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UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION WASHINGTON, DC

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: MICHAEL E. OLSEN

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

DJI Inspire 1 and DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS and a BLANKET 

EXEMPTION FOR UAS OPERATION LESS THAN 55 POUNDS, DAYLIGHT OPERATION, VLOS, 

VFR AND BELOW 200 FEET AGL.

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on MAY 21, 2015

MICHAEL E. OLSEN

14 OLD TOWN LANE

HALESITE, NY 11743

516-317-6222

MEOLSEN@YAHOO.COM
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS 4

SUMMARY 5

INTRODUCTION AND INTERESTS OF THE PETITIONER 5

BACKGROUND 5

Unmanned Aircraft Systems: DJI Inspire 1, DJI Phantom 3 (Herafter the DJI UAS Aircraft) 5

BASIS FOR PETITION 6

Name And Address Of The Petitioner. 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH MICHAEL E. OLSEN SEEKS EXEMPTION. 7

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 61.113(a) And 

(b). 7

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.7(a). 8

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.121. 8

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.151(b). 8

MICHAEL E. OLSEN Seeks Exemption From The Requirement Of Section 91.405(a). 8

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.407(a)(1) 9

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Sections 91.409(a)(1) 

And 91.409(a)(2). 9

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b). 9

THE EXTENT OF RELIEF MICHAEL E. OLSEN SEEKS AND THE REASON MICHAEL E. OLSEN 

SEEKS THE RELIEF. 10

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks Relief 

From Section 61.113(a) And (b). 11

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks 

Relief From Section 91.7(a). 11

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks 

Relief From Section 91.121. 12

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks Relief 

From Section 91.151(b). 12

Extent Of Relief MICHAEL E. OLSEN Seeks And The Reason MICHAEL E. OLSEN Seeks Relief 

From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 13

The Reasons Why Granting MICHAEL E. OLSEN Request Would Be In The Public Interest; That Is, 

How It Would Benefit The Public As A Whole. 13

The Public Will Benefit From Decreased Congestion Of The NAS. 13

The Public Will Benefit From The Safety And Efficiency Of The DJI UAS Aircraft 14

Performing Aerial Video and Photography Operations With The DJI UAS Aircraft will 

Benefit The Economy. 14

There Are No Privacy Issues. 15

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 MICHAEL E. OLSEN Seeks Exemption. 15
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Reasons Why The DJI UAS Aircraft Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333. 15

The Specifications Of The DJI UAS Aircraft Demonstrate Its Safe Characteristics. 16

Technical Specifications of DJI UAS Aircraft. 16

DJI UAS Aircraft GCS Operation. 17

Flight Operations Of DJI UAS Aircraft are Limited To The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer. 17

Flights Of DJI UAS Aircraft will Be Conducted Pursuant To Specific Operating 

Limitations. 17

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

Adversely Affect Safety. 21

Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely 

Affect Safety. 23

Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely 

Affect Safety. 23

Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely 

Affect Safety. 24

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. 24

The FAA May Prescribe Any Other Conditions For Safe Operation. 25

A Summary That Can Be Published In The Federal Register, stating: The Rules From Which 

MICHAEL E. OLSEN Seeks Exemption: 26

A Brief Description Of The Nature Of The Exemption MICHAEL E. OLSEN Seeks: 27

Any Additional Information, Views, Or Arguments Available To Support MICHAEL E. OLSEN 

Request. 27

CONCLUSION 27
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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

DJI UAS Aircraft DJI Inspire 1 and Phantom 3 subject of this Petition.

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 Mod and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UAV Unmanned Aircraft Vehicle

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 

MICHAEL E. OLSEN 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 MICHAEL E. 

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

conducting aerial video and photography in support of small business, community and 

charitable activities in and around the State of New York.

INTRODUCTION AND INTERESTS OF THE PETITIONER 

MICHAEL E. OLSEN’s primary occupation is a senior executive in a media company but has 

hundreds of hours as a UAS hobbyist. From time to time he is asked to support local 

community, small business, and charitable activities by providing commercial aerial 

photography or videography. In the absence of the exemption, MICHAEL E OLSEN must 

decline to support these interests. The objective of MICHAEL E. OLSEN and his aerial

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

residential uses, that are incidental to his primary occupation, specifically targeting

• Marketing

• Construction sites before and after

• Appraisals

• Motion Picture Filming

• Aerial acquisitions for inspections of public and private structures.

• Building Inspection operations

BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1, DJI Phantom 3 (Hereafter the DJI UAS 

Aircraft)

MICHAEL E. OLSEN seeks an exemption to operate DJI Inspire 1 and DJI Phantom 3 UAS

systems for compensation or hire within the NAS. The DJI Inspire 1, Phantom 3 are vertical 

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizing electronic tablet or smart phone systems.

The DJI Inspire 1 has a maximum gross weight of approximately 7 pounds, with a length of 

17 inches and a width of 18 inches and a height of 10 inches and a maximum speed of 

approximately 30 knots.
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DJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 

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

30 knots. The DJI Inspire 1 and Phantom 3 are equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors.

The DJI Inspire 1 and DJI Phantom 3 will be operated by MICHAEL E. OLSEN 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, MICHAEL E. OLSEN , 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 UAS Aircraft 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, MICHAEL E. OLSEN operation DJI UAS Aircraft 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, MICHAEL E. OLSEN 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.

MICHAEL E. OLSEN submits that the requested relief is proper since an equivalent level of 

safety will be ensured. MICHAEL E. OLSEN 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.

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

privileges and limitations: Pilot in command, is requested by MICHAEL E. OLSEN to the 

extent necessary to allow a Pilot in Command (PIC) with significant experience in the field 

of UAV’s, and who has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the DJI UAS Aircraft in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

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

MICHAEL E. OLSEN seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI UAS Aircraft do not require an airworthiness certificate in accordance with 

14 C.F.R. Part 21, Subpart H. As such, MICHAEL E. OLSEN submits that he will ensure the DJI 
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UAS Aircraft are in an airworthy condition, prior to every flight, by determining that the 

UASs are in compliance with the operating documents and that the aircraft are in a 

condition for safe flight.

MICHAEL E. OLSEN also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, DJI UAS aircraft will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI UAS Aircraft will be provided to the PIC 

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

link, which downlinks from the UA to the GCS for active monitoring of the flight path. This 

altitude information, combined with MICHAEL E. OLSEN operation of the DJI UAS Aircraft

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent 

to Section 91.121.

Additionally, MICHAEL E. OLSEN seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. MICHAEL E. OLSEN

submits that safety will not be affected by operation of the DJI UAS Aircraft during daylight 

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

battery power to fly for a total duration of approximately 15 minutes to the first point of 

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

5minutes.

In accordance with 14 C.F.R. § 11.81, MICHAEL E. OLSEN provides the following information 

in support of its petition for exemption:

Name And Address Of The Petitioner.

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

MICHAEL E. OLSEN

14 Old Town Lane

Halesite, NY 11743

516-317-6222 (Mobile)

meolsen@yahoo.com

The Specific Sections Of 14 C.F.R. From Which MICHAEL E. OLSEN Seeks 

Exemption. 

MICHAEL E. OLSEN 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:
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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.

A private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if—

The flight is only incidental to that business or employment; and

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

MICHAEL E. OLSEN 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.

MICHAEL E. OLSEN Seeks Exemption From The Requirements Of Section 91.121.

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

part:

Each person operating an aircraft shall maintain the cruising altitude or flight level 

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

operating—

Below 18,000 feet MSL, to--

The current reported altimeter setting of a station along the route and within 100 

nautical miles of the aircraft;

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

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.

MICHAEL E. OLSEN 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.

MICHAEL E. OLSEN Seeks Exemption From The Requirement Of Section 91.405(a).

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

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[.]

MICHAEL E. OLSEN 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:

No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless--

It has been approved for return to service by a person authorized under

§ 43.7 of this chapter[.]

MICHAEL E. OLSEN 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:

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 --

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

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

part 21 of this chapter.

MICHAEL E. OLSEN 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:

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:

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

performed; and

The date of completion of the work performed; and

The signature and certificate number of the person approving the aircraft for return 

to service.

Records containing the following information:

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

rotor.

The current status of life-limited parts of each airframe, engine, propeller, rotor, 

and appliance.

The time since last overhaul of all items installed on the aircraft which are required 

to be overhauled on a specified time basis.

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.

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.

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.

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

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.

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.

A list of defects furnished to a registered owner or operator under §43.11 of this 

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

for return to service.

The Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. 

OLSEN Seeks the Relief. 
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Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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, MICHAEL E. OLSEN submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Inspire 

1,DJI Phantom 2 UAS or DJI Phantom 3 UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely 

operate either the DJI Inspire 1, DJI Phantom 2 or 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, MICHAEL E. OLSEN submits that all flights of DJI UAS aircraft, conducted by 

the PIC pursuant to the grant of this Petition: (1) will be incidental to MICHAEL E. 

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

hire.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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 MICHAEL E. OLSEN to determine that the DJI UAS Aircraft

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

compliance with the operating documents (i.e., the MICHAEL E. OLSEN Aerial 

Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction 

Manual).

MICHAEL E. OLSEN seeks the requested relief because the DJI UAS Aircraft do not 

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

Therefore, MICHAEL E. OLSEN will ensure that the DJI UAS Aircraft are in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly 
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Maintenance Log, and DJI UAS Aircraft 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.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN Seeks 

Relief from Section 91.121.

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

flight operations of the DJI UAS Aircraft, 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), MICHAEL E 

OLSEN seeks the requested relief because the DJI UAS Aircraft 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 UAS Aircraft 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.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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 UAS 

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

visual flight rules (VFR), for a total duration of 15 minutes to the first point of 

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

minutes. MICHAEL E. OLSEN seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered 

DJI UAS Aircraft will severely constrain the practicality of any aerial video or still 

photo flight operations that MICHAEL E. OLSEN proposes to conduct pursuant to 

this Petition.

Significantly, as set forth below, the technical specifications of the DJI UAS Aircraft

operating documents, and MICHAEL E. OLSEN proposed operating limitations, 

ensure that MICHAEL E. OLSEN will safely operate the battery powered DJI UAS 

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

visual flight rules (VFR), with enough battery power to fly for a total duration of 15 
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minutes to the first point of intended landing and, assuming normal cruising speed, 

to fly after that for at least 5 minutes.

Extent of Relief MICHAEL E. OLSEN Seeks and The Reason MICHAEL E. OLSEN 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, MICHAEL E. OLSEN requests 

relief from these

Sections because the DJI UAS Aircraft do not require airworthiness certificates. As 

set forth more fully below, DJI UAS Aircraft meet the conditions of FMRA Section 

333 for operation without an airworthiness certificate. 

Accordingly, MICHAEL E. OLSEN 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 MICHAEL E. OLSEN Aerial Operations Manual, Monthly Maintenance Log, 

and DJI UAS Aircraft Instruction Manual). Furthermore, MICHAEL E. OLSEN will 

document and maintain all maintenance records for the DJI UAS Aircraft.

The Reasons Why Granting MICHAEL E. OLSEN 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 MICHAEL E. 

OLSEN to safely, efficiently, and economically perform aerial video and photography 

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

States.

Additionally, use of the DJI UAS Aircraft will decrease congestion of the NAS, reduce 

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

MICHAEL E. OLSEN proposed operation of the DJI UAS Aircraft will be realized 

without implicating any privacy issues.

The Public Will Benefit from Decreased Congestion of The NAS.

DJI UAS Aircraft 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 UAS Aircraft 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.
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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 UAS Aircraft do not require an airport to takeoff or land. Likewise, 

a reduction of manned aircraft conducting aerial video

and photography missions would result in fewer aircraft that must be handled by 

air traffic control during the ground, takeoff, departure, arrival, and landing phases 

of flight operations.

The Public Will Benefit from The Safety and Efficiency of The DJI UAS Aircraft

Conducting aerial acquisitions with the DJI UAS Aircraft, 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 UAS Aircraft

produce no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that 

are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI UAS aircraft, while reducing 

the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

UAs are propelled by battery powered electric motors, rather than an internal 

combustion engine.

By using the DJI UAS Aircraft to perform aerial acquisitions, the substantial risk to 

life and property in the air and on the ground, which is usually associated with 

traditional manned aircraft flight operations, will be substantially reduced or 

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

the aircraft, the DJI UAS Aircraft(weighing approximately 2 pounds 11 ounces and 6 

pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 

inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches 

respectively, and with no fuel on board), has less physical potential for collateral 

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

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

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

capacity of 180 gallons).

Performing Aerial Video and Photography Operations with The DJI UAS Aircraft Will

Benefit the Economy.

In addition to being safe and efficient, the DJI UAS Aircraft are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI UAS Aircraft will allow United States based companies, like 

MICHAEL E OLSEN, 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. 
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owned and operated companies must adopt new and alternative technology in 

order to remain competitive. Operating the battery powered DJI UAS Aircraft 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 UAS aircraft, petitioners such as MICHAEL E. OLSEN 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 UAS Aircraft, 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.

There Are No Privacy Issues.

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

for decades, MICHAEL E. OLSEN proposed operation of the DJI UAS Aircraft will not 

implicate any privacy issues. Specifically, the DJI UAS Aircraft will be operated only 

in compliance with operating documents (i.e., the MICHAEL E. OLSEN Aerial 

Operations Manual, Monthly Maintenance Log, and DJI UAS Aircraft Instruction 

Manual) which requires property owner involvement as well as local law 

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

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

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

How the Exemption Would Provide a Level of Safety at Least Equal to That Provided 

by The Rule from Which MICHAEL E. OLSEN Seeks Exemption.

Reasons Why The DJI UAS Aircraft 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, MICHAEL E. OLSEN operation of the 

DJI UAS Aircraft 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:
16

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.

Assessment of Unmanned Aircraft Systems. --In making the determination under 

subsection (ate Secretary shall determine, at a minimum—

which types of unmanned aircraft systems, if any, as a result of their size, weight, 

speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

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

whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1).

Requirements for Safe Operation. —

If the Secretary determines under this section that certain u), nmanned 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, MICHAEL E. OLSEN submits that the DJI UAS Aircraft can 

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

the characteristics of the DJI UAS aircraft; (b) the pilot certification requirement; 

and (c) the specific operating limitations.

The Specifications of The DJI UAS Aircraft Demonstrate Its Safe Characteristics.

The DJI UAS Aircraft do not create a hazard to users of the NAS or the public, or 

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

operational capability.

Technical Specifications of DJI UAS Aircraft.

The technical specifications of the DJI UAS Aircraft are set forth by the DJI UAS 

aircraft User Manuals, attached hereto as Appendix A and B.

The DJI UAS Aircraft Autonomous Flight and Navigation Modes Enable The UASs to

Remain Within a Defined Operational Area.

The DJI UAS Aircraft may be operated in both manual and fully autonomous flight 
17

modes. A complete description of the flight and navigational modes of the DJI UAS 

Aircraft provided in the User Manuals, attached hereto as Appendix A and B.

The DJI UAS Aircraft 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 UAS Aircraft will remain stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the DJI UAS Aircraft do not reacquire 

control link data from the GCS, the UAs will assume that the Control Link is lost and 

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

descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI UAS aircraft are 

described in the User Manuals, attached hereto as Appendix A and B.

DJI UAS Aircraft GCS Operation.

Phantom 3 GCS and flight control software is provided in the User Manual for the 

DJI UAS aircraft attached hereto as Appendix A and B.

Flight Operations of DJI UAS Aircraft are Limited to The Line of Sight of a

Certificated Pilot in Command with A Safety Observer.

MICHAEL E. OLSEN will be the only person to act as a pilot in command (PIC) of DJI 

UAS Aircraft. 

Flights of DJI UAS Aircraft Will Be Conducted Pursuant to Specific Operating 

Limitations.

In seeking this exemption, MICHAEL E. OLSEN proposes to commercially operate DJI 

UAS Aircraft for the special purpose of conducting aerial video and photography 

over certain areas of United States, pursuant to the following specific operating 

limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: DJI UAS AIRCRAFT. 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 45 knots.
18

4. The UA must be operated at an altitude of no more than 400 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/obstructions 

and is not permitted to operate the camera or other instruments. T

9. he 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 (AFS80) 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 
19

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.

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.

17. UAS operations may not be conducted during night, as defined in 14 C.F.R.

18. § 1.1. All operations must be conducted under visual meteorological conditions 

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

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

rules (SVFR) are not authorized.

19. The UAV may not operate within 5 nautical miles of an airport reference point 
20

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.

20. The UAV may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the 

PIC.

21. If the UAV 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 UAV with 25% battery power 

remaining.

24. 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.

25. 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.

26. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UAV must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements.

27. 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.

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

operations and activities at all times.

29. The UAV may not be operated by the PIC from any moving device or vehicle.
21

30. 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:

31. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UAV 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;

32. 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;

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

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

34. 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.

35. 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.

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

per instructions contained on the NTSB Web site: www.ntsb.gov.

Reasons Why an Exemption from The Requirements of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety.

MICHAEL E. OLSEN 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 UAS Aircraft unless that PIC has demonstrated, by meeting 

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

operate the DJI UAS Aircraft in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering MICHAEL E. OLSEN 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 

UAS aircraft, MICHAEL E. OLSEN submits that the training, preparation, practice, 

and experience of the Petitioner is sufficient to meet the requirements of the 
22

proposed use.

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

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

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

MICHAEL E. OLSEN will not allow any PIC to operate the DJI UAS Aircraft unless the 

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

UAS Aircraft training and currency requirements, that the PIC is able to safely 

operate the DJI UAS Aircraft 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 MICHAEL E. OLSEN 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 compliance with 
23

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 experiencebuilding flights the PIC is required to operate the UAS with appropriate distances in 

accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, MICHAEL E. OLSEN will ensure safe operations by not allowing any PIC 

to operate DJI UAS Aircraft unless that PIC has demonstrated, by meeting minimum 

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

UAS Aircraft in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

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, MICHAEL E. OLSEN will ensure that DJI UAS Aircraft 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).

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 UAS Aircraft 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 MICHAEL E. OLSEN operation of 

the DJI UAS Aircraft within visual line of sight, at or below 400 feet AGL, will ensure 

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

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a 

zero altitude initiation point is automatically established by the UASs at ground 

level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 
24

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).

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 

UAS Aircraft; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, MICHAEL E. OLSEN will 

ensure that it will safely operate the battery powered DJI UAS Aircraft during 

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

duration of 15 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 UAS Aircraft 

UASs; 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 UAS Aircraft

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

experiences low battery voltage, the first warning occurring at approximately 33% 

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

power. At the critically low battery level, the DJI Phantom Vision+ and DJI Phantom 

3 UASs 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).

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, MICHAEL E. OLSEN 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) 
25

& (b) will be met because MICHAEL E. OLSEN will use trained technicians to perform 

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

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

MICHAEL E. OLSEN Aerial Operations Manual, Monthly Maintenance Log, and DJI 

UAS Aircraft Instruction Manual).

Furthermore, MICHAEL E. OLSEN will document and maintain all maintenance 

records for the DJI UAS Aircraft UASs.

Since the DJI UAS Aircraft will be inspected as prescribed by the operating 

documents, MICHAEL E. OLSEN 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 

UAS Aircraft User Manuals are attached hereto as Appendix A and B; a copy of the 

DJI UAS Aircraft Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because MICHAEL E. 

OLSEN

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 UAS Aircraft will be performed by trained technicians. Maintenance will 

be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 

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

safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered.

In consideration of MICHAEL E. OLSEN proposed operating limitations, the 

operating documents, and the technical aspects of the DJI UAS Aircraft, MICHAEL E. 

OLSEN 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).

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, MICHAEL E. OLSEN
26

requests that the FAA prescribe special conditions for the intended operation of the 

DJI UAS Aircraft UASs, which contain such safety standards t hat 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 UAS Aircraft UASs, 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 Leading Edge’s intended operation of the DJI UAS 

Aircraft, 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 MICHAEL E. OLSEN Seeks Exemption:

MICHAEL E. OLSEN 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).
27

A Brief Description of the Nature of the Exemption MICHAEL E. OLSEN Seeks:

This exemption will permit MICHAEL E. OLSEN 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 MICHAEL E. 

OLSEN 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, MICHAEL E. OLSEN 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, MICHAEL E. OLSEN will operate DJI UAS aircraft 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, MICHAEL E. OLSEN 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 UAS Aircraft 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 MICHAEL E. OLSEN to safely, efficiently, and economically 

operate the DJI UAS Aircraft commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, MICHAEL E. OLSEN 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 UAS Aircraft commercially for the purpose of 
28

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

Dated: May 10, 2015

Attachments to this submission:

DJI Inspire 1 Manual

DJI Phantom 3 Manual

Very respectfully,

Michael E Olsen

14 Old Town Lane

Halest, NY 11743

516-317-6222

meolsen@yahoo.com

DJI Inspire 1 Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

DJI Phantom 3 Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manu

al_v1.0_e n.pdf
DJI Inspire 1 specifications

Aircraft Model

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (Gps Mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes

Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm
Gimbal Model

ZENMUSE X3

Output Power (With Camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°

Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

Iso Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed

8s - 1/8000s

Fov (Field Of View)

94°

Cmos
Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames a

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate Of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported Sd Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C

Remote Controller Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (Outdoor And Unobstru

2 km

Eirp

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply

Built-in battery

Charging
DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Charger Model

A14-100P1A

Voltage

26.3 V

Rated Power

100 W

Battery (Standard) Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type

LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range
-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Battery (Optional) Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision Positioning Velocity Range

Below 8 m/s (2 m above ground)

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm
DJI Pilot App Mobile Device System Requirements

iOS 8.0 or later

Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPa

mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optim

* Samsung S5, Note 3, Sony Xperia Z3, Google Nexus 7 I

*Support for additional Android devices available as testin
1

Phantom 3 Professional

Phantom 3 Professional

Battery 6000 mAh LiPo 2S

Phantom 3 

Professional 

Weight

1280g (with battery & propellers)

Hover 

Accuracy 

(Ready to Fly)

Vertical: +/- 0.1 m (when Vision 

Positioning is active) or +/- 0.5 m

Horizontal:1.5m

Max Ascent / 

Descent Speed

Ascent: 5m/s

Descent: 3m/s

Max Flight 

Speed

16m/s((ATTI mode, no wind)

Diagonal 

Length

590mm

Controllable 

Range of 

Gimbal

Pitch -90°to +30°

The Phantom 3 Professional’s flight controller features several important upgrades, 

including a new flight mode. Safety modes include Failsafe and Return-to-Home. These 

features ensure the safe return of your aircraft if the control signal is lost. The flight 

controller can also save critical flight data from each flight to the on-board storage 

device. The new flight controller also provides increased stability and a new air braking 

feature.

GENERAL FEATURES

▪ Epic Aerial Video

▪ Live HD View

▪ Complete Control

▪ Powerful Mobile App
2

▪ Vision Positioning

▪ Easy to Fly

▪ Worry-free Autopilot

▪ Intelligent Battery

▪ Supports Adobe DNG RAW

▪ Unmatched Propulsion

▪ SDK Development

VISION POSITIONING

▪ Max Velocity: Less than 8 m/s (when 2 m above ground)

▪ Altitude Range: 30 cm-300 cm

▪ Operating Range: 30 cm-300 cm</td></tr>

▪ Transmitter Power:CE: 25mw; FCC: 100mw

▪ Operating Environment: Surface with clear pattern and adequate lighting (Lux > 15)

CAMERA

▪ Sensor: Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

▪ Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

▪ ISO Range:100-3200 (video) 100-1600 (photo)

▪ Max Bitrate Of Video Storage: 60 Mbps

▪ Operating Temperature: 0°C to 40°C

REMOTE CONTROLLER

▪ Operating Frequency: 2.400 GHz-2.483 GHz

▪ Max Distance: 2000m (outdoors and unobstructed)

▪ Receiver Sensitivity (1%PER): -101 dBm ±2 dBm

▪ Transmitter Power (EIRP): FCC: 20 dBm CE: 16 dBm

▪ Working Voltage: 1.2 A @7.4 V

DJI VISION APP

▪ EIRP: 100mW

▪ Live View Working Frequency: 2.4GHz ISM

▪ Live View Quality:720P @ 30fps (depending on conditions and mobile device)

▪ Required Operating Systems:iOS 8.0 or later, Android 4.1.2 or later

▪ Recommended Devices: iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air 

Wi-Fi + Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 

Wi-Fi + Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is 

optimized for iPhone 5s, iPhone 6, and iPhone 6 Plus Android: Samsung S5, 

Note 3, Sony Xperia Z3, Google Nexus 7 II, Google Nexus 9, Mi 3, Nubia Z7 mini
Pack List

- Phantom 3 Pro

- Battery #1 (Charged)

- Controller (Charged)

- iPad Mini 2 (Charged)

- Props (2 sets)

- Micro SD Cards

- USB Cable

- Reading Glasses

- Sun Shade for iPad

- Lanyard

- DJI Charger

- Phone for HotSpot

Pre-Flight

- Connect USB to iPad

- Download Area Maps

- Connect Lanyard

- Remove Lens Cover

- Remove Gimbal Bracket

- Insert Micro SD Card

- Install Battery in P3P

- Install Props

- Turn On Radio

- Turn On iPad and Launch 

DJI Pilot app Max Volume

- Turn Off WIFI

- Place P3P at Take-Off 

Location (Home Point)

- Turn On P3P

- Adjust Camera Settings

- Format Micro SD Card

- Check Values:

- Compass Status

- IMU Values

- Gain Values and EXP

- Max Height

- RTH Height

- R/C EXP & Gain

- VPS On (Indoor Flight)

- Satellite Count

Hover Check

- Check Camera View and 

Level

- Check for Vibrations

- Check Distance to Home 

Point

Post Flight

- Turn Off P3P (First)

- Turn Off Radio

- Turn Off iPad

- Remove Props

- Install Gimbal Lock

- Install Lens Cover