation of small,

unmanned and relatively inexpensive UA (specifically, a DJI Phantom 3) under controlled

conditions in the National Airspace System (NAS) regulated by the FAA.

Specific Regulations from which the exemption is requested:

• 14 CFR 61.23 (a) & (c) – Medical certificates: Requirements and duration

• 14 CFR 61.101 (e) (4) & (5) – Recreational pilot privileges and limitations

• 14 CFR 61.113 (a) – Private pilot privileges and limitations: Pilot in command
• 14 CFR 61.315 (a) – What are the privileges and limits of my sport pilot certificate?

• 14 CFR 91.7 (a) – Civil aircraft airworthiness

• 14 CFR 91.119 (c) – Minimum safe altitudes: General

• 14 CFR 91.121 – Altimeter settings

• 14 CFR 91.151 (a) (1) – Fuel requirements for flights in Visual Flight Rules (VFR) conditions  

• 14 CFR 91.405 (a) – Maintenance required

• 14 CFR 91.407 (a) (1) – Operation after maintenance, preventative maintenance, rebuilding,

and alteration

• 14 CFR 91.409 (a) (1) & (2) – Inspections

• 14 CFR 91.417 (a) & (b) – Maintenance records

14 CFR § 61.23 (a) & (c): Medical certificates: Requirements and duration.

This regulation sets forth medical certificate requirements for pilots‐in‐command (PIC) of aircraft in

that a holder must have a first‐class medical certificate when exercising the PIC privileges of an

airline transport pilot certificate. Furthermore, the requirement states that the PIC must hold at

least a second‐class medical certificate when exercising PIC privileges of a commercial pilot

certificate, or must hold at least a third‐class medical certificate when exercising PIC privileges of a

private pilot certificate, recreational pilot certificate, or flight instructor certificate. It also states

that a person must hold and possess either a medical certificate issued under § 61.67 or a U.S.

driver's license when exercising the privileges of a PIC of a sport pilot certificate in a light‐sport

aircraft other than a glider or balloon.  

The FAA is granting relief from § 61.23(a) to allow any pilot that holds one of the pilot’s certificates

(discussed above) to operate a UAV with a U.S. issued driver’s license in lieu of an FAA‐issued

medical certificate. The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate

holders to operate aircraft other than light‐sport aircraft (LSA) with a U.S. issued driver’s license.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 11278, 11275,

11269, 11267, 11260, 11256, 11253, 11252, 11240, and 11230.

14 CFR § 61.101 (e) (4) & (5): Recreational pilot privileges and limitations.

This section limits recreational pilots to non‐commercial operations and that they may not act as

pilot in command of a recreational aircraft for compensation or hire, or in the furtherance of a

business. Unlike a conventional aircraft that carries the pilot and passengers, the UA is remotely

controlled with no living thing on board. The area of operation will be predetermined and in a

protected flight area under the permission of the property representative, and all flights are

planned and coordinated in advance. The FAA has issued the following exemptions to this

regulation: Exemption Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240, and

11230.

14 CFR § 61.113 (a): Private pilot privileges and limitations: Pilot in command.

This section limits private pilots to non‐commercial operations and that they may not act as pilot in

command of an aircraft that is carrying passengers or property for compensation or hire. Unlike a

conventional aircraft that carries the pilot and passengers, the UA is remotely controlled with no

living thing on board. The area of operation will be predetermined and in a protected flight area

under the permission of the property representative, and all flights are planned and coordinated in
advance. The FAA has issued the following exemptions to this regulation: Exemption Nos. 11278,

11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240, and 11230.

14 CFR § 61.315 (a): What are the privileges and limits of my sport pilot certificate?

This section limits sport pilots to non‐commercial operations and that they may not act as pilot in

command of an aircraft that is carrying passengers or property for compensation or hire, or in the

furtherance of a business. They also may not carry more than one passenger, fly at night, and under

other restrictions that are outside of the scope of intended flights of the UA. Unlike a conventional

aircraft that carries the pilot and passengers, the UA is remotely controlled with no living thing on

board. The area of operation will be predetermined and in a protected flight area under the

permission of the property representative, and all flights are planned and coordinated in advance.

The FAA has issued the following exemptions to this regulation: Exemption Nos. 11278, 11275,

11269, 11267, 11260, 11256, 11253, 11252, 11240, and 11230.

14 CFR § 91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition.

As there will be no airworthiness certificate issued for the aircraft, should this exemption be

granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the

aircraft for maintenance and use of preflight actions as prescribed by the aircraft’s manufacturer

prior to each flight, and given the FAA’s prior approval of the same types of aircraft to be used in

previous exemptions to this requirement (as set forth in Exemptions Nos. 11278, 11275, 11267,

11260, 11253 and 11230), we believe we can maintain a high standard of safety and due regard as

to the aircraft’s airworthiness during flight operations. The FAA has issued the following exemptions

to this regulation: Exemption Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252,

11240, and 11230.

14 CFR § 91.119 (c): Minimum safe altitudes.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows

helicopters to be operated at less than the minimums prescribed, provided the person operating

the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this

exemption is for UAS that are rotorcraft and the exemption requests authority to operate at

altitudes up to 200 feet above ground level (AGL), an exemption may be needed to allow such

operations. As set forth herein, the UA will never operate at higher than 200 feet AGL, will always

be operated under Visual Line of Sight (VLOS) of both the PIC and Visual Observer (VO), its area of

operation will be predetermined and in a protected flight area under the permission of the property

representative, all flights are planned and coordinated in advance and the UA will remain clear of,

and give way to all manned aviation operations and activities at all times. The equivalent level of

safety will be achieved given the size, weight, and speed of the UA, as well as the location where it

is operated and under the conditions previously stated. Compared to flight operations with aircraft

or rotorcraft weighting far more than the maximum 55 pounds proposed herein and the lack of

flammable fuel, any risk associated with these operations is far less than those presently presented

with conventional aircraft operating at or below 500 feet AGL. In addition, the low‐altitude

operations of the UA will ensure separation between these small UAS operations and the

operations of conventional aircraft that must comply with Section 91.119. The FAA has issued the

following exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260,

11256, 11253, 11252, 11240, and 11230.
14 CFR § 91.121: Altimeter Settings.

This regulation requires each person operating an aircraft to maintain cruising altitude by reference

to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter

setting available before departure.” As the UA may not have a barometric altimeter, but instead a

GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved

by the operator, pursuant to the manufacturer’s published procedures and live flight data

monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator before

flight. In the event that the GPS altitude read out system becomes none functional during flight, the

UA will also have a pre‐programmed maximum flight limit of 200 feet programmed into them so

that they may not fly above unapproved altitude limits. The FAA has issued the following

exemptions to this regulation: Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253,

11252, 11240, and 11230.

14 CFR § 91.151(a) (1): Fuel Requirements for Flight in VFR Conditions.

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, to fly

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.” The

Lithium‐ion polymer (LiPo) battery powering the DJI Phantom 3 provides approximately 20 minutes

of powered flight. The PIC will not begin a flight unless there is enough available power for the UA

to conduct the intended operation and to operate after that for at least five minutes or with the

reserve power recommended by the manufacturer if greater. Applicant believes that an exemption

from 14 CFR §91.151(a) falls within the scope of prior exemptions, and that flight with less than 30

minutes of reserve fuel does not engender the type of risks that Section 91.151(a) was intended to

alleviate given the size and speed of the small UAS. Similar exemptions have been granted to other

operations, including Exemptions Nos. 11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252,

11240, and 11230.

14 CFR § 91.405 (a); 407 (a) (1); 409 (a) (1) & (2); 417(a) & (b): Maintenance Inspections.

These regulations require that an aircraft operator or owner “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...,”

and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these

sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not

apply to the applicant.

An equivalent level of safety will be achieved because these small UASs are very limited in size and

will carry a small payload and operate only in restricted areas for limited periods of time. If

mechanical issues arise, the UA can land immediately and will be operating from no higher than 200

feet AGL and within VLOS of the PIC and VO. Prior to each flight, the PIC must conduct a pre‐flight

inspection and determine the UAS is in a condition for safe flight. The pre‐flight inspection must

account for all potential discrepancies, e.g. inoperable components, items, or equipment. 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 operator must follow the UAS manufacturer’s maintenance,

overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft

components. The FAA has issued the following exemptions to this regulation: Exemptions Nos.

11278, 11275, 11269, 11267, 11260, 11256, 11253, 11252, 11240, and 11230.

Regulatory Basis for Exemption Request

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section

333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to

consider whether certain unmanned aircraft systems may operate safely in the NAS before

completion of the rulemaking required under Section 332 of the Reform Act. In making this

determination, the Secretary is required to determine which types of UA do not create a hazard

to users of the NAS or the public or pose a threat to national security in light of the following:

• The UA’s size, weight, speed, and operational capability;

• Operation of the UA in close proximity to airports and populated areas

• Operation of the UA within visual line of sight of the operator.

Lastly, if the Secretary determines that such vehicles “may operate safely in the national

airspace system, the Secretary shall establish requirements for the safe operation of such

aircraft in the national airspace system.” Id. §333(c) (emphasis added). The Federal Aviation Act

expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms

includes exempting civil aircraft, as the term is defined under §40101 of the Act, which includes

UA, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed

under subsection (a) or (b) of this section or any sections 44702‐44716 of this title if the

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC

§44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

EPG’s UA are rotorcraft, weighting 55 or fewer pounds including payload. The sole current UA is

a DJI Phantom 3 model, however future UAs may be purchased that would be of similar size

and capability as the Phantom 3. The UA will operate under normal conditions at a speed of no

more than 50 knots and have the capability to hover and move in the vertical and horizontal

plane simultaneously. The UA will be operated only in line of sight and will be operated only

within a predetermined and protected flight area under the permission of the property

representative. The UA will be operated under the below listed limitations and conditions to

which the operator agrees to be bound when conducting commercial operations under an FAA

issued exemption, as well as any other limitations the FAA may place on future operations.

Such operations will insure that the UA will “not create a hazard to users of the national

airspace system or the public as per the Reform Act Section 333 (b).

Given the clear direction in Section 333 of the Reform Act, the authority contained in the

Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the
proposed operations; the significant public benefit, including enhanced safety; reduction in

environmental impacts, including reduced emissions associated with allowing UA for aerial data

collection, the grant of the requested exemptions is in the public interest. Accordingly, the

applicant respectfully requests that the FAA grant the requested exemption without delay.

The FAA has issued grants of exemption in circumstances similar in material respects to those

presented in this petition in Exemptions Nos. 11280, 11279, 11278, 11275, 11273, 11271,

11269, 11267, 11260, 11253, 11250, 11230, 11213, 11112, and 11109.

Reasons for Granting Exemption Will Benefit the Public as a Whole

Granting the exception will benefit the public interest by allowing Environmental Planning

Group, LLC to safely, efficiently, and economically perform surveys, project photography and

video, and compliance monitoring. Specifically:

1 – Decreased air congestion. The DJI Phantom 3 UA is battery‐powered and serves as a safe,

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain

aerial imagery and conduct inspections. By reducing the amount of manned aircraft needed to

perform aerial photography, an exemption allowing the use of a DJI Phantom 3 UA would

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

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

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

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3

does 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 – Decreased air and noise pollution. Conducting aerial acquisitions with the DJI Phantom 3

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

air and noise pollution generated during traditional aerial video and still photography flight

operations. By using battery power and electric motors, the DJI Phantom 3 produces no air

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

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

photography, while burning approximately 20‐30 gallons per hour of leaded aviation fuel. The

DJI Phantom 3 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 3 UA to perform aerial photography, the substantial risk to life and

property in the air and on the ground that is usually associated with traditional manned aircraft

flight operations will be substantially reduced or completely eliminated. Aside from the lack of

flight crew members located onboard the aircraft, the DJI Phantom 3 UA (weighing

approximately 3 pounds at maximum gross weights with lengths of 16 inches, widths 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 6,000 pounds with a wingspan of approximately 42

feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3 – Benefits to the economy in general. In addition to being safe and efficient, the DJI Phantom

3 UA is also an economical alternative to using manned aircraft to conduct similar aerial

operations. Operating the battery‐powered DJI Phantom 3 UA is a technology that allows

companies greater operational flexibility compared to manned aircraft without the operational

cost. U.S. companies such as EPG can remain competitive and profitable by operating the DJI

Phantom 3 UA and therefore provide greater job stability to employees and contractors, which

will ultimately contribute to growth of the U.S. economy by contributing to a stable workforce

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

4 – No Privacy Issues. Similar to the manned aerial acquisition flight operations that have been

conducted for decades, EPG, LLC, proposed operation of the DJI Phantom 3 UA will not

implicate any privacy issues. Specifically, the DJI Phantom 3 UA will be operated only in

compliance with operating documents (i.e., the Operations Manual, Monthly Maintenance Log,

and DJI Phantom 3 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.

Reasons Granting the Exemption Would Not Affect Safety or the Exemption Would Provide a

Level of Safety at Least Equal to the Existing Rule

1 – The DJI Phantom 3 meets 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, operation of the DJI  Phantom 3 UA meets the conditions

of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. 14.

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

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

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

the following, in part:

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

180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine if certain unmanned aircraft systems may operate safely in the national

airspace system before completion of the plan and rulemaking required by section 332 of

this Act or the guidance required by section 334 of this Act.

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

subsection (a), the Secretary shall determine, at a minimum‐‐ (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

(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.

2 – The technical specifications of the DJI Phantom 3 limit safety concerns.

The DJI Phantom 3 UA 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.

In addition to size of the DJI Phantom 3, the technical specifications of the DJI Phantom 3 limit

the distance and operations of the UA. Specifically:

A – Distance is limited to less than 1 mile from PIC.

B – The DJI Phantom 3 is designed to automatically return to Home Point in the event of

Loss of Signal from Control Link. When the Control Link is lost, the DJI Phantom 3 UA will

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3

UAs do 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.

3 – Specific EPG Standard Operating Procedures.

These limitations and conditions to which the operator agrees to be bound when conducting

commercial operations under an FAA issued exemption include:

1. The UA (DJI Phantom 3) will weigh less than 55 pounds including payload. Proposed

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

exemption.

2. Operations for the purpose of closed‐set motion picture and television filming are not

permitted.

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

4. The UA must be operated at an altitude of no more than 200 feet AGL. Altitude must be

reported in feet AGL.  

5. The UA must be operated within 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 or U.S. driver’s license.
6. All operations must utilize a VO. The UA must be operated within the VLOS of the PIC and VO

at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always

maintains VLOS capability. The VO 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 VO can perform the duties required of the VO.

7. The exemption and all documents needed to operate the UAS and conduct its operations in

accordance with the conditions and limitations stated in the grant of exemption are hereinafter

referred to as the operating documents. The operating documents must be accessible during

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

between the conditions and limitations in the exemption and the procedures outlined in the

operating documents, the conditions and limitations therein 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 or any law enforcement official 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 an 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.

8. 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 prior to conducting further operations under this exemption. Functional test flights

may only be conducted by a PIC with a VO and must remain at least 500 feet from other people.

The functional test flight must be conducted in such a manner so as to not pose an undue

hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a

condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre‐flight inspection and determine that the UAS

is in a condition for safe flight. The pre‐flight inspection must account for all potential

discrepancies, e.g., inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement,

inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated under the exemption must comply with all manufacturer's safety

bulletins.

13. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to

safely operate the UAS in a manner consistent with how the UAS will be operated under this

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must

be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the

operator’s PICs and VOs (training, proficiency, and experience‐building) and determining the

PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be

operated under this exemption 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 CFR § 91.119.

14. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). Flights under

special visual flight rules (SVFR) are not authorized.

15. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as

denoted in the current FAA Airport/Facility Directory (AFD), or for airports not denoted with an

ARP, the center of the airport symbol as denoted on the current FAA‐published aeronautical

chart, unless a letter of agreement with that airport’s management is obtained or otherwise

permitted by a Certificate of Waiver of Authorization (COA) issued to the exemption holder. The

letter of agreement with the airport management must be made available to the Administrator

or any law enforcement official upon request.

16. 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.

17. If the UAS loses communications or loses its GPS signal, the UA must return to a

predetermined location within the private or controlled‐access property.

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

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

conditions) there is enough available power for the UA to conduct the intended operation and

to operate after that for at least five minutes or with the reserve power recommended by the

manufacturer if greater.

20. The Operator must obtain an Air Traffic Organization (ATO) COA prior to conducting any

operations under the grant of this exemption. All operations shall be conducted in accordance
with an ATO‐issued COA. The exemption holder may apply for a new or amended COA if it

intends to conduct operations that cannot be conducted under the terms of the attached COA.

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

registered in accordance with 14 CFR part 47, and have identification (N‐ Number) markings in

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

22. Documents used by the operator to ensure the safe operation and flight of the UAS and any

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the

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

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

23. The UA must remain clear and give way to all manned aviation operations and activities at

all times.

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

25. All flight operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of nonparticipating

persons; and

b. The owner/controller of any vessels, vehicles, or structures has granted permission

for operating closer to those objects 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. The

PIC, VO, operator trainees, or essential persons are not considered nonparticipating persons

under the exemption.

26. All operations shall be conducted over private or controlled‐access property with

permission from the property owner/controller or authorized representative. Permission from

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

conducted.

27. 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 .
Additional Views, Information, and Summary

Use of Exemption Outside the United States

EPG does not anticipate use of the DJI Phantom 3 outside the United States.

Appendices:

Appendix A – Pre‐flight and Flight Checklist

Appendix B – Specifications

Appendix C – Maintenance Checklist

Appendix D – Monthly Maintenance Log

Appendix E – UAV Flight Log
Appendix A: Pre‐flight Inspection Checklist
Pre‐Flight Inspection Check List

Pre‐Flight Checklist

 Visual inspection for defects

 Batteries fully charged and checked ‐ Transmitter, UA, iPad, iPhone,

approved/compatible device

 Props tightened and locked

 SD card in camera

 Lens cap removed (As necessary)

 Antennae up and parallel

 Transmitter turned on (press once, release, then press and hold for 3 seconds)

 Ensure Transmitter is in P Mode

 Ensure UA is on a flat surface with no obstructions to camera or landing gear. This would

be the Home Point if flight is automatically aborted or ‘Return‐to‐Home’ feature is

manually activated.

 UA turned on (press once, release, then press and hold for 3 seconds).  

 Switch mobile device to Airplane Mode

 DJI Pilot app quit and restarted, no other running apps on iPad

 Ensure compass and sensors are calibrated

 Tap bar at top of app (Safe to Fly GPS) for full status

 Maps are cached (move the map around, zoom in and out)

 Minimum return height adjusted (check for tallest object and set accordingly)

 UA placed in safe launch and recover position

 Home point reprogrammed via app (if necessary)

 Verify weather conditions are suitable for flight

 Area clear of people/obstructions

Flight Checklist

 Hover close for 20 seconds. Look/listen for defects

 Confirm expected stick operation

 Monitor battery power

 Monitor signal strength

 Keep line‐of‐sight with UA

 Ensure area/zone of intended flight path is clear of other aerial traffic.

 Ensure area/zone of intended flight path is clear of any electrical/power lines

 Ensure atmospheric conditions are optimal for safe operation of UAV/UAS

 Select a safe zone to “ditch” the UAV/UAS in the event an emergency landing is required
Appendix B: DJI Phantom 3 Manual &

Specifications



Appendix C: Maintenance Checklist  
BEFORE & AFTER EVERY FLIGHT  

* Check condition of props  

* Check motors freely spun by hand (don't bind or grind when turned)  

* Check condition of battery connectors and data pins  

* When powered up and idling, confirm no unusual noise or vibration from motors.  

EVERY WEEK OR EVERY 10 FLIGHTS, WHICHEVER SOONER  

* Visual inspection of shell and other plastic components for cracking/damage (landing skids,

camera mounting plates, etc.);  

* Check tightness of motor retaining screws and shell retaining screws (both 2.0mm hex);  

* Plug in to Vision Assistant and check tx & IMU calibration state and all battery cells have good

balance (repeat for all batteries);  

* Check batteries for number of cycles and discharge per DJI recommendations if required.  

ONCE PER MONTH or AFTER EVERY 30 FLIGHTS  

* 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.  

* Check for firmware updates via Assistant software  
Appendix D: Monthly Maintenance Log
Date

inspected

Date

addressed

Issue (description & maintenance

conducted)

Maintenance

performed by:

(sign and print)

Software

(updates)

      

Airframe        

Motors        

Camera        

Landing Gear        

Vibration

Dampening

      

Other:        
Appendix E: UAV Flight Log
Date

Time

(start/completion) UA Pilot Spotter/Controller Flight Details

UAV Flight Log