Beukman 1

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Jonathan Beukman

Dragonfly Aerial

Yash Villas

Pointe Aux Piments

Mauritius 

742UC001 November 14, 2015

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the

Federal Aviation Regulations from: 14 CFR 21 subpart H; 14 CFR 45.23(b); 14 CFR

61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2); 14 CFR 91.103; 14 CFR 91.109; 14

CFR 91.119(c); 14 CFR 91.121; 14 C.F.R 91.145(b); 14 CFR 91.151(a); 14 CFR 91.203 (a)

and (b); 14 CFR 91.405 (a); 14 CFR 91.407 (a) (1); 14 CFR 91.409 (a)(2); 14 CFR

91.417(a) and (b)

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform

Act”) and 14 CFR Part 11. I, Jonathan Beukman, operator of Unmanned Aircraft Systems

(sUAS), DJI Inspire 1 and DJI Phantom 2, hereby applies for an exemption from the listed 

Federal Aviation Regulations (“FARs”) to allow commercial operation of these sUAS, so long as 

such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333.

Commercial operation of sUAS, as described herein, which are equipped with camera(s)

and sensors, would operate in the following manner:

• Aerial photography and/or video for public and/or private use including real estate, 

architecture, land surveying, agriculture, construction, engineering and other related 

professional activities.

• Aerial video and/or photography for public and/or private use including television, closed 

set and motion picture filming, cinematography, and news gathering.

• Aerial inspection/photography of residential/commercial structures under contract with 

the owners or local government authority.

• Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities 

or government have requested it by contract or donation.

• The ability to offer training to persons individually or belonging to both private and/or 

public organizations that have interests in the safe use and application of a UAS to 

enhance the safety of the National Airspace System (NAS) as well as for the protection 

of persons and property.

As described fully below, the requested exemption would permit the operation of sUAS

under controlled conditions in the NAS that would be a) limited b) controlled c)

predetermined and d) will provide safety enhancements to the already safe operations in the

industry presently using conventional aircraft. Approval of this exemption would thereby

enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s)

responsibilities to “....establish requirements for the safe operation of such aircraft systems
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in the national airspace system.”

The name, address, and Visa identity of the applicant is:

Jonathan Beukman

Dragonfly Aerial

Yash Villas

Pointe Aux Piments

Mauritius 742UC001

Email: dragonflyaerial@gmail.com

South African Passport Holder : A01536218

USA Visa Holder : J7811059

Visa Type/Class : R B1/B2

Expiration date : 31 May 2025

Regulations from which the exemption is requested:

14 CFR Part 21 subpart H

14 CFR 45.23 (b)

14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119 (c)

14 CFR 91.121

14 C.F.R 91.145(b)

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 91.407 (a) (1)

14 CFR 91.409 (a) (2)

14 CFR 91.417 (a) & (b)

Jonathan Beukman will operate the DJI Inspire 1, Model T600, with a total weight of

2935g or 6.47lbs. The dimensions are 438mm x 451mm x 301mm or 17.24inch x 17.75inch

x 11.85inch. Under still air, the maximum speed is no more than 22m/s or 49mph with a

cruising speed of 11m/s or 25mph. The DJI Inspire 1 has the ability to hover and move

along a vertical and horizontal plane simultaneously. The DJI Inspire 1 has four motors,

Motor Model DJI 3510, powered by a 6-cell 4500mAh or 5700mAh Lithium Polymer 

battery. There are four propellers, Propeller Model DJI 1345, in use. The DJI Inspire 1 will

be controlled with the C1 remote controller with an operating frequency of 2.400GHz –

2.483GHz. The live video feed will have an operating frequency of 5.728GHz – 5.850GHz.

The applicant will operate the UAS in line of sight within a closed off and predetermined

area owned and/operated by the property representative. The DJI Inspire 1 has an app called

The DJI GO App which allows the Pilot to monitor all aspects of the flight on the Heads Up 

Display (HUD). Attached along with this exemption request are all of the necessary documents 

and safety features of the DJI Inspire 1.

Jonathan Beukman will operate the DJI Phantom 2, with a total weight of 1000g or 2.20 lbs. The 

dimensions are 350mm x 350mm x 190mm or 13.8inch x 13.8inch x 7.5 inch. Under still air, the 

maximum speed is no more than 15m/s or 33.5mph with a cruising speed of 9 m/s or 20.13 
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mph. The DJI Phantom 2 has the ability to hover and move along a vertical and horizontal plane

simultaneously. The DJI Phantom 2 has four motors, Motor 920 Kv, 12N, 14P Configuration, 

powered by a 3-cell 5200 mAh Lithium Polymer battery. There are four propellers, Propeller 9 

inch self-tightening, in use. The DJI Phantom 2 is controlled with the 2.4 GHz remote controller 

with an operating frequency of 2.400GHz – 2.483GHz. The live video feed will have an 

operating frequency of 5.728GHz – 5.850GHz. The applicant will operate the UAS in line of 

sight within a closed off and predetermined area owned and/operated by the property 

representative.

Given the small sizes of the sUAS and the controlled environments provided, the proposed

operations will adhere to the Reform Act’s safety requirements. The approval of this

application presents no national security issues. Regarding the level of safety surrounding

the proposed operations and the public benefit, reduction in environmental impacts,

including but not limited to reduced emissions and noise, the grant of the requested

exemption is in the public interest. Accordingly the applicant requests that the FAA grant

the requested exemption with minimum delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The operation limitations proposed here are for an equivalent or higher level of safety. These

are the limitations and conditions to which the applicant agrees to adhere when conducting 

commercial operations under the FAA issued exemption as set forth in the Flight Operations 

Manual (FOM) include:

• The UAS will weigh less than 55 lbs.

• The UAS will have a maximum operating speed of no more than 50mph.

• Flights will be operated within line of sight of the Pilot in Command (PIC) and/or Visual 

Observer (VO).

• Maximum flight time for each operational flight will be 25 minutes. Flights will be 

terminated at 30% battery power reserve or 25 minutes of flight time whichever occurs 

first.

• Flights will be operated at an altitude of no more than 400 feet Above Ground Level 

(AGL) and not more than 200 feet above an elevated platform from which filming is 

planned.

• Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) 

and may include but not limited to a Camera Operator.

• The UAS pilot will be a designated Pilot in Command (PIC) and hold a 

Sport/Recreational Pilot’s License. 

 A briefing will be performed regarding the planned UAS operations prior to each day’s 

flight consisting of all the days’ production activities.

The operator will not conduct any careless or reckless operations. A flight will be terminated as 

immediately as possible if the safety of the operation cannot be maintained. Prior to each flight, 

the operator will conduct a pre-flight inspection and determine the UAS is in condition for safe 

flight. The pre-flight inspection must account for all potential discrepancies: for example,

inoperable components, items, or equipment. 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 logged, and the UAS is found to be in a condition for safe 

flight.

 The operator will not operate any UAS if a physical or mental condition would prevent 

the safe operation of that aircraft.
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 The operator will be responsible for seeing and avoiding all other users of the NAS in 

which the UAS is operating.

 The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

 The operator must follow the UAS manufacturer's maintenance: overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

 The holder of this exemption will follow manufacturer's safety bulletins for each UAS 

operated under this exemption.

• The flights will occur no closer than a 5 mile radius of the geographic center/Airport 

Reference Point (ARP) of a tower (controlled or uncontrolled) airport.

• If operations will be within a 5 mile radius of the geographic center/ ARP of a tower 

(controlled or uncontrolled) airport the respective airports will be contacted to advise

them of the estimated flight time, flight duration, elevation of flight and other pertinent 

information.

• The operator will file FAA Form 7711-1, or its equivalent, as modified in light of the 

requested exemption, with the appropriate local Flight Standards District Office (FSDO) 

no more than 72 hours but no less than 48 hours, from planned operation.

• The operator will obtain verbal/written consent of all persons involved with the planned 

operation and ensure that only consenting persons will be allowed within 100 feet of the 

flight operation. The radius may be reduced to 30 feet, based upon an equivalent level 

of safety determination, as required under the FOM. With the advanced permission of 

the FSDO, operations at closer range may be approved.

• The PIC and VO will have been trained in operation of UAS and receive up-to-date 

information for the particular UAS to be operated.

• The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

• Written and/or verbal permission and permits will be obtained from territorial, state, 

county or city jurisdictions, including law enforcement, fire or other appropriate 

governmental agencies.

• If the UAS loses communications with the remote controller or loses GPS signal, the 

UAS will have the capability to return to a pre-determined location within a designated 

location and land autonomously. The operator will set this pre-determined location within 

the private or controlled-access property as to minimize any possible contact with 

objects.

 The UAS will have the capability to abort a flight in case of unpredicted obstacles, 

weather, or emergencies.

 The operator is prohibited from beginning a flight (considering wind and forecast weather 

conditions and solar activity) unless there is enough available power for the UA to 

conduct the intended operation, and to operate after that with at least 25% energy 

reserves, or with the reserve power recommended by the manufacturer, whichever is 

greater.

 The operator will perform training tests, in a designated training area as prescribed 

herein, to assess the true energy characteristics of the specific UAS battery system to 

determine the actual flight time for reserve battery.

 All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative.

 The exemption holder will be responsible to report to the FAA any small UAS operation 

that results in: (1) any injury to a person; or (2) damage to property other than the small 

unmanned aircraft. The report would have to be made within 10 days of the operation 

that resulted in injury or damage to property. Accidents will be reported to the National 
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Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

OPERATIONS FOR CLOSED-SET MOTION PICTURE AND TELEVISION FILMING AND 

PRODUCTION INCLUDE THE FOLLOWING LIMITATIONS:

 The operator must have a motion picture and television operations manual (MPTOM) in 

his/her possession.

 At least 3 days before aerial filming, the operator of the UAS must submit a written Plan 

of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the 

area of proposed filming. The 3-day notification may be waived with the concurrence of 

the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming;

c. Name and phone number of the person responsible for the on-scene operation of the 

UAS;

d. Make, model, and serial or N-Number of UAS to be used;

e. A statement that the operator has obtained permission from property owners and/or 

local officials to conduct the filming production event; the list of those who gave 

permission must be made available to the inspector upon request;

f. Signature of operator or representative; and

g. A description of the flight activity, including maps or diagrams of any area, city, town, 

county, and/or state over which filming will be conducted and the altitudes essential to 

accomplish the operation.

 Flight operations may be conducted over/near participating persons consenting to be 

involved and necessary for the filming production, as specified in the operator's MPTOM.

14 C.F.R. PART 21, SUBPART H: AIRWORTHINESS CERTIFICATES 

14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the 

procedural requirements for the issuance of airworthiness certificates as required by FAR 

§91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be 

utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt

aircraft from the requirement for an airworthiness certificate, upon consideration of the size,

weight, speed, operational capability, and proximity to airports and populated areas of the

particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated

without an airworthiness certificate, in the restricted environment and under the conditions

proposed, will be at least as safe, or safer, than a conventional aircraft (fixed wing or

rotorcraft) operating with an airworthiness certificate without the restrictions and conditions

proposed.

The sUAS to be operated hereunder are less than 55 lbs. fully loaded, carry neither a pilot nor
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passenger, carry no explosive materials or flammable liquid fuels, and operate exclusively

within a secured and designated area. Unlike other civil aircraft, operations under this

exemption will be tightly controlled and monitored by both the operator and under the

requirements and in compliance with local public safety requirements. The FAA will have

advance notice of all operations. These safety enhancements provide a greater degree of

safety to the public and property owners than conventional operations conducted with

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of

these same criteria demonstrates that there is no credible threat to national security posed by

these sUAS, due to their size, speed of operation, location of operation, lack of explosive

materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (B). MARKING OF THE AIRCRAFT

The regulation requires:

When marks include only the Roman capital letter "N" and the registration number is

displayed on limited, restricted or light-sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that aircraft near each

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than

6 inches high, the words "limited," "restricted," "light-sport," "experimental," or

"provisional," as applicable. Even though the UAS will have no airworthiness certificate, an 

exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station 

on which the word “Experimental” can be placed. Given the size of the UAS, two-inch lettering 

will be impossible. The word “Experimental” will be placed on the fuselage in compliance with

§45.29 (f). The equivalent level of safety will be provided by having the UAS marked on its 

fuselage as required by §45.29 (f) where the pilot, observer and others working with the UAS 

will see the identification of the UAS as “Experimental.”

14 C.F.R. § 61.113 (A) AND (B): PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PILOT 

IN COMMAND. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot certificate may act

as a pilot in command of an aircraft that is carrying passengers or property for compensation 

or hire. Jonathan Beukman may achieve an equivalent level of safety as achieved by current 

Regulations because the applicant’s sUAS do not carry any pilots or passengers nor

property. The risks attendant to the operation of sUAS are far less than the risk levels inherent

in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will have a 

Sport/Recreational Pilot License along with a minimum of 20 hours of flight time which meet the 

safety levels in relation to 14 CFR 61.113 (a) & (b). The operation and limitations set forth in the 

FOM will equate to the safe operation of the UAS.

14 C.F.R. §91.7(A): CIVIL AIRCRAFT AIRWORTHINESS.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, no FAA regulatory standard will exist for determining airworthiness.

Given the size of the aircraft for maintenance and use of safety check lists prior to each

Flight, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (B) (2): CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT.

Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft ... (2)

for which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter,

unless there is available in the aircraft a current approved airplane or Rotorcraft Flight

Manual, approved manual material, markings, and placards, or any combination thereof.

The sUAS, given their size and configuration, have no ability or place to carry such a flight
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manual on the aircraft, not only because there is no pilot on board, but because there is no

room or capacity to carry such an item on the aircraft. The equivalent level of safety will be

maintained by keeping the flight manual at the ground control point where the pilot flying

the UAS will have immediate access to it. If for some reason the Pilot forgets the flight

manual, the DJI GO app has all documentation indicated in the hard copy manual,

electronically built into the smart phone or tablet application.

14 C.F.R. § 91.103: PREFLIGHT ACTION.

This regulation requires each pilot in command to take certain actions before flight to insure

the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the

aircraft, an exemption will be needed. The PIC will take all actions as stated in the FOM in

Section 4 under Normal Procedures, including but not limited to, reviewing weather, flight

battery requirements, landing and takeoff distances and aircraft performance data before

initiation of flight. Before the aircraft takes flight, a home GPS location will be set, so that if for 

any reason the aircraft becomes disoriented in flight, it can return safely to home.

14 C.F.R. §91.109: FLIGHT INSTRUCTION.

Section 91.103 provides that no person may operate a civil aircraft (except a manned free

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls. UAS and remotely piloted aircraft, by their design, do not have fully functional dual

controls. Flight control is accomplished through the use of a control box that communicates 

with the aircraft via radio communications. The FAA has approved exemptions for flight

training without fully functional dual controls for a number of aircraft and for flight

instruction in experimental aircraft. The equivalent level of safety is provided by the fact that

neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the

aircraft.

14 C.F.R. §91.119: MINIMUM SAFE ALTITUDES.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d)

allows helicopters to be operated at less than the minimums prescribed, provided the person

operating the helicopter complies with any route or altitudes prescribed for helicopters by

the FAA. As this exemption is for sUAS that are helicopters, and the exemption requests

authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated

platform from which filming is planned, an exemption may be needed to allow such

operations. As set forth herein, the sUAS will never operate at higher than 400 AGL with the

exception that in circumstances where the sUAS are used to survey or photograph a structure

whose height exceeds 400 feet AGL, the sUAS will not be operated more than 200 feet above

the highest point on the structure. They will, however, be operated in a restricted area with

security perimeter, where buildings and people will not be exposed to operations without

their pre-obtained consent. They also may be operated over open water close to shore keeping 

a distance of 500 feet as indicated in Section 91.119 (c).

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as

well as the location where they are operated. No flight will be taken without the permission of

the property owner or local officials. Because of the advance notice to the property owner

and participants in the filming activity, all affected individuals will be aware of the planned

flight operations. Compared to flight operations with aircraft or rotorcraft weighting far more

than the maximum 55lbs. proposed herein and the lack of flammable fuel, any risk

associated with these operations is far less than those presently presented with conventional

aircraft operating at or below 500 AGL. In addition, the low-altitude operations of the sUAS

will ensure separation between these UAS operations and the operations of conventional
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aircraft that must comply with Section 91.119.

14 C.F.R. §91.121 ALTIMETER SETTINGS..

This regulation requires each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an

appropriate altimeter setting available before departure.” As the sUAS may not have

barometric altimeters, but instead a GPS altitude read out, an exemption may be needed. An

equivalent level of safety will be achieved by the operator, pursuant to the safety check list

and live flight data monitoring, confirming the altitude of the launch site shown on the GPS

altitude indicator before flight. The DJI Inspire 1 uses DJI Vision Positioning. It is a

positioning system that uses ultrasonic and image data to help the aircraft identify its current

position. With the help of Vision Positioning, the Inspire 1 can hover in place more precisely

and fly indoors or in other environments where there is no GPS signal available. The main

components of DJI Vision Positioning are located on the bottom which include two sonar 

sensors and one monocular camera. This provides a significant level of safety.

14 C.F.R §91.145(B) MANAGEMENT OF AIRCRAFT OPERATIONS IN THE VICINITY OF 

AERIAL DEMONSTRATIONS 

CFR 91.145 states:

(b) In deciding whether a temporary flight restriction is necessary for an aerial demonstration 

not listed in paragraph (a) of this section, the FAA considers the following factors:

(1) Area where the event will be held.

(2) Effect flight restrictions will have on known aircraft operations.

(3) Any existing ATC airspace traffic management restrictions.

(4) Estimated duration of the demonstration.

(5) Degree of public interest.

(6) Number of spectators.

(7) Provisions for spectator safety.

(8) Number and types of participating aircraft.

(9) Use of mixed high and low performance aircraft.

(10) Impact on non-participating aircraft.

(11) Weather minimums.

(12) Emergency procedures that will be in effect.

If Jonathan Beukman intends to use the sUAS to cover demonstrations or news reporting from 

outside the activity, coordination will be completed by contacting the FSDO prior to the event to 

ascertain the presence of any other unmanned activities. Flight activity will be conducted based 

on safety and with particular attention to the avoidance of overflight of large concentrations of 

people. However, specific relief from this regulation is still necessary to ensure compliance with

FARs.

14 C.F.R. § 91.151(A): FUEL REQUIREMENTS FOR FLIGHT IN VFR CONDITIONS.

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 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 -(1) During

the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45

minutes.”

The battery powering the UAS provides approximately 25 minutes of powered flight. To

meet the 30 minute reserve requirement in 14 CFR §91.151, UAS flights would be limited to

approximately 25 minutes in length. Given the limitations on the UAS’s proposed flight area
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and the location of its proposed operations within a predetermined area, a longer time frame

for flight in daylight or twilight VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior

exemptions. Operating the UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less than

30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was

intended to alleviate given the size and speed of the small UAS. Additionally, limiting UAS

flights to 10 minutes would greatly reduce the utility for which the exemption will be

granted. Applicant believes that an equivalent level of safety can be achieved by limiting

flights to 25 minutes or 30% of battery power— whichever happens first. This restriction

would be more than adequate to return the UAS to its planned landing zone from anywhere

in its limited operating area.

14 C.F.R. §91.203 (A) AND (B): CARRYING CIVIL AIRCRAFT CERTIFICATION AND 

REGISTRATION.

The regulation provides in pertinent part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within

it the following:

(1) An appropriate and current airworthiness certificate. . . .

(b) No person may operate a civil aircraft unless the airworthiness certificate required by

paragraph (a) of this section or a special flight authorization issued under §91.715 is

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The UAS fully loaded weigh no more than 55 lbs. and are operated without an onboard pilot.

As such, there is no ability or place to carry certification and registration documents or to

display them on the UAS.

An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the UAS will have immediate access to them, to the

extent they are applicable to the UAS. Again, if Pilot forgets documents, all documents can

be achieved via the DJI GO App.

14 C.F.R. §91.405 (A); 407 (A) (1); 409 (A) (2); 417(A) & (B): MAINTENANCE INSPECTIONS.

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the aircraft in compliance

with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate,

these sections will not apply to the applicant. Maintenance will be accomplished by the

operator pursuant to the flight manual and operating handbook. An equivalent level of safety

will be achieved because the UAS is very limited in size and will carry a small payload and

operate only in restricted areas for a limited period of time. If mechanical issues arise the

UAS can land immediately and will be operating from no higher than 400 feet AGL. The

operator will ensure that the UAS is in working order prior to initiating flight, perform

required maintenance, and keep a log of any maintenance performed. Most importantly, the

operator is the person most familiar with the aircraft and best suited to maintain the aircraft 

in an airworthy condition to provide the equivalent level of safety.
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An equivalent level of safety will be achieved because maintenance and inspections will be

performed in accordance with the UAS Manufacturer's User Manual. As provided in the

FOM, the operator will ensure that the UAS is in working order prior to initiating flight and

perform required maintenance needed.

PUBLIC INTEREST.

Use of the UAS in lieu of a manned aircraft would enhance safety and reduce environmental 

impact compared to similar operations conducted with much larger fuel laden manned aircraft. 

Additionally, the use of UAS to facilitate commerce can help to encourage economic growth. 

Operations for this petition will enable service for property owners or their designees seeking an 

enhanced perspective for characteristics, amenities, and benefits of their desired photographic 

subjects that cannot be displayed through ground level videography/photography. Aerial 

photography is a valuable marketing tool that can facilitate increased commerce and enhance 

personal photography. Crop surveying and inspections could lead to decreased use of 

pesticides and fertilizer, conservation of water, increased crop yields and decreased costs. 

Aerial surveying and inspections can increase work site efficiency, improve volumetric 

estimations, and reduce risk.

ADDITIONAL INFORMATION.

The applicant, Jonathan Beukman, has been involved in the building and the piloting of remote

controlled aircraft for more than 3 years. He has logged more than 150 hours on sUAS since 

2012. He has executed hundreds of takeoffs and landings, and has demonstrated continuous 

proficiency over the last three years. He currently has logged more than 30 hours on the Inspire 

1 between the built in flight simulator on the DJI GO App that simulates the true functionality of 

the aircraft to authentic flying in real life scenarios. Jonathan Beukman wishes to utilize the 

sUAS to their fullest potential within the constraints of this request, without the long turnaround 

time associated with additional exemptions. The petitioner plans to offer services to individuals 

or companies seeking to enhance their business in a safe and lawful way. The petitioner has 

been working in project management in South Africa and Mauritius for 13 years; he knows there 

is extensive demand for lawful aerial photography and videography to complete multifaceted 

projects in a cost effective, quick manner. The primary pilot, Jonathan Beukman, has an indepth understanding of the capabilities and safety concerns involved in using this technology as 

an asset to the community, whereby future pilots can be educated in a safe environment. The 

satisfaction of criteria provided in Section 333 of the Reform Act of 2012 provides a level of 

safety that should be satisfactory to the FAA and general public. In view of the beneficial 

advantages to public safety, Jonathan Beukman of Dragonfly Aerial respectfully submits this 

Section 333 exemption request for allowing the commercial operations of these sUAS.

DJI Inspire 1 FCC ID: SS3-WM6101410

DJI Phantom 2 Model No: P330Z

Jonathan Beukman

(electronic signature)