1

January 18, 2016

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: CDCS: Cameron Douglas Consulting Services

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS

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

91.409(a) (1) &

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

Phantom 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEMS PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC 

LAW 112-95)

Cameron Douglas

Owner

CDCS / Cameron Douglas Consulting Services

430 Ranchette RD

Monroe, Louisiana 71203

318-376-4576 Fax 318-345-2451

vdouglas@comcast.net or camerondouglas.cd@gmail.com
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TABLE OF CONTENTS: Page

GLOSSARY OF 

ABBREVIATIONS..................................................................................................3

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

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

BACKGROUND.....................................................................................................4

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

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

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

SEEKS EXEMPTION.............................................................................................6

THE EXTENT OF RELIEF CDCS SEEKS AND THE REASON CDCS SEEKS 

THE RELIEF...............................................................................................9

THE REASONS WHY GRANTING CDCS’S REQUEST WOULD BE

IN THE PUBLIC INTEREST ...............................................................................11

THE REASONS WHY GRANTING THE EXEMPTION TO CDCS

WOULD NOT ADVERSELY AFFECT SAFETY...................................................12

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........22

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT CDCS’S REQUEST...........................................................................22

CONCLUSION......................................................................................................23

APPENDICES......................................................................................................23
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GLOSSARY OF ABBREVIATIONS:

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CDCS Cameron Douglas Consulting Services

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY:

CDCS 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 (DJI Phantom 3 Professional) pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption 

will permit CDCS to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of vehicle crash sites, construction 

sites, residential and commercial real estate, and civil landscapes over certain areas of 

the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER:

CDCS has over twenty years of crash investigation experience (which include motor 

vehicle crash investigation of various types) with expertise and knowledge in video and 

crash photography training using advanced technologies and solutions. CDCS has 

worked on hundreds of investigations over the past 20 years in all types of locations 

with an excellent safety record. In the past we have supplied our client’s aerial video 

and photography using commercial aircraft. The objective of CDCS and our

Unmanned Aircraft System (DJI Phantom 3 Professional) aerial operations is to provide 

a more affordable, high-quality production system for a variety of governmental, 

commercial, public, and residential uses, specifically targeting

• Motor vehicle crash site photography

• Evidence collection and recording

• Documenting location of markers

• Economic development

• Civic landmarks

• Private and governmental training

I have safely flown small RC electric quadcopters recreationally for approximately 2 years

without incident.

BACKGROUND:

Unmanned Aircraft Systems: DJI Phantom 3 Professional, UAS CDCS seeks an 

exemption to operate DJI Phantom 3 system for compensation or hire within the NAS. 

The DJI Phantom 3 is vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with 

a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The 

DJI Phantom 3 has a maximum gross weight of approximately 2.8 lb. while having a 

diagonal dimension of 23.2”, a maximum speed of approximately 16.4’ fps and a 

maximum flying height of 400'. The DJI Phantom 3 is equipped with four main rotors;

driven by Lithium Polymer battery powered electric motors

The DJI Phantom 3 that will be operated by CDCS 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.
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BASIS FOR PETITION:

Petitioner, CDCS, pursuant to the provisions of the Federal Aviation

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

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

petitions the Administrator to commercially operate the DJI Phantom 3 Professional, 

UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(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, CDCS operation of 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, CDCS 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.

CDCS submits that the requested relief is proper since an equivalent level of safety will 

be ensured. CDCS will use experienced personnel or technicians to perform 

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

techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, CDCS will 

document and maintain all maintenance records for the 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 CDCS to the extent

necessary to allow a Pilot in Command (PIC) holding a unmanned aerial vehicle pilot 

license or higher level certificate, as well as an airman medical certificate, and who has 

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

is able to safely operate the DJI Phantom UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

CDCS seeks relief from Section 91.7(a), entitled civil aircraft airworthiness, because the 

DJI Phantom 3 Professional UAS do not require an airworthiness certificate in

accordance with 14 C.F.R. Part 21, Subpart H. As such, CDCS submits that they will 

ensure that the DJI Phantom 3 UAS is in an airworthy condition, prior to every flight, by 

determining that the UAS are in compliance with the operating documents (i.e.,

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual), and that the aircraft 

is in a condition for safe flight.

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

Altimeter Settings, as the DJI Phantom 3 UAS will not have a typical barometric

altimeter onboard. However, altitude information of the DJI Phantom 3 Professional 

UAS 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 
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active monitoring of the flight path. This altitude information, combined with CDCS’s 

operation of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, CDCS seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. CDCS submits that safety will not 

be affected by operation of the DJI Phantom 3 UAS during daylight hours in visual 

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

power to fly for a total duration of approximately 23 minutes. Battery power indicators 

are also able to show exactly how much battery power is left, as well as how much time 

is needed to return safely back to point of takeoff, along with the DJI Phantom’s 

automatic “ return to home “ system programed into the (UAV).

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

Cameron Douglas

Owner

CDCS/ Cameron Douglas Consulting Services

430 Ranchette RD

Monroe, Louisiana 71203 

318-376-4576 Fax 318-345-2451

vdouglas@comcast.net or camerondouglas.cd@gmail.com

Exemption:

1. CDCS Seeks Exemption from the Requirements of Section

61.113(a) and (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot 

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

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

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor 

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

may, for compensation or hire, act as PIC of an aircraft in connection with any business 

or employment if —

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

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

2. CDCS 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. CDCS Seeks Exemption from the Requirements of Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:
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(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. CDCS 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. CDCS 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. CDCS 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. CDCS 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.
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8. CDCS 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.
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C. The Extent of Relief CDCS Seeks and the Reason CDCS Seeks the Relief.

1. Extent of Relief CDCS Seeks and the Reason CDCS 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 

unmanned aerial vehicle pilot or higher level certificate, as well as a current and valid 

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

requirements, to conduct the proposed UAS flight operations for compensation or hire.

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

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

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

employment; and

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

As set forth more fully below, CDCS submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional 

UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the DJI Phantom 3 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, CDCS submits that all flights of the DJI Phantom 3 UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to CDCS’s business; and (2) 

will not carry passengers or property for compensation or hire.

2. Extent of Relief CDCS Seeks and the Reason CDCS 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 CDCS to determine that the DJI Phantom 3 UAS is in airworthy 

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

operating documents (i.e., Cameron Douglas Consulting Services (CDCS) Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual).

CDCS seeks the requested relief because the DJI Phantom 3 UAS does not require an 

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

CDCS will ensure that the DJI Phantom 3 UAS is in airworthy condition based upon its 

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

Phantom 3) prior to every flight, and further, determine that the aircraft is in condition for 

safe flight, as stated in the conditions and limitations below.

3. Extent of Relief CDCS Seeks and the Reason CDCS Seeks Relief from Section 

91.121.

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

operations of the DJI Phantom 3 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), CDCS seeks the requested relief 
10

because the DJI Phantom 3 UA’s altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

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

maintained since the DJI Phantom 3 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 CDCS Seeks and the Reason CDCS Seeks Relief from Section 

91.151(b).

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

requested to the extent required to allow flights of the battery powered DJI Phantom 3 

UAS during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), for a total duration of 23 minutes. CDCS seeks the requested relief 

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

battery powered DJI Phantom 3 UAS will severely constrain the practicality of any aerial 

video or still photo flight operations that CDCS proposes to conduct pursuant to this 

Petition.

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

the DJI Phantom 3 operating documents, and CDCS’s proposed operating limitations, 

ensure that CDCS will safely operate the battery powered DJI Phantom 3 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 23 minutes.

5. Extent of Relief CDCS Seeks and the Reason CDCS Seeks Relief from Sections 

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

And 91.417(a) & (b).

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

apply to aircraft with an airworthiness certificate, CDCS requests relief from these 

Sections because the DJI Phantom 3 UAS do not require airworthiness certificates. As 

set forth more fully below, the DJI Phantom 3 UAS meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, CDCS 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 CDCS Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Phantom 3 Instruction Manual). Furthermore, CDCS will document and 

maintain all maintenance records for the DJI Phantom 3 UAS.
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D. The Reasons Why Granting CDCS 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 CDCS to safely, 

efficiently, and economically perform aerial video and photography of Crash sites, 

construction sites, real estate, events and civic landscape over certain areas of the 

United States.

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of CDCS proposed operation of the DJI 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 3 UAS is battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS would reduce the 

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

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

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

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

The DJI Phantom 3 UAS do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 

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

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

UAS.

Conducting aerial acquisitions with the DJI Phantom 3 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 3 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 3 UAS, while reducing the carbon footprint of aerial acquisitions, 

also eliminates noise pollution, as the UAS are propelled by battery powered electric 

motors, rather than an internal combustion engine.

By using the DJI Phantom 3 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 3 UAS (weighing approximately 2.8 pounds at their maximum gross weight 

with diagonal dimension of 23.2 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 
12

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

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations with the DJI Phantom 3 

UAS

Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI Phantom 3 UAS will allow United States based companies, like 

Cameron Douglas Consulting Services (CDCS), to remain competitive and contribute to 

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered DJI

Phantom 3 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 3 UAS, companies such as CDCS, can remain 

competitive and profitable, and therefore, provide greater job stability to employees and

contractors, which will ultimately contribute to growth of the U.S. economy. Improved 

financial performance of U.S. companies, through commercial use of the DJI Phantom 3 

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, CDCS’s proposed operation of the DJI Phantom 3 UAS will not implicate any 

privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in compliance 

with operating documents (i.e., the CDCS Aerial 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.

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 CDCS Seeks Exemption.

1. Reasons Why the DJI Phantom 3 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, CDCS’s operation of the DJI Phantom 3 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 
13

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 (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, CDCS submits that the DJI 

Phantom 3 UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 UAS; (b) the pilot 

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

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe 

Characteristics.

The DJI Phantom 3 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 3 UAS.

The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 

3 User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 3 UAS Global Positioning Modes Enable the UAS to Remain

Within A Defined Operational Area.

The DJI Phantom 3 UAS may be operated in both manual and global positioning flight 

modes. A complete description of the flight and navigational modes of the DJI Phantom 

3 UAS is provided at pages 11 of the DJI Phantom 3 User Manual attached hereto as 

Appendix A.

iii. The DJI Phantom 3 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 3 Professional UAS will remain 

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

does not reacquire control link data from the GCS, the UAS will assume that the Control 

Link is lost and the will return to the home position (i.e., failsafe mode) via GPS, and will 

descend to the takeoff position and shutdown.
14

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are set forth 

at pages 12 through 14 of the DJI Phantom 3 User Manual, the web address is referred 

hereto as Appendix A.

iv. The DJI Phantom 3 GCS and Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 GCS 

and flight control software is provided at pages 23 through 29 of the DJI Phantom 3 

User Manual. DJI Phantom 3 User Manual web address is attached hereto as Appendix 

A.

b. Flight Operations of DJI Phantom 3 UAS Is Limited To the Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

CDCS crash reconstruction staff will be the only persons to act as a pilot in command 

(PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist him at all

times during flight time.

c. Flights of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, CDCS proposes to commercially operate DJI

Phantom 3 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 UAS weighing less than 55

pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems.

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

amend this grant.

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

purpose of aerial video and photography.

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

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

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

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

feet AGL.

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

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

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

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

p7. 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
15

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 permitted.

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 a UAV pilot certificate and at least a current third-class 

medical certificate.

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

operator’s qualification criteria and demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under the exemption,

including evasive and emergency maneuvers and maintaining appropriate distances

from persons, vessels, vehicles and structures. PIC qualification flight hours must be
16

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 14C.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). Flight 

at night is not expected however 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 approved by the FAA 

personnel in the control tower, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA.

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 24 hours prior to the

operation. All operations shall be conducted in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements.

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be 

as large as practicable.

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

control of the UA must comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

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

the PIC at the Ground Control Station of the UAS any time the UAS is operating.

These documents must be made available to the Administrator or any law enforcement 

official upon request.

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

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.
17

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.

CDCS submits that the equivalent level of safety established by Section 61.113(a) and 

(b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 

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

requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.

Considering CDCS’s proposed area of operations, and the operating limitations set 

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

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

skills necessary to safely operate the DJI Phantom 3 UAS, CDCS submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for CDCS’s 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.
18

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

11138, 11150,

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

CDCS will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3

UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 3 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

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

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

5 hours of those hours as a UAS pilot operating the same make and model of UAS to

be used for operations under the exemption). In addition to the hour requirements, the 

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

purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience

that was obtained in compliance with applicable regulations will ensure an equivalent 

level of safety during CDCS’s proposed operations. The Administrator has held that

prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the

purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

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

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

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

make and model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be inclusive rather 

than additive; i.e. 5 hours make and model time may be included in the 10 hours of 

multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft 

time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to 

practice and build proficiency in the skills necessary to safely conduct the petitioner’s 

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

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

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

grant of exemption to accomplish the required flight time. During training, proficiency, 

and experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 18.

Accordingly, CDCS will ensure safe operations by not allowing any PIC to operate the 

DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate the DJI Phantom 3
19

UAS in a manner consistent with the exemption, including evasive and emergency 

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

structures.

3. Reasons Why an Exemption from the Requirements of Section 91.7(a) Would 

Not Adversely Affect Safety. The equivalent level of safety established by Section 

91.7(a) will be maintained because prior to every flight, CDCS will ensure that the DJI 

Phantom 3 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 3 UAS 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 CDCS’s operation of the DJI Phantom 3 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 UAS 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 3 

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, CDCS will ensure that it will safely operate the

battery powered DJI Phantom 3 UAS during daylight hours in VFR conditions, with

enough battery power to fly for a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 

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 
20

91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 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 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, CDCS 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 CDCS 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., CDCS Aerial Operations Manual,

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore, CDCS

will document and maintain all maintenance records for the DJI Phantom 3

UAS. Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating 

documents, CDCS 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 3 User Manuals 

are attached hereto as Appendix A and B; a copy of the DJI Phantom 3 UAS 

Maintenance LOG is attached hereto as Appendix C.

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

Douglas Consulting Services (CDCS) will use trained technicians to perform 

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

techniques, and practices prescribed by the operating documents.

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

established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 

3 UAS will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log.

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 CDCS’s proposed operating limitations, the 
21

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

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, CDCS requests that the 

FAA prescribe special conditions for the intended operation of the DJI 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 §§ 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 3 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 Leading Edge’s intended 

operation of the DJI 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 Sections61.113(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).
22

• A Summary that can be published in the Federal Register, stating: The

Rules from Which CDCS Seeks Exemption:

CDCS 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 for CDCS:

This exemption will permit CDCS to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial video and photography over certain 

areas of the United States.

• Any Additional Information, Views, or Arguments Available To Support

CDCS’s Request.

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

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

certain UAS may operate safely in the NAS. As such, CDCS’s request for exemption

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, 

as set forth above.

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, CDCS will operate the DJI Phantom 3 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.
23

CONCLUSION:

As set forth herein, CDCS seeks an exemption pursuant to 14 C.F.R. §11.61 and 

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

permit safe operation of the DJI Phantom 3 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 CDCS to safely,

efficiently, and economically operate the DJI Phantom 3 UAS commercially within the 

NAS.

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

Modernization and Reform Act of 2012, Section 333, CDCS respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

Phantom 3 UAS commercially for the purpose of conducting aerial video and

photography over certain areas of the United States.

Dated: September 12, 2015

Respectfully submitted,

Cameron Douglas

Owner

Cameron Douglas Consulting Services

430 Ranchette RD

Monroe, Louisiana 71203

318-376-4576 Fax 318-345-2451

vdouglas@comcast.net / camerondouglas.cd@gmail.com

Appendices:

A – Link to DJI Phantom 3 Manual: Cut and paste the link below in your browser

http://www.dji.com/support