UNITED STATES OF AMERICA

 DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

ANNA BOLSHAKOVA

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF 

THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 

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

COMMERCIAL OPERATION OF DJI PHANTOM 3, DJI PHANTOM 2 VISION+, AND DJI 

INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE 

FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Submitted on June 21, 2015 

 

 

ANNA BOLSHAKOVA

606 SWALLOWTAIL DRIVE

FREDERICK, MD 21703

(301) 768-7455
TABLE OF CONTENTS 

Page 

GLOSSARY OF 

ABBREVIATIONS.................................................................................................................3 

SUMMARY............................................................................................................................. 4 

INTRODUCTION AND INTERESTS OF PETITIONER......................................................4 

BACKGROUND.....................................................................................................................5 

BASIS FOR PETITION...........................................................................................................6 

NAME AND ADDRESS OF PETITIONER................................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

ANNA BOLSHAKOVA SEEKS EXEMPTION..........................................................7 

THE EXTENT OF RELIEF ANNA BOLSHAKOVA SEEKS AND 

THE REASON ANNA BOLSHAKOVA SEEKS THE RELIEF.........................10

 

THE REASONS WHY GRANTING ANNA BOLSHAKOVA REQUEST

WOULD BE IN THE PUBLIC INTEREST .............................................................13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................15

CONCLUSION.......................................................................................................................21 
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 

DJI UAV manufacturer
ESC Electronic speed control

FPV First Person View 

LI-PO Lithium Polymer battery

RCV Radio Controlled vehicle 

SUMMARY

ANNA BOLSHAKOVA seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

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

(b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (FMRA). This exemption will permit ANNA BOLSHAKOVA to 

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial 

video and photography for real estate photography, and real estate fly-over video over certain 

areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is ANNA BOLSHAKOVA, and I am a drone operator (pilot) with expertise and 

knowledge in all aspects of operating multiple types of UAS'S along with camera set up and 

operation. ANNA BOLSHAKOVA also provides clients with the highest quality digital content 

for use in their commercial real estate listings. ANNA BOLSHAKOVA has 10 years of radio 

controlled helicopter experience.

The objective of ANNA BOLSHAKOVA’ aerial video and photography operations is to provide 

high quality imaging for a variety of commercial, and residential uses. ANNA BOLSHAKOVA 

will also provide knowledge of UAS and promote safe UAS operations. 
BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs

ANNA BOLSHAKOVA seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 are vertical 

takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross 

weight of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 

inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 2 

Vision+ has a maximum gross weight of approximately 2 pounds 13 ounces, while having a 

length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of

approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, 

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

approximately 42 knots. The DJI Phantom 3, Phantom 2 Vision+, and DJI Inspire 1UAs are 

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

The DJI Phantom 3, Phantom 2 Vision+, and DJI Inspire 1 UAs that will be operated by ANNA 

BOLSHAKOVA 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 Markings. 
BASIS FOR PETITION 

Petitioner, ANNA BOLSHAKOVA, pursuant to the provisions of the Federal Aviation 

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

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

Administrator to commercially operate the DJI Phantom 3, Phantom 2 Vision+, DJI Inspire 1 

UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(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, ANNA BOLSHAKOVA operation of DJI Phantom 3, DJI 

Phantom 2 Vision+, and DJI Inspire 1 UASs meets the conditions of FMRA Section 333 and 

therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. 

Accordingly, ANNA BOLSHAKOVA 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. 

ANNA BOLSHAKOVA submits that the requested relief is proper since an equivalent level of 

safety will be ensured. ANNA BOLSHAKOVA will use experienced personnel or technicians to 

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

techniques, and practices prescribed in the operating documents (i.e., and DJI Phantom 3, DJI 

Phantom 2 Vision+, and DJI Inspire 1 Instruction Manual). Furthermore, ANNA 

BOLSHAKOVA will document and maintain all maintenance records for the DJI Phantom 3, 

DJI Phantom 2 Vision+, and DJI Inspire 1 UASs. 

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

and limitations: Pilot in command, is requested by ANNA BOLSHAKOVA to the extent 

necessary to allow a Pilot in Command (PIC) who has demonstrated, by meeting minimum 

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

Vision+, and DJI Inspire 1 UASs in a manner consistent with this exemption, including evasive 

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

and structures. 

ANNA BOLSHAKOVA seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs do not require an 

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

BOLSHAKOVA submits that he will ensure that the DJI Phantom 3, DJI Phantom 2 Vision+,

and DJI Inspire 1 UASs are in an airworthy condition, prior to every flight, by determining that 

the UASs are in compliance with the operating documents (i.e, and DJI Phantom 3, DJI Phantom 

2 Vision+, and DJI Inspire 1 Instruction Manuals), and that the aircraft are in a condition for safe 

flight. 
ANNA BOLSHAKOVA also seeks an exemption from the requirements of Section 91.121, 

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

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

2 Vision+, and DJI Inspire 1 UAs will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the UA 

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

ANNA BOLSHAKOVA’S operation of the DJI Phantom 3v DJI Phantom 2 Vision+, and DJI 

Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety

equivalent to Section 91.121. 

Additionally, ANNA BOLSHAKOVA seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. ANNA BOLSHAKOVA 

submits that safety will not be affected by operation of the DJI Phantom 3, DJI Phantom 2 

Vision+, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions 

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

approximately 15.5 minutes to the first point of intended landing and, assuming normal cruising 

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

In accordance with 14 C.F.R. § 11.81, ANNA BOLSHAKOVA 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:

ANNA BOLSHAKOVA

606 Swallowtail Drive,

Frederick, MD 21703

(301) 768-7455

 Email: rimbaudy@gmail.com

B. The Specific Sections of 14 C.F.R. From Which ANNA BOLSHAKOVA Seeks 

Exemption.

1. ANNA BOLSHAKOVA Seeks Exemption from the Requirements of Section 

61.113(a) And (b).

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

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

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

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

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

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

connection with any business or employment if— 

a. The flight is only incidental to that business or employment; and

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

2. ANNA BOLSHAKOVA Seeks Exemption from The Requirements Of Section 

91.7(a). 

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

following: 

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

condition.

3. ANNA BOLSHAKOVA Seeks Exemption from The Requirements Of Section 

91.121. 

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

part: 

(i) 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 UAs Below 18,000 feet MSL, to:

a. The current reported altimeter setting of a station along the route 

and within 100 nautical miles of the aircraft; 

b. If there is no station within the area of this section, the current 

reported altimeter setting of an appropriate available station; or 

c. In the case of an aircraft not equipped with a radio, the elevation of 

the departure airport or an appropriate altimeter setting available before departure.

4. ANNA BOLSHAKOVA Seeks Exemption from The Requirements Of Section 91.151(b). 

(a) 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. ANNA BOLSHAKOVA Seeks Exemption from The Requirement Of Section 

91.405(a).

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

following: Each owner or operator of an aircraft— 

(i) Shall have that aircraft inspected as required and shall between required 

inspections have discrepancies repaired as required.
6. ANNA BOLSHAKOVA Seeks Exemption from The Requirements Of Section 

91.407(a)(1)

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

rebuilding, or alteration, subsection (a)(1), states the following: 

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

preventive maintenance, rebuilding, or alteration unless-- 

a. It has been approved for return to service by a person authorized 

under § 43.7 of this chapter [.] 

7. ANNA BOLSHAKOVA Seeks Exemption from The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

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

(i) 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 -- 

a. 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 

b. An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter. 

8. ANNA BOLSHAKOVA Seeks Exemption from the Requirements of Sections 

91.417(a) and 91.417(b). 

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

following: 

(i) 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: 

a. 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--

1. A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

2. The date of completion of the work performed; and 

3. The signature, and certificate number of the person approving the 

aircraft for return to service.

b. Records containing the following information:

1. The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

2. The current status of life-limited parts of each airframe, engine, 

propeller, rotor, and appliance.
3. The time since last overhaul of all items installed on the aircraft 

which are required to be overhauled on a specified time basis.

4. 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. 

5. 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. 

6. 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. 

c. The owner or operator shall retain the following records for the 

periods prescribed: 

1. The records specified in paragraph (a) 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) of this section shall 

be retained and transferred with the aircraft at the time the 

aircraft is sold. 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 ANNA BOLSHAKOVA Seeks And The Reason ANNA 

BOLSHAKOVA Seeks The Relief. 

1. Extent of Relief ANNA BOLSHAKOVA Seeks and the Reason ANNA 

BOLSHAKOVA Seeks Relief From Section 61.113(a) And (b). 

(a) 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 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: 

d. The flight is only incidental to that business or employment; and 

e. The aircraft does not carry passengers or property for compensation or 

hire. 

As set forth more fully below, ANNA BOLSHAKOVA submits that an 

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

Phantom 3 UAS, DJI Phantom 2 Vision+, or DJI Inspire 1 UAS unless that PIC has met certain 

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

the DJI Phantom 3, DJI Phantom 2 Vision+, or DJI Inspire 1 UAS in a manner consistent with 
the operations specifications as described in this exemption, including evasive and emergency 

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

structures. Further, ANNA BOLSHAKOVA submits that all flights of the DJI Phantom 3, DJI 

Phantom 2 Vision+, and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 

Petition: 

1. Will be incidental to ANNA BOLSHAKOVA'S business; and 

2. Will not carry passengers or property for compensation or hire. 

2. Extent Of Relief ANNA BOLSHAKOVA Seeks And The Reason ANNA 

BOLSHAKOVA Seeks Relief From Section 91.7(a).

3.

(a) Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow ANNA BOLSHAKOVA to determine that the DJI 

Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs are in airworthy 

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

operating documents (i.e., DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 

1 Instruction Manual). ANNA BOLSHAKOVA seeks the requested relief because 

the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs do not require 

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

Therefore, ANNA BOLSHAKOVA will ensure that the DJI Phantom 3, DJI 

Phantom 2 Vision+, and DJI Inspire 1 UASs are in airworthy condition based upon 

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

DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 Instruction Manual) 

prior to every flight, and further, determine that the aircraft are in condition for safe 

flight, as stated in the conditions and limitations below.

3. Extent Of Relief ANNA BOLSHAKOVA Seeks And The Reason ANNA 

BOLSHAKOVA Seeks Relief from Section 91.121. 

(a) Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 

UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the 

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), ANNA BOLSHAKOVA seeks the 

requested relief because the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 

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

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

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

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

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

DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UAs are equipped with a 
barometric pressure sensor and GPS equipment, which automatically ensures that a 

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

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

4. Extent Of Relief ANNA BOLSHAKOVA Seeks And The Reason ANNA 

BOLSHAKOVA Seeks Relief From Section 91.151(b). 

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

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

Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UAs during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), for a total 

duration of 15.5 minutes to the first point of intended landing and, assuming normal 

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

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

time duration of the battery powered DJI Phantom 3, DJI Phantom 2 Vision+, and 

DJI Inspire 1 UAs will severely constrain the practicality of any aerial video or still 

photo flight operations that ANNA BOLSHAKOVA proposes to conduct pursuant to 

this Petition. Significantly, as set forth below, the technical specifications of the DJI 

Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs, the DJI Phantom 3, DJI 

Phantom 2 Vision+, and DJI Inspire 1 operating documents, and ANNA 

BOLSHAKOVA’S proposed operating limitations, ensure that ANNA 

BOLSHAKOVA will safely operate the battery powered DJI Phantom 3, DJI 

Phantom 2 Vision+, and DJI Inspire 1 UAs during daylight hours in visual 

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

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

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

5. Extent Of Relief ANNA BOLSHAKOVA Seeks And The Reason ANNA 

BOLSHAKOVA Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

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

(a) 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, ANNA BOLSHAKOVA 

requests relief from these Sections because the DJI Phantom 3, DJI Phantom 2 

Vision+, and DJI Inspire 1 UASs do not require airworthiness certificates. As set 

forth more fully below, the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 

UASs meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, ANNA BOLSHAKOVA will use trained 

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

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

documents (i.e., ANNA BOLSHAKOVA Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 

Instruction Manual). Furthermore, ANNA BOLSHAKOVA will document and 

maintain all maintenance records for the DJI Phantom 3, DJI Phantom 2 Vision+, and 

DJI Inspire 1 UASs. 
D. The Reasons Why Granting ANNA BOLSHAKOVA 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 ANNA 

BOLSHAKOVA to safely, efficiently, and economically perform aerial video and photography 

of real estate properties over certain areas of the United States.

 Additionally, use of the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 

1 UASs will decrease congestion of the NAS, reduce pollution, crashes and accidents caused by 

pilot error and provide significant benefits to the economy. Notably, the benefits of ANNA 

BOLSHAKOVA’S proposed operation of the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI 

Inspire 1 UASs will be realized without implicating any privacy issues.

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

The DJI Phantom 3 and DJI Inspire 1 UAs are battery powered and serve as a 

safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain 

aerial imagery. By reducing the amount of manned aircraft needed to perform aerial 

acquisitions, an exemption allowing the use of a DJI Phantom 3, DJI Phantom 2 Vision+, or DJI 

Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air 

pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UAs do not require an airport to 

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

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

during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

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

Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 3, DJI Phantom 2 Vision+,

and DJI Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically 

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

photography flight operations. By using battery power and electric motors, the DJI Phantom 3, 

DJI Phantom 2 Vision+, and DJI Inspire 1 UASs produce no air pollution, and is the most viable 

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine 

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

20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3, DJI Phantom 2 Vision+, and 

DJI Inspire 1 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates 

noise pollution, as the UAs are propelled by battery powered electric motors, rather than an 

internal combustion engine. 

By using the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs to 

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

which is usually associated with traditional manned aircraft flight operations, will be 
substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UAs 

(weighing approximately 2 pounds 14 ounces and 6 pounds 7.5 ounces respectively, at their 

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

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

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).

4. Performing Aerial Video and Photography Operations With The DJI 

Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3, DJI Phantom 2 

Vision+, and DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the DJI Phantom 3, DJI Phantom 2 

Vision+, and DJI Inspire 1 UASs will allow United States based companies remain competitive 

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded 

aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in 

order to remain competitive. Operating the battery powered DJI Phantom 3, DJI Phantom 2 

Vision+, and DJI Inspire 1 UASs is one such technology that not only allows companies greater 

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

high operational cost of a traditional manned aircraft.

 By operating the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 

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

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

Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 

3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to 

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

abroad. 

5. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been 

conducted for decades, ANNA BOLSHAKOVA’S proposed operation of the DJI Phantom 3, 

DJI Phantom 2 Vision+, and DJI Inspire 1 UASs will not implicate any privacy issues. 

Specifically, the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs will be 

operated only in compliance with operating documents (i.e., Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 Instruction 

Manual) which requires property owner involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, 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 ANNA BOLSHAKOVA Seeks Exemption. 

1. Reasons Why The DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UAs 

Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333.

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

with the unmanned aircraft and its operation, ANNA BOLSHAKOVA’S operation of the 

DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs 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: 

(i) 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.

(ii) Assessment of Unmanned Aircraft Systems.--In making the determination 

under subsection (a), the Secretary shall determine, at a minimum—

(a) which types of unmanned aircraft systems (UAS), 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 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).

 (b) 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, ANNA BOLSHAKOVA submits that the DJI Phantom 

3 and, DJI Phantom 2 Vision+, DJI Inspire 1 UASs can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: 

(a) The characteristics of the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 

1 UASs; 
(b) The pilot certification requirement; and 

(c) The specific operating limitations. 

a. The Specifications Of The DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 

UASs Demonstrate Its Safe Characteristics. 

The DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs do not create a 

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

considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3, DJI Phantom 2 Vision+,

and DJI Inspire 1 UASs. 

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 UASs are set forth 

by the DJI Phantom 3 and DJI Inspire 1 Specifications and Data Sheets, attached.

ii. The DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs 

Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined 

Operational Area. 

The DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs may be operated in 

both manual and fully autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs is 

provided at pages 25-35 of the DJI Phantom 3, pages 11-12 of the DJI Phantom 2 Vision+, and 

pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals.

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

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

Navigation. 

When the Control Link is lost, the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI 

Inspire 1 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UAs do not reacquire control link data 

from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the 

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

shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are set 

forth at page 13 of the DJI Phantom 3, pages 27-28 of the DJI Phantom 2 Vision+, and page 13

of the DJI Inspire 1 User Manuals.

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

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

Phantom 2 Vision+, and DJI Inspire 1 GCS and flight control software is provided at pages 32-

43 of the DJI Phantom 3, pages 32-35 of the DJI Phantom 2 Vision+, and pages 40- 47 of the 

DJI Inspire 1 User Manuals.

b. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UASs Are Limited To The Line 

Of Sight Of A Certificated Pilot in Command With A Safety Observer. 
ANNA BOLSHAKOVA will only utilize pilots who comply with the FAA requirements 

the to act as a pilot in command (PIC) of the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI 

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

c. Flights Of DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs Will Be 

Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, ANNA BOLSHAKOVA proposes to commercially operate 

DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs for the special purpose of 

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

following specific operating limitations: 

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

aircraft described in the operating documents, rotorcraft UASs weighing less than 

55 pounds maximum gross weight: DJI Phantom 3, DJI Phantom 2 Vision+, and 

DJI Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other 

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

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

the purpose of aerial video and photography. 

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

4. The UA must be operated at an altitude of no more than 500 feet above ground 

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

unless a special request is made and approved by ATC. All altitudes reported to 

ATC must be in feet AGL.

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

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

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

certificate. 

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

permitted. 

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

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

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

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the functions 

prescribed in the operating documents. 

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

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments. 

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

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 
conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The 

operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that 

any update or revision would affect the basis upon which the FAA granted the 

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

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

questions arise regarding updates or revisions to the operating documents. 

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

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

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

maintenance has been performed and the UAS is found to be in a condition for 

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

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

aircraft records.

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

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

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

flight must make an entry in the aircraft records. 

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

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

sections of the operating documents.

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

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

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

requirements, in accordance with the operating documents. Maintenance, 

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

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

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

to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

17. The 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 

18. Operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. 

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

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

closest to proposed area of operations. Flights under special visual flight rules 

(SVFR) are not authorized. 

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

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

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

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

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

Administrator upon request. 

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

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

PIC.

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

accordance with the operating documents.

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

in accordance with the operating documents. 

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

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

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

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

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

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

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

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

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

level and potential transponder requirements. 

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

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

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

Markings must be as large as practicable. 

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

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

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

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

operating. These documents must be made available to the Administrator or any 

law enforcement official upon request. 

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

operations and activities at all times. 

30. The UAS may not be operated by the PIC from any moving device or vehicle. 31.

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

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

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

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

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

arises where nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

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

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

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

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

c. Operations nearer to the PIC, SO, operator trainees or essential persons do 

not present an undue hazard to those persons per § 91.119(a). 

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

permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

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

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

Accidents must be reported to the National Transportation Safety Board (NTSB) 

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

2. Reasons Why an Exemption From The Requirements Of Section 61.113(a) and (b) 

Would Not Adversely Affect Safety. 

ANNA BOLSHAKOVA 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, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs unless that PIC has demonstrated, 

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

operate the DJI Phantom 3, DJI Phantom 2 Vision+, or DJI Inspire 1 UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

 Considering ANNA BOLSHAKOVA’S proposed area of operations, the 

operating limitations set forth-above, and the airmanship skills necessary to safely operate the 
DJI Phantom 3, DJI Phantom 2 Vision+, or DJI Inspire 1 UAS, ANNA BOLSHAKOVA submits 

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

correlate to the airmanship skills necessary for BLAKE J COPPINGER’ 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.

ANNA BOLSHAKOVA will not allow any PIC to operate the DJI Phantom 3, DJI Phantom 2 

Vision+, or DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flighthour requirements or the DJI Phantom 3, DJI Phantom 2 Vision+, or DJI Inspire 1 UAS training 

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

Phantom 2 Vision+, or DJI Inspire 1 UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner 

consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those 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). 

CONCLUSION

ANNA BOLSHAKOVA seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

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

operation of the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs commercially, 

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

photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing ANNA 

BOLSHAKOVA to safely, efficiently, and economically operate the DJI Phantom 3 and DJI 

Inspire 1 UASs commercially within the NAS. WHEREFORE, in accordance with the Federal 

Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, ANNA 

BOLSHAKOVA 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 Leading Edge to 

operate the DJI Phantom 3, DJI Phantom 2 Vision+, and DJI Inspire 1 UASs commercially for 

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

Dated: June 21, 2015 

 Submitted by 

 ANNA BOLSHAKOVA