Attn: 

U. S. Department of Transportation Docket Operations 

West Building Ground Floor, Room w12-140 

1200 New Jersey Ave, SE Washington, DC 20590 

RE: Dennis McDOugall dba. MDEZIN CREATIVE GROUP 

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OFTITLE 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 

3UNMANNED AIRCRAFT SYSTEMSPURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Dennis McDougall (owner)

MDEZIN CREATIVE GROUP

224 Pease Ct. Janesville WI 53545

608-774-3623

dmcdougall@mdezin.com

1 
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 THEMDEZIN CREATIVE GROUP 

SEEKS EXEMPTION............................................................................................................7 

THE EXTENT OF RELIEF THEMDEZIN CREATIVE GROUP SEEKS AND THE REASON THE 

MDEZIN CREATIVE GROUP SEEKS THE RELIEF..............................................................10 

THE REASONS WHY GRANTING THEMDEZIN CREATIVE GROUP’S REQUEST WOULD 

BE IN THE PUBLIC INTEREST ............................................................................................12 

THE REASONS WHY GRANTING THE EXEMPTION TO THE MDEZIN CREATIVE GROUP 

WOULD NOT ADVERSELY AFFECT SAFETY..............................................................14 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT THE MDEZIN CREATIVE GROUP’S REQUEST..................................................25 

CONCLUSION.....................................................................................................................25 

APPENDICES.........................................................................................26 

2 
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC	 Air Traffic Control

ATO	 Air Traffic Organization

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA	 Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

3 
SUMMARY 

Dennis McDougall, dba. MDEZIN CREATIVE GROUP hereafter referred to as The MDEZIN 

CREATIVE GROUP seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), 

to operate an Unmanned Aircraft System (DJI Phantom 2+) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit The MDEZIN 

CREATIVE GROUP to operate an Unmanned Aircraft System (UAS ) for the commercial purpose of conducting aerial video and photography of construction sites, residential and commercial real estate, civil landscapes and eventsover certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

The MDEZIN CREATIVE GROUP has for over 15 years provided their clients (which include 

private sector businesses and non-profits, along with local state agencies) with expertise and

knowledge in video and multimedia marketing, advertising, public relations and training using advanced technologies and solutions. The MDEZIN CREATIVE GROUP has worked on 

thousands of productions over the past 15 years in all types of locations with a perfect client and 

employee safety record. The objective of The MDEZIN CREATIVE GROUP and our Unmanned 

Aircraft System (DJI Phantom 2+) aerial operations is to provide a more affordable, high-quality 

production system for a variety of governmental, commercial, public, and residential uses, specifically targeting

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic land marks

• Special event coverage

• Private and governmental training 

My staff has safely flown small RC electric quadcopters recreationally for approximately 2 years 

without incident. 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 2+, UAS 

The MDEZIN CREATIVE GROUP seeks an exemption to operate DJI Phantom 2+ systemfor compensation or hire within the NAS. The DJI Phantom 2+is vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2+ has a maximum gross weight of approximately 

2.8lb. while having a diagonal dimension of 23.2”, a maximum speed of approximately 16.4’fpsand a maximum flyingheightof 400’. The DJI Phantom 2+ is equipped with four main rotors;

driven by Lithium Polymer battery powered electric motors. 

4 
The DJI Phantom 2+ that will be operated by The MDEZIN CREATIVE GROUP 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, The MDEZIN CREATIVE GROUP, pursuant to the provisions of the Federal Aviation 

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

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

Administrator to commercially operate the DJI Phantom 2+, UAS in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, The MDEZIN CREATIVE GROUP operation of DJI Phantom 

2+ UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, The MDEZIN CREATIVE GROUP requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements 

for maintenance that only apply to aircraft with an airworthiness certificate. 

The MDEZIN CREATIVE GROUP submits that the requested relief is proper since an equivalent 

level of safety will be ensured. TheMDEZIN CREATIVE GROUP will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS 

using the methods, techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2+Instruction Manual). Furthermore, The MDEZIN 

CREATIVE GROUP will document and maintain all maintenance records for the DJI Phantom 

2+UAS . 

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

and limitations: Pilot in command, is requested by The MDEZIN CREATIVE GROUP 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

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

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

The MDEZIN CREATIVE GROUP seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 2+ UAS do not require an airworthiness certificate

in accordance with 14 C.F.R. Part 21, Subpart H. As such, The MDEZIN CREATIVE GROUP 

submits that theywill ensure that the DJI Phantom 2+UAS isin an airworthy condition, prior to 

every flight, by determining that the UAS are in compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manual), and that the aircraft are in a 

condition for safe flight. 

5 
The MDEZIN CREATIVE GROUP also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 2+UAS will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Phantom 2+ 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 The MDEZIN CREATIVE GROUP’s operation of the DJI 

Phantom 2+ UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, The MDEZIN CREATIVE GROUP seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. The MDEZIN CREATIVE GROUP submits that safety will not be affected by operation of the DJI Phantom 2+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 23minutes. Battery power 

indicators are also able to show exactly how much battery power is left, as well as how much 

time is needed to return safely back to point of take off. 

In accordance with 14 C.F.R. § 11.81, The MDEZIN CREATIVE GROUP 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: 

Dennis McDougall (owner)

MDEZIN CREATIVE 

GROUP

224 Pease Ct. Janesville WI 

53545

608-774-3623

dmcdougall@mdezin.com

6 
B. The Specific Sections Of 14 C.F.R. From Which The MDEZIN CREATIVE GROUP 

Seeks Exemption. 

1. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: 

(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 maythat 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. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Section 91.7(a). 

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

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

3. The MDEZIN CREATIVE GROUP 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) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate available 

station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

7 
4. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Section 91.151(b). 

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

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first 

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

least 20 minutes. 

5. The MDEZIN CREATIVE GROUP 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. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration,subsection (a)(1), states the following: 

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

maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter[.] 

7. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 

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

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

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

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

approved for return to service by a person authorized by § 43.7 of this chapter; or 

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

with part 21 of this chapter. 

8 
8. The MDEZIN CREATIVE GROUP Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). 

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

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in

paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, 

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

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

work performed; and 

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

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

for return to service. 

(2) Records containing the following information: 

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

each rotor. 

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

rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 

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

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained. 

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

directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. 

9 
(b) The owner or operator shall retain the following records for the periods prescribed: 

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

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

performed. 

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

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

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

this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. 

C. The Extent Of Relief The MDEZIN CREATIVE GROUPSeeks And The Reason The 

MDEZIN CREATIVE GROUPSeeks The Relief. 

1. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The 

MDEZIN CREATIVE GROUPSeeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business 

or employment if: (1) The flight is only incidental to that business or employment; and (2) The

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

As set forth more fully below, The MDEZIN CREATIVE GROUPsubmits that an equivalent level 

of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2+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 2+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, The MDEZIN CREATIVE GROUP submits that all flights of the DJI Phantom 2+UAS , 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to The MDEZIN 

CREATIVE GROUP’s business; and (2) will not carry passengers or property for compensation

or hire. 

10 
2. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The 

MDEZIN CREATIVE GROUPSeeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow The MDEZIN CREATIVE GROUPto determine that the DJI Phantom 2+ UAS 

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

the operating documents (i.e., the MDEZIN CREATIVE GROUPAerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2+Instruction Manual). 

The MDEZIN CREATIVE GROUPseeks the requested relief because the DJI Phantom 2+ UAS 

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

Therefore, The MDEZIN CREATIVE GROUPwill ensure that the DJI Phantom 2+ UAS are 

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

Maintenance Log, and DJI Phantom 2+) 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 The MDEZIN CREATIVE GROUP Seeks And The Reason The 

MDEZIN CREATIVE GROUP Seeks Relief From Section 91.121. 

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

of the DJI Phantom 2+UAS , which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the 

PIC at the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level

(AGL), The MDEZIN CREATIVE GROUP seeks the requested relief because the DJI Phantom 

2+ UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric 

pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought 

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the DJI 

Phantom 2+ 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 The MDEZIN CREATIVE GROUP Seeks And The Reason The 

MDEZIN CREATIVE GROUP 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 2+ UAS during

daylight hours invisual meteorological conditions (VMC), under visual flight rules (VFR), for a

total duration of 23minutes.The MDEZIN CREATIVE GROUP seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the 

11 
battery powered DJI Phantom 2+ UAS will severely constrain the practicality of any aerial video 

or still photo flight operations that The MDEZIN CREATIVE GROUP proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2+ UAS , the DJI 

Phantom 2+ operating documents, and The MDEZIN CREATIVE GROUP’s proposed operating 

limitations, ensure that The MDEZIN CREATIVE GROUP will safely operate the battery powered DJI Phantom 2+ UAS during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total duration of 18 minutes. 

5. Extent Of Relief The MDEZIN CREATIVE GROUP Seeks And The Reason The 

MDEZIN CREATIVE GROUP Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), 

And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, The MDEZIN CREATIVE GROUP requests relief from 

these Sections because the DJI Phantom 2+ UAS do not require airworthiness certificates. As set 

forth more fully below, the DJI Phantom 2+ UAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, The MDEZIN CREATIVE GROUP

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

the UAS using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the The MDEZIN CREATIVE GROUP Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manual). Furthermore, The MDEZIN CREATIVE 

GROUP will document and maintain all maintenance records for the DJI Phantom 2+ UAS . 

D. The Reasons Why Granting The MDEZIN CREATIVE GROUP 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 The ALTEK MEDIA 

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

construction sites, real estate, events and civic landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 2+ UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of The MDEZIN

CREATIVE GROUP’s proposed operation of the DJI Phantom 2+ UAS will be realized without 

implicating any privacy issues. 

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

The DJI Phantom 2+ 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 

12 
amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

of a DJI Phantom 2+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 

2+ 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 2+ UAS . 

Conducting aerial acquisitions with the DJI Phantom 2+ UAS , instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated 

duringtraditional aerial video and still photography flight operations. By using battery power and

electric motors, the DJI Phantom 2+ UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine 

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

20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2+ 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 2+ UAS to perform aerial acquisitions, the substantial risk to life and 

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

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Phantom 2+ UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 inches, and 

with no fuel on board), has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length 

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

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2+ 

UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2+ UAS are also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI 

Phantom 2+ UAS will allow United States based companies, like The MDEZIN CREATIVE 

GROUP, 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 2+ UAS is one such technology that not only allows companies greater operational 

13 
flexibility compared to manned aircraft, but provides such flexibility without the high operational

cost of a traditional manned aircraft. 

By operating the DJI Phantom 2+ UAS , companies such as The MDEZIN CREATIVE GROUP, 

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 2+ UAS ,

provides a stable workforce that increases consumer spending; improves local, state, and federal

tax revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

The MDEZIN CREATIVE GROUP’s proposed operation of the DJI Phantom 2+ UAS will not 

implicate any privacy issues. Specifically, the DJI Phantom 2+ UAS will be operated only in 

compliance with operating documents (i.e., the MDEZIN CREATIVE GROUP Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manual) which requires 

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

with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

§ 91.119. 

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 The MDEZIN CREATIVE GROUP Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, The MDEZIN CREATIVE GROUP’s operation of the DJI 

Phantom 2+ UAS meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

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

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

shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 

332 of this Act or the guidance required by section 334 of this Act. 

14 
(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), theSecretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

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

areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national 

security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, 

is required for the operation of unmanned aircraft systems 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, The MDEZIN CREATIVE GROUP submits that the DJI Phantom 2+ 

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

characteristics of the DJI Phantom 2+ UAS ; (b) the pilot certification requirement; and (c) the 

specific operating limitations. 

a. The Specifications Of The DJI Phantom 2+ UAS Demonstrate Its Safe Characteristics. 

The DJI Phantom 2+ UAS does not create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJIPhantom 2+ UAS . 

The technical specifications of the DJI Phantom 2+ UAS are set forth by the DJI Phantom 2+

User Manual, attached hereto as Appendix A. 

ii. The DJI Phantom 2+ UAS Global Positioning Modes Enable The UAS To Remain Within A Defined Operational Area. 

The DJI Phantom 2+ UAS may be operated in both manual and global positioning flight modes. A 

complete description of the flight and navigational modes of the DJI Phantom 2+ UAS is provided at pages 5 of the DJI Phantom 2+ User Manual attached here to as Appendix A. 

iii. The DJI Phantom 2+ UAS Are Designed For Automatic Return To Home 

Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 2+ UAS will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Phantom 2+ UAS doesnot reacquire controllink data 

from the GCS, the UAS will assume that the Control Link is lost and thewill return to the home 

position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 

15 
A complete description of the Failsafe Functions of the DJI Phantom 2+UAS are set forth at 

pages 12through 14of the DJI Phantom 2+ User Manual, attached hereto as Appendix A. 

iv. The DJI Phantom 2+ GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 2+ GCS and flight 

control software is provided at page 5 of the DJI Phantom 2+ User Manual. DJI Phantom 2+ 

User Manualis attached hereto as Appendix A. 

b. Flight Operations Of DJI Phantom 2+ UAS IsLimited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer. 

The MDEZIN CREATIVE GROUP video production staff will be the only personsto act as a 

pilot in command (PIC) of the DJI Phantom 2+ UAS . Additionally, a safety observer will assist 

him at all times during flight time. 

c. Flights Of DJI Phantom 2+ UAS Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, The MDEZIN CREATIVE GROUP proposes to commercially operate DJI Phantom 2+ UAS for the special purpose of conducting aerial video and photography 

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

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

aircraft described in the operating documents, rotorcraft UAS weighing less than 55 

pounds maximum gross weight: DJI Phantom 2+ 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 nomore than 400 feet above ground level 

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

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all 

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

16 
7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

the VLOS requirement as long as the PIC always maintains VLOS capability. The 

SO and PIC must be able to communicate verbally at all times. Electronic messaging 

or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight.

The PIC must ensure that the SO can perform the functions prescribed in the operating 

documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and 

avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 

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

UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption 

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

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

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

operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents 

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

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

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

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation

of the UAS , the aircraft is prohibited from operating until the necessary maintenance 

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

Ground Control Station must be included in the 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. 

17 
14. The operator must carry out its maintenance, inspections, and record keeping 

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

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

aircraft records, including total time in service, description of work accomplished, 

and the signature of the authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all 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 thirdclass 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 5 nautical miles of an airport reference point 

as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and theoperation is conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon 

request. 

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

18 
23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies 

in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the

intended landing point and land the UA with 25% battery power remaining. 

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

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

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

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

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

in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (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 PIC at the Ground Control Station of the UAS any time the UAS is operating. 

These documents must be made available to the Administrator or any law enforcement officialupon 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 atleast 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, 

vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flightoperations must cease immediately and/or; 

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

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

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

objects and determined that it does not present an undue hazard, and; 

19 
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 operationsshall be conducted over private or controlled-access property with 

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

from land owner/controller or authorized representative will be obtained for each 

flight to be conducted.

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

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA’s UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov. 

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

Would Not Adversely Affect Safety. 

The MDEZIN CREATIVE GROUP submits that the equivalent level of safety established by 

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

Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2+ UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering The MDEZIN CREATIVE GROUP’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. 11062); and the airmanship

skills necessary to safely operate the DJI Phantom 2+ UAS , The MDEZIN CREATIVE GROUP 

submits that the additional manned airmanship experience of a commercially certificated pilot

would not correlate to the airmanship skills necessary for The MDEZIN CREATIVE GROUP’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). 

The MDEZIN CREATIVE GROUP will not allow any PIC to operate the DJI Phantom 2+UAS 

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

Phantom 2+ UAS training and currency requirements, that the PIC is able to safely operate the 

DJI Phantom 2+ UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances frompeople, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 

20 
hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during 

The MDEZIN CREATIVE GROUP’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 of total time asa UAS 

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

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

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

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

these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make

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

be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for 

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

Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior

documented flight experience that was obtained in compliance with 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, The MDEZIN CREATIVE GROUP will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 2+UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2+

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. 

21 
The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, The MDEZIN CREATIVE GROUP will ensure that the DJI Phantom 2+ UAS is in

an airworthy condition based upon the UAS ’s compliance with its operating documents and as 

stated in the conditions and limitations herein. 

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

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

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

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

altitude information of the DJI Phantom 2+ 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 The 

MDEZIN CREATIVE GROUP’s operation of the DJI Phantom 2+ UAS within visual line of sight, 

at 

or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

information will be generated by GPS equipment installed onboard the aircraft. Prior to each 

flight, a zero altitude initiation point is automatically established by the UAS at ground level. 

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

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

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

Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2+ UAS ; (2) 

the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, The MDEZIN CREATIVE GROUP will ensure that it will safely operate 

the battery powered DJI Phantom 2+ UAS during daylight hours in VFR conditions, with enough 

battery power to fly for a total duration of 23minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2+ UAS ; the 

limitations on the proposed flight operations; and the location of the proposed operations, will 

ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, 

safety will be ensured as the DJI Phantom 2+ UAS provide audible and visual warnings tothe PIC 

at the GCS when the UAS experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery 

22 
power. At the critically lowbattery level, the DJI Phantom 2+ UAS will descend and land automatically. 

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

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

of the UAS are considered. Relief has been granted for manned aircraft to operate at less than 

the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. 

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS , in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 

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

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, The MDEZIN CREATIVE GROUP submits that the equivalent level 

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

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because The MDEZIN CREATIVE GROUP will use trained technicians to perform maintenance, 

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

prescribed in the operating documents (i.e., the MDEZIN CREATIVE GROUP Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2+ Instruction Manual). Furthermore, The 

MDEZIN CREATIVE GROUP will document and maintain all maintenance records for the DJI 

Phantom 2+ 

UAS . 

Since the DJI Phantom 2+ UAS will be inspected as prescribed by the operating documents, The 

MDEZIN CREATIVE GROUP will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2+ User Manuals are 

attached hereto as Appendix A and B; a copy of the DJI Phantom 2+ UAS Maintenance LOG is 

attached hereto as Appendix C. 

Likewise, the exemption sought will not adversely affect safety because The MDEZIN CREATIVE GROUP will use trained technicians to perform maintenance, alterations or preventive 

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

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

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2+ UAS 

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. 

23 
In consideration of The MDEZIN CREATIVE GROUP’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2+ UAS , The MDEZIN 

CREATIVE GROUP submits that safety will not be adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). 

The FAA has previously granted relief specific to UAS in circumstances similar, in all material

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 

11161). 

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 

14 C.F.R. § 21.16 entitled Special Conditions, The MDEZIN CREATIVE GROUP requests that 

the FAA prescribe special conditions for the intended operation of the DJI Phantom 2+ UAS , 

which contain such safety standards that the Administrator finds necessary to establish a level of 

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) 

&(b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) 

& (b). Such special conditions will permit safe operation of the UAS for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will 

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

and further, provides the authority for such UAS to operate without airworthiness certification in

accordance with any requirements that must be established for the safe operation of the UAS in 

the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the DJI Phantom 2+ UAS , since the airworthiness regulations of 14 C.F.R. Part 21 

do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because 

of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions 

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

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

safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16. 

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

special conditions for Leading Edge’s intended operation of the DJI Phantom 2+ UAS , which 

contain such safety standards that the Administrator finds necessary to establish a level of safety

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

24 
61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

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

Rules From Which The MDEZIN CREATIVE GROUP Seeks Exemption: 

The MDEZIN CREATIVE GROUP seeks exemption from the requirements of 14 C.F.R 

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

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

A Brief Description Of The Nature Of The Exemption The MDEZIN CREATIVE GROUP 

Seeks: 

This exemption will permit The MDEZIN CREATIVE GROUP to commercially operate an 

Unmanned Aircraft System (UAS ) for the purpose of conducting aerial video and photography over certain areas of the United States. 

• Any Additional Information, Views, Or Arguments Available To Support The 

MDEZIN CREATIVE GROUP’sRequest. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS 

may operate safely in the NAS. As such, The MDEZIN CREATIVE GROUP’s request for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, 

as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further,

provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, The MDEZIN CREATIVE GROUP will operate the DJI Phantom 

2+ UAS safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security. 

CONCLUSION 

As set forth herein, The MDEZIN CREATIVE GROUP seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will 

permit safe operation of the DJI Phantom 2+ UAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial video and photography over certain areas 

of the United States. By granting this Petition, the FAAAdministrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing The MDEZIN CREATIVE GROUP to safely, 

efficiently, and economically operate the DJI Phantom 2+ UAS commercially within the NAS. 

25 
WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, The MDEZIN CREATIVE GROUP respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

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

(1) & (a)(2), and 91.417(a) & (b), and permit MDEZIN CREATIVE GROUP to operate the DJI 

Phantom 2+ UAS commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States. 

Dated: Jan, 2016 

Respectfully submitted, 

Dennis McDougall (owner)

MDEZIN CREATIVE 

GROUP

224 Pease Ct. Janesville WI 

53545

608-774-3623

dmcdougall@mdezin.com

Appendices: 

A – Link to DJI Phantom 2+ Manual: Click on link below 

http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

26 

B- List of Unmanned Aircraft Systems UAS

Make & Model Description N-# Weight

DJI Phantom 2+ 4 rotor electric N-127TQ reserved 4 lbs
27 

2. DJI Phantom 2+ - The operation of the DJI Phantom 2+ system is as follows.

1. Build Materials - Plastic, Aluminum and internal electrics.

2. Motor Configuration - The Phantom 2+ has a quadcopter configuration.

3. Payload - The Phantom 2+ it’s own integrated camera. Total Weight- 4lbs

4. Maintaining the Phantom 2+

I. Before each flight:

•	 1. Check all hardware to ensure it is securely tightened.

•	 2. Check that the motor is level and locked in place.

•	 3. Check the propeller to ensure it is tight and there are no visible signs of cracks, stress, 

and/or chips.

•	 Replace if propeller is questionable.

•	 4. Check all wiring to motors, motor controllers, batteries, and flight controller for signs 

of

•	 5. Check all navigational lighting to ensure it is properly working.

II. After 45 hours of flight

•	 1. Remove and check all motors and motor mounts for signs of wear and tear. Replace 

as necessary.

•	 2. Remove motor controllers and visually inspect and check for damage. Replace as 

necessary.

•	 3. Remove flight controllers and visually inspect and check for damage. Replace as necessary.

•	 4. Check for cuts, fraying, cracks, and/or loose/cold solder connections. Fix before flying.

•	 5. Check for updates to flight controller firmware. If available, install and perform a 

minimum of 15 test flights before conducting commercial work.

C- FAA Small Craft Registartion

D- General Operations
E- Flight Log Sheet
F - Maintenace Log Sheet