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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: HUQA LIVE LLC

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 3 UNMANNED 

AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

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

Submitted on February 25, 2016

Huqa Live, LLC

Attn. Raakin Iqbal

590 15th ST S #400

Arlington, VA 22202

202-527-9342

riqbal@huqalive.com
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TABLE OF CONTENTS

Page

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH HUQA LIVE, LLC

SEEKS EXEMPTION...................................................................................................7

THE EXTENT OF RELIEF HUQA LIVE, LLC SEEKS AND THE REASON HUQA LIVE 

LLC SEEKS THE 

RELIEF.....................................................................................................................10

THE REASONS WHY GRANTING HUQA LIVE, LLC’S REQUEST WOULD BE IN THE 

PUBLIC INTEREST .........................................................................................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY......................................................................................................16

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.................28

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT HUQA LIVE, LLC REQUEST.............................................................28

CONCLUSION........................................................................................................................29

APPENDICES.......................................................................................................30
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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

HUQA LIVE, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an 

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 (FMRA). This exemption will permit HUQA LIVE, LLC to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of real estate, 

weddings, music videos, online short films/trailers and landscape over certain areas of the United 

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

HUQA LIVE, LLC provides its clients with photography and video recording services. The 

scope of work includes real estate, commercial events, private events (i.e. weddings, non-profit galas), 

and music/short/motion picture film/videos. The objective of HUQA LIVE, LLC, and it’s aerial

operations is to provide high quality imaging for a variety of commercial, public, and residential uses, 

specifically targeting:

• Residential Construction

• Real-estate marketing

• Resort property marketing

• Wedding Videos

• Music Videos

• Corporate Videos

• Online Short Videos/Films

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 UAS

HUQA LIVE, LLC seeks an exemption to operate DJI systems for compensation or hire within 

the NAS. The DJI Phantom 3 UAS is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with 

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

The DJI Phantom 3 UAS has a maximum gross weight of 6 pounds 7.5 ounces, a length of 
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17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 

knots. The DJI Phantom 3 UAS is equipped with four main rotors; driven by Lithium Polymer battery 

powered electric motors.

BASIS FOR PETITION

Petitioner, HUQA LIVE, LLC. (HUQA), pursuant to the provisions of the Federal 

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

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

Administrator to commercially operate the DJI Phantom 3 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, HUQA’s proposed operation of DJI Phantom 3 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, HUQA 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.

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

ensured. HUQA will use experienced personnel or technicians to perform maintenance, alterations, or 

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

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). 

Furthermore, HUQA will document and maintain all maintenance records for the DJI Phantom 3 UAS.

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

privileges and limitations: Pilot in command, is requested by HUQA to the extent necessary to allow 

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

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

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

with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.
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HUQA seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, HUQA submits that it will ensure that the DJI 

Phantom 3 UAS is in airworthy condition, prior to every flight, by determining that the 

UAS is in compliance with the operating documents (i.e., Monthly Maintenance Log, and 

DJI Phantom 3 Instruction Manual), and that the aircraft is in a condition for safe flight. He 

will utilize the preflight instructions provided by DJI to ensure airworthiness checks prior 

to each flight.

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

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

onboard. However, altitude information of the DJI Phantom 3 UAS will be provided to the 

PIC via Global Positioning System (GPS) equipment and radio communications telemetry 

data link, which downlinks from the UAS to the GCS for active monitoring of the flight 

path. This altitude information, combined with HUQA’s operation of the DJI Phantom 3 

UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121.

Additionally, HUQA seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. HUQA submits that 

safety will not be affected by operation of the DJI Phantom 3 UAS during daylight 

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

enough battery power to fly for a total duration of approximately 14.5 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, HUQA provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

HUQA LIVE, LLC

ATTN: Raakin Iqbal

590 15th ST S

Arlington, VA 22202

202-527-9342

riqbal@huqalive.com
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B. The Specific Sections Of 14 C.F.R. From Which HUQA LIVE, LLC Seeks 

Exemption.

1. HUQA LIVE, LLC 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. HUQA LIVE, LLC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states 

the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. HUQA LIVE, LLC 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.
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4. HUQA LIVE, LLC Seeks Exemption From The Requirements Of Section 

91.151(b).

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

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to 

fly to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 20 minutes.

5. HUQA LIVE, LLC Seeks Exemption From The Requirement Of Section 

91.405(a).

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

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and 

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

section, have discrepancies repaired as prescribed in part 43 of this chapter [.]

6. HUQA LIVE, LLC 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. HUQA LIVE, LLC 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
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(2) An inspection for the issuance of an airworthiness certificate 

in accordance with part 21 of this chapter.

8. HUQA LIVE, LLC 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.
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(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.

C. The Extent Of Relief HUQA LIVE, LLC, INC. Seeks And The Reason 

HUQA LIVE, LLC Seeks The Relief.

1. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE, LLC

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, HUQA submits that an equivalent level of safety 

will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS 
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unless that PIC has met certain flight-hour and currency requirements, demonstrating that 

the PIC is able to safely operate either the DJI Phantom 3 UAS in a manner consistent with 

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

emergency maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures.

Further, HUQA submits that all flights of the DJI Phantom 3 UAS, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to HUQA’s business; 

and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE, 

LLC 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 HUQA to determine that the DJI Phantom 3 UAS is in 

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

the operating documents (i.e., the HUQA Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 Instruction Manual).

HUQA seeks the requested relief because the DJI Phantom 3 UAS does not

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

Therefore, HUQA will ensure that the DJI Phantom 3 UAS is in airworthy condition based 

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

DJI Phantom 3 Instruction Manual) prior to every flight, and further, determine that the 

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

3. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE, 

LLC Seeks Relief From Section 91.121.

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

flight operations of the DJI Phantom 3 UAS, which utilize a barometric pressure sensor, 

GPS equipment, and a radio communications telemetry data link to downlink altitude 

information from the UAS 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), HUQA seeks the requested relief 

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

rather than the local barometric pressure or field altitude, before each flight.
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Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

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

maintained since the DJI Phantom 3 UAS are equipped with a barometric pressure sensor 

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

be established prior to each flight, and provides the PIC with altitude information of the 

UAS on the heads-up display of the GCS.

4. Extent Of Relief HUQA LIVE, LLC Seeks And The Reason HUQA LIVE, 

LLC Seeks Relief From Section 91.151(b).

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

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), under 

visual flight rules (VFR), for a total duration of 14.5 minutes to the first point of intended 

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

HUQA seeks the requested relief because without an exemption from Section 91.151(b), 

the flight time duration of the battery powered DJI Phantom 3 UAS will severely constrain 

the practicality of any aerial video or still photo flight operations that HUQA proposes to 

conduct pursuant to this Petition.

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

UAS, the DJI Phantom 3 operating documents, and HUQA’s proposed operating 

limitations, ensure that HUQA will safely operate the battery powered DJI Phantom 3 

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

rules (VFR), with enough battery power to fly for a total duration of 14.5 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 HUQA LIVE, LLC Seeks And The Reason HUQA LIVE, LLC

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, HUQA requests relief from 

these Sections because the DJI Phantom 3 UAS does not require an airworthiness 
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certificate. As set forth more fully below, the DJI Phantom 3 UAS meets the conditions 

of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, 

HUQA will use trained technicians to perform maintenance, alterations, or preventive 

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

UAS operating documents (i.e., the HUQA Aerial Operations Manual, Monthly 

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

document and maintain all maintenance records for the DJI Phantom 3 UAS.

D. The Reasons Why Granting HUQA LIVE, LLC Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing HUQA to 

safely, efficiently, and economically perform aerial video and photography of real estate, 

wedding/engagement shoots, music videos, online short films, and landscape over certain 

areas of the United States.

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

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

HUQA’s proposed operation of the DJI Phantom 3 UAS will be realized without 

implicating any privacy issues.

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

UAS.

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned 

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 

pollution generated during traditional aerial video and still photography flight operations. 

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

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

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

and photography, while burning approximately 20-30 gallons per hour of leaded aviation 

fuel. The DJI Phantom 3 UAS, while reducing the carbon footprint of aerial acquisitions, 

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

motors, rather than an internal combustion engine.

By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial 

risk to life and property in the air and on the ground, which is usually associated with 
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traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the 

DJI Phantom 3 UAS (weighing approximately 6 pounds 7.5 ounces at its maximum gross 

weight with a length of 17.3 inches, width of 17.7 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).

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 UAS 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 3 UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and 

property in the air and on the ground.

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

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

DJI Phantom 3 UAS 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.

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 3 UAS Will Benefit The Economy.

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

economical alternative to using manned aircraft to conduct similar aerial operations. As 

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

HUQA 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 
15

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

battery powered DJI Phantom 3 UAS is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 UAS, companies such as HUQA can remain 

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

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

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

UAS, provides a stable workforce that increases consumer spending; improves local, state, 

and federal tax revenues; and allows companies to invest in research and development in 

order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted 

for many years, HUQA’s proposed operation of the DJI Phantom 3 UAS will not implicate 

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

compliance with operating documents (i.e., the HUQA Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 Instruction Manual) which requires property owner 

involvement and permission to videotape/photograph as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which HUQA LIVE, LLC Seeks Exemption.

i. Reasons Why The DJI Phantom 3 UAS 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, HUQA’s operation of the DJI Phantom 3 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.
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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, HUQA submits that the DJI Phantom 3 UAS can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics 

of the DJI Phantom 3 UAS; (b) the pilot certification requirement; and (c) the specific 

operating limitations.

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

Characteristics.

The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the 
17

public, or otherwise pose a threat to national security considering its size, weight, speed, 

and operational capability.

Technical Specifications Of The DJI Phantom 3 UAS.

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

Phantom 3 User Manuals, attached hereto as Appendix A.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable The 

UAS To Remain Within A Defined Operational Area.

The DJI Phantom 3 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 3 UAS is provided at pages 45-50 of the DJI Phantom 3 User Manuals, 

attached hereto as Appendix A.

iii. The DJI Phantom 3 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 3 UAS will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UAS does not 

reacquire control link data from the GCS, the UAS will assume that the Control Link is lost 

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

descend to the takeoff position and shutdown. A complete description of the Failsafe 

Functions of the DJI Phantom 3 at pages 13 through 15 of the DJI Phantom 3 User Manuals, 

attached hereto as Appendix A.

iv. The DJI Phantom 3 GCS And Its Operation.

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

GCS and flight control software is provided at pages 40 through 47 of the DJI Phantom 3 

User Manual. DJI Phantom 3 User Manuals are attached hereto as Appendix A.

b. Flight Operations Of THE DJI Phantom 3 UAS Is Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer.

RAAKIN IQBAL will be the only person to act as a pilot in command (PIC) of the 

DJI Phantom 3 UAS. Additionally, a safety observer will assist in flights.
18

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

Specific Operating Limitations.

In seeking this exemption, HUQA proposes to commercially operate DJI Phantom 3 

UAS for the special purpose of conducting aerial video and photography over certain 

areas of United States, pursuant to the following specific operating limitations:

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

following aircraft described in the operating documents, rotorcraft UAS

weighing less than 55 pounds maximum gross weight: DJI Phantom 3 

Unmanned Aircraft Systems. Proposed operations of any other aircraft will 

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

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

operations for the purpose of aerial video and photography.

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

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

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

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

reported to ATC must be in feet AGL.

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

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

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

airman medical certificate.

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

not permitted.

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS

capability. The SO and PIC must be able to communicate verbally at all 

times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot transfer 

his or her designation for the duration of the flight. The PIC must ensure that 

the SO can perform the functions prescribed in the operating documents.

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

with seeing and avoiding other air traffic and other ground based obstacles/ 
19

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 record.
20

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 PIC must possess at least a private pilot certificate and at least a current 

third- class medical certificate.

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

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be 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.

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 UAS 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.
21

21. The UAS 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 UAS loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

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

accordance with the operating documents.

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

weather conditions) there is enough power to fly at normal cruising speed to the intended 

landing point and land the UA with 25% battery power remaining.

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

Waiver or Authorization (COA) prior to conducting any operations under the grant of 

exemption. This COA will also require the operator to request a Notice to Airman 

(NOTAM) not more than 72 hours in advance, but not less than 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 (NNumber) 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 UAS 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 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 
22

owner/controller of such vessels, vehicles or structures has granted permission and 

the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property with 

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

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

conducted.

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

boundaries of the operational area as defined by the applicable COA must be reported to 

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

to the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

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

will be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that 

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

able to safely operate the DJI Phantom 3 UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

Considering HUQA’s proposed area of operations, and the operating limitations set forthabove; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the DJI Phantom 3 UAS, HUQA LIVE, LLC submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for HUQA’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 
23

11156, 11158, 11159, 11160, 11161).

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

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

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

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

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

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

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

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes).

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

was obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during HUQA’s proposed operations. The Administrator has held that prior documented flight 

experience that was obtained in compliance with applicable regulations would ensure safe 

operations, stating as follows:

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

of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a 

manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 

11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

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

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

i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours 

may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The 

FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to 

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

operations. The FAA also finds that prior documented flight experience that was obtained in 
24

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, HUQA LIVE, LLC will ensure safe operations by not allowing any PIC to 

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

and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 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, HUQA LIVE, LLC will ensure that the DJI Phantom 3 UAS is in an airworthy 

condition based upon the UAS’s compliance with its operating documents and as stated in the 

conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161).
25

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would 

Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the 

altitude information of the DJI Phantom 3 UAS will be provided to the PIC via GPS equipment and a 

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

monitoring of the flight path and altitude. This altitude information, combined with HUQA’s 

operation of the DJI Phantom 3 UAS within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by 

GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is 

automatically established by the UAS at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 UAS; (2) the 

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

Accordingly, HUQA will ensure that it will safely operate the battery powered DJI Phantom 3 UAS 

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 14.5 

minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for 

at least 4.5 minutes.

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

limitations on the proposed flight operations; and the location of the proposed operations, will ensure 

an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be 

ensured as the DJI Phantom 3 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 Phantom 3 UAS will descend and land automatically.
26

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish 

that safety is not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. Relief has been granted for manned aircraft to operate at less than the 

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety.

In seeking this exemption, HUQA 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 HUQA 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., the HUQA 

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

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

UAS.

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

HUQA LIVE, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 User Manuals is attached hereto as 

Appendix A; a copy of the DJI Phantom 3 UAS Maintenance LOG is attached hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because HUQA LIVE, LLC will use 

trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed by the operating documents.

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

by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS will 

be performed by trained technicians. Maintenance will be documented and maintained utilizing the 

monthly maintenance log.
27

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected 

when the technical characteristics and operating limitations of the UAS are considered.

In consideration of HUQA’s proposed operating limitations, the operating documents, and the 

technical aspects of the DJI Phantom 3 UAS, HUQA LIVE, LLC 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, HUQA requests that the FAA prescribe special 

conditions for the intended operation of the DJI Phantom 3 UAS, which contains such safety standards 

that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAS for the limited purpose of conducting aerial video and photography over certain 

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

considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate without 

airworthiness certification in accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 

21.16, for operation of the DJI Phantom 3 UAS, since the airworthiness regulations of 14 C.F.R. 

Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate 
28

or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel 

or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special 

conditions and amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards for the aircraft, 

aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent 

to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Leading Edge’s intended operation of the Phantom 3 UAS, which 

contain such safety standards that the Administrator finds necessary to establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 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 Summary That Can Be Published In The Federal Register, stating: The Rules From

Which HUQA LIVE, LLC Seeks Exemption:

HUQA LIVE, LLC 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 HUQA LIVE, LLC Seeks:

This exemption will permit HUQA LIVE, LLC to commercially operate an Unmanned 

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

certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support HUQA LIVE, 

LLC’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, HUQA’s request for exemption may be granted pursuant to the authority 

of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.
29

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, HUQA will operate the DJI Phantom 3 UAS safely in the NAS, without creating a hazard 

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

CONCLUSION

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

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

operation of the DJI Phantom 3 UAS commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of the United States. By 

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing 

HUQA LIVE, LLC to safely, efficiently, and economically operate the DJI Phantom 3 UAS 

commercially within the NAS.

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

and Reform Act of 2012, Section 333, HUQA LIVE LLC respectfully requests that the Administrator 

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

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and 

permit Leading Edge to operate the DJI Phantom 3 UAS commercially for the purpose of conducting 

aerial video and photography over certain areas of the United States.

Respectfully submitted on February 25, 2016

HUQA LIVE, LLC

Attn. Raakin Iqbal

590 15th ST S #400

Arlington, VA 22202

202-527-9342

riqbal@huqalive.com
30

Appendices:

A – DJI Phantom 3 Specifications Data Sheet

B – Monthly Maintenance Log

D- DJI Phantom Users Guide

APPENDIX – A

DJI Phantom 3 TECHNICAL SPECIFICATIONS

HUQA LIVE, LLC only utilizes a safe and reliable UAS. DJI is an industry leader in small 

UAS production. The DJI UAS is 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/tablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model – Phantom 3

2.2.1.2 Weight (Battery Included) – 1280 grams

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: +/- 10cm; Horizontal:

+/-1m

2.2.1.4 Max Angular Velocity –Yaw: 2000/s

2.2.1.5 Max Tilt Angle - 35

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 3m/s

2.2.1.8 Max Speed – 16m/s (ATTI mode, no wind – NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude – 6000m

2.2.1.10 Max Flight Time – Approximately 23 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 14F to 104F (-10C to 40C)

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12”
31

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

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

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA

2.2.2.4 Angular Vibration Range - ±0.03

2.2.2.5 Mounting – Detachable

2.2.2.6 Controllable Range – Pitch: -90 to +30; Pan: ±320

2.2.2.7 Mechanical Range – Pitch: -125 to 45; Pan: ±330

2.2.2.8 Max Controllable Speed – Pitch: 120/s; Pan: 180/s

2.2.3 Camera

2.2.3.1 Name – Sony EXMOR

2.2.3.2 Model – 12.4M Pixel

2.2.3.3 Total Pixels – 12.4M

2.2.3.4 Effective Pixels – 12.76M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 94

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; 

FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60

2.2.3.10 Operating Temperature Range - 32F - 104F (0C - 40C)

2.2.4 Transmitter

2.2.4.1 Name – C1

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W

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

2.2.4.6 Battery – 600mAh LiPo 2S