UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Droneography 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), 91.119, 91.121, 91.151(b), 91.405(a), 

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

COMMERCIAL OPERATION OF DJI PHANTOM 3 PROFESSIONAL

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on March 31, 2015

Christopher L Parrish ATP CFI CFII

Droneography LLC

6776 S. Ivy St. #A3

Centennial CO, 80112

Tel: (303) 521-3611

Email: Chris@Droneography360.com
2

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............................................................ 7

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

LLC SEEKS EXEMPTION................................................................ 8

THE EXTENT OF RELIEF DRONEOGRAPHY LLC SEEKS AND THE

REASON DRONEOGRAPHY LLC SEEKS THE RELIEF............................ 11

THE REASONS WHY GRANTING DRONEOGRAPHY LLC’S REQUEST

WOULD BE IN THE PUBLIC INTEREST ........................................................ 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY......................................................................... 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT DRONEOGRAPHY LLC’S REQUEST............34

CONCLUSION................................................................................................................... 35

APPENDICES........................................................................................37
3

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
4

SUMMARY

Christopher L. Parrish ATP, CFI CFII 3331167, seeks exemption from the

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.119, 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 Droneography LLC to operate an Unmanned Aircraft

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

construction sites, real estate, special events, film sets, farm & agriculture, insurance and 

natural disaster surveys as well as landscape over the United States its territories and 

possessions.
5

INTRODUCTION AND INTERESTS OF THE PETITIONER

Droneography LLC seeks to provide its clients with the highest quality digital

content for use in their commercial, personal, and non-profit multimedia projects.

Christopher Parrish ATP, CFII, CFI has over 5 years aircraft based aerial photography

experience, in all aspects of aerial video and aerial photography. The objective of

Droneography LLC, is to provide high quality imaging that includes both digital 

photography and filming for a variety of commercial, public, and residential uses,

specifically targeting:

• Special event’s

• Safety inspections

• Land and property surveying and scouting

• Real Estate appraisal and advertisement

• Commercial Real Estate appraisal and advertisement 

• Ongoing construction progress surveys

• Farm & Agriculture survey

• Natural disaster surveys

• Insurance claim surveys

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS

Droneography LLC seeks an exemption to operate the DJI Phantom 3 Professional

UAS for compensation or hire within the NAS. The DJI Phantom 3 Professional 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 

Professional has a maximum gross weight of approximately 2.82 lbs., while having a
6

length of 19 1/4 inches width of 19 1/4 inches, height of 8 inches, and a maximum speed

of approximately 40 knots. The DJI Phantom 3 Professional UA is equipped with four

main rotors; driven by Lithium Polymer (LiPo 4S) battery powered electric motors.

The DJI Phantom 3 Professional UA that will be operated by Droneography LLC

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

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

Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Droneography LLC, pursuant to the provisions of the Federal Aviation 

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

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

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

in the National Airspace System (NAS), and for an exemption from the requirements of 14

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), and 91.417(a) & (b).

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

with the unmanned aircraft and its operation, Droneography LLC operation of DJI 

Phantom 3 Professional UAS meets the conditions of FMRA Section 333 and therefore,

will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart

H.

Accordingly, Droneography LLC 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.

Droneography LLC submits that the requested relief is proper since an equivalent
7

level of safety will be ensured. Droneography LLC will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

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

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

Droneography LLC will document and maintain all maintenance records for the DJI 

Phantom 3 Professional UAS.

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

privileges and limitations: Pilot in command, is requested by Droneography LLC to the

extent necessary to allow a Pilot in Command (PIC), holding a pilot’s license that would 

usually require a Commercial pilots license or better to operate for hire. Any pilot flying for 

Droneography LLC and acting as PIC of the UAS is able to safely operate the DJI Phantom 

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

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

and structures.

Droneography LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 3 Professional UAS do not require an

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

Droneography LLC submits that it will ensure that the DJI Phantom 3 Professional UAS is

in an airworthy condition, prior to every flight, by determining that the UASs are in

compliance with the operating documents (i.e., Maintenance Log, and DJI Phantom 3 

Professional Instruction Manual), and that the UAS aircraft are in a condition that permits

for safe flight.

Droneography LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UA will not have a
8

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

Professional UA will be provided to the PIC via Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlinks from the UA

to the GCS for active monitoring of the flight path and altitude. This altitude information

combined with Droneography LLC’s operation of the DJI Phantom 3 Professional UAS

within visual line of sight or an observer in constant contact with the PIC, at or below 200

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

Additionally, Droneography LLC seeks an exemption from the requirements of 

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

LLC submits that safety will not be affected by operation of the DJI Phantom 3 

Professional UA during daylight hours in visual meteorological conditions (VMC) under

visual flight rules (VFR), with enough battery power to fly for a total duration of

approximately 18 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 5 minutes.

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

Christopher L Parrish

Droneography LLC

6776 S. Ivy St. # A3

Centennial CO, 80112

Tel: (303) 521-3611

Email:Chris@Droneography360.com

B. The Specific Sections Of 14 C.F.R. From Which Droneography LLC Seeks 

Exemption.

1. Droneography LLC Seeks Exemption from The Requirements of Section 
9

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. Droneography 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. Droneography LLC Seeks Exemption From the Requirements of 

Section 91.119.

Sec. 91.119 — Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency

landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 1,000 feet 

above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, 

vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the surface—
10

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the helicopter 

complies with any routes or altitudes specifically prescribed for helicopters by the 

FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less 

than the minimums prescribed in paragraph (c) of this section.

4. Droneography LLC 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) 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) the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.

5. Droneography LLC 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.

6. Droneography LLC Seeks Exemption from The Requirement of

Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following:
11

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[.]

7. Droneography 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[.]

8. Droneography 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

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

with part 21 of this chapter.

9. Droneography 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 
12

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

include--

(i) description (or reference to data acceptable to the Administrator) of the

work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

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

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

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

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances.

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

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after the

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service.
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C. The Extent of Relief; Droneography LLC Reasons for The Relief.

1. Extent of Relief; Droneography 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

an appropriate pilots license which includes any of the following: Sport Pilot, Recreational 

Pilot or Private Pilot or any license able to conduct commercial operations such as 

Commercial Pilot or ATP, 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, Droneography LLC submits that an equivalent level

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

Professional UAS UA 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 

Professional 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, Droneography LLC submits that all flights of the DJI Phantom 3 

Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to Droneography LLC business; and (2) will not carry passengers or property for 
14

compensation or hire.

2. Extent of Relief; Droneography 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 Droneography LLC to determine that the DJI Phantom 3 

Professional UAS are in airworthy condition prior to every flight by ensuring that the UAS

is in compliance with the operating documents (i.e., the Droneography LLC Aerial

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

Droneography LLC seeks the requested relief because the DJI Phantom 3 

Professional UAS do not require an airworthiness certificate in accordance with 14 C.F.R.

Part 21, Subpart H. Therefore, Droneography LLC will ensure that the DJI Phantom 3 

Professional UAS are in airworthy condition based upon its compliance with the operating

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

prior to every flight, and further, determine that the aircraft is in condition for a safe flight,

as stated in the conditions and limitations below.

3. Extent of Relief; Droneography LLC Seeks relief from Section 91.119. 

Relief from Section 91.119, entitled Minimum Safe Altitudes: General, will be 

required in order to capture high quality digital images below 1,000 feet in congested areas 

and 500 feet in other than congested areas. Due to the nature of the operations the light 

weight nature of the DJI Phantom 3 Professional, and the low risk for damage or injury to 

persons, vessels, vehicles or structures in private or public areas and considering the low 

potential for personal injury to the general public, workers and bystanders as well as 

damage to property, Droneography LLC seeks relief of 91.119 to the extent necessary to 

complete the operations while utilizing the PIC to exercise good judgment in determining 

that the UAS does not pose an undue risk to those in close proximity to the operations of 
15

the UAS. 

Furthermore, Droneography LLC will have adequate warning signs placed in and 

around the area of operations to alert the general public, workers and bystanders of the 

operations being conducted. It is Droneography LLC’s belief that information and public 

awareness and dialog will contribute to public safety and understanding.

4. Extent of Relief; Droneography 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 Professional UAS, which utilize a barometric

pressure sensor, GPS equipment, and a radio communications telemetry data link to

downlink altitude information from the UA to the PIC at the ground control station (GCS).

Since the FAA requires that any altitude information concerning UAS operations be

reported to air traffic control (ATC) in feet above ground level (AGL), Droneography LLC

seeks the requested relief because the DJI Phantom 3 Professional UA’s altimeter may be

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

altitude, before each flight.

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

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

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

be maintained since the DJI Phantom 3 Professional UAs are equipped with a barometric

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

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

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

5. Extent of Relief; Droneography LLC Seeks Relief from Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR
16

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

Phantom 3 Professional UAs during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for a total duration of 18 minutes to the first point

of intended landing and, assuming normal cruising speed, to fly after that for at least 5

minutes. Droneography LLC seeks the requested relief because without an exemption from

Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 

Professional UA will severely constrain the practicality of any aerial video or still photo

flight operations that Droneography proposes to conduct pursuant to this Petition.

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

Professional UAS, the DJI Phantom 3 Professional operating documents, and

Droneography LLC’s proposed operating limitations, ensure that Droneography LLC will

safely operate the battery powered DJI Phantom 3 Professional 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 18 minutes to the first point of intended landing

and, assuming normal cruising speed, to fly after that for at least 5 minutes.

6. Extent of Relief; Droneography 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, Droneography LLC requests relief 

from these Sections because the DJI Phantom 3 Professional UAS does not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional

UAS meets the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Droneography LLC will use trained technicians to perform

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

techniques, and practices prescribed in the UAS operating documents (i.e., the Maintenance
17

Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore, Droneography

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

UAS.

D. The Reasons Why Granting Droneography LLC Request Would Be in The

Public Interest;

Granting the present Petition will further the public interest by allowing

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

photography of special events, film sets, real estate, safety inspections, farm & agriculture 

survey, insurance surveys, natural disaster surveys and landscape photography over the

United States its territories and possessions.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease

congestion of the NAS, reduce pollution, and provide significant benefits to the economy 

by expanding who can take advantage of lower cost aerial filming & photography. 

The Public Will Benefit from Decreased Congestion of The NAS.

The DJI Phantom 3 Professional UA are battery powered and serve as a safe,

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

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

acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional 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 Professional UAS do not require an airport to takeoff or land. Likewise, a

reduction of manned aircraft conducting aerial video and photography missions would 

result in fewer aircraft that must be handled by air traffic control during the ground, 
18

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

1. The Public Will Benefit from The Safety and Efficiency of The DJI 

Phantom 3 Professional UAS.

Conducting aerial photography and surveying with the DJI Phantom 3 Professional

UAS, instead of manned aircraft, will benefit the public by 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 Professional

UAS produce no air pollution. The DJI Phantom 3 Professional UA, while reducing the

carbon footprint of aerial film & photography acquisitions, also reduce noise.

By using the DJI Phantom 3 Professional UAS to perform aerial film & 

photography acquisitions, the risk to life and property in the air and on the ground can be 

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

the DJI Phantom 3 Professional UAS, 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.

2. Performing Aerial Video and Photography Operations with The DJI 

Phantom 3 Professional UAS Will Benefit the Economy.

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

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

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

companies, like Droneography LLC, to remain competitive and contribute to the growth of 

the U.S. economy. Operating the battery powered DJI Phantom 3 Professional UAS

allows companies greater operational flexibility in conjunction with traditional manned

aircraft.

3. There Are No Privacy Issues.
19

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

conducted for decades, Droneography LLC proposed operation of the DJI Phantom 3 

Professional UAS would not create any privacy issues. Specifically, the DJI Phantom 3 

Professional UAS will be operated only in compliance with operating, which would be at

the instruction or discretion of property owners, lessee’s or their agents. 

4. Reasons Why The DJI Phantom 3 Professional UA Meet the Conditions Of

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

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

with the unmanned aircraft and its operation, Droneography LLC operation of the DJI 

Phantom 3 Professional 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
20

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, Droneography LLC submits that the DJI Phantom 3 

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

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

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

a. The Specifications of The DJI Phantom 3 Professional UAS Demonstrate

Its Safe Characteristics.

The DJI Phantom 3 Professional UAS does not create a hazard to users of the

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

weight, speed, and operational capability.

i. Technical Specifications of The DJI Phantom 3 Professional UAS.

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

the DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as Exhibit

A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight And

Navigation Modes Enable The UAS To Remain Within A Defined

Operational Area.

The DJI Phantom 3 Professional 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 Professional UAS is provided in the DJI Phantom 3 Professional User

Manual, attached hereto as Exhibit B.

iii. e DJI Phantom 3 Professional UAS Are Designed for Automatic

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

Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3 Professional UA will remain 
21

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

Professional UA does not reacquire control link data from the GCS, the UA will assume

that the Control Link is lost and the UA will return to the home position (i.e., failsafe

mode) via GPS, and will descend to the takeoff position and shutdown. A complete

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

at pages 12 through 14 of the DJI Phantom 3 Professional User Manual, attached hereto as

B.

iv. The DJI Phantom 3 Professional GCS and Its Operation.

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

Professional GCS and flight control software is provided at pages 22 through 29 of the

DJI Phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manual is

attached hereto as Exhibit B.

b. Flight Operations of DJI Phantom 3 Professional UAS Are Limited to

The Line Of Sight Of A Certificated Pilot in Command Or With A

Safety Observer As Necessary.

Where the UAS will not be out of the direct line of sight of the PIC a safety 

observer would be optional. However, a safety observer will be utilized to assist the PIC

during flight operations that the UAS potentially or will be out of site of the operator.

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

To Specific Operating Limitations.

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

Professional UAS for the special purpose of conducting aerial digital video and

photography over the United States its Territories and Possessions, pursuant to the

following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less than 

55 pounds’ maximum gross weight: DJI Phantom 3 Professional Unmanned

Aircraft System. Proposed operations of any other aircraft will require a new
22

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 100 MPH.

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.

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

not permitted.

7. When operations are conducted out of view of the PIC, all operations must utilize

a safety observer (SO). The SO may be used to satisfy the VLOS requirement as

long as the PIC or SO maintains VLOS capability. The SO and PIC must be able

to communicate verbally at all times via phone or handheld radio’s. 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 with 

an emphasis on safety for persons and property 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 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.
23

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 UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess an appropriate pilots license as deemed by the FAA.

(Sport Pilot, Recreational Pilot, Private Pilot, Commercial Pilot or ATP)

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.
24

19. UAS operations may not be conducted during night (Official sunset to sunrise), as

defined in 14 C.F.R. unless a special request is made and approved by the FAA. §

19.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made to the FAA

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

rules (SVFR) are not authorized.

20. The UAS may not be operated less than than 3 statute miles visibility as seen

from the PIC’s location.

21. 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.

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 at least 15% 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. 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.

26. No Operations are allowed in Class A (18,000 feet & above). Operation in 

Class B, C, D and E Airspace are allowed with the permission of the 

controlling ATC Facility. Operations in Class G airspace are allowed 

without ATC permission.

27. At all times the small unmanned aircraft must remain close enough to the 

operator for the operator to be capable of seeing the aircraft with vision 

unaided by any device other than corrective lenses, except when using a 

Visual Observer in constant contact with the PIC.

28. The UAV must remain clear and yield the right of way to all manned

aviation operations and activities at all times.

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

30. Flight operations must not be conducted directly over non-participating persons

(persons other than the PIC, SO, operator trainees or essential persons), vessels,

vehicles, and structures unless:
25

a. 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;

b. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a).

31. 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.

Droneography LLC submits that the equivalent level of safety established by

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

DJI Phantom 3 Professional 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 Professional UAS in a manner consistent with the exemption, including evasive

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

vehicles and structures.

Considering Droneography LLC proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge

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

the airmanship skills necessary to safely operate the DJI Phantom 3 Professional UAS,

Droneography LLC submits that the additional manned airmanship experience of a

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

Droneography LLC specific proposed flight operations.

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

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 
26

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Droneography LLC will not allow any PIC to operate the DJI Phantom 3 

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

requirements or the DJI Phantom 3 Professional UAS training and currency requirements,

that the PIC is able to safely operate the DJI Phantom 3 Professional 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), 10 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).

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 Droneography LLC 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
27

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and

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

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15.

Accordingly, Droneography will ensure safe operations by not allowing any PIC to

operate the DJI Phantom 3 Professional 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 Professional 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, Droneography LLC will ensure that the DJI Phantom 3 

Professional UAS is in an airworthy condition based upon the UAS’s compliance with

its operating documents and as stated in the conditions and limitations herein.

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

to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

Would Not Adversely Affect Safety.

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

because the altitude information of the DJI Phantom 3 Professional UA will be provided to

the PIC via GPS equipment and a radio communications telemetry data link, which
28

downlinks from the UA to the GCS for active monitoring of the flight path and altitude.

This altitude information, combined with Droneography LLC’s operation of the DJI 

Phantom 3 Professional UA 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 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 3 Professional UAs; (2) the limitations on the proposed flight operations; and (3)

the location of the proposed flight operations. Accordingly, Droneography will ensure that

it will safely operate the battery powered DJI Phantom 3 Professional UA during daylight

hours in VFR conditions, with enough battery power to fly for a total duration of 18

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

after that for at least 5 minutes.

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

Professional 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 Professional

UAS provide audible and visual warnings to the PIC at the GCS when the UAs experiences
29

low battery voltage, the first warning occurring at approximately 25% remaining battery

power, and again at approximately 10% remaining battery power. At the critically low

battery level, the DJI Phantom Vision+ UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

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, Droneography LLC 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 Droneography LLC will use licensed pilots and 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 Maintenance Log,

and DJI Phantom 3 Professional Instruction Manual). Furthermore, Droneography LLC will

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

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

operating documents, Droneography 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 
30

Phantom 3 Professional User Manuals are attached hereto as Exhibit B.

Likewise, the exemption sought will not adversely affect safety because

Droneography 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 Professional UAS will be performed by trained technicians. Maintenance

will be documented and maintained utilizing a standard aircraft maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Droneography LLC proposed operating limitations, the

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

Droneography 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, Droneography LLC requests 
31

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

Professional UAS, which contain such safety standards that the Administrator finds

necessary 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 the United States its territories and possessions 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 Professional UAS, since the airworthiness 

regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, 

due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special

Conditions, states the following:

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

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations.

See 14 C.F.R. § 21.16.

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

may prescribe special conditions for Droneography LLC intended operation of the DJI 
32

Phantom 3 Professional 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).

E. A Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which Droneography LLC Seeks Exemption:

Droneography LLC seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.119, 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 Droneography LLC 

Seeks:

This exemption will permit Droneography LLC to commercially operate an 

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

photography over the United States its territories and possessions.

F. Any Additional Information, Views, Or Arguments Available to Support

Droneography LLC 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, Droneography LLC request for exemption 

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

set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will

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

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

certification.

As discussed in detail above, Droneography LLC will operate the DJI Phantom 3 

Professional UASs safely in the NAS, without creating a hazard to users of the NAS, or the

public, or otherwise pose a threat to national security.
33
34

CONCLUSION

As set forth herein, Droneography 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 Professional UAS commercially, without an

airworthiness certificate, for the purpose of conducting aerial video and photography over the

United States its territories and possessions.

Respectfully submitted, 

Christopher L Parrish

Christopher L Parrish

Droneography LLC

6776 S. Ivy St. #A3

Centennial, CO 80112

Tel: (303) 521-3611

Email:Chris@Droneography360.com
35

Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Phantom 3 Professional Manufacturer’s User Manual
36

APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

Droneography LLC only utilizes safe and reliable UASs. DJI is an industry leader in 

small UAS production. DJI UASs are loaded with ground breaking software enabling the

user to set parameters which will not allow flight into controlled airspace. Parameters can 

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

limit flight to a predetermined and set distance. In addition, DJI software provides realtime altitude and location information to the PIC via the linked monitor (smart

phone/tablet devices)

DJI Phantom 2 Vision+

Aircraft

Supported Battery – DJI PH3-4480 mAh-15.2 V (LiPo 4S) Battery

Weight (Battery & Propellers Included) – 2.822lbs (1280g)

Max Ascent Speed – 5m/s

Max Descent Speed – 3m/s

Max Flight Speed – 16m/s (No Wind)

Transmitter

Operating Frequency – 2.400GHz – 2.483GHz

Transmitting Distance – 1.25 Miles (Outdoor and unobstructed)
37

APPENDIX – B

DJI Phantom 3 Professional Manufacturer’s User Manual