... FROM: 

Rodney Nordstrom 

201 W. McClure 

Peoria, IL 61604 

Tel: 309-685-2326 

Email: jurydoctor@sbcglobal.net 

TO: 

DOCKET OPERATIONS 

ROOM W12-140 OF THE WESTBUILDING 

GROUND FLOOR 

' 1200NEW JERSEY AVENUE, SE. 

WASHINGTON, DC, 20590 

Regulatory Docket No. _____ _ 

PETITION FOR EXEMPTION OF: 

Rodney Nordstrom 

•.• r • 

...,,... 0- I , ... I 0 ~ "/ 

j J l .I i -

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

PART21, SUBPART HAND SECTIONS§§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 3 Advanced UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO :SECTION 333 OF I 

THE FAA MODERNIZATION AND REFORM ACT OF2012 

(PUBLIC L}\ W 1 i 2-95) 

Submitted on November 3,2015 

Rodney Nordstrom for Peoria Area Drone Videography Page 1 
.., 

TABLE OFCONTENTS 

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

S~Y ~·················5··~·······················,.······························~································-································~···· 4 

IN1RODUCTION AND INTERESTS OFPETITIONER ......................................................... 4 

BACKGROUND .................... : .................................................................................................... 4 

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

NAME AND ADDRESS OFPETITIONER .............................................................................. 7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Rodney Nordstrom SEEKS 

EXEMPTION ............................................................................................................................. 8 

THE EXTENT OF RELIEF Rodney Nordstrom SEEKS AND THE 

REASON Rodney Nordstrom SEEKS THE RELIEF.;~ .... ~ ............. ................................... 11 

THE REASONS WHY GRANTING Rodney Nordstrom REQUEST 

WOULD BE IN THE PUBLIC INTEREST ........ · ...... · ............................................................ 1 S 

THE REASONS wHY GRANTING THE EXEMPTION WOULD NOT 

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ........................ 33 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

CONCLUSION .......................................................................................................................... 33 

Rodney Nordstrom for Peoria Area Drone Videography Page2 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal A viationRegulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) Section333 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules ·· 

Visual Line 1of Site 

Visual Mete,orological Conditions 

Vertical Takeoff and Landing 

Rodney Nordstrom for Peoria Area Drone Videography Page3 
SUMMARY 

Rodney Nordstrom (Peoria Area Drone Videography) seeks exemption from the requirements 

of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

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

Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will 

permit Rodney Nordstrom to operate an Unmanned Aircraft System (UAS) for the commercial 

purposeof conducting aerial video and photography of Real Estate Properties (for homeowners, 

realtors, horny builders, home contractors and I or home inspectors for real estate marketing and 

inspection of home exteriors), inspection of farm land, railroad and emergency concerns, as well 

as filming of special events, fil~ sets over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Rodney Nordstrom owner of Peoria Area Drone Videography which is a production company 

based in Illinois specializing in real estate videography, photography, video production, and 

special event production. The principals of Rodney Nordstrom (Peoria Area Drone 

Videography) have been in the video and entertainment production business 5 years. Rodney 

Nordstrom's objective is to conduct aerial photography and videography in order to provide 

high quality digital imaging and video content to its clients, in particular to homeowners, real 

estate agepts, realtors, home builders, home contractors, and/or home inspectors for real estate 

marketing and inspections of home exteriors as well as filming of special events, film sets, 

landscape, aerial mapping, surveying utilizingDll Phantom 3 UAS. More specifically, Rodney 

Nordstrom aerial video and photography operations will serve in the following areas: 

• Aerial photography of houses I residential and commercial buildings and power lines 

• Aerial videography of houses I residential and commercial buildings and power lines 

• Aerial event photography 

• Aerial event filming 

• Aerial videography of rail road tracks and bridges 

• Aerial videography of farms and farmland 

• Increase public knowledge of UAS and 

promote safe UAS operations 

Rodney Nordstrom for Peoria Area Drone Videography Page4 
The proposed aerial filming will be conducted over private property with controlled access in 

the NAS and with the knowledge and permit of the private property's owner. 

Unmanned Aircraft Systems; DJI Phantom 3 Advanced UAS 

Rodney Nordstrom seeks an exemption to operate DJI systems DRONES for compensation 

or hire within the NAS. The DJI Phantom 3 Advanced is a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or 

smart phone systems. The DJI Phantom 3 Advanced UAS has a maximum gross weight of 

approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height 

of 8 inches, and a maximum speed of approximately 29 knots. DJI Phantom 3 Advanced UAS is 

equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3 Advanced UAS that will be operated by a licensed pilot, 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 RegistrationMarking. 

BASIS. FOR PETITION 

Petitioner, Rodney Nordstrom, 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 conunercially operate the DJI Phantom 3 Advanced UAS 

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

§§ 61.113(a) & (b), 91.109, 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, Rodney Nordstrom's operation of DJI Phantom 3 Advanced UAS meets 

the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Rodriey Nordstrom requests in 

relieffrom Sections 91.405(a),91.407(a)(l), 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. 

Rodney Nordstrom for Peoria Area Drone Videography PageS 
Rodney Nordstrom submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Rodney Nordstrom will use only experienced personnel or 

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

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

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

Furthermore, Rodney Nordstrom will document and maintain all maintenance records for 

the DJI Phantom 3 Advanced UAS. 

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

and limitations: Pilot In Command, is requested by Rodney Nordstrom to the extent 

necessary to allow a Pilot in Command (PIC) holding a Supplemental Pilot Certificate, 

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

PIC is able to safely operate the DJI Phantom 3 Advanced UAS ina manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Rodney Nordstrom seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Advanced UAS does not require an 

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

Rodney Nordstrom submits that he will ensure that the DJI Phantom3 Advanced UAS is 

in an airworthy condition, prior to every flight, by determining,thatthe UAS's is in 

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

Phantom 3 Advanced Instruction Manual), and thatthe aircraft is in a condition for safe 

flight. Rodney Nordstrom also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Ad:vanced UAS will not have a 

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

3 Advanced UAS will be provided to the PIC via Global Positioning System (GPS) 

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

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

combined with Rodney Nordstrom's operation of the DJJ Phantom 3 Advanced UAS 

within visual line of sight, at or below 200 feet AGL, will ensurea level of safety 

equivalent to Section 91.121. 

Rodney Nordstrom for Peoria Area Drone Videography Page6 
Additionally; Rodney Nordstrom seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Rodney Nordstrom submi1s 

that safety will not be affected by operation of the DJIPhantom 3 Advanced UAS during daylight 

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

battery power to fly for a total duration of approximately 13.5 minutes to the first point of 

inten,ded landing and, assuming normal cruising speed, to fly 

after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Rodney Nordstrom provides the 

following information in support of his petition for exemption: 

A. Name And Address Of The Petitioner. 

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

Rodney Nordstrom· 

661 S. Ridgeview Ln. 

Peoria, IL 61604 

Tel: ~09-369-7067 

Email: iurydoctor@sbcglobal.net 

B. The Specific Sections Of 14 C.F.R. From Which Rodney Nordstrom 

Seeks Exemption. 

1. Rodney Nordstrom Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). Section 61.113, entitled Private pilot 

privileges and limitations: Pilot in corninand, subsections (a) and (b) 

prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a: pilot in command 

(PIC) of an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as PIC of an aircraft. 

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

connection with any business or employment if.-

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

(2) The aircraft does not carry passengers or property for compensation or 

hire. 

Rodney Nordstrom for Peoria Area Drone Videography Page7 
.. 

2. Rodney Nordstrom Seeks Exemption From The Requirements Of Section 91. 7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a}, states the followh1g: 

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

3. Rodney Nordstrom Seeks Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a}, states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight 

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

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 1 00 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1 )(i)of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure. 

4. Rodney Nordstrom Seeks Exemption From The Requirements OfSection 

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 conditionsunless 

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

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

fly after that for at least 20 minutes. 

5. Rodney Nordstrom Seeks Exemption From The Requirement Of 

Section 91.405(a). 

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

Each owner or operator of an aircraftRodney Nordstrom for Peoria Area Drone Videography Page 8 
.. (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

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

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

6. Rodney Nordstrom Seeks Exemption From The Requirements Of 

Section 91.407(a)(l) Section 91.407, entitled Operation after maintenance, 

preventive maintenance, rebuilding, or alteration, subsection (a)(l), states 

the following: 

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

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under§ 

43.7 of this chapter. 

7. Rodney Nordstrom Seeks Exemption From The Requirements Of 

Sections 91.409(a)(l) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following: 

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

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

accordance with part 21 of this chapter. 

8. Rodney Nordstrom Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b). Section 91.417, entitled 

Maintenance records, subsections (a) and (b), statethe following: 

(a) Except for work performed in accordance with§§ 91.411 and 91.413,each 

registered owner or operator shall keep the following records for theperiods 

specified in paragraph (b) of this section: 

Rodney Nordstrom for Peoria Area Drone Videography Page9 
( 1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and 

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

include--

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

the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

each rotor. 

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

propeller, rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 

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. 

(iv) 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. 

(v) Copies of the forms prescribed by§ 43.9(d) of this chapter foreach 

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

propellers, and appliances. 

(vi) Copies ofthe forms prescribed by §43.9(d) ofthis chapter for 

each major alteration to the airframe and currently installed engines, 

rotors, propellers, and appliances. 

Rodney Nordstrom for Peoria Area Drone Videography Page 10 
(b) The owner or operator shall retain the following records for the periods 

prescribed: 

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

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

work is performed. 

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

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

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

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

approved for return to service. 

C. The Extent Of Relief Rodney Nordstrom Seeks And The Reason ·· 

Rodney Nordstrom Seeks The Relief. 

1. Extent OfReliefRodney Nordstrom Seeks And The Reason Rodney 

Nordstrom Seeks ReliefFrom Section 61.113(a) And(b). 

Relieffrom Section 61.113(a) and (b) entitled Private pilot privilegesand 

limitations: Pilot in command, is requested to the extent necessary to allow aPIC 

holding a Supplemental Pilot 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 isonly 

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, Rodney Nordstrom submits that an equivalent 

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

Phantom 3 Advanced UAS unless that PIC has met certain flight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate 

either the Phantom 3 Advanced UAS in a manner consistent with the operations 

specifications as described in this exemption, including evasive and emergency 

Rodney Nordstrom for Peoria Area Drone Videography Page 11 
maneuvers, as well as maintaining appropriate distances from people, vessels, 

vehicles and structures. Further) Rodney Nordstrom submits that all flights of the 

DJI Phantom 3 Advanced UAS, conducted by the PIC pursuant to the grant of 

this Petition: (1) will be incidental to Rodney Nordstrom's business; and (2) will 

not carry passengers or property for compensation or hire. 

Rodney Nordstrom believes that though U AS are not traditional aircrafts, a PIC 

operating the UA must have knowledge of Airman rules, basic Airspace and 

comply with all the rules proposed by the FAA. However, considering the fact 

that a UA is almost like a toy, weighing less than a skinny person, the PIC may 

be exempt from obtaining a Private Pilot Certificate, a Sports Certificate, a 

Recreational Certificate considering these certificates require flight hours of 

several thousand tons weighing aircrafts. The operation of UAS by Rodney 

Nordstrom is strictly for commercial/entertainment I informational purposes, 

thus the operators of the UAS have a career and I or freelance employment as a 

Camera Operator and Cinematographer and will be not be entertaining a career 

as a pilot. Lastly, the UAS will operate no higher than 200 feet, consequently 

causing no danger do any other aircraft in the NAS. 

2. Extent OfReliefRodney Nordstrom Seeks And The Reason Rodney 

Nordstrom 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 

Rodney Nordstrom to determine that the DJI Phantom 3 Advanced UAS is in 

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

compliance with the operating documents (i.e., the Aerial Drone Media 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Advanced 

Instruction Manual). Rodney Nordstrom seeks the requested relief because the 

DJI Phantom 3 Advanced UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Rodney Nordstrom 

will ensure that the DJI Phantom 3 Advanced UAS is in airworthy condition 

based upon its compliance with the operating documents (i.e., Monthly 

Rodney Nordstrom for Peoria Area Drone Videography Page 12 
Maintenance Log, andDJI Phantom 3 Advanced Instruction Manual) priorto 

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 Rodney Nordstrom Seeks And The Reason 

Rodney Nordstrom 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 AdvancedUAS, which utilize 

a barometric pressure sensor, GPS equipment, and aradio 

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), Rodney Nordstrom seeks the 

requested relief because the Phantom 3 Advanced UAS's altimeter 

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

barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief 

from 14 CFR 91.121 is sought to the extent necessary to comply with 

the applicable conditions and limitations stated below. As more fully 

set forth herein, an equivalent level of safety will be maintained since 

the DJI Phantom 3 Advanced UAS are equipped with abarometric 

pressure sensor and GPS equipment, which automatically ensures 

that aground level pressure setting will be established prior to each 

flight, and provides the PIC with altitude information of the UA on 

the heads-up display of the GCS. 

4. Extent Of Relief Rodney Nordstrom Seeks And The Reason 

Rodney Nordstrom 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 Advanced UAS during daylight hours in visual 

Rodney Nordstrom for Peoria Area Drone Videography Page 13 
meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 13.5 minutes to the first point of intended landing and, assuming 

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

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

the flight time duration of the battery powered DJI Phantom 3 Advanced UAS 

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

operations that Rodney Nordstrom proposes to conduct pursuant to this Petition. 

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

Advanced UAS operating documents, and Rodney Nordstrom proposed operating 

limitations, ensure that safe operation of the battery powered DJI Phantom 3 

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

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

duration of 13.5 minutes to the first point of intended landing and, assuming 

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

5. Extent OfReliefRodney Nordstrom Seeks And The Reason Rodney 

Nordstrom Seeks ReliefFrom Section 91.405(a), 91.407(a)(l), 91.409(a)(1) & 

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

Since Sections 9L405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a)& 

(b) only apply to aircraft with an airworthiness certificate, Rodney Nordstrom 

requests relief from these Sections because the DJI Phantom 3 Advanced UAS 

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

Phantom 3 Advanced UAS meets the conditions ofFMRA Section 333 for 

operation without anairworthiness certificate. Accordingly, Rodney Nordstrom 

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

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

in the UAS operating documents (i.e., the Rodney Nordstrom Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Advanced Instruction 

Manual). 

Furthermore, Rodney Nordstrom will document and maintain all maintenance 

records for the DJI Phantom 3 Advanced UAS. 

Rodney Nordstrom for Peoria Area Drone Videography Page 14 
D. The Reasons Why Granting Rodney Nordstrom 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 Rodney 

Nordstrom to safely, efficiently) and economically perform aerial video and 

photographyof real estate, safety inspection, special events, film sets, and landscape 

over certain areas of the United States. 

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

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

the benefits of Rodney Nordstrom's proposed operation of the DJI 

Phantom 3 Advanced UAS will be realized without implicating any privacy issues. 

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

Phantom 3 Advanced UAS is battery powered and serves as a safe) efficient, and 

economical alternative to the mannedaircraft 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 Advanced U AS 

will 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 Advanced UAS does not require an airport to takeoff 

or land. Likewise, a reduction of manned aircraft conducting aerial video and 

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

traffic control during the ground, takeoJf, departure, arrival, and landing phases 

of flight operations. 

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

3 Advanced UAS Conducting aerial acquisitions with the DJI Phantom3 

Advanced UAS, instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery 

Rodney Nordstrom for Peoria Area Drone Videography Page 15 
power and electric motors, the DJI Phantom 3 Advan::ed.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, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The DJI Phantom 3 Advanced UAS, 

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 DJ1 Phantom 3 Advanced U AS 

to perform aerial acquisitions; the substantial risk to life and property in the air 

and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside 

from the lack of flight crew members located onboard the aircraft, the DJI 

Phantom 3 Advanced UAS (weighing approximately 2 pounds 11 with a length 

of 16 inches, widths of 16 inches, and with no fuel on board), has less physical 

potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, 

a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 3 Advanced UAS Will Benefit The Economy. In addition to 

being safe and efficient, the DJI Phantom3 Advanced UAS is also an 

economical alternative to using manned aircraft to conduct similar 

aerial operations. As such, operation of the DJI Phantom 3 Advanced 

UAS will allow United States based companies, like Peoria Area 

Drone Videography, 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 

Advanced UAS is one such technology that not only allows 

Rodney Nordstrom for Peoria Area Drone Videography Page 16 
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 AdvancedUAS, companies such as 

\ 

Peoria Area Drone Videography, 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 

Advanced UAS, provides a stable workforce that increases consumer spending; 

improves local, state, and federal tax revenues; and allows companies to invest in 

research and development in order to remain competitive both in the United States 

and abroad. 

4.There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, Rodney Nordstrom proposed operation of the DJI 

Phantom 3 Advanced UAS will not implicate any privacy issues. Specifically, the 

DJI Phantom 3 Advanced UAS will be operated only in compliance with 

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

Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual) which 

requires property owner involvement as well as local law enforcement 

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

theminimum 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 Rodney Nordstrom Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 Advanced UAS Meets The Conditions Of The 

FAA Modernization and Reform Act of2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, Rodney Nordstrom's operation of the DJI 

Phantom 3 Advanced UAS meets the conditions ofFMRA Section 333, and will not require 

Rodney Nordstrom for Peoria Area Drone Videography Page 17 
.. 

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

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

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

security. 

Specifically, FMRA Section 333 states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of ~ 

Transportation shall determine if certain unmanned aircraft systems may operate 

safely in the national airspace system before completion of the plan 

and rule-making required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making 

the determination under subsection (a), the Secretary shall 

determine, at aminimum--

(1) which types of unmanned aircraft systems, if any, 

as a result of their size, weight, speed, operational 

capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a 

hazard to users of the national airspace system or the 

public or pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of 

authorization, or airworthiness certification under 

section 44704 oftitle 49, United States Code, is required 

for the operation of unmanned aircraft systems identified 

under paragraph (1 ). 

(c) Requirements for Safe Operation.--Ifthe Secretary 

determines under this section that certain unmanned aircraft 

systems may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of 

Rodney Nordstrom for Peoria Area Drone Videography Page 18 
such aircraft systems in the national airspace system. 

In seeking this exemption, Rodney Nordstrom submits that the DJI Phantom 3 

Advanced UAS can operate safely in the NAS pursuantto FMRA Section 333, 

as demonstrated by: (a) the characteristics of the DJI Phantom 3 Advanced 

UAS; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 

The Specifications Of The DJI Phantom 3 Advanced UAS Demonstrate Its 

Safe Characteristics. 

The DJI Phantom 3 Advanced UAS does not create ahazard 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 Advanced UAS. 

The technical specifications of the DJI Phantom 3 Advanced UAS is set 

forth by the DJI Phantom 3 Advanced UAS Specifications and Data 

Sheet, attached hereto as Exhibit A. 

ii. The DJI Phantom 3 Advanced UAS Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area. The DJI Phantom 3 Advanced UAS may be operated in 

both manual and fully autonomous flight modes. 

m. The DJI Phantom 3 Advanced U AS 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 

Advance UAS will remains stationary, in flight, for3 seconds or more. If, 

after 3 seconds, the DJI Phantom 3 Advanced UA Sdoes not reacquire 

control link data from the GCS, the UAS will assume that the Control 

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

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

Rodney Nordstrom for Peoria Area Drone Videography Page 19 
complete description of the Failsafe Functions of the DJI Phantom 3 

Advanced UAS are set forth at pages 27 through 29 of the OJI Phantom 3 

Advanced User Manual, atta~hed hereto as B. 

Flight Operations Of DJI Phantom 3 Advanced UAS Are Limited To The 

Line Of Sight Of A Certificated Pilot in Command With A Safety Observer. 

· Rodney Nordstrom will only utilize certificated pilots who possess a current and 1 

valid UA V credential as a pilot in command (PIC) of the DJI Phantom 3 

Advanced UAS. Additionally, a safety observer will assist all pilots during flight 

.time. 

Flights Of DJI Phantom 3 Advanced UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

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

Advanced U AS 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 Advanced Unmanned Aircraft 

System. Proposed operations of any other aircraft will require a new petition or a petition 

to amend this grant. 

Rodney Nordstrom for Peoria Area Drone Videography Page20 
' 

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

purpose of aerial video and photography for homeowners, Realtors, home builders, 

contractors, home inspectors for use in real estate marketing and real estate inspections. 

Additionally, aerial video and photography may be conducted on occasional basis for 

special events and landscape photography, aerial mapping, surveying as deemed 

necessary. 

3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s). 

4. The UAS must be operated at an altitude of no more than 200 (500 per the User 

Manual) 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 ATCmust be in feetAGL. 

5. The UAS must be operated within visual line of sight (VLOS) ofthe 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 VLOScapability. 

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. 

Rodney Nordstrom for Peoria Area Drone Videography Page 21 
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 ina 

condition for safe flight. The Ground Control Station must be included in the preflight 

inspection. All maintenance and alterations must be properly documented in the aircraft 

records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who conducts the 

Rodney Nordstrom for Peoria Area Drone Videography Page 22 
functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UAS operated under this exemption must comply with all manufacturers 

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 5 hours training with an Drone pilot certified by 

Peoria Area Drone Videography before being allowed to be assigned any solo 

flights with a SO. 

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

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

Rodney Nordstrom for Peoria Area Drone Videography Page 23 
... 

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. 

§ 61.5l(b). Flights for the purposes of training the operator's PICsare 

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

only be conducted during dedicated training sessions. During training, 

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

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

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

91.119. 

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

1.1. All operations must be conducted under visual meteorological conditions (VMC). 

If flight at night is required, a special request will be made at the FAA office closest 

to proposed area of operations. Flights under special visual flight 

rules (SVFR) are not authorized. 

20. The 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 NOT AM as required by the operator'sCOA. 

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 berecovered 

Rodney Nordstrom for Peoria Area Drone Videography Page 24 
in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

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. 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. 

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. 

Rodney Nordstrom for Peoria Area Drone Videography Page 25 
29. The UAS must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

31. Flight operations must be conducted at least 500 feet from all nonparticipating 

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

vessels, vehicles, an'd 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 within500 

' 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 sQ.ch 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 must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB .Web site: 

www.ntsb.gov. 

Rodney Nordstrom for Peoria Area Drone Videography Page 26 
.. 

2. Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety. 

Rodney Nordstrom submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 

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

currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Advanced UAS 

in a manner consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering Rodney Nordstrom's proposed area of operations, and the operating limitations 

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

those of commercial pilot requirements (See Exemption No. 11 062); and the ainnanship skills 

necessary to safely operate the DJI Phantom 3 Advanced UAS, Rodney Nordstrom submits that 

the additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Rodney Nordstrom's specific proposed flight 

operations. 

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

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

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

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

3. Reasons Why An Exemption From The Requirements Of Section 

91.7(a) Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, Rodney Nordstrom will ensure that the DJI Phantom 3 

Advanced UAS is in an airworthy condition based upon the UAS's compliance with 

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

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

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

Rodney Nordstrom for Peoria Area Drone Videography Page 27 
ExemptionNos.ll062, 11063,11064,11065,11066,11067,11080,11109,111101 11112, 

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

4. Reasons Why An Exemption From The Requirements OfSection91.121 

Would Not Adversely Affect Safety. 

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

because the altitude information of the DJI Phantom 3 Advanced UAS will be provided to the 

PIC via GPS equipment and a radio communications telemetry data link, which downlinks from 

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

information, combined with Rodney Nordstrom's operation of the DJI Phantom 3 Advanced 

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

equivalent to Section 91.121. The altitude information will be generated by GPS equipment 

installed on board the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs at ground leveL 

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

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

11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 

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

5. Reasons Why An Exemption From The Requirements Of Section91.15l(b) 

Would Not Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.P.R. Section 91.151 (b) as a result of ( 1) the technical specifications of the DJI 

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

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

he will safely operate the battery powered DJI Phantom 3 Advanced UA during daylight 

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

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

after that for at least 4.5 minutes. 

Here, as in Exemption No. Ill 09, the technical specifications of the DJI Phantom 3 Advanced 

liAS; the Jjmitations on the proposed flight operations; and the location of the proposed 

Rodney Nordstrom for Peoria Area Drone Videography Page 2 8 
operations, will ensure an equivalent level of safety established by 14 

C.P.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Advanced 

UAS 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 3 UAS will descend and land automatically. Significantly, previous 

exemptions granted by the FAA concerning Section 91.151 

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

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

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

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

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

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

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

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements OfSections 91.405{a), 

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

Safety. 

In seeking this exemption, Rodney Nordstrom submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 9L405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will bernet 

because Rodney Nordstrom will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., the Rodney Nordstrom Aerial Operations 

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

Furthermore, Rodney Nordstrom will document and maintain all maintenance records for the 

DJI Phantom 3 Advanced UAS. 

Phantom 3 Advanced User Manual is attached hereto as .Exhibit B & D; a copy of the DJI 

Phantom 3 Advanced U AS Maintenance LOG is attached hereto as Exhibit C. 

Rodney Nordstrom for Peoria Area Drone Videography Page 29 
Since the DJI Phantom 3 Advanced UAS will be inspected as prescribed by the operating 

documents, Rodney Nordstrom will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy of the DJI 

Likewise, the exemption sought will not adversely affect safety because Rodney Nordstrom 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. Purthennore, 

the exemption sought would maintain an .equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Phantom 3 Advanced UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the PM concerning Sections 

91.405(a), 91.407(a)(l), 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 Rodney Nordstrom's proposed operating limitations, the 

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

Nordstrom submits that safety will not be adversely affected by granting exemption from 14 

C.P.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2),and 91.417(a) and (b). The 

PAAhas previously granted relief specific to UAS in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 

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

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

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

In accordance with Section 333 of the PAAModemization and Reform Act of2012 

(PMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, Rodney Nordstrom requests 

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

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

necessary to establish a level of safety equivalent to that established by 14 C.P.R. Part 21, 

Subpart H, and 14 C.P.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 

91.405(a), 91.407(a) (1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b). Such special conditions 

will permit safe 

Rodney Nordstrom for Peoria Area Drone Videography 
operation of the UAS for the limited purpose of condu'cting 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 witho~t airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in theNAS. 

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

§ 21.16, for operation of the DJI Phantom 3 Advanced UAS, since the airworthiness regulations 

of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or. 

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

following: 

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

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

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

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

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

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

FAA fi!lds 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, theFAA 

may prescribe special conditions for Rodney Nordstrom's intended operation of the DJI 

Phantom 3 UAS, which contain such safety standards that the Administrator finds necessary 

to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, 

and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) &(b). 

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

Rules Froni Which Rodney Nordstrom Seeks Exemption: 

Rodney Nordstrom seeks exemption from the requirements of 14 C.F.RSections 

61.113(a)&(b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

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

Rodney Nordstrom for Peoria Area Drone Videography Page ·31 
A Brief Description Of The Nature Of The Exemption Rodney Nordstrom Seeks: 

This exemption will permit Rodney Nordstrom to commercially operate an 

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

photography over certain areas of the UnitedStates. 

G. Any Additional Information, Views, Or Arguments Available To Support Rodney 

Nordstrom's Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of20 12 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Rodney Nordstrom request for exemption may be granted 

pursuant to the authority ofFMRA Section 333 and 14 C.P.R. Part ll,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, Rodney Nordstrom will operate the DJI Phantom 3 

Advanced 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, Rodney Nordstrom seeks an exemption pursuant t9 14 C.P.R. 

§ 11.61 and Section 333 ofthe FAA Modernization and ReformAct of2012 (FMRA), 

which will permit safe operation of the DJI Phantom 3 Advanced 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 of2012, while 

also advancing the interests of the public, by allowing Rodney Nordstrom owner of Peoria 

Area Drone Videography to safely, efficiently, and economically operate the DJI Phantom 3 

Advanced UAS commercially within the NAS. 

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

Rodney Nordstrom for Peoria Area Drone Videography Page 32 
.. 

Modernization and Reform Act of2012, Section 333, Rodney Nordstrom respectfully 

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

of14 C.F.R Sections 61.113(a) & (b), 91. 7(a), 91.121, 91.151 (b), 91.40S(a), 91.407(a)(l ), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Rodney Nordstrom to operate the DJI 

Phantom 3 Advanced UAS commercially for the purpose of conducting aerial video and 

photography of Real Estate Properties (for homeowners, realtors, home builders, home 

contractors and I or home inspectors for real estate marketing and inspectionofhome exteriors) 

as well as filming of special events, film sets, landscape as well as aerial mapping, surveying over 

certain areas of the United States. 

Dated: November 3, 2015 

Rodney Nordstrom P 

661 S. Ridgeview 

Peoria, IL 61602 

Tel: 309-369-7067 

Email: jurydoctor@sbcglobal.net 

Rodney Nordstrom for Peoria Area Drone Videography Page 33 
Appendixes: 

A- OJI Phantom 3 Advanced/Technical S'pecifications 

B - OJI Phantom 3 Advanced Manufacturer's User Manual 

C- OJI Phantom 3 Advanced Technical Specifications 

0 - Monthly Maintenance Log 

/ 

Rodney Nordstrom for Peoria Area Drone Videography 
APPENDIX-A 

DJI PHANTOM 3 ADVANCED/TECHNICAL 

SPECIFICATIONS 

Rodney Nordstrom only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with. ground breaking software enabling the user to set 

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

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

predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices) 

Rodney Nordstrom for Peoria Area Drone Videography 
APPENDIX-B 

DJI Phantom 3 Advanced Manufacturer's User Manual 

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

Manual can be downloaded from above link. Manual was not included to 

conserve space. 

Rodney Nordstrom for Peoria Area Drone Videography 
APPENDIX-C 

DJI PHANTOM 3 ADVANCED TECHNICAL 

SPECIFICATIONS 

AIRCRAFT 

Weight (Including Battery And Propellers) 1280 g 

Diagonal Size (lncludingPropeUers) 5.90 rnm 

Max Ascent Speed 5 m/s 

Max Descent Speed 3 m/s 

Hover Accuracy 

• Vertical:+/- lOcm 

• Horizt)ntal: +/- l1n 

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

Max Altitude Above Sea Level 6000m 

Operating Temperature 

GpsMode GPS/GLONASS 

GIMBAL 

Controllable Range Pitch -90° to+ 30° 

StabiJization 3-axis (pitch, roll, yaw) 

Rodney Nordstrom for Peoria Area Drone Videography 
REMOTE CONTROLLER 

Operating Frequency 2.400 GHz-2.483 GHz 

Max Distance 2000m (outdoors and unobstructed) 

Video Output Port USB 

Operating Temperature 

Battery 6000 mAh LiPo 2S 

Mobile Device Holder For tablet or phone 

Receiver Sensitivity(! %Per) -101 dBm ±2 dBm 

Transmitter Power (Eirp) 

• FCC: 20dBm 

• CE: 16 dBm 

Working Voltage 1.2 A @7.4V 

BATTERY CHARGER 

Voltage 17.4 v 

Rated Power Phantom 3 Advanced lOOW 

Rodney Nordstrom for Peoria Area Drone Videography 3ff 
INTELLIGENT FLIGHT BATTERY 

Capacity 4480 mAb 

Voltage 15.2 v 

Battery Type LiPo 48 

Energy 68Wh 

Net Weight 365g 

Max Flight Time Approximately 23minutes 

Operating Temperature 

Max Charging Power lOOW 

Rodney Nordstrom for Peoria Area Drone Videography 39 
. 

UAS 

~r~ 

Software Up,dates 

Airframe 

Engines 

Propellers 

Camera Gimbal 

Landing Gear 

Vibration 

Dampenin 

Other: 

APPENDIX-D 

MONTHLY MAINTENANCE LOG 

Pssue 9~er~tten &. . Ml§,'ktll~nan~@C!Ill.eotetJ: 

Rodney Nordstrom 

month: Yter: 

·M;;~te~ee .•• ~ 

Pei&ilm6G m': · 

J?rilllt & S:igm: 

Peoria Area Drone Videography 

661 S. Ridgeview 

Peoria, IL 61604 

Tel: 309-369-7067 

Email: j urydoctor@sbcglobal.net 

Rodney Nordstrom for Peoria Area Drone Videography 40