1 

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL 

AVIATION ADMINISTRATION WASHINGTON, D.C. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: RSA MARKETING 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

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

OPERATION OF DJI PHANTOM 3 PROFESSIONAL AND DJI INSPIRE 1 

UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 

112-95) 

Submitted on June 12,2015 

RSA Marketing 

400 S Commerce 

Wichita, KS 67202 

Tel: (316) 977-9600 

._, .. :• 
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TABLE OF CONTENTS 

Page 

GLOSSARY OF ABBREVIATIONS 3 

SUMMARY 4 

INTRODUCTION AND INTERESTS OF PETITIONER 4 

BACKGROUND 4 

BASIS FOR PETITION 5 

NAME AND ADDRESS OF PETITIONER 6 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH RSA MARKETING 7 

SEEKS EXEMPTION 

THE EXTENT OF RELIEF RSA MARKETING SEEKS AND THE REASON 10 

RSA MARKETING SEEKS THE RELIEF 

THE REASONS WHY GRANTING RSA MARKETINGS' REQUEST WOULD 13 

BE IN THE PUBLIC INTEREST 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 15 

ADVERSELY AFFECT SAFETY 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 26 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 26 

TO SUPPORT RSA MARKETING'S REQUEST 

CONCLUSION 28 

APPENDICES 29 
3 

GLOSSARY OF ABBREVIATIONS 

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 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofF ederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

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) 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 
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SUMMARY 

RSA Marketing 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)(l), 91.409(a)(1) & 

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

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

will permit RSA Marketing to operate a UAS for the commercial purpose of conducting 

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

INTRODUCTION AND INTERESTS OF THE PETITIONER 

RSA Marketing provides its clients with expertise and knowledge in 

advanced technologies and solutions to increase efficiency, productivity and effectiveness. 

RSA Marketing also provides its clients with the highest quality digital content for use in 

their commercial, personal, and non-profit multimedia projects. RSA Marketing has five 

years of professional experience in commercial videography and photography for 

promotions, commercials, long-form corporate and product videos, promotion of both 

private and community events, and is recognized as an expert in this field. RSA Marketing 

has more than two years of recreational/hobby experience in all aspects of aerial video and 

photography. The objective ofRSA Marketing's aerial video and photography operations is 

to provide high-quality imaging for clients ranging from health care to manufacturing, retail, 

law and industrial, specifically targeting: 

Increase direct employment related to commercial video production in Wichita, KS. RSA 

Marketing plans to add up to three (3) additional full-time staff over the next 12 months 

related to the operation of the UAS. 

· Achieve high-quality, locally accessible and cost-efficient marketing communications 

effective in the growth of local businesses and their local employment. 

Improve the ability of the local video production industry to compete nationally. 

Increase public knowledge ofUAS and promote safe UAS operations. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 ProfessionaL DJI Inspire 1 UASs 

RSA Marketing seeks an exemption to operate DJI systems for compensation or hire within 

the National Airspace System (NAS). The DJI Phantom 3 Professional and DJI Inspire 1 are 

vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 
5 

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 

Professional has a maximum gross weight of approximately 2 pounds 8 ounces, while 

having a diagonal length of 23 inches, height of 8 inches, and a maximum speed of 

approximately 31 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 

ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum 

speed of approximately 42 knots. The DJI Phantom 3 Professional and DJI Inspire 1 UAs 

are equipped with four main Lithium Polymer battery powered electric motors. The DJI 

Phantom 3 Professional and DJI Inspire 1 UAs that will be operated by RSA Marketing will 

be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, RSA Marketing, pursuant to the provisions ofthe Federal Aviation Regulations 

(FAR) (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), 

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

Administrator to commercially operate the DJI Phantom 3 Professional Vision+, DJI Inspire 

1 UASs 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)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, 

weight, size, and limited operating area associated with the unmanned aircraft and its 

operation, RSA Marketing's operation ofDJI Phantom 3 Professional and DJI Inspire 1 

UASs 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, 

RSA Marketing requests relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), 

and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply 

to aircraft with an airworthiness certificate. RSA Marketing submits that the requested relief 

is proper since an equivalent level of safety will be ensured. RSA Marketing will use 

experienced personnel or technicians to perform maintenance, alterations, or preventive 

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

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

DJI Inspire 1 Instruction Manual). Furthermore, RSA Marketing will document and maintain 

all maintenance records for the DJI Phantom 3 Professional and DJI Inspire 1 UASs. 

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

privileges and limitations: Pilot in command, is requested by RSA Marketing to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

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

DJI Phantom 3 Professional and DJI Inspire 1 UASs in a manner consistent with this 

exemption, including evasive and emergency maneuvers, as well as maintaining appropriate 

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

because the DJI Phantom 3 Professional and DJI Inspire 1 UASs do not require an 

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

Marketing submits that it will ensure that the DJI Phantom 3 Professional and DJI Inspire 1 

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

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

Phantom 3 Professional and DJI Inspire 1 Instruction Manual), and that the aircraft are in a 

condition for safe flight. 

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

Altimeter Settings, as the DJI Phantom 3 Professional and DJI Inspire 1 UAs will not have a 

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

Professional and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning 

System (GPS) equipment and radio communications telemetry data link, which downlinks 

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

combined with RSA Marketing's operation of the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs within Visual Line of Sight (VLOS), at or below 500 feet Above Ground 

Level (AGL), will ensure a level of safety equivalent to Section 91.121. 

Additionally, RSA Marketing seeks an exemption from the requirements of Section 

91.151(b ), entitled Fuel requirements for flight in T-'FR conditions. RSA Marketing submits 

that safety will not be affected by operation of the DJI Phantom 3 Professional and DJI 

_Inspire 1 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 intended landing and, assuming normal 

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

In accordance with 14 C.F.R. § 11.81, RSA Marketing provides the following information 

in support of its petition for exemption: 

A. Name And Address Of The Petitioner. 

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

Bruce Rowley 

RSA Marketing 

400 S. Commerce 

Wichita, KS 67202 

Tel: (316) 977-9600 

Email: browley@rsaconnect. com 

B. The Specific Sections Of 14 C.F.R. from Which RSA Marketing Seeks Exemption. 

1. RSA Marketing Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 
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Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

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

an aircraft that is carrying passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as PIC of an aircraft. 

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

with any business or employment if: 

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

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

2. RSA Marketing Seeks Exemption From The Requirements Of Section 91.7(a). 

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

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

3. RSA Marketing Seeks Exemption From The Requirements Of Section 91.121. 

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

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

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

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

(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

( ii) Ifthere is no station within the area prescribed in paragraph (a)( 1 )( i) ofthis 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. RSA Marketing Seeks Exemption From The Requirements Of Section 91.15l(b). 

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

states the following: 
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(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering 

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 20 

minutes. 

5. RSA Marketing Seeks Exemption From The Requirement Of Section 91.405(a). 

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

owner or operator of an aircraft: 

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

required inspections, except as provided in paragraph (c) of this section, have discrepancies 

repaired as prescribed in part 43 of this chapter[.] 

6. RSA Marketing 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)( 1 ), states the following: 

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

maintenance, rebuilding, or alteration unless: 

(1) It has been approved for return to service by a person authorized under §4 3. 7 of this 

chapter[.] 

7. RSA Marketing 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 ofthis chapter and has been approved 

for return to service by a person authorized by§ 43.7 ofthis chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 

ofthis chapter. 

8. RSA Marketing Seeks Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 
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Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

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

owner or operator shall keep the following records for the periods specified in paragraph (b) 

of this section: 

( 1) Records of the maintenance, preventive maintenance, and alteration and records of the 

100-hour, annual, progressive, and other required or approved inspections, as appropriate, 

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of 

an aircraft. The records must include: 

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

performed; and 

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

(iii) The signature, and certificate number of the person approving the aircraft for return to 

service. 

(2) Records containing the following information: 

(i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. 

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

appliance. 

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

be overhauled on a specified time basis. 

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

required by the inspection program under which the aircraft and its appliances are 

maintained. 

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

including, for each, the method of compliance, the AD or safety directive number and 

revision date. If the AD or safety directive involves recurring action, the time and date when 

the next action is required. 

(vi) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter for each major alteration to 

the airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 
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( 1) The records specified in paragraph (a)( 1) of this section shall be retained until the work 

is repeated or superseded by other work or for one 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 ofthis chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to 

service. 

C. The Extent Of Relief RSA Marketing Seeks And The Reason RSA Marketing Seeks 

The Relief. 

1. Extent Of Relief RSA Marketing Seeks And The Reason RSA Marketing 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 Pilot In Command (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, RSA Marketing submits that an equivalent level of safety will 

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

UAS or DJI Inspire 1 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 

Professional or 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. 

Further, RSA Marketing submits that all flights ofthe DJI Phantom 3 Professional and DJI 

Inspire 1 UASs, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be 

incidental to RSA Marketing's business; and (2) will not carry passengers or property for 

compensation or hire. 
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2. Extent Of Relief RSA Marketing Seeks And The Reason RSA Marketing 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 RSA Marketing to determine that the DJI Phantom 3 Professional and DJI 

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

in compliance with the operating documents (i.e., the RSA Marketing Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 

Instruction Manual). 

RSA Marketing seeks the requested relief because the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. Therefore, RSA Marketing will ensure that the DJI Phantom 3 Professional 

and DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the 

operating documents (i.e. Monthly Maintenance Log, and DJI Phantom 3 Professional 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 RSA Marketing Seeks And The Reason RSA Marketing Seeks 

Relief From Section 91.121. 

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

operations ofthe DJI Phantom 3 Professional and DJI Inspire 1 UASs, which utilize a 

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

to downlink altitude information from the Unmanned Aircraft (UA) to the Pilot In 

Command (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), RSA Marketing seeks the requested relief because the DJI 

Phantom 3 Professional and DJI Inspire 1 UA's altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

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

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

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

maintained since the DJI Phantom 3 Professional and DJI Inspire 1 UAs are equipped with a 

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

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

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

4. Extent Of Relief RSA Marketing Seeks And The Reason RSA Marketing 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 
12 

Professional and DJI Inspire 1 UAs during daylight hours in visual meteorological 

conditions (VMC), under Visual Flight Rules, 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. RSA Marketing seeks the requested relief because without an exemption from 

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

Professional and DJI Inspire 1 UAs will severely constrain the practicality of any aerial 

video or still photo flight operations that RSA Marketing proposes to conduct pursuant to 

this Petition. 

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

Professional and DJI Inspire 1 UASs, the DJI Phantom 3 Professional and DJI Inspire 1 

operating documents, and RSA Marketing's proposed operating limitations, ensure that 

RSA Marketing will safely operate the battery powered DJI Phantom 3 Professional and DJI 

Inspire 1 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 Of Relief RSA Marketing Seeks And The Reason RSA Marketing Seeks 

Relief From Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & 

(b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, RSA Marketing requests relief from these 

Sections because the DJI Phantom 3 Professional and DJI Inspire 1 UASs do not require 

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

and DJI Inspire 1 UASs meet the conditions ofFMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, RSA Marketing will use trained technicians to 

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

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

RSA Marketing Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

Professional and DJI Inspire 1 Instruction Manual). Furthermore, RSA Marketing will 

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

Inspire 1 UASs. 

D. The Reasons Why Granting RSA Marketing's 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 RSA Marketing to 

safely, efficiently, and economically perform aerial video and photography for value 

creation in a wide range of businesses that are critical to the health ofthe local economy. 
13 

Additionally, use of the DIT Phantom 3 Professional and DJI Inspire 1 UASs will decrease 

congestion ofthe NAS and reduce pollution. Notably, the benefits ofRSA Marketing's 

proposed operation ofthe DJI Phantom 3 Professional and DJI Inspire 1 UASs will be 

realized without implicating any privacy issues. 

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

The DJI Phantom 3 Professional and 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 Professional or 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 Professional and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, 

a reduction of manned aircraft conducting aerial video and photography missions would 

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

departure, arrival, and landing phases of flight operations. 

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

Professional and DJI Inspire 1 UASs. 

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

Professional and DJI Inspire 1 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 DJI Phantom 3 Professional and DJI Inspire 1 UASs 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 Professional and DJI Inspire 1 UAs (weighing 

approximately 2 pounds 13 ounces and 6 pounds 7.5 ounces respectively, at their maximum 

gross weights, with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches 

and 17.7 inches respectively, and with no fuel on board), has less physical potential for 
14 

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 \Vith The DJI Phantom 3 

Professional and DJI Inspire 1 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 Professional and DJI Inspire 1 

UASs are also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs 

will allow United States based companies, like RSA Marketing, 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 

Professional and DJI Inspire 1 UASs 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 Professional and DJI Inspire 1 UASs, companies such as 

RSA Marketing, 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 Professional and DJI Inspire 1 UASs, 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, RSA Marketing's proposed operation of the DJI Phantom 3 Professional and DJI 

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

Professional and DJI Inspire 1 UASs will be operated only in compliance with operating 

documents (i.e. the RSA Marketing Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual) which requires 

property owner involvement, as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations (FAR), 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 RSA Marketing Seeks Exemption. 
15 

1. Reasons Why The DJI Phantom 3 Professional and DJI Inspire 1 UAs Meet 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, RSA Marketing's operation of the DJI Phantom 3 

Professional and DJI Inspire 1 UASs meet the conditions ofFMRA Section 333, and will 

not require 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 U AS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA 

Section 333 states the following, in part: 

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

180 days after the date of enactment of this Act, the Secretary of Transportation shall 

determine if certain unmanned aircraft systems may operate safely in the national airspace 

system before completion of the plan and rulemaking required by section 332 of this Act or 

the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum: 

(I) 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 (VLOS) do not create a ha::ard 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 authori:;ation, or airworthiness 

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

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

(c) Requirements for Safe Operation--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, the 

Secretary shall establish requirements for the safe operation of such aircraft systems in the 

national airspace system. 

In seeking this exemption, RSA Marketing submits that the DJI Phantom 3 Professional and 

DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional and DJI Inspire 1 

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

a. The Specifications Of The DJI Phantom 3 Professional and DJI Inspire 1 UASs 

Demonstrate Its Safe Characteristics. 
16 

The DJI Phantom 3 Professional and DJI Inspire 1 UASs 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 Professional and DJI Inspire 1 

UASs. 

The technical specifications ofthe DJI Phantom 3 Professional and DJI Inspire 1 UASs are 

set forth by the DJI Phantom 3 Professional and DJI Inspire 1 Specifications and Data Sheet, 

attached hereto as Exhibit A and B. 

ii. The DJI Phantom 3 Professional and DJI Inspire 1 UASs Autonomous Flight And 

Navigation Modes Enable The UASs To Remain Within A Defined Operational Area. 

The DJI Phantom 3 Professional and DJI Inspire 1 UASs may be operated in both manual 

and fully-autonomous flight modes. A complete description of the flight and navigational 

modes of the DJI Phantom 3 Professional and DJI Inspire 1 UASs is provided at pages 

25-35 ofthe DJI Phantom 3 Professional and pages 12-16 and 45-50 ofthe DJI Inspire 1 

User Manuals, attached hereto as Exhibit C and D. 

iii. The DJI Phantom 3 Professional and DJI Inspire 1 UASs Are Designed For 

·Automatic Return To Home Point Or Hover In The Event Of Loss OfThe Control 

Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 3 Professional and DJI Inspire 1 UAs will 

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

Phantom 3 Professional and DJI Inspire 1 UAs 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 Professional UAS 

are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 ofthe 

DJI Phantom 3 Professional and DJI Inspire 1 User Manuals, attached hereto as Exhibit C 

and D. 

iv. The DJI Phantom 3 Professional and DJI Inspire 1 GCS And Its Operation. 

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

Professional and DJI Inspire 1 GCS and flight control software is provided at pages 32 

through 43 of the DJI Phantom 3 Professional User Manual and pages 40 through 47 of the 

DJI Inspire 1 User Manual. DJI Phantom 3 Professional and DJI Inspire 1 User Manuals are 

attached hereto as Exhibits C and D. 
17 

b. Flight Operations Of DJI Phantom 3 Professional and DJI Inspire 1 UASs Are 

Limited To The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

RSA Marketing will only utilize certificated pilots who possess a current and valid airman 

medical certificate to act as a Pilot In Command (PIC) of the DJI Phantom 3 Professional 

and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight 

time. 

c. Flights Of DJI Phantom 3 Professional and DJI Inspire 1 UASs Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, RSA Marketing proposes to commercially operate DJI Phantom 

3 Professional and DJI Inspire 1 UASs 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 Professional 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 UA must be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL), as indicated by the procedures specified in the operating documents unless a special 

request is made and approved by A TC. All altitudes reported to A TC 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. 
18 

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 (GCS) 

must be included in the preflight inspection. All maintenance and alterations must be 

properly documented in the aircraft records. 

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

or flight characteristics (e.g. replacement of a flight critical component) must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry in 

the aircraft records. 

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

components, items, or equipment) not already covered in the relevant sections of the 

operating documents. 

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

overhaul, replacement, inspection, and life limit requirements. 

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

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the aircraft 

records, including total time in service, description of work accomplished, and the signature 

of the authorized person returning the UAS to service. 
19 

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 Flight Rules (SVFR) are not 

authorized. 

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

denoted on a current FAA-published aeronautical charts unless a letter of agreement with 

that airport's management is obtained and the operation is conducted in accordance with a 

Notice to Airman (NOTAM) as required by the operator's Certificate of Waiver or 

Authorization (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 three 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. 
20 

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 percent 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 

(NOT AM) not more than 72-hours in advance, but not less than 48-hours prior to the 

operation. All operations shall be conducted in accordance with airspace requirements in the 

ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. 

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 

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

control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

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

Pilot In Command (PIC) at the Ground Control Station (GCS) of the UAS anytime 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 non-participating 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 non-participating persons from 

the UA and/or debris in the event of an accident. The operator must ensure that 

non-participating persons remain under such protection. If a situation arises where 

non-participating persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or; 
21 

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 

website: www.ntsb.gov. 

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

Would Not Adversely Affect Safety. 

RSA Marketing 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 opetate the DJI Phantom 3 

Professional and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting 

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

DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Considering RSA Marketing'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 airmanship 

skills necessary to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS, 

RSA Marketing submits that the additional manned airmanship experience of a 

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

RSA Marketing'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). 
22 

RSA Marketing will not allow any PIC to operate the DJI Phantom 3 Professional or DJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 3 Professional or DJI Inspire 1 UAS training and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional or DJI 

Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency 

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

structures. 

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

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

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

operations under the exemption). In addition to the hour requirements, the PIC must 

accomplish three takeoffs and landings in the preceding 90 days (for currency purposes). 

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

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

safety during RSA Marketing's proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations 

would ensure safe operations, stating as follows: 

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

purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25-hours oftotal time as a UAS 

rotorcraft pilot including at least 10-hours logged as a UAS pilot with a multi-rotor UAS. 

Prior to operations under Exemption No. 11062, the PIC must also have accumulated and 

logged a minimum of 5-hours as a UAS pilot operating the same make and model ofUAS to 

be used for operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive (i.e. 5-hours make and 

model time may be included in the 10-hours of multi-rotor time and the 10-hours may be 

included in the total25-hours ofUAS rotorcraft time). In addition to the hour requirements, 

the PIC must accomplish three takeoffs and landings in the preceding 90 days (for currency 

purposes). The FAA finds that at a minimum, the flight-hour requirements in Exemption 

No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely 

conduct the petitioner's proposed operations. The FAA also finds that prior documented 

flight experience that was obtained in compliance with applicable regulations would satisfy 

this requirement. Training, proficiency, and experience-building flights can also be 

conducted under the grant of exemption to accomplish the required flight time. During 

training, proficiency and experience-building flights the PIC is required to operate the UA 

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

Exemption No. 11138 at page 15. 

Accordingly, RSA Marketing will ensure safe operations by not allowing any PIC to operate 

the DJI Phantom 3 Professional or DJI Inspire 1 UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to safely 
23 

operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

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

Adversely Affect Safety. 

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

prior to every flight, RSA Marketing will ensure that the DJI Phantom 3 Professional or DJI 

Inspire 1 UAS is in an airworthy condition based upon the UASs compliance with its 

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

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

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

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

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

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

Adversely Affect Safety. 

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

altitude information of the DJI Phantom 3 Professional and DJI Inspire 1 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 RSA Marketing's operation of the DJI 

Phantom 3 Professional and DJI Inspire 1 UAs within Visual Line of Sight (VLOS), at or 

below 400 feet Above Ground Level (AGL), will ensure a level of safety equivalent to 

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

onboard the aircraft. 

Prior to each flight, a zero altitude initiation point is automatically established by the UASs 

at ground level. 

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

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

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

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

5. Reasons Why An Exemption From The Requirements Of Section 91.15l(b) Would 

Not Adversely Affect Safety. 

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

14 C. F. R. Section 91. 151 (b) as a result of ( 1) the technical specifications of the DJI 

Phantom 3 Professional and DJI Inspire 1 UASs; (2) the limitations on the proposed flight 
24 

operations; and (3) the location of the proposed flight operations. Accordingly, RSA 

Marketing will ensure that it will safely operate the battery powered DJI Phantom 3 

Professional and DJI Inspire 1 UAs during daylight hours in Visual Flight Rules (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. 11109, the technical specifications ofthe DJI Phantom 3 

Professional and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and 

the location of the proposed operations, will ensure an equivalent level of safety established 

by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 

Professional and DJI Inspire 1 UASs 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 percent remaining battery power, and again at approximately 10 percent 

remaining battery power. At the critically low-battery level, the DJI Phantom and DJI 

Inspire 1 UASs will descend and land automatically. 

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

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

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

operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 

2689, 5745, and 10650. Moreover, the FAA has previously granted relieffrom Section 

91.151 specific to UAS, in circumstances similar, in all material respects, to those presented 

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

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

11157,11158,11159,11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would 

Not Adversely Affect Safety. 

In seeking this exemption, RSA Marketing submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because 

RSA Marketing will use trained technicians to perform maintenance, alterations or 

preventive maintenance on the UASs using the methods, techniques and practices prescribed 

in the operating documents (i.e. the RSA Marketing Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual). 

Furthermore, RSA Marketing will document and maintain all maintenance records for the 

DJI Phantom 3 Professional and DJI Inspire 1 UASs. 

Since the DJI Phantom 3 Professional and DJI Inspire 1 UASs will be inspected as 

prescribed by the operating documents, RSA Marketing will maintain the equivalent level 
25 

of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe 

DJI Phantom 3 Professional and DJI Inspire 1 User Manuals are attached hereto as Exhibit 

C and D; a copy of the DJI Phantom 3 Professional and DJI Inspire 1 UAS Maintenance 

LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because RSA Marketing 

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

on the UAS using the methods, techniques and practices prescribed by the operating 

documents. 

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

by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Phantom 3 

Professional and DJI Inspire 1 UASs will be performed by trained technicians. Maintenance 

will be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

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

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

UAS are considered. 

In consideration ofRSA Marketing's proposed operating limitations, the operating 

documents, and the techllicaLaspects of the DJI Phantom 3 Professional and DJI Inspire 1 

UASs, RSA Marketing submits that safety will not be adversely affected by granting 

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to UAS 

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

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

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

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

In accordance with Section 333 ofthe FAA Modernization and Reform Act of2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, RSA Marketing requests that 

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

Professional and DJI Inspire 1 UASs, 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 §§ 61.113(a) & (b), 91.7 (a), 91.121, 

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

conditions will permit safe operation of the U As for the limited purpose of conducting aerial 

video and photography over certain areas of the United States for compensation or hire. 

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

hazard to users of the National Airspace System (NAS) or the public, or otherwise pose a 
26 

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

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

§ 21.16, for operation of the DJI Phantom 3 Professional and DJI Inspire 1 U ASs, since the 

airworthiness regulations of 14 C.P.R. Part 21 do not contain adequate or appropriate safety 

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

Special Conditions, states the following: 

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

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

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

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

issued in accordance with Part 11 of this chapter and contain such safety standards for the 

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

equivalent to that established in the regulations. 

See 14 C.P.R.§ 21.16. 

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

prescribe special conditions for RSA Marketing's intended operation of the DJI Phantom 3 

Professional and DJI Inspire 1 UASs, 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.F.R Sections 61. r13(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). 

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

From Which RSA Marketing Seeks Exemption: 

RSA Marketing seeks exemptionfrom 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)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b). 

A Brief Description Of The Nature Of The Exemption RSA Marketing 

Videography Seeks: 

This exemption will permit RSA Marketing to commercially operate an Unmanned Aircraft 

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

areas of the United States. 

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

RSA Marketing's Request. 
27 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) 

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

operate safely in the NAS. As such, RSA Marketing's request for exemption may be granted 

pursuant to the authority ofFMRA 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, RSA Marketing will operate the DJI Phantom 3 Professional 

and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or 

the public, or otherwise pose a threat to national security. 
28 

CONCLUSION 

As set forth herein, RSA Marketing seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will permit 

safe operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs commercially, 

without an airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas ofthe 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 RSA 

Marketing to safely, efficiently and economically operate the DJI Phantom 3 Professional 

and DJI Inspire 1 UASs commercially within the NAS. 

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

Modernization and Reform Act of2012, Section 333, RSA Marketing 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)(l), 

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

Phantom 3 Professional and DJI Inspire 1 UASs commercially for the purpose of 

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

15,2015 

Respectfully submitted, 

RSA Marketing 

Bruce Rowley RSA Marketing, CEO/Principal 

400 S. Commerce 

Wichita, KS 67202 

Tel: (316)977-9600 

Appendices: 

A- DJI Phantom 3 Professional Specifications Data Sheet 

B- DJI Inspire 1 Specifications Data Sheet 

C- DJI Phantom 3 Professional Manufacturer's User Manual 

D- DJI Inspire 1 Manufacturer's User Manual 

E- Monthly Maintenance Log 
29 

APPENDIX-A 

DJI Phantom 3 Professional TECHNICAL SPECIFICATIONS 

RSA Marketing 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). 

1. 1 DJI Phantom 3 Professional 

1. 1. 1 Aircraft 

1.1.1.1 Supported Battery- DJI 5200mAH LiPo Battery 

1.1.1.2 Weight (Battery & Propellers Included)- 2lbs 11.810oz (1242g) 

1.1.1.3 Hover Accuracy (Ready to Fly)- Vertical: .8m; Horizontal: 2.5m 

1.1.1.4 Max Yaw Angular Velocity- 200°/s 

1.1.1.5 Max Tilt Angel- 35° 

1.1.1.6 Max Ascent Speed- 6m/s 

1.1.1. 7 Max Descent Speed- 2m/s 

1.1.1.8 Max Flight Speed- 15m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 

1.1.2.2 Control Accuracy- ±0.03° 

1.1.2.3 Controllable Range- Pitch: -90° to 0° 

1.1.2.4 Maximum Angular Speed- Pitch: 90°/s 

1.1.3 Camera 

1.1.3 .1 Operating Temperature Range- 32°F to 1 04°F (0°C to 40°C) 

1.1.3.2 Sensor Size- 1/2.3" 

1.1.3.3 Effective Pixels- 14M 

1.1.3.4 Resolution- 4384x3288 

4.1.3.5 HD Video Recording- 1080p30 & 720p 

4.1.3.6 Recording Field of View- 110°/85° 

1.1.4 Transmitter 

1.1.4.1 Operating Frequency- 5.728GHz-5.85GHz 

1.1.4.2 Communication Distance (unobstructed)- FCC Compliance: 800m 

1.1.4.3 Receiver Sensitivity (1 %PER)- 93dBm 

1.1.4.4 Transmitter Power- FCC Compliance: 100mW 

1.1.4.5 Working Voltage- 120mA@3.7V 
30 

1. 1. 5 Range Extender 

1.1.5.1 Operating Frequency- 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed)- 500 to 700m 

1.1. 5. 3 Transmitter Power - 20dBm 

1.1. 5. 4 Power Consumption - 2W 

APPENDIX-B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

RSA Marketing 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). 

2.2 DJI Inspire 1 

2.2.1 Aircraft 

2.2.1.1 Model- T600 

2.2.1.2 Weight (Battery Included)- 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode)- Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity- Pitch: 300°/s; Yaw: 150°/s 

2.2.1.5 Max Tilt Angle- 35° 

2.2.1.6 Max Ascent Speed- 5m/s 

2.2.1. 7 Max Descent Speed- 4m/s 

2.2.1.8 Max Speed- 22m/s (ATTI mode, no wind- NOT RECOMMENDED) 

2.2.1. 9 Max Flight Altitude- 4500m 

2.2.1.10 Max Wind Resistance- 1 Om/s 

2.2.1.11 Max Flight Time- Approximately 18 minutes 

2.2.1.12 Motor Model- DJI 3510 

2.2.1.13 Propeller Model - DJI 1345 

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

2.2.1.15 Dimensions- 17 1;4" x 17 %" x 12" 

2.2.2 Gimbal 

2.2.2.1 Model - ZENMUSE X3 

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

2.2.2.3 Operating Current- Static: 750mA; In Motion: 900mA 
31 

2.2.2.4 Angular Vibration Range- ±0.03° 

2.2.2.5 Mounting- Detachable 

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

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

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

2.2.3 Camera 

2.2.3.1 Name-X3 

2.2.3.2 Model- FC350 

2.2.3.3 Total Pixels- 12.76M 

2.2.3.4 Effective Pixels- 12.4M 

2.2.3.5 Image Max Size- 4000x3000 

2.2.3.6 ISO Range- 100-3200 

2.2.3.7 Field ofView- 94° 

2.2.3.8 CMOS- Sony EXMOR 1/2.3" 

2.2.3.9 HD Video Recording- UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 

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

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

2.2.4 Transmitter 

2.2.4.1 Name- C1 

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

2.2.4.3 Communicating Distance (unobstructed)- 2000m 

2.2.4.4 Output Power- 9W 

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

2.2.4.6 Battery- 600mAh LiPo 2S 
32 

APPENDIX-C 

DJI Phantom 3 Professional Manufacturer's User Manual 
33 

APPENDIX-D 

DJI Inspire 1 Manufacturer's User Manual 
PHANTOM 

l ,=>.=c:=;:::::= :::;';.:.~] 

User Manual D 
Using this manual 

0 Warning & Important :\): Hints and Tips liGJ Reference 

Read the following documents before using the Phantorn 3 Professional: 

1. In the Box 

2. Phantom 3 Professional User Manual 

3. Phantom 3 Professional Quick Start Guide 

4. Phantom 3 Professional I Advanced Safety Guidelines and Disclaimer 

5. Phantom 3 Professional I Advanced Intelligent Flight Battery Safety Guidelines 

We recornrnend that you watch all tutorial videos on the official DJI website and read the Disclaimer 

before you fly. Prepare for your first flight by reviewing the Phantorn 3 Professional Quick Start Guide and 

refer to the User Manual for rnore detailed information. 

Please watch the tutorial videos at the link below, which demonstrates how to use Phantorn 3 Professional 

safely: 

http //www. dji. corn/p roduct/phantorn-3/video 

Download and install the DJI Pilot app before using the aircraft. Scan the OR code to the right 

~~~~~~~. ~~~ 

• - ... J.·i.l. . 

The Android version of the DJI Pilot app is compatible with Android 4.1.2 or later. fi~i~ 

The iOS version of the DJI Pilot app is compatible with iOS 8.0 or later. ~ ~.·.~~~~ 
Contents 

Using this manual 

Legends 

Read Before the First Flight 

Video Tutorials 

Download the DJI Pilot app 

Product Profile 

Introduction 

Feature Highlights 

Preparing the Aircraft 

Aircraft Diagram 

Remote Controller Diagram 

Aircraft 

Flight Controller 

Flight Mode 

Flight Status Indicator 

Return-to-Home (RTH) 

Smart RTH 

Low Battery RTH 

Failsafe RTH 

Vision Positioning System 

Flight Recorder 

Attaching and Detaching the Propellers 

DJI Intelligent Flight Battery 

Remote Controller 

Remote Controller Profile 

Using the Remote Controller 

Remote Controller Status LED 

Linking the Remote Controller 

Remote Controller Compliance Version 

2 

2 

2 

2 

6 

6 

7 

8 

8 

11 

11 

11 

12 

12 

13 

14 

14 

16 

16 

17 

23 

23 

27 

28 

29 
Camera and Gimbal 

Camera Profile 31 

Gimbal 32 

DJI Pilot App 

Camera 35 

Director 38 

Store 38 

Discovery 38 

Flight 

Flight Environment Requirements 40 

Flight Limits and No-Fly Zones 40 

Preflight Checklist 44 

Calibrating the Compass 44 

Auto Takeoff and Auto Landing 45 

Flight Test 46 

Starting/Stopping the Motors 46 

Troubleshooting (FAQ) 

Appendix 

Specifications 53 

Intelligent Orientation Control (IOC) 55 

FCC Compliance 56 

4 
rofile 

This section introduces the Phantom 3 

Professional and lists the components of 

the aircraft and remote controller. 
Product Profile 

The Phantom 3 Professional represents the next generation of OJI quadcopters. It is capable of capturing 

4K video and transmitting an HD video signal out of the box. The built-in camera has an integrated gimbal 

to maximize stability while minimizing both weight and size. Even when no GPS signal is available, the 

Vision Positioning System allows the aircraft to hover accurately in place. 

Camera and Gimbal: With the Phantom 3 Professional, you're shooting 4K video at up to 30 frames per 

second and capturing 12 megapixel photos that look crisper and cleaner than ever. An enhanced sensor 

gives you greater clarity, lower noise, and better pictures than any previous flying camera. 

HD Video Downlink: The low-latency long range HD downlink is powered by an enhanced version of OJI 

Lightbridge. 

DJI Intelligent Flight Battery: The 4480 mAh OJI Intelligent Flight Battery features upgraded battery cells 

and an advanced power management system. 

Flight Controller: The next-generation flight controller has been updated to provide a safer. more reliable 

flight experience. A newly implemented flight recorder stores critical data from each flight and the Vision 

Positioning System enhances hovering precision when flying indoors or in environments where GPS is 

unavailable. 
Phantom 3 Professional User Manual 

Removing Gimbal Clamp 

Remove the gimbal clamp by sliding it to the right (when facing the nose of the aircraft), as shown below. 

Attaching the Propellers: 

Mount the propellers with black dots on to motors with black axes and spin counter-clockwise to secure. 

Mount the propellers with sliver dots on to motors with sliver axes and spin clockwise to secure. Be sure 

all propellers are securely in place. 

& Place all propellers onto the correct motors and tighten by hand to lock them in position. 

Preparing the Remote Controller: 

The mobile device holder is designed for securing tablet or mobile device. Tilt the mobile device holder to 

the desired position, then adjust the antennas so they are facing outward. 

1. Press the button on the top right side of the mobile device holder to release the clamp, then adjust the 

clamp to fit the size of your mobile device. 

2. Secure your mobile device in the clamp by pressing down, and connect your mobile device to the 

remote controller using a USB cable. 

3. Plug one end of the cable into the mobile device, and the other end into the USB port on the back of 

the remote controller. 

7 
Phantom 3 Professional User Manual 

II 

b 'I== 11-----. .1ft (Q ~ ~'0 

···' ) 

[1] GPS 

[2] Propeller 

[3] Motor 

[4] Front LED Indicator 

[5] Landing gear 

[6] Gimbal and Camera 

[7] Aircraft Micro-USB Port 

[8] Aircraft Status Indicator 

[9] Intelligent Flight Battery 

[10] Vision Positioning Sensors 

[ 11] Antennas 

[12] Camera Micro-SO Card Slot 

[13] Camera Micro-USB Port 

[14] Link Button 

[1] Antennas 

Relays aircraft control and 

video signal. 

[2] Mobile Device Holder 

Securely mounts your mobile 

device to the remote controller. 

[3] Control Stick 

Controls the orientation and 

movement of the aircraft. 

[4] Return Home (RTH) Button 

Press and hold the button to 

initiate Return to Home (RTH). 
[5] Battery Level LEDs 

Displays the battery level of the remote 

controller. 

[6] Status LED 

Displays the remote controller's system status. 

[7] Power Button 

Used to turn the remote controller on and off. 

[8] RTH LED 

Circular LED around the RTH button displays 

RTH status. 

[9] Camera Settings Dial 

Turn the dial to adjust camera settings. 

(Only functions when the remote controller is 

connected to a mobile device running the OJI 

Pilot app.) 

[1 0] Playback Button 

Playback the captured images or videos. 

(Only functions when the remote controller is 

connected to a mobile device running the OJI 

Pilotapp.) 

[11] Shutter Button 

Press to take a photo If burst mode is 

selected, the set number of photos will be 

taken with one press. 

[12] Flight Mode Switch 

Switch between P-mode, A-mode, and 

F-mode. 

[13] Video Recording Button 

Press to start recording video. Press again to 

stop recording. 

[17] C1 Button 

Customizable through the OJI Pilot app. 

[18] C2 Button 

Customizable through the OJI Pilot app. 

[19] Power Port 

Connect to the DJI Phantom 3 Charger to 

charge the battery of the remote controller. 

Phantom 3 Professional User Manual 

[14] Gimbal Dial 

Use this dial to control the tilt of the gimbal. 

[15] Mircro-USB Port 

Connect to a SO card reader to upgrade the 

firmware. 

[16] USB Port 

Connect to mobile device or to a USB port for 

firmware upgrade. 
Aircraft 

This section introduces the features of 

the Flight Controller, Vision Positioning 

System. and the Intelligent Flight Battery 

10 
Aircraft 

The Phantom 3 Professional's flight controller features several important upgrades, including a new flight 

mode. Safety modes include Failsafe and Return-to-Home. These features ensure the safe return of your 

aircraft if the control signal is lost. The flight controller can also save critical flight data from each flight 

to the on-board storage device. The new flight controller also provides increased stability and a new air 

braking feature. 

Three flight modes are available. The details of each flight mode are found below: 

P-mode (Positioning) : P-mode works best when GPS signal is strong. There are three different states 

of P-mode, which will be automatically selected by the Phantom 3 Professional depending on signal 

strength of GPS and Vision Positioning sensors : 

P-GPS: GPS and Vision Positioning both are available. The aircraft is using GPS for positioning. 

P-OPTI: Vision Positioning is available but the GPS signal strength is not sufficient. The aircraft is 

using only the Vision Positioning System for positioning. 

P-ATTI: Neither GPS nor Vision Positioning is available. The aircraft is using only its barometer for 

positioning, so only altitude can be stabilized. 

A-mode (Attitude): GPS and Vision Positioning System are not used for stabilization. The aircraft only uses 

its barometer. The aircraft can still automatically return to the home point if the control signal is lost and 

the Home Point was recorded successfully. 

F-mode (Function): Intelligent Orientation Control (IOC) is activated in this mode. For more information 

about IOC, refer to the IOC section in the Appendix. 

:<;/; Use the Flight Controller mode switch to change the flight rnode of the aircraft, refer to the "Flight 

Mode Switch" on Page 26 for more information. 

The Phantom 3 Professional has Front LEOs and Aircraft Status Indicators. The positions of these LEOs 

are shown in the figure below: 

The Front LEOs show the orientation of the aircraft. The Front LEOs glow solid red when the aircraft is 

turned on to indicate the front (or nose) of the aircraft. The Aircraft Status Indicators communicate the 

system status of the flight controller. Refer to the table below for more information about the Aircraft Status 

Indicators: 

11 
l> 

::; 

D 

Phantom 3 Professional User Manual 

Norrnal 

-c'f!J:tfjriS:f: .. ···· Red, Green and Yellow Flash 

Alternatively Turning On and Self Diagnostic Testing 

:ff?!.:¢1;.. .... Green and Yell ow Flash Alternatively Warming Up 

:@.:······Green Flashes Slowly 

:t/J!:X2 ······Green Flashes Twice 

:@ ...... Yellow Flashes Slowly 

:warning 

¢· ...... Fast Yellow Flashing 

:JBF ...... Slow Red Flashing 

!6): · · · · · · Fast Red Flashing 

:f/!f: · · · · · · Red Flashing Alternatively 

tf!J.·- Solid Red 

Safe to Fly (P-mode with GPS and Vision 

Positioning) 

Safe to Fly (P-mode with Vision Positioning but 

without GPS) 

Safe to Fly (A-mode but No GPS and Vision 

Positioning) 

Remote Controller's Signal Lost 

Low Battery Warning 

Critical Battery Warning 

IMU Error 

Critical Error 

:IJ!l-.:.1$..-······ Red and Yellow Flash Alternatively Compass Calibration Required 

The Return-to-Home (RTH) function brings the aircraft back to the last recorded Home Point. There are 

three types of RTH procedures: Smart RTH, Low Battery RTH, and Failsafe RTH. This section describes 

these three scenarios in detail. 

Home Point 

If a strong GPS signal was acquired before takeoff, the Home Point 

is the location from which the aircraft was launched. The GPS signal 

strength is indicated by the GPS icon ( ~,ull ). The aircraft status 

indicator will blink rapidly when the home point is recorded. 

Use the RTH button on the remote controller (refer to "RTH button" on page 26 for more information) or 

tap the RTH button in the DJI Pilot app and follow the on-screen instructions when GPS is available to initiate Smart RTH. The aircraft will then automatically return to the last recorded Home Point. You may use 

the remote controller's control sticks to control the aircraft's position to avoid a collision during the Smart 

RTH process. Press and hold the Smart RTH button once to start the process, and press the Smart RTH 

button again to terminate the procedure and regain full control of the aircraft. 

12 
Phantom 3 Professional User Manual 

The low battery level failsafe is triggered when the DJI Intelligent Flight Battery is depleted to a point that 

may affect the safe return of the aircraft. Users are advised to return home or land the aircraft immediately 

when prompted. The DJI Pilot app will display a notice when a low battery warning is triggered. The 

aircraft will automatically return to the Home Point if no action is taken after a ten-second countdown. The 

user can cancel the RTH procedure by pressing the RTH button on the remote controller. The thresholds 

for these warnings are automatically determined based on the aircraft's current altitude and distance from 

the Home Point. 

The aircraft will land automatically if the current battery level can only support the aircraft long enough 

to descend from its current altitude. The user can still use the remote controller to alter the aircraft's 

orientation during the landing process. 

The Battery Level Indicator is displayed in the DJI Pilot app, and is described below: 

SuffiCif-nt battt:ry 

'J' 

aircraft return to the Home Fly the aircraft 

point and land automatically, back and land 

Low battery The battery Aircraft status or "Cancel" to resume normal it as soon as 

level warning power is low. flight. If no action is taken, possible, then 

Please land the the aircraft will automatically stop the motors 

aircraft. go home and land after 10 and replace the 

seconds. Remote controller battery. 

will sound an alarm. 

Critical Low The aircraft Aircraft status 

The DJI Pilot app display will 

Allow the aircraft to 

battery level must land indicator blinks flash red and the aircraft will 

descend and land 

start to descend. The remote 

warning immediately. RED quickly. controller will sound an alarm. automatically. 

Estimated 

Estimated 

remaining remaining flight N/A N/A N/A based on current 

flight time battery level. 

13 
Phantom 3 Professional User Manual 

:\;): • When Critical battery level warning is triggered and the aircraft begins to land automatically, 

you may push the throttle upward to make the aircraft hover at its current altitude, giving you an 

opportunity to navigate to a more appropriate landing location. 

• The colored zones and markers on the battery level indicator bar reflect the estimated 

remaining flight time. They are automatically adjusted according to the aircraft's current location 

and status. 

If the Home Point was successfully recorded and the compass is functioning normally, Failsafe RTH will 

be automatically activated if the remote controller signal is lost for more than three seconds. The Returnto-Home process may be interrupted and the operator may regain control of the aircraft if the remote 

controller signal connection is re-established. 

Failsafe Illustration 

1 Record Home Point 

Blink1ng Green 

4 Signal Lost Lasts (after 3 sec.) 

>38 

Fast Blinking Yellow 

2 Confirming Home Point 

~~1111 

y 

Blinking Green 

5 RTH (adjustable altitude) 

v~::::::::::::::~ ___ Y 0 I :y ~ @ 

Fast Blinking Yellow 

3 Remote Controller Signal Lost 

Fast Blinking Yellow 

6 Landing (after hovering for 5 sees) 

T 

.. 

@ 

Fast Blinking Yellow 

& . The aircraft cannot avoid obstruction during the Failsafe RTH, therefore, it is important to set an 

suitable Failsafe altitude before each flight. Launch the DJI Pilot app and enter "Camera" and 

select "MODE> Advanced Settings > Failsafe mode" to set the Failsafe altitude. 

• The aircraft will stop its ascent and return to the Home Point immediately if the throttle stick is 

moved during the Failsafe RTH procedure. 

The DJI Vision Positioning System uses ultrasound and image data to help the aircraft maintain its current 

position. With the help of Vision Positioning, your Phantom 3 Professional can hover in place more precisely 

and fly indoors or in other environments where a GPS signal is not available. The main components of the 

Vision Positioning System are located on the bottom of your Phantom 3 Professional; they include [2] two 

ultrasonic sensors and [ 1] one monocular camera. 

14 
Phantom 3 Professional User Manual 

Using Vision Positioning 

Vision Positioning is activated automatically when the Phantom 3 Professional is turned on. No 

further action is required. Vision Positioning is typically used in indoor environments, where GPS 

is unavailable. Using the sensors that are built into the Vision Positioning system, the Phantom 3 

Professional can hover precisely even without GPS. 

~.,___ ____ _____,./ 

I -y- . 

i I ~ I I 1/ ~ ~I 

Follow the steps below to use Vision Pos1t1on1ng ep 1. Toggle the flight mode switch toP-mode. ' ' 

2. Place the aircraft on a flat surface. Note that the Vis1on Posit1on1ng system cannot work 

properly on surfaces without clear pattern vanat1ons. 

3. Turn on the aircraft. The aircraft status indicator will flash green two times, which indicates the Vision 

Positioning system is ready. Gently push the throttle up to lift off and the aircraft will hover in place. 

& The performance of your Vision Positioning System is affected by the surface over which it is 

flying. The ultrasonic sensors may not be able to accurately measure distances when operating 

above sound-absorbing materials. In addition, the camera may not function correctly in 

suboptimal environments. The aircraft will switch from P-mode to A-rnode automatically if neither 

GPS nor Vision Positioning System are available. Operate the aircraft with great caution in the 

following situations: 

• Flying over monochrome surfaces (e.g. pure black, pure white, pure red, pure green). 

• Flying over a highly reflective surfaces. 

• Flying at high speeds( over 8 m/s at 2 meters or over 4 m/s at 1 meter). 

• Flying over water or transparent surfaces. 

• Flying over moving surfaces or objects. 

• Flying in an area where the lighting changes frequently or drastically. 

• Flying over extremely dark (lux< 10) or bright (lux> 100,000) surfaces. 

• Flying over surfaces that can absorb sound waves (e.g. thick carpet). 

• Flying over surfaces without clear patterns or texture. 

• Flying over surfaces with identical repeating patterns or textures (e.g. tiles with the sarne design). 

• Flying over inclined surfaces that will deflect sound waves away from the aircraft. 

;\;): • Keep the sensors clean at all times. Dirt or other debris may adversely affect the effectiveness 

of the sensors. 

• Vision Positioning is only effective when the aircraft is at altitudes of 0.3 to 3 meters. 

• The Vision Positioning System may not function properly when the aircraft is flying over water. 

• The Vision Positioning System may not be able to recognize pattern on the ground in low light 

conditions (less than 100 lux) 

• Do not use other ultrasonic devices with frequency of 40 KHz when Vision Positioning system is 

in operation. 

• Vision Positioning System may not be able to stabilize the aircraft when flying close to the 

ground (below 0.5 meters) at fast speeds .. 

15 
Phantom 3 Professional User Manual 

0 Keep the animals away from the aircraft when Vision Positioning system is activated. The sonar 

sensor emits high frequency sounds that are only audible to some animals. 

Flight data is automatically recorded to the internal storage of the aircraft. This includes flight 

telemetry, aircraft status information, and other parameters. To access these data, connect the 

aircraft to the PC through the Micro-USB port and launch the OJI Pilot app. 

Use only DJI approved propellers with your Phantom 3 Professional. The grey and black nuts on 

the propeller indicate where they should be attached and in which direction whey should spin. To 

attach the propellers properly, match the nut color with the motor axis color. 

·~ropellers 

Figure 

Attach On 

Legends 

Silv~r Dol 

'\, \\" ,, ,, 

~iack.Qbt: 

Motors with a grey axes Motors with a black axes 

Ell Lock :Turn the propellers in the indicated direction to mount and tighten. 

'D'l Unlock: Turn the propellers in the indicated direction to loosen and remove. 

Attaching the Propellers 

1. Be sure to remove the warning stickers from the motors before attaching the propellers. 

2. Attach the propellers with silver dots onto the motors with silver axes and spin the propellers clockwise 

to secure them in place. Attach the propellers with black dots onto the motors with black axes and spin 

the propellers counter-clockwise to secure them in place. Be sure to tighten each propeller by hand 

before flight. 

16 
Phantom 3 Professional User Hanual 

6 • Ensure propellers are attached to its corresponding motors, otherwise the aircraft cannot take off . 

• Wear gloves when handling propellers. 

• Hand tighten each of the propellers on the corresponding motors to ensure it is attached firmly. 

Detaching the Propellers 

Hold the motor in place with one hand, then spin the propeller in the indicated unlock direction. 

& · Check that the propellers and motors are installed correctly and firmly before every flight. 

• Ensure that all propellers are in good condition before each flight. DO NOT use aged, chipped, 

or broken propellers. 

• To avoid injury, STAND CLEAR of and DO NOT touch propellers or motors when they are spinning. 

• ONLY use original OJI propellers for a better and safer flight experience. 

The OJI Intelligent Flight Battery has a capacity of 4480 mAh, a voltage of 15.2 V, and a smart charge/ 

discharge functionality. It should only be charged using an appropriate charger that has been approved 

by DJI. 

6 The Intelligent Flight Battery must be fully charged before using it for the first time. Refer to 

"Charging the Intelligent Flight Battery" for more information. 

:\): Be aware that the output power of the supplied Phantom 3 Professional charger is 100W. 

DJI Intelligent Flight Battery Functions 

1. Battery Level Display: the LED indicators display the current battery level. 

2. Battery Life Display: the LEOs display the current battery power cycle. 

3. Auto-Discharging Function: To prevent swelling, the battery automatically discharges to below 65% of 

total power when it is idle for more than ten days. It takes around two days to discharge the battery to 

65%. It is normal to feel moderate heat being emitted from the battery during the discharge process. 

Discharge thresholds can be set in the OJI Pilot app. 

4. Balanced Charging: Automatically balances the voltage of each battery cell when charging. 

5. Overcharge Protection: Charging automatically stops when the battery is fully charged. 

6. Temperature Detection: The battery will only charge when the temperature is between ooc (32°F) and 

40°C (104°F). 

7. Over Current Protection: The battery stops charging when high amperage (more than 8 A) is detected. 

8. Over Discharge Protection: To prevent over-discharge damage, discharging automatically stops when 

the battery voltage reaches 12 V. 

9. Short Circuit Protection: Automatically cuts the power supply when a short circuit is detected. 

17