1

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Edward E. Mathews, dba Amelia Island Images

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)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF DJI PHANTOM 2 VISION+ UNMANNED AIRCRAFT

SYSTEMS PURSUANT TO SECTION 333 OF

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

Submitted on April 29, 2015 

Edward E. Mathews

Mailing address:

PO Box 1945; Yulee, FL 32041

Physical address:

85332 Miner Road; Yulee, FL 32097

Tel: (904) 225-0581

Cell: (904) 314-4300

Email: edmathew@comcast.net
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TABLE OF CONTENTS

Page

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

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

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

BACKGROUND..............................................................5

BASIS FOR PETITION......................................................6

NAME AND ADDRESS OF PETITIONER ....................................9

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONER SEEKS 

EXEMPTION .........................................................9

THE EXTENT OF RELIEF PETITIONER SEEKS AND THE REASON 

PETITIONER SEEKS THE RELIEF.......................................13

THE REASONS WHY GRANTING PETITIONER’S REQUEST WOULD BE IN THE

PUBLIC INTEREST ..................................................17

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT 

SAFETY............................................................21

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...............37

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT PETITIONER’S REQUEST........................................37

CONCLUSION..............................................................38

APPENDICES..............................................................39

A – DJI Phantom 2 Vision+ Specifications Data Sheet ...............39

B - DJI Phantom 2 Vision+ Manufacturer’s User Manual .............40

C – Preflight And Mission Checklist ...............................90

D – Monthly Maintenance Log .......................................91

E – Photocopy of Aircraft Registration Application ...............92
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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 of 2012 (FMRA) Section 333 

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

Edward E. Mathews, hereinafter referred to as Petitioner, 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 Edward E. 

Mathews, doing business as Amelia Island Images, a sole 

proprietorship with no employees, to operate an Unmanned 

Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and photography of construction sites, real estate, 

special events, and landscape over certain areas of the United 

States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Petitioner provides his clients with quality digital 

content and printed products for use in their commercial, 

personal, and non-profit multimedia projects. Amelia Island 

Images has been in continuous operation since 1987, and 

petitioner is proud of consistently providing quality products

and services. The objective of Petitioner is to provide high 

quality imaging for a variety of commercial, public, and 

residential uses. Petitioner’s primary activity involves the 

creation of photograph post cards for wholesale distribution to 
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state parks, museums, lighthouses, and a variety of retail 

stores in southeast Georgia and northeast Florida small towns 

and rural areas.

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 2 Vision+

Petitioner seeks an exemption to operate a single DJI 

system to support his existing post card business, for 

compensation, or for hire within the NAS. The DJI Phantom 2 

Vision+ is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) using a smart 

phone monitoring system. The DJI Phantom 2 Vision+ has a maximum 

gross weight of approximately 2 pounds 11 ounces, a length of 16 

inches, width of 16 inches, height of 8 inches, and a maximum 

speed of approximately 25 miles per hour. The DJI Phantom 2 

Vision+ UA is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors.

The DJI Phantom 2 Vision+ UAS will be operated only by 

Edward E. Mathews. An Aircraft Registration Application for this 

UAS was submitted using an original AC Form 8050-1 on April 29, 

2015 (see Appendix E) in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and will be marked in accordance with 14 C.F.R. 

Part 45, Identification and Registration Marking. 
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BASIS FOR PETITION 

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, petition is hereby submitted 

to the Administrator to commercially operate the DJI Phantom 2 

Vision + 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, use of the DJI Phantom 2 Vision+ 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, Petitioner 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. 

Petitioner submits that the requested relief is proper 

since an equivalent level of safety will be ensured. Petitioner
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will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs 

using the methods, techniques, and practices prescribed in the 

operating documents (i.e., Petitioner’s Preflight and Mission 

Checklist, Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

Instruction Manual). Furthermore, Petitioner will document and 

maintain all maintenance records for the DJI Phantom 2 Vision+ 

UAS. 

Relief from certain requirements of Section 61.113(a) and 

(b), entitled Private pilot privileges and limitations: Pilot in 

command, is requested by Petitioner because the aircraft cannot 

carry passengers or property, and the flight of this aircraft is 

only incidental to Petitioner’s business.

Petitioner seeks relief from Section 91.7(a), entitled 

Civil aircraft airworthiness, because the DJI Phantom 2 Vision+ 

UAS does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Petitioner submits 

that it will ensure that the DJI Phantom 2 Vision+ UAS is in an 

airworthy condition prior to every flight by determining that 

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

Petitioner’s Preflight and Mission Checklist, Monthly 

Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual), 

and that the aircraft is in a condition for safe flight. 
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Petitioner also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ UA will 

not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Phantom 2 Vision+ UA will be provided to the PIC 

via Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which downlinks from the UA to the GCS for active 

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

Petitioner’s operation of the DJI Phantom 2 Vision+ UAS within visual line 

of sight, at or below 396 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, Petitioner seeks an exemption from the requirements of 

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

conditions. Petitioner submits that safety will not be affected by 

operation of the DJI Phantom 2 Vision+ UA during daylight hours in visual 

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

enough battery power to fly for a total duration of 25 minutes, 

and will always be landed at the position it started from.

In accordance with 14 C.F.R. § 11.81, Petitioner provides 

the following information in support of its petition for 

exemption:
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A. Name And Address Of The Petitioner.

Edward E. Mathews

Mailing address:

PO Box 1945; Yulee, FL 32041

Physical address:

85332 Miner Road; Yulee, FL 32097

Tel: (904) 225-0581

Cell: (904) 314-4300 

Email: edmathew@comcast.net 

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

Seeks Exemption. 

1. Petitioner 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. Petitioner Seeks Exemption From The Requirements Of 

Section 91.7(a)
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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. Petitioner Seeks Exemption From The Requirements Of 

Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states 

the following, in part: 

(a) Each person operating an aircraft shall maintain the 

cruising altitude or flight level of that aircraft, as the 

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

operating-

(1) Below 18,000 feet MSL, to-

(i) The current reported altimeter setting of a 

station along the route and within 100 nautical 

miles of the aircraft; 

(ii) If there is no station within the area 

prescribed in paragraph (a)(1)(i) of this section, 

the current reported altimeter setting of an 

appropriate available station; or 

(iii) In the case of an aircraft not equipped with 

a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before 

departure. 

4. Petitioner 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. Petitioner Seeks Exemption From The Requirement Of 

Section 91.405(a).
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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. Petitioner 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. Petitioner Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the 

following: 

(a) Except as provided in paragraph (c) of this section, no person 

may operate an aircraft unless, within the preceding 12 calendar 

months, it has had –

(1) An annual inspection in accordance with part 43 of this 

chapter and has been approved for return to service by a 

person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness 

certificate in accordance with part 21 of this chapter.

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

shall be retained and transferred with the aircraft at the 

time the aircraft is sold.

(3) A list of defects furnished to a registered owner or 

operator under § 43.11 of this chapter shall be retained until 

the defects are repaired and the aircraft is approved for 

return to service.

C. The Extent Of Relief Petitioner Seeks And The Reason 

Petitioner Seeks The Relief.

1. Extent Of Relief Petitioner Seeks And The Reason Petitioner 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 

by Petitioner because the aircraft cannot carry passengers or 

property, and the flight of this aircraft is only incidental to 

Petitioner’s business.

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 if: (1) The flight is only incidental to that 

business; and (2) The aircraft does not carry passengers or 

property for compensation or hire. 

Petitioner submits that an equivalent level of safety will 

be maintained because Petitioner is an experienced hobby drone 

pilot, and no other person will be allowed to act as PIC. 

Additionally, as explained more fully below, the software used 
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by the Phantom 2 Vision+ has many safety features and 

capabilities that reduce incident likelihood.

Further, Petitioner submits that all flights of the DJI 

Phantom 2 Vision+ UAS, conducted by the PIC pursuant to the 

grant of this Petition: (1) will be incidental to Petitioner’s 

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

compensation or hire. 

2. Extent Of Relief Petitioner Seeks And The Reason 

Petitioner 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 

Petitioner to determine that the DJI Phantom 2 Vision+ UAS is in 

airworthy condition prior to every flight by ensuring that the 

UAS and its operation are in compliance with the DJI Phantom 2 

Vision+ Instruction Manual and Petitioner’s Preflight and 

Mission Checklist). 

Petitioner seeks the requested relief because the DJI 

Phantom 2 Vision+ UA does not require an airworthiness 

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

Therefore, Petitioner will ensure that the DJI Phantom 2 Vision+ 

UAS is in airworthy condition based upon its compliance with the 

DJI Phantom 2 Vision+ Instruction Manual and Petitioner’s 

Preflight and Mission Checklist prior to every flight, and 
15

further, determine that the system is in condition for safe 

flight, as stated in the conditions and limitations below. 

3. Extent Of Relief Petitioner Seeks And The Reason 

Petitioner Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, 

may be required to allow flight operations of the DJI Phantom 2 

Vision+ UA, which utilizes 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), 

Petitioner seeks the requested relief because the DJI Phantom 2 

Vision+ UA’s altimeter is automatically set on the ground to 

zero feet AGL, rather than the local barometric pressure or 

field altitude, before each flight.

Considering the limited altitude of the proposed 

operations, relief from 14 CFR 91.121 is sought to the extent 

necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an 

equivalent level of safety will be maintained since the DJI 

Phantom 2 Vision+ UAs are equipped with a barometric pressure 

sensor and GPS equipment, which automatically ensures that a 
16

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 Petitioner Seeks And The Reason 

Petitioner Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements 

for flight in VFR conditions, is requested to the extent 

required to allow flights of the battery powered DJI Phantom 2 

Vision+ UA during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), for a total 

duration of 25 minutes and will always be landed at the position 

it started from. Petitioner 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+ UA will 

severely constrain the practicality of any aerial video or still 

photo flight operations that Petitioner proposes to conduct 

pursuant to this Petition. 

Significantly, as set forth below, the technical 

specifications of the DJI Phantom 2 Vision+ UAS, the DJI Phantom 

2 Vision+ operating documents, and Petitioner’s proposed 

operating limitations, ensure that Petitioner will safely 

operate the battery powered DJI Phantom 2 Vision+ UAs during 

daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), with enough battery power to fly for 
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a total duration of 25 minutes, and will always land at the 

position it started from.

5. Extent Of Relief Petitioner Seeks And The Reason 

Petitioner 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, Petitioner requests relief from these 

Sections because the DJI Phantom 2 Vision+ UAS does not require 

airworthiness certificates. As set forth more fully below, the 

DJI Phantom 2 Vision+ UAS meets the conditions of FMRA Section 

333 for operation without an airworthiness certificate. 

Accordingly, Petitioner will personally perform ownerrecommended maintenance such as battery charging and inspection 

and propeller inspections, and will use DJI trained repair 

facilities to perform more technical maintenance and alterations 

on the UAS using the methods, techniques, and practices

prescribed in the DJI Phantom 2 Vision+ Instruction Manual.

D. The Reasons Why Granting Petitioner 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 Petitioner to safely, efficiently, and 

economically perform aerial video and photography for his 

clients over certain areas of the United States. 
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Additionally, use of the DJI Phantom 2 Vision+ UAS will 

decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of 

Petitioner’s proposed operation of the DJI Phantom 2 Vision+ UAS 

will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The 

NAS.

The DJI Phantom 2 Vision+ UA is battery powered and serves

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+ UAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and air pollution, as well as increase the 

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

Furthermore, by reducing the number of manned aircraft 

operating in the NAS, congestion around airports caused by 

arriving and departing aircraft will be reduced. The DJI Phantom 

2 Vision+ UA does not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video 

and photography missions would result in fewer aircraft that 

must be handled by air traffic control during the ground, 
19

takeoff, departure, arrival, and landing phases of flight 

operations. 

2. The Public Will Benefit From The Safety And Efficiency 

Of The DJI Phantom 2 Vision+ UAS.

Conducting aerial acquisitions with the DJI Phantom 2 

Vision+ 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+ UA produces no air 

pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion 

engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour 

of leaded aviation fuel. The DJI Phantom 2 Vision+ UA, while 

reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion 

engine. 

By using the DJI Phantom 2 Vision+ 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 
20

lack of flight crew members located onboard the aircraft, the 

DJI Phantom 2 Vision+ UA (weighing approximately 2 pounds 11 

ounces at its maximum gross weight, and with a length of 16 

inches, width of 16 inches, and with no fuel on board), has less 

physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 

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+ UAS Will Benefit The Economy.

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

Vision+ is also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, 

operation of the DJI Phantom 2 Vision+ UAS will allow United 

States based companies, like Petitioner’s, 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 such battery powered aircraft is one such technology 

that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility 
21

without the high operational cost of a traditional manned 

aircraft. 

By operating systems similar to the DJI Phantom 2 Vision+ 

UAS, entities similar to Petitioner’s 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 such UASs, will help 

provide 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, Petitioner’s proposed operation 

of the DJI Phantom 2 Vision+ UAS will not implicate any privacy issues. 

Specifically, the DJI Phantom 2 Vision+ UAS will be operated only in 

compliance with the DJI Phantom 2 Vision+ 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 (a) and 

(d) (1).

E. The Reasons Why Granting The Exemption Would Not Adversely 

Affect Safety, Or How The Exemption Would Provide A Level 
22

Of Safety At Least Equal To That Provided By The Rule From 

Which Petitioner Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ UA Meets The 

Conditions Of The FAA Modernization and Reform Act of 2012 

(FMRA) Section 333. 

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

operating area associated with the unmanned aircraft and its 

operation, Petitioner’s operation of the DJI Phantom 2 Vision+ 

UAS meets the conditions of FMRA Section 333, and will not 

require an airworthiness certificate in accordance with 14 

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

Section 333 provides authority for a UAS to operate without 

airworthiness certification and sets forth requirements for 

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

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

security. Specifically, FMRA Section 333 states the following, 

in part:

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

subtitle, and not later than 180 days after the date of enactment of 

this Act, the Secretary of Transportation shall determine if certain 

unmanned aircraft systems may operate safely in the national 

airspace system before completion of the plan and rulemaking 

required by section 332 of this Act or the guidance required by 

section 334 of this Act.

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

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

at a minimum-

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

result of their size, weight, speed, operational capability, 

proximity to airports and populated areas, and operation 

within visual line of sight do not create a hazard to users of 
23

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, Petitioner submits that the DJI 

Phantom 2 Vision+ UAS can operate safely in the NAS pursuant to 

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

the DJI Phantom 2 Vision+ UAS; (b) Petitioner’s experience as a 

drone pilot; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 2 Vision+ UAS 

Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ UAS does not create a hazard to 

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

national security considering its size, weight, speed, and 

operational capability.

i. Technical Specifications Of The DJI Phantom 2 Vision+ 

UAS.

The technical specifications of the DJI Phantom 2 Vision+ 

UAS are set forth by the DJI Phantom 2 Vision+ Specifications 

and Data Sheet, attached hereto as Exhibit A.
24

ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area.

The DJI Phantom 2 Vision+ UAS may be operated in both 

manual and fully autonomous flight modes. Controller software is 

programed to prevent the UAS from operating above 394 feet AGL

or at a distance greater than 400 meters (when set to CE 

compliance, as Petitioner’s is) or within No Fly Zones, in 

autonomous mode. In manual (also called ready to fly) mode, 

operation above 394 feet AGL is prevented. A complete 

description of the flight and navigational modes of the DJI 

Phantom 2 Vision+ UAS is provided at pages 25-35 of the DJI 

Phantom 2 Vision+ User Manual, attached hereto as Exhibit B. 

iii. The DJI Phantom 2 Vision+ UAS is Designed For 

Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ UA 

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

after 3 seconds, the DJI Phantom 2 Vision+ UA does not reacquire 

control link data from the GCS, the UA will assume that the 

Control Link is lost and the UA will return to the home position 

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

position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 

2 Vision+ UAS are set forth at pages 27 through 29 of the DJI Phantom 2 

Vision+ User Manual, attached hereto as Appendix B.
25

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

A complete description of the operation and specifications 

of the DJI Phantom 2 Vision+ GCS and flight control software is 

provided at pages 32 through 43 of the DJI Phantom 2 Vision+ 

User Manual. DJI Phantom 2 Vision+ User Manual is attached 

hereto as Exhibit B.

b. Flight Operations Of The DJI Phantom 2 Vision+ UAS 

Are Limited To The Line Of Sight Of Petitioner.

Petitioner is experienced at operating the UAS, will limit 

operations to line of site situations, and will not allow the 

UAS to be operated by others.

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

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Petitioner proposes to 

commercially operate a DJI Phantom 2 Vision+ UAS for the special 

purpose of conducting aerial video and photography over certain 

areas of United States, pursuant to the following specific 

operating limitations:

1. Operations authorized by this grant of exemption will be limited 

to the following aircraft described in the operating documents, 

rotorcraft UASs weighing less than 55 pounds maximum gross weight: 

DJI Phantom 2 Vision+ Unmanned Aircraft System. Proposed operations 

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

amend this grant.

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

operations for the purpose of aerial video and photography, and 

camera controls will be set up prior to takeoff to avoid in-flight 

distraction.
26

3. The UA may not be flown at an indicated airspeed exceeding 25

miles per hour.

4. The UA must be operated at an altitude of no more than 396 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.

6. The use of first person view (FPV) is not permitted.

7. Since all operations will be conducted in remote locations or 

where danger to property or people does not exist, the need for a 

safety observer will not be necessary.

8. In the unlikely event an SO is needed, he or she must be 

adequately trained, must not perform any other duties beyond 

assisting the PIC with seeing and avoiding other air traffic and 

other ground based obstacles/obstructions and is not permitted to 

operate the camera or other instruments.

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

accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the 

conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption take precedence 

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

procedures as outlined in its operating documents. The operator may 

update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator 

must also present updated and revised documents if it petitions for 

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

determines that any update or revision would affect the basis upon 

which the FAA granted the exemption, then the operator must petition 

for amendment to its grant of exemption. The FAA’s UAS Integration 

Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that 

it is in a condition for safe flight. If the inspection reveals a 

condition that affects the safe operation of the UAS, the aircraft 

is prohibited from operating until the necessary maintenance has 

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

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

inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 
27

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 UASs 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. Petitioner is the only person authorized to be the PIC, and the 

UAS will only be operated in autonomous mode except when evasive 

maneuvers are necessary, to regain control after the control signal 

is lost, or when satellite guidance is lost.

18. Due to the size of Petitioner’s business and the fact that there 

are no employees, the need to train and certify an alternate PIC 

does not exist.

19. UAS operations may not be conducted during night, as defined in 

14 C.F.R. § 1.1. All operations must be conducted under visual 

meteorological conditions (VMC). If flight at night is required, a 

special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) 

are not authorized.

20. The UA may not operate within 5 nautical miles of an airport 

reference point as denoted on a current FAA-published aeronautical 

chart unless a letter of agreement with that airport’s management is 

obtained, and the operation is conducted in accordance with a NOTAM 

as required by the operator’s COA. The letter of agreement with the 

airport management must be made available to the Administrator upon 

request.
28

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 the location from which it took off 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 accomplish the photography 

or video goal, and land the UA with 25% battery power remaining.

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

issued Certificate of Waiver or Authorization (COA) prior to 

conducting any operations under the grant of exemption. This COA 

will also require the operator to request a Notice to Airman (NOTAM) 

not more than 72 hours in advance, but not less than 48 hours prior 

to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of 

airspace, altitude level and potential transponder requirements.

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

identified by serial number, registered in accordance with 14 C.F.R. 

part 47, and have identification (N-Number) markings in accordance 

with 14 C.F.R. part 45, Subpart C. Markings must be as large as 

practicable.

27. Before conducting operations, the radio frequency spectrum used 

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

Communications Commission (FCC) or other appropriate government 

oversight agency requirements.

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

be available to the PIC at the Ground Control Station of the UAS any 

time the UAS is operating. These documents must be made available to 

the Administrator or any law enforcement official upon request. 

29. The 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.

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 
29

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 do not present an undue hazard 

to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlledaccess 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.

34. The integrated ground station function may not be used.

2. Reasons Why An Exemption From The Requirements Of 

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

Safety.

Petitioner submits that the equivalent level of safety established 

by Section 61.113(a) and (b) will be maintained because no individual 

other than Petitioner will be allowed to operate the DJI Phantom 2 Vision+ 

UAS and Petitioner has demonstrated, by meeting minimum flight-hour and 

currency requirements, that Petitioner as PIC is able to safely operate 

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

including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.
30

Considering Petitioner’s proposed area of operations, and the 

operating limitations set forth-above, and the airmanship skills necessary 

to safely operate the DJI Phantom 2 Vision+ UAS, Petitioner submits that 

the additional manned airmanship experience of a certificated pilot would 

not correlate to the airmanship skills necessary for Petitioner’s specific 

proposed flight operations. 

Petitioner will not allow any other individual to operate the DJI 

Phantom 2 Vision+ UAS for commercial purposes.

Petitioner submits that he has accumulated and logged, in a manner 

consistent with 14 C.F.R. § 61.51(b), 31 hours of total time as a UAS 

rotorcraft pilot operating the same make and model of UAS to be used for 

operations under the exemption. In addition, each hour involved an average 

of 9 takeoffs and landings. 

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 Petitioner

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 
31

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 15. 

Accordingly, Petitioner will ensure safe operations by not allowing 

any other individual to operate the DJI Phantom 2 Vision+ UAS; and 

Petitioner has demonstrated, by meeting minimum flight-hour and currency 

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

Vision+ 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, Petitioner will ensure that 

the DJI Phantom 2 Vision+ 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). 
32

4. Reasons Why An Exemption From The Requirements Of 

Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be 

maintained because the altitude information of the DJI Phantom 2 Vision+ 

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

communications telemetry data link, which downlinks from the UA to the GCS 

for active monitoring of the flight path and altitude. This altitude 

information, combined with Petitioner’s operation of the DJI Phantom 2 

Vision+ UA within visual line of sight, at or below 396 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed onboard the 

aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific 

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

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

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

11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of 

Section 91.151(b)Would Not Adversely Affect Safety. 

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

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

technical specifications of the DJI Phantom 2 Vision+ UAS; (2) the 

limitations on the proposed flight operations; and (3) the locations of 

the proposed flight operations. Accordingly, Petitioner will ensure that 

it will safely operate the battery powered DJI Phantom 2 Vision+ UA during 
33

daylight hours in VFR conditions, with enough battery power to fly 

for a total duration of 25 minutes, and will always land at the 

position it started from.

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

DJI Phantom 2 Vision+ UAS; the limitations on the proposed flight 

operations; and the location of the proposed operations, will ensure an 

equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ UAS 

provides audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at 

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

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

Phantom Vision+ 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). 
34

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, Petitioner 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 Petitioner 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., Petitioner’s Preflight and 

Mission Checklist, Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

Instruction Manual).

Furthermore, Petitioner will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+ UAS. Since the DJI Phantom 2 Vision+ 

UAS will be inspected as prescribed by the operating documents, Petitioner 

will maintain the equivalent level of safety established by Sections 

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

Vision+ User Manual is attached hereto as Exhibit B; a copy of the DJI 

Phantom 2 Vision+ UAS Maintenance LOG is attached hereto as Appendix D. 

Likewise, the exemption sought will not adversely affect safety 

because Petitioner will use trained technicians to perform maintenance, 

alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level 

of safety established by Sections 91.407, 91.417(a) and 91.417(b), because 

all maintenance of the DJI Phantom 2 Vision+ UAS will be performed by 
35

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 this UAS is considered. 

In consideration of Petitioner proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2 

Vision+ UAS, Petitioner 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, 

Petitioner requests that the FAA prescribe special conditions for the 

intended operation of the DJI Phantom 2 Vision+ 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 
36

purpose of conducting aerial video and photography over certain areas of 

the United States for compensation or hire. FMRA Section 333 sets forth 

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

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

security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements 

that must be established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions 

pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 Vision+ 

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 Petitioner’s intended 

operation of the DJI Phantom 2 Vision+ 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 
37

14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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

Stating: The Rules From Which Petitioner seeks Exemption:

Edward E. Mathews, dba Amelia Island Images, 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 Petitioner Seeks:

This exemption will permit Edward E. Mathews to commercially operate 

an Unmanned Aircraft System (UAS) for the purpose of conducting 

aerial video and photography over certain areas of the United 

States. 

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

Support Petitioner’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, Petitioner 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, Petitioner will operate the DJI 

Phantom 2 Vision+ UASs safely in the NAS, without creating a hazard to 

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

security.
38

CONCLUSION 

As set forth herein, Petitioner seeks an exemption pursuant to 14 

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA), which will permit safe operation of the DJI Phantom 2 Vision+ 

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 Petitioner to safely, efficiently, and economically operate the 

DJI Phantom 2 Vision+ UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and 

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

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 Petitioner to operate the DJI 

Phantom 2 Vision+ UAS commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States.

Dated: May 25, 2015 

Respectfully submitted, 

Edward E. Mathews

______________________________________
39

Appendices:

A – DJI Phantom 2 Vision+ Specifications Data Sheet 

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

C - Amelia Island Images Preflight And Mission Checklist

D – Monthly Maintenance Log

E – Aircraft Registration Application

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

DJI is an industry leader in small UAS production. DJI UASs are loaded 

with ground breaking software enabling the user to set parameters which 

will not allow flight into controlled airspace. Parameters can also be set 

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

as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location information to the PIC 

via the linked monitor (smart phone)

1.1. DJI Phantom 2 Vision+ 

1.1.1. Aircraft 

1.1.1.1. Supported Battery – DJI 5200mAH LiPo Battery 

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

(1242g) 

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

Horizontal: 2.5m 

1.1.1.4. Max Yaw Angular Velocity -200°/s 

1.1.1.5. Max Tilt Angel -35° 

1.1.1.6. Max Ascent Speed – 6m/s 

1.1.1.7. Max Descent Speed – 2m/s 

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

1.1.2. Gimbal 

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

1.1.2.2. Control Accuracy -±0.03° 

1.1.2.3. Controllable Range – Pitch: -90°-0° 

1.1.2.4. Maximum Angular Speed – Pitch: 90°/s 

1.1.3. Camera 

1.1.3.1. Operating Temperature Range -32°F -104°F (0°C -40°C) 

1.1.3.2. Sensor Size – 1/2.3” 

1.1.3.3. Effective Pixels – 14M 

1.1.3.4. Resolution – 4384x3288 

1.1.3.5. HD Video Recording – 1080p30 & 720p 

1.1.3.6. Recording Field of View -110°/85° 

1.1.4. Transmitter 

1.1.4.1. Operating Frequency – 5.728GHz – 5.85GHz 

1.1.4.2. Communication Distance (unobstructed) – FCC Compliance: 

800m 

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

1.1.4.4. Transmitter Power – FCC Compliance: 100mW 

1.1.4.5. Working Voltage – 80mA@6V 

1.1.5. Range Extender 

1.1.5.1. Operating Frequency – 2412-2462MHz 

1.1.5.2. Communication Distance (unobstructed) – 500-700m 

1.1.5.3. Transmitter Power – 20dBm 

1.1.5.4. Power Consumption – 2W 
40

APPENDIX – B

DJI Phantom 2 Vision+ Manufacturer’s User Manual

(reprint authorized by DJI Global)
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APPENDIX – C

AMELIA ISLAND IMAGES PREFLIGHT AND MISSION CHECKLIST

1. Remote controller, smart battery, range extender and smartphone are fully charged.

2. Propellers are undamaged and mounted correctly.

3. Aircraft inspected and no conditions affecting safe operation exist.

4. Gimbal clamp has been removed.

5. Damping absorbers are in good condition, not broken or worn.

6. Anti-drop kits have been mounted correctly.

7. Camera lens cap has been removed.

8. Micro-SD card has been inserted.

9. Gimbal is functioning as normally.

10. Motors can start and are functioning as normal.

11. DJI VISION App can connect to the camera.

12. UAS on-board compass calibration successfully completed

13. Prop guards installed if required for additional safety.

14. Weather satisfactory (wind less than 12 mph, visibility greater than 3 miles, no clouds below 3000 feet AGL)

15. Distance from nonparticipating persons at least 500 feet.

16. Distance from airports exceeds FAA guidelines for each airport category.

17. Permission obtained from the land owner/controller or authorized representative.

18. Operating documents and grant of exemption or COA accessible and available.

19. Look for and take into account the presence of any wildlife, manned aircraft, and obstacles.

20. Controller switches are set to autonomous flight mode.

21. Camera controls are set up prior to takeoff.

22. At least six (6) satellites are locked on.

23. All flight parameters are displayed on monitor (speed, distance, altitude, and battery levels)

24. All appropriate law enforcement agencies have been notified.
91

APPENDIX – D

AMELIA ISLAND IMAGES MONTHLY MAINTENANCE LOG
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APPENDIX – E

PHOTOCOPY OF AIRCRAFT REGISTRATION APPLICATION