US DEPARTMENT OF TRANSPORTATION 

DOCKET MANAGEMENT SYSTEM 

1200 NEW JERSEY AVE. 

SE WASHINGTON DC 20590 

PETITION FOR EXEMPTION 

Anthony James Pierro

DBA AJPierro Photography

2603 Ivy Lane

Beaufort, SC 29902

(843) 263 -2044

ajpierro@gmail.com

ajpierro@ajpierrophotography.com

With respect to those who may be concerned: 

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, 

Anthony James Pierro, a Commercial and Real Estate Photographer, hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) listed below to allow operation of his Small Unmanned Aircraft System 

(sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations 

are conducted with and under the conditions outlined herein or as may be established by the FAA as required by 

Section 333. 

The requested exemption would permit Anthony James Pierro of AJPierro Photography to pursue his commercial 

and photographic interests in providing services to clients using a small advanced sUAV in the following areas: 

-Real Estate Photography/video

-Local Land Development Projects

-Construction site before and after photography

-City and County marketing projects

Anthony James Pierro of AJPierro Photography states that all sUAS flights will occur only over Properties/

Communities/Townships with which consent and knowledge has been granted by said Owners/HOA’s/Local 

Leaders and that only people who have consented to be within the UAS’ radius will be able to be present during 

filming and photography applications.

Anthony James Pierro of AJPierro Photography has all the necessary skills and abilities required to safely and 

effectively fly the DJI Phantom 2 vision+ which will be used for all commercial and private purposes. 
Anthony James Pierro of AJPierro Photography complies with any and all local ordinances and laws regarding the 

operation of sUAS as well as any and all state/local laws regarding privacy.

I, Anthony James Pierro of AJPierro Photography, am seeking the exemption because I am committed to complying 

lawfully with all of the rules, guidelines, limitations, and future legislation set forth by the FAA. I agree to operate 

the sUAS for the purposes that I have described with safety at the forefront. With the granting of these exemptions 

I, Anthony James Pierro of AJPierro Photography, would be able to safely and effectively run my business in a 

manner that would allow future growth and expansion in areas that would otherwise be unattainable, and it is my 

intention to comply with the FAA and obtain an exemption of the following regulations.

The Specific Sections Of 14 C.F.R. From Which ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 

Seeks Exemption.

1. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks Exemption From The Requirement Of 

Section 91.405(a).

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

aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, 

except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this 

chapter.

6. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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. ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b).

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

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

keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, 

progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

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

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containing the following information:

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

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

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a 

specified time basis.

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

inspection program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the 

method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.

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

currently installed engines, rotors, propellers, and appliances.

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

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded 

by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the 

time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until 

the defects are repaired and the aircraft is approved for return to service.
The Extent Of Relief ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks And The Reason 

ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks The Relief.

1. Extent Of Relief ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks And The Reason 

ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks Relief From Section 61.113(a) And (b).

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

requested to the extent necessary to allow a PIC holding a 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, Anthony James Pierro of AJPierro Photography submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 vision+ 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+ 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, Anthony James Pierro of AJPierro Photography 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 Anthony James Pierro of 

AJPierro Photography’s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks And The Reason 

ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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 Anthony 

James Pierro of AJPierro Photography to determine that the DJI Phantom 2 vision+ UAS is in airworthy condition 

prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e. DJI Phantom 2 

vision+ Instruction Manual).

Anthony James Pierro of AJPierro Photography seeks the requested relief because the DJI Phantom 2+ UAS does 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Anthony James 

Pierro of AJPierro Photography will ensure that the DJI Phantom 2 vision+ UAS is in airworthy condition based 

upon its compliance with the operating documents (i.e., DJI Phantom 2 vision+ Instruction Manual) prior to every 

flight, and further, determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations 

below.

3. Extent Of Relief ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks And The Reason 

ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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+ UAS, 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 UA operations be reported to air traffic control 

(ATC) in feet above ground level (AGL), Anthony James Pierro of AJPierro Photography seeks the requested relief 
because the DJI Phantom 2 vision+ UAS altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight.

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

necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an 

equivalent level of safety will be maintained since the DJI Phantom 2 vision+ UA is equipped with a barometric 

pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of 

the GCS.

4. Extent Of Relief ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks And The Reason 

ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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+ UAS during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first 

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

James Pierro of AJPierro Photography 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+ UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that Anthony James Pierro of AJPierro Photography

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 Anthony James Pierro of AJPierro Photography’s proposed operating limitations, 

ensure that Anthony James Pierro of AJPierro Photography 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 a total duration of 13.5 minutes to the first point of intended landing and, assuming 

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

5. Extent Of Relief ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY Seeks And The Reason 

ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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, Anthony James Pierro of AJPierro Photography requests relief from these Sections because 

the DJI Phantom 2+ 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, Anthony James Pierro of AJPierro Photography will perform maintenance, alterations, and 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., DJI Phantom 2 vision+ Instruction Manual). Furthermore, Anthony James Pierro of AJPierro 

Photography will document and maintain all maintenance records for the DJI Phantom 2 vision+ UAS.

The Reasons Why Granting ANTHONY PIERRO OF AJPIERRO PHOTOGRAPHY 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 Anthony James Pierro of AJPierro 

Photography 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+ UAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of Anthony James Pierro of AJPierro 

Photography’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+ UA is battery powered and serves as a safe, efficient, and economical alternative to the manned 

aircraft currently utilized to obtain aerial imagery. By reducing the amount of manned aircraft used to perform aerial 

acquisitions, an exemption allowing the use of the 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, 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+ UAS 

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+ UAS, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA is 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 lack of flight crew members located onboard the 

aircraft, the DJI Phantom 2 vision+ UA (weighing less than 10 pounds 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.

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2+ UAS Will Benefit The 

Economy.

In addition to being safe and efficient, the DJI Phantom 2 vision+ UAS 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 Anthony James Pierro of AJPierro Photography, 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+ UAS is one such technology that not only allows companies greater 

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

a traditional manned aircraft.
4. There Are No Privacy Issues.

Anthony James Pierro of AJPierro Photography’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 

operating documents (i.e., 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.

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

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

PIERRO OF AJPIERRO PHOTOGRAPHY 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, Anthony James Pierro of AJPierro Photography’s operation of the DJI Phantom 2 vision+ 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 minimum--

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

proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of 

title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph 

(1).

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

systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system.

In seeking this exemption, Anthony James Pierro of AJPierro Photography, 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) the pilot certification requirement; and (c) the specific operating limitations.
a. The Specifications Of The DJI Phantom 2 vision+ UAS Demonstrates 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 is set forth by the DJI Phantom 2 vision+ User 

Manual attached.

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. A complete 

description of the flight and navigational modes of the DJI Phantom 2 vision+ UAS is provided in the DJI Phantom 

2 vision+ User Manual attached.

iii. The DJI Phantom 2 vision+ UAS is Designed to Automatically 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+ UAS will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Phantom 2 vision+ UAS do not reacquire control link data from the GCS, the UA 

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

and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 vision+ UAS is provided in the DJI Phantom 

2 vision+ UAS User Manual attached.

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 in the DJI Phantom 2 vision+ UAS User Manual attached.

b. Flight Operations Of DJI Phantom 2 vision+ UAS Are Limited To The Line Of Sight Of the Pilot in 

Command With A Safety Observer.

Anthony James Pierro of AJPierro Photography under this exemption will be the only operator to act as a pilot in 

command (PIC) of the DJI Phantom 2 vision+ UAS. Additionally, a safety observer will assist him during flight 

time.
I, ANTHONY JAMES PIERRO OF AJPIERRO PHOTOGRAPHY (THE OPERATOR), ASSUME THE 

FOLLOWING RESPONSIBILITIES:

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 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 UA may not be flown at an indicated airspeed exceeding 35 knots.

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

5. The UA 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. 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.

7. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the 

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

perform the functions prescribed in the operating documents.

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

other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made 

available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained 

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

contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the 

procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is 

the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it petitions for extension or 

amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis 

upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

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

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating 

until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The 

Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, 

e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records.
12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or 

equipment, not already covered in the relevant sections of the operating documents.

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

inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with 

the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts 

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

signature of the authorized person returning the UAS to service.

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

16. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections.

17. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and 

demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under 

the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. 

However, training operations may only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 

14 C.F.R. § 91.119.

18. 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.

19. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished 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.

20. 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.

21. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location within the 

planned operating area and land or be recovered in accordance with the operating documents.

22. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the 

operating documents.

23. 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.
24. 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.

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 Web site: www.ntsb.gov.

Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not Adversely 

Affect Safety.

Anthony James Pierro of AJPierro Photography 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+ 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+ UAS in a manner consistent with the exemption, including evasive and 

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

Considering Anthony James Pierro of AJPierro Photography’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; and the airmanship skills necessary to safely operate the DJI Phantom 2 vision+ 

UAS, Anthony James Pierro of AJPierro Photography submits that the additional manned airmanship experience of 
a commercially certificated pilot would not correlate to the airmanship skills necessary for Anthony James Pierro of 

AJPierro Photography’s specific proposed flight operations.

Anthony James Pierro of AJPierro Photography will not allow any PIC to operate the DJI Phantom 2 vision+ UAS 

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

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

Accordingly, Anthony James Pierro of AJPierro Photography will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 2 vision+ 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+ 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, 

Anthony James Pierro of AJPierro Photography 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.)

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 Anthony James Pierro of AJPierro Photography’s operation of the DJI 

Phantom 2 vision+ UA within visual line of sight, at or below 400 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 location of the proposed flight operations. Accordingly, Anthony James Pierro of AJPierro 

Photography will ensure that it will safely operate the battery powered DJI Phantom 2 vision+ UA during daylight 

hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of 

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

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, Anthony James Pierro of AJPierro Photography 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 Anthony James Pierro of AJPierro Photography 

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. DJI Phantom 2 vision+ Instruction 

Manual). Furthermore, Anthony James Pierro of AJPierro Photography 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, Anthony James 

Pierro of AJPierro Photography will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 1.409(a)(2). A copy of the DJI Phantom 2 vision+ UAS User Manual is attached.

Likewise, the exemption sought will not adversely affect safety because Anthony James Pierro of AJPierro 

Photography will perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the operating documents.
Conclusion

As set forth herein, Anthony James Pierro of AJPierro Photography 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 Anthony James Pierro of AJPierro 

Photography 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, Anthony James Pierro of AJPierro 

Photography 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 Anthony James Pierro of 

AJPierro Photography 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: July 14th, 2015 

Submitted with respect, 

Anthony James Pierro

DBA AJPierro Photography

2603 Ivy Lane

Beaufort, SC 29902

(843) 263 -2044

ajpierro@gmail.com

ajpierro@ajpierrophotography.com