Summary

Phillip Colling 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 Phillip Colling to operate an Unmanned

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

for film sets, real estate photography, special events, school events, wedding videography, and

landscape over certain areas of the United States.

Introduction and Interests of the Petitioner

My name is Phillip Colling and I am a freelance videographer and video production

teacher at Hendersonville High School in Hendersonville, Tennessee. Phillip Colling has two

years of videography and photography experience, and one year of video production teaching

experience. The main objectives of Phillip Colling’s aerial video and photography operations is

to provide the highest quality imagery for a wide range of commercial, public, residential, and

potentially private uses. Phillip Colling will be use the Unmanned Aircraft System to focus

primarily on providing services for:

● Wedding Videography and Photography

● Music Video Videography and Photography

● Educational Event and Instruction Videography and Photography

● Community Events Videography and Photography

● Real Estate Videography and Photography

● Coverage of outdoor only sporting events

● Motion Picture Filming

● Land Survey and Appraisals
Background

Unmanned Aircraft System: DJI Phantom 3 Standard UAS

Phillip Colling seeks an exemption to operate DJI systems for compensation or hire within the

NAS. The DJI Phantom 3 is a 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 3 pounds 11 ounces, while having a

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

approximately 29 knots.

The DJI Phantom 3 UAS are equipped with four main rotors; driven by Lithium Polymer

battery powered electric motors. The DJI Phantom 3 UAs that will be operated by Phillip Colling,

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, Phillip Colling, 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 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, Phillip Colling operation of DJI Phantom 3 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, Phillip Colling 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.

Phillip Colling submits that the requested relief is proper since an equivalent level of

safety will be ensured. Phillip Colling 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 3 Instruction Manual). Furthermore, Phillip Colling will document and

maintain all maintenance records for the DJI Phantom 3 UAS.

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

privileges and limitations: Pilot in command, is requested by Phillip Colling 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 flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 UASs

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

maintaining appropriate distances from people, vessels, vehicles and structures.
Phillip Colling seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the DJI Phantom 3 UAS do not require an airworthiness certificate in accordance with

14 C.F.R. Part 21, Subpart H. As such, Phillip Colling submits that he will ensure that the DJI

Phantom 3 UAS are in an airworthy condition, prior to every flight, by determining that the UASs

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

Phantom 3 Instruction Manual), and that the aircraft are in a condition for safe flight.

Phillip Colling also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI Phantom 3 UA will not have a typical barometric altimeter

onboard. However, altitude information of the DJI Phantom 3 UA 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 Phillip Colling's operation of the DJI Phantom 3 UAS within visual

line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, Phillip Colling seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Phillip Colling submits that

safety will not be affected by operation of the DJI Phantom 3 UA during daylight hours in visual

meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly

for a total duration of approximately 13.5 minutes to the first point of intended landing and,

assuming normal cruising speed, to fly after that for at least 4.5 minutes. In accordance with 14

C.F.R. § 11.81, Phillip Colling provides the following information in support of its petition for

exemption: A.

A. Name and Address of Petitioner:
Phillip Colling

101 Brierfield Way

Hendersonville, TN 37075

815­922­2016

phillipcolling@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Phillip Colling Seeks Exemption.

1. Phillip Colling 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 may that person,

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

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

with any business or employment if—

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

not carry passengers or property for compensation or hire.

2. Phillip Colling Seeks Exemption From The Requirements Of Section 91.7(a).

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

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

3. Phillip Colling 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.

4. Phillip Colling 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. Phillip Colling 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. Phillip Colling 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. Phillip Colling 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. Phillip Colling 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 100­hour, 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

life­limited 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. (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 Phillip Colling Seeks And The Reason Phillip Colling

Seeks The Relief. ​1. Extent Of Relief Phillip Colling Seeks And The Reason Phillip Colling

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

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

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

level certificate, as well as a current and valid airman medical certificate, and who has met

certain flight­hour 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, Phillip Colling submits that an equivalent level of safety will

be maintained because no PIC will be allowed to operate the DJI Phantom 3 UAS unless that
PIC has met certain flight­hour and currency requirements, demonstrating that the PIC is able to

safely operate the DJI Phantom 3 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, Phillip Colling submits that all flights of the DJI Phantom 3 UAS conducted by

the PIC pursuant to the grant of this Petition: (1) will be incidental to Phillip Colling's business;

and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief Phillip Colling Seeks And The Reason Phillip Colling Seeks

Relief From Section 91.7(a).

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

required to allow Phillip Colling to determine that the DJI Phantom 3 UAS are in airworthy

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

documents (i.e., the Phillip Colling Aerial Operations Manual, Monthly Maintenance Log, and

DJI Phantom 3 Instruction Manual). Phillip Colling seeks the requested relief because the DJI

Phantom 3 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part

21, Subpart H. Therefore, Phillip Colling will ensure that the DJI Phantom 3 UAS are in airworthy

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

Log, and DJI Phantom 3 Instruction Manual) prior to every flight.

3. Extent Of Relief Phillip Colling Seeks And The Reason Phillip Colling 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 3UAS, 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), Phillip Colling seeks the requested relief because the DJI Phantom 3 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 UA 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 heads­up display of the GCS.

4. Extent Of Relief Phillip Colling Seeks And The Reason Phillip Colling Seeks

Relief From Section 91.151(b).

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

requested to the extent required to allow flights of the battery powered DJI Phantom 3 UA

during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR),

for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 4.5 minutes. Phillip Colling seeks the requested relief

because without an exemption from Section 91.151(b), the flight time duration of the battery

powered DJI Phantom 3 UA will severely constrain the practicality of any aerial video or still

photo flight operations that Phillip Colling proposes to conduct pursuant to this Petition.

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

operating documents, and Phillip Colling's proposed operating limitations, ensure that Phillip

Colling will safely operate the battery powered DJI Phantom 3 UA during daylight hours in visual

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to
fly for a total duration of 15 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 5 minutes.

5. Extent Of Relief Phillip Colling Seeks And The Reason Phillip Colling 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, Phillip Colling requests relief from these

Sections because the DJI Phantom 3 UAS do not require airworthiness certificates. As set forth

more fully below, the DJI Phantom 3 UAS meet the conditions of FMRA Section 333 for

operation without an airworthiness certificate. Accordingly, Phillip Colling 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

Phillip Colling Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3

Instruction Manual). Furthermore, Phillip Colling will document and maintain all maintenance

records for the DJI Phantom 3 UAS.

D. The Reasons Why Granting Phillip Colling's Request Would Be In The Public

Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Phillip Colling to

safely, efficiently, and economically perform aerial video and photography of construction sites,

real estate, and landscape over certain areas of the United States. Additionally, use of the DJI

Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide significant

benefits to the economy. Notably, the benefits of Phillip Colling’s proposed operation of the DJI

Phantom 3 UAS will be realized without implicating any privacy issues.
1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 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 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

UA 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

UAS.

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned aircraft,

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

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

power and electric motors, the DJI Phantom 3 UAS produce no air pollution, and is the most

viable environmentally cconscious alternative to the cabin class, six cylinder internal combustion

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

approximately 20­30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 UA, 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 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 3 UA (weighing

approximately 2 pounds 11 ounces at their maximum gross weights with lengths of 16 inches

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

damage to life and property on the ground, and in the air, compared to the manned aircraft that

typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

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

UAS Will Benefit The Economy.​

In addition to being safe and efficient, the DJI Phantom 3 UAS are also an economical

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of

the DJI Phantom 3 UAS will allow United States based companies, like Phillip Colling, to remain

competitive and contribute to the 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 UAS is

one such technology 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 UAS, companies such as Phillip Colling, 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 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, Phillip Colling's proposed operation of the DJI Phantom will not implicate any privacy

issues. Specifically, the DJI Phantom UAS will be operated only in compliance with operating

documents (i.e., the Phillip Colling Aerial Operations Manual, Monthly Maintenance Log, and

DJI Phantom 3 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 Phillip Colling 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, Phillip Colling's operation of the DJI Phantom 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. (b) Assessment of Unmanned Aircraft Systems.­­In making

the determination under subsection (a), the Secretary 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, Phillip Colling submits that the DJI Phantom 3 UAS can

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by:

(a) the characteristics of the DJI Phantom 3 UAS; (b) the pilot certification requirement; and (c)

the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe

Characteristics.
The DJI Phantom 3 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 UAS.​

The technical specifications of the DJI Phantom are set forth by the UASs are set forth

by the DJI Phantom Specifications and Data Sheet. Exhibit A and B.

ii. The DJI Phantom UASs Autonomous Flight and Navigation Modes Enable The

UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 UAS 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 UAS

is provided at pages 25­35 of the DJI Phantom 3.

1 User Manuals, attached hereto as Exhibit C and D.

iii. The DJI Phantom 3 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 3 UA will remain stationary, in flight, for 3

seconds or more. If, after 3 seconds, the DJI Phantom 3 UA does not reacquire control link data

from the GCS, the UA 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 pages 27 through 29 of the DJI Phantom 3 User Manuals, attached hereto as Exhibit C.

iv. The DJI Phantom 3 GCS And Its Operation.

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

and flight control software is provided at pages 32 through 43 of the DJI Phantom 3 User

Manual. DJI Phantom 3 User Manuals are attached hereto as Exhibit C.
b. Flight Operations Of DJI Phantom 3 UAS Are Limited To The Line Of Sight Of A

Certificated Pilot in Command.

Phillip Colling will only utilize certificated pilots who possess a current and valid airman

medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 UAS.

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific

Operating Limitations.

In seeking this exemption, Phillip Colling proposes to commercially operate DJI Phantom

3 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 UASs weighing less than 55 pounds maximum

gross weight: DJI Phantom and 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 2 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 FAA­issued 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 (AFS­80) 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 pre­flight 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's

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 experience­building 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 FAA­published 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. 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 controlled­access 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 (AFS­80) 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.

Phillip Colling 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 UAS unless that PIC has demonstrated, by meeting minimum flight­hour and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner

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

appropriate distances from people, vessels, vehicles and structures.

Considering Phillip Colling’s proposed area of operations, and the operating limitations

set forth­above; 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 3 UAS, Phillip Colling submits that the additional

manned airmanship experience of a commercially certificated pilot would not correlate to the

airmanship skills necessary for Phillip Colling’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).

Phillip Colling will not allow any PIC to operate the DJI Phantom 3 UAS unless that PIC

has demonstrated, by meeting minimum flight­hour requirements or the DJI Phantom 3 UAS

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

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 Phillip Colling’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 as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a

multi­rotor 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 multi­rotor 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 flighthour 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 experience­building flights can also be conducted under the grant of

exemption to accomplish the required flight time. During training, proficiency, and

experience­building 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, Phillip Colling

will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 UAS unless

that PIC has demonstrated, by meeting minimum flight­hour and currency requirements, that the

PIC is able to safely operate the DJI Phantom 3 UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate distances

from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would

Not Adversely Affect Safety.

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

prior to every flight, Phillip Colling will ensure that the DJI Phantom 3 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 3 UA 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 Phillip

Colling’s operation of the DJI Phantom 3 UA within visual line of sight, at or below 500 feet AGL,

will ensure a level of safety equivalent to Section 91.121. The altitude information will be

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude

initiation point is automatically established by the UASs at ground level. The FAA has previously

granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material

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

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

11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(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 3 UAS; (2) the limitations on the proposed flight operations;

and (3) the location of the proposed flight operations. Accordingly, Phillip Colling will ensure that

it will safely operate the battery powered DJI Phantom 3 UA during daylight hours in VFR

conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point

of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5

minutes. Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3

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 3 UAS provide audible and

visual warnings to the PIC at the GCS when the UA experiences low battery voltage, the first

warning occurring at approximately 25% remaining battery power, and again at approximately

10% remaining battery power. At the critically low battery level, the DJI Phantom 3 UAS will

descend and land automatically. Significantly, previous exemptions granted by the FAA

concerning Section 91.151 establish that safety is not adversely affected when the technical

characteristics and operating limitations of the UAS are considered. Relief has been granted 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, Phillip Colling 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 Phillip

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

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

operating documents (i.e., the Phillip Colling Aerial Operations Manual, Monthly Maintenance

Log, and DJI Phantom 3 Instruction Manual). Furthermore, Phillip Colling will document and

maintain all maintenance records for the DJI Phantom 3 UAS. Since the DJI Phantom 3 UAS

will be inspected as prescribed by the operating documents, Phillip Colling 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 3 User Manuals are attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Phillip Colling

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 3 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.

In consideration of Phillip Colling’s proposed operating limitations, the operating documents,

and the technical aspects of the DJI Phantom 3 UAS, Phillip Colling 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, Phillip Colling requests that the FAA prescribe special conditions for the intended

operation of the DJI Phantom 3 UAS, which contain such safety standards that the

Administrator finds necessary to establish a level of safety equivalent to that established by 14
C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 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 Vision+ and DJI Inspire 1 UASs, 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 Phillip

Colling’s intended operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, which

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

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 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 Summary That Can Be Published In The Federal Register, stating: The Rules

From Which Phillip Colling Seeks Exemption:

Phillip Colling 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 Phillip Colling Seeks:

This exemption will permit Phillip Colling 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 Phillip

Colling's Request.

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, Phillip Colling'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, Phillip Colling will operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs

safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise

pose a threat to national security.
CONCLUSION

As set forth herein, Phillip Colling 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 Standard UAS commercially, without an airworthiness

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

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

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

advancing the interests of the public, by allowing Phillip Colling to safely, efficiently, and

economically operate the DJI Phantom 3 Standard UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Phillip Colling 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 Phillip Colling to operate the DJI Phantom 3 Standard

UAS commercially for the purpose of conducting aerial video and photography over certain

areas of the United States.

Dated: February 14, 2016

Respectfully submitted,
Phillip Colling

Appendices: A – DJI Phantom 2 Vision+ Specifications Data Sheet B – DJI Inspire 1

Specifications Data Sheet

APPENDIX – A DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS Phillip

Colling only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production.

DJI UASs are loaded with ground breaking software enabling the user to set parameters which

will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher

than a predetermined and set altitude as well as limit flight to a predetermined and set distance.

In addition, DJI software provides real­time altitude and location information to the PIC via the

linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+ 1.1.1 Aircraft 1.1.1.1 Supported Battery – DJI 5200mAH LiPo

Battery 1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 1.1.1.3 Hover

Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity ­

200/s 1.1.1.5 Max Tilt Angel ­ 35 1.1.1.6 Max Ascent Speed – 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 1.1.2 Gimbal 1.1.2.1

Working Current – Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy ­ ±0.03 1.1.2.3

Controllable Range – Pitch: ­90 ­ 0 1.1.2.4 Maximum Angular Speed – Pitch: 90/s 1.1.3 Camera

1.1.3.1 Operating Temperature Range ­ 32F ­ 104F (0C ­ 40C) 1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M 1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording –

1080p30 & 720p 4.1.3.6 Recording Field of View ­ 110/85 1.1.4 Transmitter 1.1.4.1 Operating

Frequency – 5.728GHz – 5.85GHz 1.1.4.2 Communication Distance (unobstructed) – FCC

Compliance: 800m 1.1.4.3 Receiver Sensitivity (1%PER) ­ ­93dBm 1.1.4.4 Transmitter Power –

FCC Compliance: 100mW 1.1.4.5 Working Voltage – 120mA@3.7V 1.1.5 Range Extender
1.1.5.1 Operating Frequency – 2412­2462MHz 1.1.5.2 Communication Distance (unobstructed)

– 500­700m 1.1.5.3 Transmitter Power – 20dBm 1.1.5.4 Power Consumption – 2W APPENDIX

– B DJI INSPIRE 1 TECHNICAL SPECIFICATIONS Phillip Colling only utilizes safe and reliable

UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground

breaking software enabling the user to set parameters which will not allow flight into controlled

airspace. Parameters can also be set to limit flight to no higher than a predetermined and set

altitude as well as limit flight to a predetermined and set distance. In addition, DJI software

provides real­time altitude and location information to the PIC via the linked monitor (smart

phone/tablet devices) 2.2 DJI Inspire 1 2.2.1 Aircraft 2.2.1.1 Model –

T600 2.2.1.2 Weight(Battery Included) – 6lbs 7.5291oz (2935 g)

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

2.5m 2.2.1.4 Max Angular Velocity – Pitch: 3000/s;Yaw: 1500/s

2.2.1.5 Max Tilt Angle ­ 3502.2.1.6 Max Ascent Speed – 5m/s 2.2.1.7

Max Descent Speed – 4m/s 2.2.1.8 Max Speed – 22m/s (ATTI mode,

no wind – NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 4500m 2.2.1.10 Max Wind Resistance – 10m/s 2.2.1.11 Max

Flight Time – Approximately 18 minutes 2.2.1.12 Motor Model –

DJI 3510 2.2.1.13 Propeller Model – DJI 1345 2.2.1.14

Operating Temperature Range – 140F to 1040F (­100C to 400C)

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 2.2.2

Gimbal 2.2.2.1 Model – ZENMUSE X3 2.2.2.2 Output Power (with

camera) – Static: 9W; In Motion: 11W 2.2.2.3 Operating

Current – Static: 750mA; In Motion: 900mA 2.2.2.4

Angular Vibration Range ­ ±0.0302.2.2.5 Mounting –
Detachable 2.2.2.6 Controllable Range – Pitch: ­900 to +300; Pan:

±3200 2.2.2.7 Mechanical Range – Pitch: ­1250 to 450; Pan: ±3300

2.2.2.8 Max Controllable Speed – Pitch: 1200/s;Pan: 1800/s 2.2.3 Camera

2.2.3.1 Name – X3 2.2.3.2 Model – FC350 2.2.3.3 Total Pixels –

12.76M 2.2.3.4 Effective Pixels – 12.4M 2.2.3.5 Image Max Size –

4000x3000 2.2.3.6 ISO Range – 100­3200 2.2.3.7 Field of View ­

9402.2.3.8 CMOS – Sony EXMOR 1/2.3” 2.2.3.9 HD Video

Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD:

1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10

Operating Temperature Range ­ 320F ­ 1040F (00C ­ 400C) 2.2.4

Transmitter 2.2.4.1 Name – C1 2.2.4.2 Operating Frequency –

5.728­5.850GHz; 2.400­2.483GHz 2.2.4.3 Communicating Distance

(unobstructed)– 2000m 2.2.4.4 Output Power – 9W 2.2.4.5 Operating

Temperature Range ­ 140F to 1040F (­100C to 400C) 2.2.4.6 Battery

– 600mAh LiPo 2S