UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Name and Address Of The Petitioner:

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

AIRWOLFE, LLC

211 Big Tree Road, 

South Daytona, Fla. 32119

CELL: 540-220-8885

Email: billcroom32@gmail

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on March 6, 2016

William P. Croom

AIRWOLFE, LLC

211 Big Tree Road, South Daytona, Fla. 32119

CELL: 540-220-8885

Email: billcroom32@gmail

Private Pilot Certificate with Glider Rating

Certificate No. 231703257

SUMMARY

AIRWOLFE, LLC seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2),and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 

333 ofthe FAA Modernization and Reform Act of 2012 (FMRA). This exemption will 

permit AIRWOLFE, LLC to operate an Unmanned Aircraft commercial purpose of 

conducting aerial video and photography of construction sites, real

estate, special events, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

AIRWOLFE, LLC provides its clients with expertise and knowledge in

drone advanced technologies and solutions to provide photo, videography and 

monitoring services. AIRWOLFE, LLC also provides its clients with the highest quality 

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

As a holder of a Private Pilot License since 1979, the principal, William P. Croom has

over 20 years of recreational/hobby experience in all aspects of aerial video and 

photography.
The objective of AIRWOLFE, LLC aerial video and photography operations is to provide 

high quality imaging for a variety of commercial,

public, and residential uses, including:

Aerial inspections of public and private structures.

Aerial photography/videography of residential and commercial buildings

Aerial event photography/videography

Aerial Appraisals

Real Estate Marketing

Insurance Inspections of Home and Property

Commercial Advertising Video and Photography

Real Estate Photography and Videography

No cost services offered to community, firefighter and state officials

Aerial surveying

Construction site inspections and monitoring

Wildlife and forestry monitoring system (UAS) 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 UAS and DJI Inspire 1

AIRWOLFE, LLC seeks an exemption to operate DJI systems for compensation or

hire within the NAS. The DJI Phantom 3 and the DJI Inspire 1 are 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 has a maximum gross 

weight of 1260 grams and a maximum speed of approximately 16 m/s. The DJI Inspire 

1has a maximum gross weight of 2935 grams and a maximum speed of approximately 

22 m/s.

The DJI Phantom 3 and DJI Inspire 1 UA’s are equipped with four main rotors; Driven 

by Lithium Polymer battery powered electric motors.

BASIS FOR PETITION

Petitioner, AIRWOLFE, 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 and the DJI 

Inspire 1 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).

A. Name and Address Of The Petitioner.

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

William P. Croom

AIRWOLFE, LLC

211 Big Tree Road

South Daytona, Florida 32119

Tel: (540) 220-8885
B. The Extent Of Relief AIRWOLFE, LLC Seeks And The Reason AIRWOLFE, LLC

Seeks The Relief.

1. Extent Of Relief AIRWOLFE, LLC Seeks And The Reason AIRWOLFE, LLC

Seeks Relief From Section 61.113(a) And (b). Relief from Section 61.113(a) and (b) 

entitled Private pilot privileges and limitations: Pilot in command, is requested to the 

extent necessary to allow a PIC holding a private pilot or higher level certificate, as well 

as a current and valid airman medical certificate, and who has met certain flight-hour 

and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b)

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that

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

compensation or hire.

As set forth more fully below, AIRWOLFE, LLC submits that an equivalent

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

Phantom 3 UAS unless that PIC has met certain flight-hour and currency requirements,

demonstrating that the PIC is able to safely operate either the DJI Phantom 3 and DJI 

Inspire 1 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.

2. Extent Of Relief AIRWOLFE, LLC Seeks And The Reason AIRWOLFE, 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 Max Aerial Imagery, LLC to determine that the DJI Phantom 3 

DJI Inspire 1 UAS are in airworthy condition prior to every flight by ensuring that the 

UAS is in compliance with the operating documents provided online by DJI, the 

manufacturer, at

http://www.dji.com/product/phantom-3/download and5

http://www.dji.com/product/inspire-1/download

AIRWOLFE, LLC seeks the requested relief because the DJI Phantom 3 and

DJI Inspire 1 UAS do not require an airworthiness certificate in accordance with 14 

C.F.R.Part 21, Subpart H. Therefore, Max Aerial Imagery, LLC will ensure that the DJI 

Phantom 3 and DJI Inspire 1 UAS are in airworthy condition based upon its compliance 

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

Inspire 1 (Instruction Manual) prior to every flight, and further, determine that the aircraft 

are in condition for safe flight, as stated in the conditions and limitations below.
3. Extent Of Relief AIRWOLFE, LLC Seeks And The Reason AIRWOLFE, 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 and DJI Inspire 1 UAS, which utilize a GPS 

altitude reading, 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), AIRWOLFE, 

LLC seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 UAS 

altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude,before each flight. Considering the limited altitude of the 

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

comply with the applicable conditions and limitations stated below.

4. Extent Of Relief AIRWOLFE, LLC Seeks And The Reason AIRWOLFE, LLC

Seeks Relief From Section 91.151(b).

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

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

Phantom 3 and DJI Inspire 1 UA during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for a total duration of 14 minutes to the first point

of intended landing and, assuming normal cruising speed, to fly after that for at least 4

minutes. Max Aerial Imagery, 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 and DJI Inspire 1 UAs will severely constrain the practicality of any aerial

video or still photo flight operations that Max Aerial Imagery, LLC proposes to conduct

pursuant to this Petition.

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

and DJI Inspire 1 UAS operating documents, and Max Aerial Imagery, LLC proposed

operating limitations, ensure that Max Aerial Imagery, LLC will safely operate the battery

powered DJI Phantom 3 and DJI Inspire 1 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 14 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4 minutes.
5. Extent Of Relief AIRWOLFE, LLC Seeks And The Reason AIRWOLFE, 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, AIRWOLFE, LLC

requests relief from these Sections because the DJI Phantom 3 and DJI Inspire 1 UAS 

do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 

3 and DJI Inspire 1 UAS meet the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, AIRWOLFE, LLC will use trained

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

using the methods, techniques, and practices prescribed in the UAS operating 

documents

Online at http://www.dji.com/product/phantom-3/download and

http://www.dji.com/product/inspire-1/download

AIRWOLFE, LLC will document and maintain all maintenance records for

the DJI Phantom 3 and DJI Inspire 1.

D. The Reasons Why Granting AIRWOLFE, LLC Request Would Be In The

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

Granting the present Petition will further the public interest by allowing AIRWOLFE, 

LLC to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, special events, film sets, and landscape over

certain areas of the United States. Additionally, use of the DJI Phantom 3 and the DJI 

Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of AIRWOLFE, LLC proposed 

operation of the DJI Phantom 3 and the DJI Inspire 1 UAS will be realized without 

implicating any privacy issues.

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

The DJI Phantom 3 and the DJI Inspire 1 UAs 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 and the DJI 

Inspire 1 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 and the DJI Inspire 1 UA do not require an airport to takeoff or land.
2. The Public Will Benefit From The Safety And Efficiency Of The DJI

Phantom 3 and the DJI Inspire1 UAS.

Conducting aerial acquisitions with the DJI Phantom 3 and the DJI Inspire 1 UASs,

instead of manned aircraft, will greatly benefit the public by drastically reducing the 

levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the DJI 

Phantom 3 and the DJI Inspire 1 UAS 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. 

The DJI Phantom 3 and the DJI Inspire 1 UA, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UA are propelled by battery 

powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 and the DJI Inspire 1 UAS to perform aerial

acquisitions, the substantial risk to life and property in the air and on the ground, which 

is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced.

3. Performing Aerial Video and Photography Operations with DJI Phantom 3

and the DJI Inspire 1 UAS Will Benefit The Economy.

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

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

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

like

AIRWOLFE, LLC, to remain competitive and contribute to growth of the U.S.

economy. Specifically, with the rising cost of aviation fuel and the Environmental

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S.

owned and operated companies must adopt new and alternative technology in order to

remain competitive. Operating the battery powered DJI Phantom 3 UAS is one such

technology that not only allows companies greater operational flexibility compared to

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

traditional manned aircraft.

By operating the DJI Phantom 3 and the DJI Inspire 1 UAS, AIRWOLFE, LLC, can 

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

employees and contractors, which will ultimately contribute to growth of the U.S.

economy. Improved financial performance of U.S. companies, through commercial use 

of the DJI Phantom 3 and the DJI Inspire 1 UAS, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues.
4. There Are No Privacy Issues.

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

decades, AIRWOLFE, LLC proposed operation of the DJI Phantom 3 and the DJI

Inspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 and

the DJI Inspire 1 UAS will be operated only in compliance with operating documents

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.

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

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

Provided By The Rule From Which AIRWOLFE, LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 UA’s 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, AIRWOLFE, LLC operation of the

DJI Phantom 3 and the DJI Inspire 1 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.

a. The Specifications Of The The DJI Phantom 3 and DJI Inspire 1 UA’s

UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 3 and DJI Inspire 1 UAS 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.

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1

UAS.

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

Phantom 3 Specifications and Data Sheet, attached hereto as Exhibit A. The DJI Inspire 

1 UAS Specifications and Data Sheet, attached hereto as Exhibit C.

ii. The DJI Phantom 3 and DJI Inspire 1 UA’s Autonomous Flight And

Navigation Modes Enable The UAS To Remain Within A Defined

Operational Area.

The DJI Phantom 3 and the DJI Inspire 1 UAS may be operated in both manual and 

fully autonomous flight modes.
iii. The DJI Phantom 3 and DJI Inspire 1 UA’s 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 and the DJI Inspire 1 UA will

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

3 UA 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 Phantom 3 and the DJI Inspire 1 UAS is provided in 

the Manufacturer’s User Manual.

b. Flights Of The DJI Phantom 3 and DJI Inspire 1 UA’s Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, AIRWOLFE, LLC proposes to commercially operate DJI 

Phantom 3 and DJI Inspire 1 UAS for the special purpose of conducting aerial

video and photography over certain areas of United States, pursuant to the following

specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less

than 55 pounds maximum gross weight: DJI Phantom 3 and DJI Inspire 1

Unmanned Aircraft Systems. Proposed operations of any other aircraft will

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

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

for the purpose of aerial video and photography.

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

4. The UAs 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.

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

UAS operations and made available to the Administrator upon request. If a discrepancy 

exists between the conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions and limitations 

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

the operator must follow the procedures as outlined in its operating documents. The 

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

to track such revisions and present updated and revised documents to the Administrator 

upon request. The operator must also present updated and revised documents if it 

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

determines that any update or revision would affect the basis upon which the FAA 

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

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

arise regarding updates or revisions to the operating documents.

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

for safe flight. If the inspection reveals a condition that affects the safe operation of the 

UAS, the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the 13 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 at least a private pilot certificate and at least a current

third- class medical certificate.

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

operator’s qualification criteria and demonstrates the ability to safely operate

the UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

appropriate distances from persons, vessels, vehicles and structures. PIC

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

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

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training,

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

operations are considered nonparticipants, and the PIC must operate the UA

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.

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

1.1. All operations must be conducted under visual meteorological conditions

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

closest to proposed area of operations. Flights under special visual flightrules (SVFR) 

are not authorized.

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

denoted on a current FAA-published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to

the Administrator upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet

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

PIC.
22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined

location within the planned operating area and land or be recovered

in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

forecast weather conditions) there is enough power to fly at normal cruising

speed to the intended landing point and land the UA with 25% battery power

remaining.

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

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

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

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to the operation. All operations shall be conducted in accordance

with airspace requirements in the ATO issued COA including class of airspace,

altitude level and potential transponder requirements.

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

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N- Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.

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

and control of the UA must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

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

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

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

Administrator or any law enforcement official upon request.

29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.
31. Flight operations must be conducted at least 500 feet from all nonparticipating

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

vessels, vehicles, and structures unless: a. Barriers or structures are present that 

sufficiently protect nonparticipating persons from the UA and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease immediately 

and/or; b. The aircraft is operated near vessels, vehicles or structures where the

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

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

determined that it does not present an undue hazard, and; c. Operations nearer to the 

PIC, SO, operator trainees or essential persons do not present an undue hazard to 

those persons per § 91.119(a).

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

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

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted

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

vertical boundaries of the operational area as defined by the applicable COA

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

hours. Accidents must be reported to the National Transportation Safety Board

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

Any Additional Information, Views, Or Arguments Available To Support 

AIRWOLFE, 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, Max Aerial Imagery, 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, AIRWOLFE, LLC will operate the DJI

Phantom 3 UAS safely in the NAS, without creating a hazard to users of the NAS, or the

public, or otherwise pose a threat to national security.
CONCLUSION

As set forth herein, AIRWOLFE, 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 and DJI Inspire UAS

commercially, without an airworthiness certificate, for the limited purpose of conducting

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

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

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

by allowing AIRWOLFE, LLC to safely, efficiently, and economically operate the

DJI Phantom 3 UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Max Aerial Imagery, LLC

respectfully requests that the Administrator grant this Petition for an exemption from the

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

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

AIRWOLFE, LLC to operate the DJI Phantom 3 and DJI Inspire 1 UAS commercially for 

the purpose of conducting aerial video and photography over certain areas of the United 

States.

Dated: March 6, 2016

Respectfully submitted,

William P. Croom

AIRWOLFE, LLC

211 Big Tree Road

South Daytona, Florida 32119

Tel: (540) 220-8885