UNITED STATES OF AMERICA DEPARTMENT OFTRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. FAA-2007-0001

Docket Operations, M-30

U.S. Department of Transportation (DOT) 1200 New 

Jersey Avenue,

Room W12-140, West Building Ground Floor 

Washington, DC 20590-0001

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PMT PROPERTIES

 a Tennessee Limited Liability Commpany

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE 

CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151 (b), 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 2 VISION+ AND DJIINSPIRE 1 UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT 

OF 2012 (PUBLIC LAW 112-95)

Submitted on January 25, 2016

PMT PROPERTIES LLC 

c/o JOHN PEGRAM, MANAGER 

188 Front Street Suite 116-18 Franklin, Tennessee 

37064

615-586-1298
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TABLE OF CONTENTS

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

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

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

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

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

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

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROMWHICH

PMT PROPERTIES LLC EXEMPTION................................................7

C. THE EXTENT OF RELIEF PMT PROPERTIES LLC SEEKS AND THE 

REASON PMT PROPERTIES LLC

SEEKS THE RELIEF........................................................................... ..........10

D. THE REASONS WHY GRANTING PMT PROPERTIES LLC

REQUEST WOULD BE IN THE

PUBLIC INTEREST.......................................................................12

E. THE REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY...................................14

THE REASONS WHY GRANTING AN EXEMPTION FROM 

THE REQUIREMENTS OF 61.113(A) AND (B)

WOULD NOT ADVERSELY AFFECT SAFETY....................................................... 20

CONCLUSION ........................................................................................................... 21
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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

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 of2012 (FMRA) SO Safety 

Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAS Small Unmanned Aircraft System (under 55 pounds Gross Weight) VFR

Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions VTOL

Vertical Takeoff and Landing

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View

LI-PO Lithium Polymer battery

RCV Radio Controlled vehicle
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SUMMARY

PMT PROPERTIES LLC seeks exemption from the requirements of 14 C.F.R

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

(a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

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

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

conducting aerial video and photography for marketing, film sets, real estate photography, 

commercials, special events, cinematography, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is JOHN PEGRAM, and I am the Manager and owner PMT PROPERTIES, LLC. I also 

hold a Single engine land pilot certificate with high performance ratings, along with a 3rd Class 

Medical Certificate.

JOHN PEGRAM, is a Real Estate Broker, specializing in Land Acquisition, Land Development, 

Residential Community Development, New Home Construction, Commercial Development, 

Commercial Sales and some Re-Sale Residential Sales. 

The objective of PMT PROPERTIES, LLC aerial video and photography operations is to provide 

high quality imaging directly associated with real estate, both commercial, and residential 

applications. UAS High Definition videography and photography provides a client with a clearer 

view of the property from vantage points once prohibited by manned flights. In addition, the 

aerial presentation offers a cost effective means of marketing, managing, improving construction 

costs. High Definition Aerial Videography serves the public and governing bodies by providing 

an advance visual display which allows for more effective planning, and superior information 

which lead to better informed decision.

 BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1

PMT PROPERTIES seeks an exemption to operate DJI systems for compensation or hire within the 

NAS. The DJI Phantom 2 Vision + and DJI Inspire I are vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. The DJI Phantom 2 Vision+ has a maximum gross weight of approximately 2 

pounds 7 ounces, while having a length of 16 inches’ width of 16 inches, height of 8 inches, and a 

maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 

pounds 7.5 ounces, a length of

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 

42 knots. The DJI Phantom 2 Vision + and DJI Inspire l UA’s are equipped with four main rotors; 

driven by electric motors powered by a Lithium Polymer battery.

The DJI Phantom 2 plus and DJI Inspire 1 UAS’s that will be operated by JOHN PEGRAM, PMT 

PROPERTIES LLC and registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as 

well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Markings.
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BASIS FOR PETITION

Petitioner, PMT PROPERTIES,LLC, pursuant to the provisions of the Federal Aviation Regulations 

(14C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 

Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate the DJI Phantom 2 Vision + and the DJI Inspire 1 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), 91.119, 91.121, 91.l51(b), 91.405(a), 91.407(a)(I), 91.409(a)(l) & (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, PMT PROPERTIES LLC operation of DJI Phantom 2 and DJI 

Inspire 1 UAS’s 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, PMT PROPERTIES LLC requests relief from Sections 91.405(a), 91.407(a)(I), 

91.409(a)(I) & (a)(2), and 91.417 (a) & (b), as these sections set forth requirements for maintenance 

that only apply to aircraft with an airworthiness certificate.

PMT PROPERTIES LLC submits that the requested relief is proper since an equivalent level of

safety will be ensured. PMT PROPERTIES LLC 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 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, PMT PROPERTIES 

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

Inspire 1 UAS.

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

limitations: Pilot in command, is requested by PMT PROPERTIES LLC to the extent necessary to 

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an 

airman medical certificate, and who has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision + and DJI 

Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

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

PMT PROPERTIES LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 2 and DJI Inspire 1 UAS do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, PMT PROPERTIES LLC submits that he 

will ensure that the DJI Phantom 2 Vision+ and DJI Inspire l UAS are 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 2 Vision+ and DJI Inspire 1 Instruction Manual), 

and that the aircraft are in a condition for safe flight.
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PMT PROPERTIES LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Phantom 2 Vison+ and DJI Inspire 1 UAs will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 2Vision+ and DJI 

Inspire 1 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 active 

monitoring of the flight path. This altitude information, combined with PMT PROPERTIES LLC

operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS within visual line of sight, at or 

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

Additionally, PMT PROPERTIES LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. PMT PROPERTIES LLC submits 

that safety will not be affected by operation of the DJI Phantom 2 and DJI Inspire 1 UAS’s during 

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

enough battery power to fly for a total duration of approximately 15.5 minutes to the first point of 

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

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

PMT PROPERTIES LLC 

JOHN PEGRAM, MANAGER 

188 Front Street Suite 116-18 Franklin, Tennessee 

37064

615-586-1298

 John@thepegramteam.com
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B. The Specific Sections of 14 C.F.R. from which PMT PROPERTIES LLC Seeks Exemption.

1. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 61.1l3(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 ifi. The flight is only incidental to that business or employment; and

ii. The aircraft does not carry passengers or property for compensation or hire.

2. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 91.7(a).

Section 91.7, entitled civil aircraft airworthiness, subsection (a), states the following: (a) No 

person may operate a civil aircraft unless it is in an airworthy condition.

 3. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 91.121.

a. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

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

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

when operating-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)(l)(i) of this 

section, the current reported altimeter setting of an appropriate available 

station;

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

departure airport or an appropriate altimeter setting available before 

departure.

4. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection (b), states the following: (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.
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4. PMT PROPERTIES LLC Seeks Exemption from The Requirement of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a) states the following: Each owner 

or operator of an aircraft:

a. Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

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

discrepancies repaired as prescribed in part 43 of this chapter

5. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Section 91.407(a)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration;

a. Subsection (a)(1), states the following: No person may operate any aircraft that has 

undergone maintenance, preventive maintenance, rebuilding, or alteration unless--

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

7. PMT PROPERTIES LLC Seeks Exemption from The Requirements of Sections 91.409(a)(1) 

And 91.409(a)(2).

a. Section 91.409, entitled Inspections, subsection (a), states the following:

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

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

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

approved for return to service by a person authorized by § 43.7 of this chapter; or

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

part 21 of this chapter.

8. PMT PROPERTIES LLC Seeks Exemption from The Requirements of

Sections 91.417(a) And 91.417(b).

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

following:

i. 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

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

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

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

for return to service.

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 I 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 PMT PROPERTIES LLC Seeks and The reason PMT PROPERTIES LLC

Seeks the Relief.

1. Relief from Section 61.113(a) And (b):

a. Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight 

operations for compensation or hire. This relief is requested since the limitations set forth in 

Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of 

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

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

for compensation or hire. As set forth more fully below, PMT PROPERTIES LLC submits 

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

operate the DJI Phantom 2Vision + UAS or DJI Inspire 1 UAS unless that PIC has met certain 

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

either the DJI Phantom 2 Vision + or DJI Inspire 1 UAS in a manner consistent with the 

operations specifications as described in this exemption, including evasive and emergency 

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

structures. Further, PMT PROPERTIES LLC submits that all flights of the DJI Phantom 2 

Vision + and DJI Inspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to PMT PROPERTIES LLC’s business; and (2) will not carry 

passengers or property for compensation or hire.

b. Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow PMT PROPERTIES LLC to determine that the DJI Phantom 2 and DJI 

Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., PMT PROPERTIES LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision + and DJI Inspire 1 

Instruction Manual). PMT PROPERTIES LLC seeks the requested relief because the DJI 

Phantom 2 and DJI Inspire 1 UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, PMT PROPERTIES LLC will ensure that the 

DJI Phantom 2 Vision + and DJI Inspire 1 UAS are in airworthy condition based upon its 

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

2 and DJI Inspire 1 User Manuals; prior to every flight, and further, determine that the 

aircraft are in condition for safe flight, as stated in the conditions and limitations below. 

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

operations of the DJI Phantom 2 Vision+ and DJI Inspire 1 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), PMT PROPERTIES LLC seeks 

the requested relief because the DJI Phantom 2 Vision + and DJI Inspire 1 UA's altimeter

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

altitude, before each flight. Considering the limited altitude of the proposed operations, 

relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable 

conditions and limitations stated below. As more fully set forth herein, an equivalent level of 
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safety will be maintained since the DJI Phantom 2 and DJI Inspire 1 UAs are equipped with a 

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

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

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

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

requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision + 

and DJI Inspire 1 UAS during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), for a total duration of approximately15.5 minutes to the first point of 

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

PMT PROPERTIES LLC. seeks the requested relief because without an exemption from Section 

91.151 (b), the flight time duration of the battery powered DJI Phantom 2 Vision + and DJI Inspire 

1 UAS will severely constrain the practicality of any aerial video or still photo flight operations 

that proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical 

specifications of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS, the DJI Phantom 2 Vision + 

and DJI Inspire 1 operating documents, and the operating limitations proposed by, PMT 

PROPERTIES LLC ensure that PMT PROPERTIES LLC will safely operate the battery powered 

DJI Phantom 2 Vison +and DJI Inspire 1 UAS during daylight hours in visual meteorological 

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

duration of 13 minutes to the first point of intended landing and, assuming normal cruising 

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

d. 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 PMT PROPERTIES LLC requests relief from these Sections 

because the DJI Phantom 2 Vision + and DJI Inspire 1 UAS do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS meet 

the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, PMT PROPERTIES LLC 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 PMT PROPERTIES LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Inspire 1 Instruction Manual). 

Furthermore, will document and maintain all maintenance records for the DJI Phantom 2 Vision 

+ and DJI Inspire 1 UAS. 
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D. The Reasons Why Granting PMT PROPERTIES LLC Request Would Be in The Public 

Interest: That Is, How It Would Benefit the Public as A Whole.

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

PROPERTIES LLC to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the United 

States.

Additionally, use of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS will decrease 

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

significant benefits to the economy. Notably, the benefits of PMT PROPERTIES LLC proposed

operation of the DJI Phantom 2 and DJI Inspire 1 UAS will be realized without conflicting with or 

violation of any privacy issues.

1. The Public Will Benefit from Decreased Congestion of The NAS.

The DJI Phantom 2 Vision and DJI Inspire 1 UAs are battery powered and serve as a safe, 

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

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

acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI Inspire 1 

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

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

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

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

2Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

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

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

2. The Public Will Benefit from The Safety and Environmentally friendly renewable energy

DJI Phantom 2 Vision + and DJI Inspire 1 UAS.

Conducting aerial media acquisitions with the DJI Phantom 2 Vision + and DJI Inspire 

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

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

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

2 Vision + and DJI Inspire 1 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 which burn 

approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 Vision +

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

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

rather than an internal combustion engine. By using the DJI Phantom 2 Vision + and DJI 

Inspire 1 UAS to perform aerial acquisitions, the substantial risk to life and property in the 

air and on the ground, which is usually associated with traditional manned aircraft flight 

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

flight crew members located onboard the aircraft, the DJI Phantom 2 and DJI Inspire 1 UAs 

(weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 
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inches and 17.7 inches respectively, and with no fuel on board), has less physical potential 

for collateral damage to life and property on the ground, and in the air, compared to the 

manned aircraft that typically conduct similar operations (weighing approximately 6,000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 

180 gallons).

3. Performing Aerial Video and Photography Operations with The DJI Phantom 2 Vision + 

and DJI Inspire 1 UAS Will Benefit the Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision + and DJI Inspire 1 UAS are 

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

As such, operation of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS will allow United 

States based companies, such as PMT PROPERTIES LLC to remain competitive and 

contribute to growth of the U.S. economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain competitive. 

Operating the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAS utilizes 

technology that not only allows companies greater operational flexibility compared to 

manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS, 

companies such as can remain competitive and profitable, and therefore, provide greater job 

stability to employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial use of the 

DJI Phantom 2 Vision + and DJI Inspire 1 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 media acquisition flight operations that have been conducted 

for decades, proposed operation of the DJI Phantom 2 Vison + and DJI Inspire 1 UAS would 

not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision + and DJI Inspire 1 

UAS will be operated only in compliance with operating documents (i.e., PMT 

PROPERTIES LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 and DJI Inspire 1 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.

 
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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

PMT PROPERTIES LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 vision + and DJI Inspire 1 UAV Meet the Conditions of

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

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

unmanned aircraft and its operation, operation of the DJI Phantom 2 Vision + and DJI 

Inspire 1 UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Section 333 

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

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

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

the following, in part:

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

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

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

national airspace system before completion of the plan and 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 minimumc. 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 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 (J).

d. Requirements for Safe Operation. --If the Secretary determines under this section 

that certain unmanned aircraft systems may operate safely in the national airspace 

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

aircraft systems in the national airspace system.
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In seeking this exemption, PMT PROPERTIES LLC submits that the DJI Phantom 2 Vision+ and 

DJI Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated 

by: (a) the characteristics of the DJI Phantom 2 and DJI Inspire 1 UAS, (b) the pilot certification 

requirement and (c) the specific operating limitations.

i. The Specifications of The DJI Phantom 2 Vision + and DJI Inspire 1 UAS 

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision + and DJI Inspire 1 UAS do not create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security considering its size, 

weight, speed, and operational capability.

ii. Technical Specifications of The DJI Phantom 2 Vision + and DJI Inspire 1 UAS.

The DJI Phantom 2 and DJI Inspire 1 Specifications and Data Sheet, attached hereto as 

Exhibits A and B, set the technical specifications of the DJI Phantom 2 Vision+ and DJI 

Inspire 1 UAS forth.

iii. The DJI Phantom 2 Vision + and DJI Inspire 1 UAS Autonomous Flight and

Navigation Modes Enable The UAS to Remain Within A Defined Operational 

Area.

The DJI Phantom 2 Vision + and DJI Inspire 1 UAS may be operated in both manual and 

fully autonomous flight modes. A complete description of the flight and navigational 

modes of the DJI Phantom 2 Vision + and DJI Inspire 1 UAS is provided at pages 25-35 

of the DJI Phantom 2 Vision + and pages 12-16 and 45-50 of the DJI Inspire I User 

Manuals, attached hereto as Exhibit C and D.

iv. The DJI Phantom 2 Vision + and DJI Inspire 1 UAS Are Designed for Automatic 

Return to Home Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision + and DJI Inspire 1 UAs will 

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2

vision + and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs 

will assume that the Control Link is lost and the UAs will return to the home position 

(i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. A 

complete description of the Failsafe Functions of the DJI Phantom 2 Vision + UAS are set 

forth at pages 27 and 28 and for the DJI Inspire 1 at pages 13 through 15 of the DJI 

Phantom 2 vision +along with complete DJI Inspire 1 User Manuals, attached hereto as 

Exhibit C and D.

v. The DJI Phantom 2 Vision + and DJI Inspire 1 Ground Control Station (“GCS”) And 

Its Operation.

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

Inspire 1 GCS and flight control software is provided at pages 32 through 44 of the DJI 

Phantom 2 Vision + User Manual and pages 23 through 33 of the DJI Inspire 1 User 

Manual. DJI Phantom 2 Vision + and DJI Inspire 1 User Manuals are attached hereto as 

Exhibits C and D.
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vi. Flight Operations of DJI Phantom 2 Vision +and DJl Inspire 1 UAS Are Limited to The 

Line of Sight of a Certificated Pilot in Command with A Safety Observer.

vii. PMT PROPERTIES LLC will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2

Vision + and DJI Inspire 1 UAS. Additionally, a safety observer will assist all pilots 

during flight time.

viii.Flights of DJI Phantom 2 Vision + and DJI Inspire 1 UAS Will Be Conducted 

Pursuant to Specific Operating L i mi t at i o n s .

In seeking this exemption, PMT PROPERTIES LLC proposes to commercially operate DJI 

Phantom 2 and DJI Inspire 1 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(s) weighing less 

than 55 pounds’ maximum gross weight: DJI Phantom 2 Vision + and DJI Inspire 

1 Unmanned Aircraft Systems. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this grant.

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

operations for the purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 500 feet above ground 

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All 

altitudes reported to ATC must be in feet AGL.

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

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

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

medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is 

permitted as long as SO maintains visual on UAV.

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

the VLOS requirement as long as the PIC always maintains VLOS capability. The 

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

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

designated before the flight and cannot transfer his or her designation for the 

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

prescribed in the operating documents.

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

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments.
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9. The operating documents and the grant of exemption must be accessible during 

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

discrepancy exists between the conditions and limitations contained in the grant 

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

conditions and limitations contained in the grant of exemption take precedence 

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

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

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

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

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

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

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

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

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

questions arise regarding updates or revisions to the operating documents.

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

f or safe flight. If the inspection reveals a condition that affects the safe operation 

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

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

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

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

aircraft records.

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

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

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

flight must make an entry in the aircraft records.

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

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

sections of the operating documents.

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

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

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts must 

be noted in the aircraft records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the UAS to 

service.

15. Each UAS operated under this exemption must comply with all 

manufacturer Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections 

 
18 | P a g e

 17. The PIC must possess at least a private pilot certificate and at least a current t

hird-class medical certificate.

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

minimumWhich 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 

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 (J).

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.

closest to proposed area of operations. Flights under special visual flight rules 

(SVFR) are not authorized.

17. The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport's management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator's COA. 

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

the Administrator upon request.

18. 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.

19. 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.

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

emergencies in accordance with the operating documents.

21. 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.

22. 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
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in advance, but not less than 48 hours prior to the operation. All operations shall 

be conducted in accordance with airspace requirements in the ATO issued COA 

including class of airspace, altitude level and potential transponder requirements.

23. 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.

24. 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.

25. 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.

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

aviation operations and activities at all times.

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

28. 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).

29. 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.

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

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

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

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

instructions contained on the NTSB Website: www.ntsb.gov.
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Reasons Why an Exemption from The Requirements of Section 61.113(a) And

(b) Would Not Adversely Affect Safety.

PMT PROPERTIES LLC submits that the equivalent level of safety established by Section 

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

Phantom 2 Vision + and DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

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

DJI Phantom 2 Vision + or DJI Inspire 1 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering PMT PROPERTIES LLC’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 2 Vision + or DJI Inspire 1 

UAS, PMT PROPERTIES LLC submits that the additional manned airmanship experience 

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

PMT PROPERTIES LLC specific proposed flight operations. The FAA has previously 

granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all 

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

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

11153, 11156, 11158, 11159, 11160, 11161). PMT PROPERTIES LLC 

will not allow any PIC to operate the DJI Phantom 2 Visio + or DJI Inspire 1 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 2 

or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely 

operate the DJI Phantom 2 or DJI Inspire 1 UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

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

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

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

operations under the exemption). In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). 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 PMT PROPERTIES LLC’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
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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, thePIC 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 night 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 15. Accordingly, PMT PROPERTIES LLC will ensure safe

operations by not allowing any PIC to operate the DJI Phantom 2 or DJI Inspire 1 U AS 

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

requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision + or DJI 

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

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

structures.

CONCLUSION

PMT PROPERTIES LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

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

Phantom 2 and DJI Inspire 1sUAS 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 PMT PROPERTIES LLC to safely, efficiently, and economically operate the 

DJI Phantom 2 and DJI Inspire 1sUAS commercially within the NAS. WHEREFORE, in accordance 

with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 20 12, 

Section 333, PMT PROPERTIES LLC respectfully requests that the Administrator grant this 

Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

91.121, 91.151 (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) &

(a)(2), and 91.417(a) & (b), and permit PMT PROPERTIES LLC operate the DJI Phantom 2Vision 

+ and DJI Inspire 1 UAS commercially for the purpose of conducting aerial video and

photography over certain areas of the United States.

Dated: 

January 25, 2016

Submittedby:

PMT PROPERTIES LLC 

John D. Pegram, Manager
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EXHIBIT A

DJI PHANTOM 2 VISION +

TECHNICALSPECIFICATIONS

PMT PROPERTIES LLC only utilizes safe and reliable UAS. DJI is an industry leader in small UAS 

production. DJI UAS are complete with leading edge and proven software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also he set to limit flight 

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

distance. In addition, DJI software provides

real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices)

DJI Phantom 2

1.1 Aircraft

1.1.1 Supported Battery -DJI 5,200mAh 2S LiPo Battery

1.1.2 Weight (Battery & Propellers Included) -2 lbs 11.81 oz (1,242g)

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

1.1.4 Max Yaw Angular Velocity 200°/s

1.1.5 Max Tilt Angel 35°

1.1.6 Max Ascent / Descent Speed: Ascent 6m/s Descent 2m/s

1.1.7 Max Flight Speed-15m/s (NOT RECOMMENDED)

1.2 Gimbal

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

1.2.2 Control Accuracy -±O.03°

1.2.3 Controllable Range -Pitch: 90° to 0°

1.2.4 Maximum Angular Speed Pitch: 90°/s

1.3 Camera

1.3. 1 Operating Temperature Range 32°F - 104°F (O°C to 40°C)

1.3.2 Sensor Size 1⁄2.3"

1.3.3 Effective Pixels: 14 Megapixels

1.3.4 Resolution 4384x3288px

1.3.5 HD Video Recording: 1080p 30 & nop

1.3.6 Recording Field of View: 110°/85°
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EXHIBIT B

DJI INSPIRE 1 TECHNICALSPECIFICATIONS

PMT PROPERTIES LLC only utilizes safe and reliable UAS. DJI is an industry leader in small UAS 

production. DJI UAS are complete with leading edge and proven software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to 

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

distance. In addition, DJI software provides

real-time altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices)

DJI Inspire 1

1.1 Aircraft

1.1.1 Model -T600

1.1.2 Weight (Battery Included) -6 lbs 7.52910z(2,935g)

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

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

1.1.5 Max Tilt Angle: 35°

1.1.6 Max Ascent Speed: 5m/s

1.1.7 Max Descent Speed: 4m/s

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

1.1.9 Max Flight Altitude 4,500mMSL

1.1.10 Max Wind Resistance: 10m/s

1.1.11 Max Flight Time -Approximately 18minutes

1.1.12 Motor Model: DJI 3510

1.1.13 Propeller Model: DJI 1345

1.1.14 Operating Temperature Range: 14°F to 104°F (-10°C to 40°C) 1.1.15

Dimensions 438x451x201 mm 17.25” x 17.76" x 7.9"

1.2 Gimbal

1.2.1 Model: ZENMUSEX3

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

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

1.2.4 Angular Vibration Range -±0.03 °

1.2.5 Mounting -Detachable

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

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

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

1.3 Transmitter

1.3.1 Name-CI

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

1.3.3 Communicating Distance (unobstructed): 3.1miles

1.3.4 Output Power-9W

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

1.3.6 Battery 4,500mAh 2S or optional 5,700mAh LiPo2S

All specifications can be found in the attached user manual or at 

https://dl.djicdn.com/downloads/inspire_1/en/Inspire%20_1_User_Manual__V1.8.pdf