UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: SkyPOV Media, LLC

Federal Employer ID #: 47-5665118

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 a) DJI PHANTOM 2 VISION+ and b) 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 December, 15th, 2015

SkyPOV Media, LLC

George Brandon Reed, II

51755 Hwy 25

Vandiver, Al 35176

bandsreed@bellsouth.net

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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS ................................................................................3

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

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

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

BASIS FOR PETITION .....................................................................................................5

NAME AND ADDRESS OF PETITIONER ..................................................................6

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

SkyPOV Media, LLC SEEKS EXEMPTION..............................................................7

THE EXTENT OF RELIEF SkyPOV Media, LLC SEEKS AND THE

REASON SkyPOV Media, LLC SEEKS THE RELIEF ................................................10

THE REASONS WHY GRANTING SkyPOV Media, LLC’S

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

THE REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY.............................................................16

CONCLUSION..................................................................................................................26

2
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing 3
SUMMARY

SkyPOV Media, LLC 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 SkyPOV Media, LLC to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial video and photography for real estate 

photography, wedding videography, special events, film sets and landscape over certain areas of the 

United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is George Brandon Reed, II of SkyPOV Media, LLC a Federally recognized LLC. It is my 

mission to provide my clients with expertise and knowledge in all aspects of picture, video & audio 

production, as well as provide them with advanced technologies & solutions that will increase 

efficiency, productivity and effectiveness. SkyPOV Media, LLC also provides clients with the highest 

quality digital content for use in their commercial, personal, and non-profit multimedia projects.

SkyPOV Media, LLC has several years of professional experience in photography and videography and 

has expertise in this field. SkyPOV Media, LLC has 10 years of recreational/hobby experience in all 

aspects of aerial video and photography. I personally have been a pilot since 2005, with over 2000hrs 

of flight time, both Commercial and recreational. I've been an airport manager, corporate pilot, airline 

pilot, CFI, CFII, MEI, and I'm currently instructing the UAS program at Auburn University. The 

objective of SkyPOV Media, LLC's aerial video and photography operations is to provide high quality 

imaging for a variety of commercial, public, and residential uses, specifically targeting:

• Real Estate Videography and Photography

• Wedding Videography and Photography

• Land survey & appraisals

• Equipment Inspections

• Roof Inspections

• Construction sites before & after

• Precision Agriculture

• Creation of commercial messages for Television.

• Search and Rescue Operations

• Motion Picture Filming

• Increase public knowledge of UAS and promote safe UAS operations. 4
BACKGROUND

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

SkyPOV Media, LLC seeks an exemption to operate DJI systems for compensation or hire within the 

NAS. The 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 2 Vision+ has a maximum gross weight of approximately 2 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 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 2 Vision+ and DJI Inspire 1 UAS are equipped with four 

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

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS that will be operated by Myself and other qualified 

pilots I may hire and 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, SkyPOV Media, LLC, pursuant to the provisions of the Federal Aviation Regulations (14 

C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special 

Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially 

operate the DJI Phantom 2 Vision+, DJI Inspire 1 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, SkyPOV Media, LLC operations of DJI Phantom 2 Vision+ and DJI Inspire 1 

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, Sub-part H.

Accordingly, SkyPOV Media, LLC 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.

SkyPOV Media, LLC submits that the requested relief is proper since an equivalent level of safety will 

be ensured. SkyPOV Media, LLC will use experienced personnel or technicians to perform 

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

practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 

Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, SkyPOV Media, LLC will document and 

maintain all maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS.

5
Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and 

limitations: Pilot in command , is requested by SkyPOV Media, LLC to the extent necessary to allow a 

Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight-hour and currency requirements, 

that the PIC is able to safely operate the DJI Phantom 2 Vision+ and 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.

SkyPOV Media, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Sub-part H. As such, SkyPOV Media, LLC submits that they will 

ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS are in an airworthy condition, prior to 

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

Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and that 

the aircraft are in a condition for safe flight.

SkyPOV Media, LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings , as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS will not have a typical 

barometric altimeter on-board. However, altitude information of the DJI Phantom 2 Vision+ and DJI 

Inspire 1UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which down-links from the UA to the GCS for active monitoring 

of the flight path. This altitude information, combined with SkyPOV Media, LLC's operation of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UAS within visual line of sight, at or below 500 feet AGL, will 

ensure a level of safety equivalent to Section 91.121.

Additionally, SkyPOV Media, LLC seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. SkyPOV Media, LLC submits that safety will 

not be affected by operation of the 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 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, SkyPOV Media, LLC 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: George Brandon Reed, II C/O SkyPOV 

Media, LLC, 51755 Hwy 25 Vandiver, AL 35176, (205)-492-5846 bandsreed@bellsouth.net

6
B. The Specific Sections Of 14 C.F.R. From Which SkyPOV Media, LLC Seeks Exemption.

1. SkyPOV Media, LLC Seeks Exemption From The Requirements Of Section Part 21, Sub-part H

14 C.F.R. Part 21, Sub-part H, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by 14 C.F.R. §91.203(a)(1)

2. SkyPOV Media, LLC 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.

3. SkyPOV Media, LLC 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.

4. SkyPOV Media, LLC Seeks Exemption From The Requirements Of Section 91.121.

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

operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may 

be, by reference to an altimeter that is set, when operating-(1) Below 18,000 feet MSL, to-(i) The 

current reported altimeter setting of a station along the route and within 100 nautical miles of the 

aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the 

current reported altimeter setting of an appropriate available station; or(iii) In the case of an aircraft not 

equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available 

before departure.

7
5. SkyPOV Media, LLC 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 rotor-craft 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 f or at least 20 minutes.

6. SkyPOV Media, LLC 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 sub-part 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[.]

7. SkyPOV Media, LLC 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[.]

8. SkyPOV Media, LLC 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
9. SkyPOV Media, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b).

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

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

operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, 

annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records 

must include-

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

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

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

(2) Records containing the following information:

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

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

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

overhauled on 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.

9
C. The Extent Of Relief SkyPOV Media, LLC Seeks And The Reason SkyPOV Media, LLC Seeks 

The Relief.

CI.

1. SkyPOV Media, LLC Seeks Exemption From The Requirements Of Section Part 21, Sub-part H

Given the size and limited operating area associated with the UAS to be utilized by SkyPOV Media, 

LLC, an exemption from Part 21 Sub-part H meets the requirements of an equivalent level of safety 

under Part 11 and Section 333 of the Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act both authorize the 

FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the 

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

particular UAS.

In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness 

certificate, in the restricted environment and under the conditions proposed will be at least as safe, or 

safer, than a conventional rotor-craft operating with an airworthiness certificate without the restrictions 

and conditions of the proposed UAS operations.

2. Extent Of Relief SkyPOV Media, LLC Seeks And The Reason SkyPOV Media, LLC 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 flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private 

pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or 

employment if:

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

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

As set forth more fully below, SkyPOV Media, LLC submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS or DJI Inspire 1 

UAS unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC 

is able to safely operate either the DJI Phantom 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.

10
Further, SkyPOV Media, LLC submits that all flights of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to SkyPOV 

Media, LLC business; and (2) will not carry passengers or property for compensation or hire.

3. Extent Of Relief SkyPOV Media, LLC Seeks And The Reason SkyPOV Media, LLC 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 SkyPOV Media, LLC to determine that the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS are in 

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

documents (i.e., the SkyPOV Media, LLC Aerial Operations Manual, Monthly Maintenance Log, and 

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

SkyPOV Media, LLC seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 1 

UAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Sub-part H. 

Therefore, SkyPOV Media, LLC will ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS 

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

Maintenance Log, and 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.

4. Extent Of Relief SkyPOV Media, LLC Seeks And The Reason SkyPOV Media, LLC Seeks 

Relief From Section 91.121.

Relief from Section 91.12 1, entitled Altimeter settings , may be required to allow flight operations of 

the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to down-link 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),

SkyPOV Media, LLC seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 1 

UAS altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or 

field altitude, before each flight.

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

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

set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2 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.

11
5. Extent Of Relief SkyPOV Media, LLC Seeks And The Reason SkyPOV Media, LLC Seeks 

Relief From Section 91.151(b).

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

the extent required to allow flights of the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1

UAS 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. SkyPOV Media, LLC seeks the requested relief because 

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

Phantom 2 Vision+ and DJI Inspire 1 UAS swill severely constrain the practicality of any aerial video 

or still photo flight operations that SkyPOV Media, LLC proposes to conduct pursuant to this Petition.

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

Inspire 1 UAS, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating documents, and SkyPOV Media, 

LLC's proposed operating limitations, ensure that we will safely operate the battery powered 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.

6. Extent Of Relief SkyPOV Media, LLC Seeks And The Reason SkyPOV Media, LLC 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, SkyPOV Media, LLC requests relief from these Sections 

because the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS do not require airworthiness certificates.

As set forth more fully below, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS meet the conditions 

of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, SkyPOV Media, 

LLC 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 

SkyPOV Media, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, We will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS.

12
D. The Reasons Why Granting SkyPOV Media, LLC 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 us to safely, efficiently, and 

economically perform aerial video and photography of, real estate, wedding films, special events, 

precision agriculture, land survey & appraisal, construction sites, equipment & roof inspections, film 

sets and landscape over certain areas of the United States. Additionally, use of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. Notably, the benefits of SkyPOV Media, LLC's proposed operation 

of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS will be realized without implicating any privacy 

issues.

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

The DJI Phantom 2 Vision+ 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 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 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 2 Vision+ and 

DJI Inspire 1 UAS.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS ’s, 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 2 Vision+ and DJI Inspire 1 UAS produce no air 

pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder 

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

burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 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.

13
By using the DJI Phantom 2 Vision+ and DJI Inspire 1 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 on-board the aircraft, the DJI Phantom 2 Vision+ 

and DJI Inspire 1 UAS (weighing approximately 2 pounds 11 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).

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

Inspire 1 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS are also an 

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

of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS will allow United States based companies, like 

SkyPOV Media, LLC, to remain competitive and contribute to growth of the U.S. Economy.

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) 

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt 

new and alternative technology in order to remain competitive. Operating the battery powered DJI 

Phantom 2 Vision+ and DJI Inspire 1 UAS 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 2 Vision+ and DJI Inspire 1 UAS, companies such as SkyPOV Media, 

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

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

Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 

Vision+ and DJI Inspire 1 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.

There Are No Privacy Issues.

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

SkyPOV Media, LLC’s proposed operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS will 

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

be operated only in compliance with operating documents (i.e., the SkyPOV Media, LLC. Aerial 

Operations Manual, Monthly Maintenance Log, and 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.

14
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 SkyPOV Media, LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Meet The Conditions Of The 

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

2. In consideration of the size, weight, speed, and limited operating area associated with the unmanned 

aircraft and its operation, SkyPOV Media, LLC’s operation of the DJI Phantom 2 Vision+ and DJI 

Inspire 1 UAS ’s meet the conditions of FMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Sub-part 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 rule making 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, SkyPOV Media, LLC submits that the DJI Phantom 2 Vision+ and DJI 

Inspire 1 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) 

the characteristics of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations.

15
a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Demonstrate Its Safe 

Characteristics.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS 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 2 Vision+ and DJI Inspire 1 UAS. The technical 

specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS are set forth by the DJI Phantom 2 

Vision+ and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B.

ii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational Area. The DJI Phantom 2 Vision+ and DJI 

Inspire 1 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 2 Vision+ and DJI Inspire 1 UAS 

are provided at pages 2341 of the DJI Phantom 2 Vision+; and pages 12-18 and 45-52 of the DJI 

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

iii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Are Designed For Automatic Return To 

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

Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the 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., fail-safe mode) via GPS, and will descend to the takeoff 

position and shutdown.

A complete description of the Fail-safe Functions for the DJI Phantom 2 Vision+ UAS are set forth at 

pages 32 through 34 of the DJI Phantom 2 Vision+ User Manual; and for the DJI Inspire 1 at pages 13 

through 15 of the DJI Inspire 1 User Manual, attached hereto as Exhibit C and D.

iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS And Its Operation. A complete description 

of the operation and specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 GCS and flight 

control software is provided at pages 7 through 17 of the DJI Phantom 2 Vision+ User Manual; and 

pages 24 through 34 of the DJI Inspire 1 User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User 

Manuals are attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Are Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer.

SkyPOV Media, LLC 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 2 Vision+ and DJI Inspire 1 

UAS. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific

Operating Limitations.

16
In seeking this exemption, SkyPOV Media, LLC proposes to commercially operate DJI Phantom 2 

Vision+ and DJI Inspire 1 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, rotor-craft UAS weighing less than 55 pounds maximum gross 

weight: 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.

17
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 pre-flight 

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 UAS operated under this exemption must comply with all manufacturer Safety Bulletins.

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

against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third class medical 

certificate.

18
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with 

how the UAS will be operated under the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes 

of training the operator’s PICs are permitted under the terms of the exemption. However, training 

operations may only be conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are considered nonparticipants, 

and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 

C.F.R. § 91.119.

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

operations must be conducted under visual meteorological conditions (VMC). If flight at night is 

required, a special request will be made at the FAA office closest to proposed area of operations. 

Flights under special visual flight rules (SVFR) are not authorized.

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

current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is 

obtained, and 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, Sub-part C. Markings must be as large as practicable.

19
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 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.

SkyPOV Media, LLC 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 2 Vision+ and DJI 

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

requirements, that the PIC is able to safely operate the DJI Phantom 2 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.

20
Considering SkyPOV Media, LLC’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of 

commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to 

safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS, SkyPOV Media, LLC submits that the 

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

the airmanship skills necessary for SkyPOV Media, LLC.’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).

SkyPOV Media, LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 

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

Phantom 2 Vision+ or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to 

safely operate the 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 rotor-craft 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

SkyPOV Media, LLC'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 rotor-craft pilot including at least 10 

hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, 

the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the 

same make and model of UAS to be used for operations under the exemption. For clarification, the 

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

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

in the total 25 hours of UAS rotor-craft time. In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds 

that at a minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice 

and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations.

21
The FAA also finds that prior documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, and experience-building 

flights can also be conducted under the grant of exemption to accomplish the required flight time.

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

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

Exemption No. 11138 at page 15. Accordingly, SkyPOV Media, LLC will ensure safe operations by not 

allowing any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has 

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

safely operate the 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.

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, SkyPOV Media, LLC will ensure that the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS is in an 

airworthy condition based upon the UAS compliance with its operating documents and as stated in the 

conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 

91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064,11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

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

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

Affect Safety.

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

information of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which down-links from the UAS to the 

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

SkyPOV Media, LLC's operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS 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 on board the aircraft.

Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground 

level.

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

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

11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

22
5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety.

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

91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight 

operations. Accordingly, SkyPOV Media, LLC will ensure that it will safely operate the battery 

powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAS 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 2 Vision+ and DJI 

Inspire 1 UAS; the limitations on the proposed flight operations; and the location of the proposed 

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

Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS provide 

audible and visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the 

first warning occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and DJI Inspire 1 

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, SkyPOV Media, LLC 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 SkyPOV Media, LLC 

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

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

Media, LLC's Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+and 

DJI Inspire 1 Instruction Manual). Furthermore, SkyPOV Media, LLC will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS.

Since the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS will be inspected as prescribed by the 

operating documents, SkyPOV Media, LLC will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 Vision+ and DJI 

Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 Vision+ 

and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E.

23
Likewise, the exemption sought will not adversely affect safety because we will use trained technicians 

to perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the operating documents.

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

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

DJI Inspire 1 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 SkyPOV Media, LLC’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS, SkyPOV Media, LLC 

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, SkyPOV Media, LLC requests that the FAA prescribe 

special conditions for the intended operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 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, Sub-part 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 UAS, since the airworthiness regulations of 

14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual 

design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the 

FAA finds that the airworthiness regulations of this sub-chapter 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.

24
See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the 

FAA may prescribe special conditions for Leading Edge ’s intended operation of the DJI Phantom 2 

Vision+ and DJI Inspire 1 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, Sub-part H, 

and 14 C.F.R Sections61.113(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).

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

The Rules From Which SkyPOV Media, LLC Seeks Exemption:

SkyPOV Media, LLC 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 SkyPOV Media, LLC Seeks:

This exemption will permit SkyPOV Media, LLC 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 our 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, SkyPOV Media, LLC’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, SkyPOV Media, LLC will 

operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS safely in the NAS, without creating a hazard 

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

25
Conclusion:

As set forth herein, SkyPOV Media, LLC seeks an exemption pursuant to 14 CFR 11.61 and Section 

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

the DJI Phantom Vision 2+ and DJI Inspire 1 UAS commercially, without an airworthiness certificate, 

for the limited purpose of conduction 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 interest of the public, by 

allowing SkyPOV Media, LLC to safely, efficiently, and economically operate the DJI Phantom 2+ and 

DJI Inspire 1 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulation and the FAA Modernization and 

Reform act of 2012, Section 333, SkyPOV Media, LLC respectfully requests that the Administrator 

grant this petition for an exemption from the requirements of 14 CFR 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 

SkyPOV Media, LLC, leading edge to operate the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS 

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

United States.

Date: 12/15/2015

Respectfully Submitted

SkyPOV Media, LLC

George Brandon Reed, II

(205)-492-5846

51755 Hwy 25

Vandiver, Al 35176

 

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 George Brandon Reed, II
APPENDIX –A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

SkyPOV Media, LLC only utilizes safe and reliable UAS. DJI is an industry leader in small UAS 

production. DJI UAS are loaded with ground breaking software enabling the user to set parameters 

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

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

In addition, DJI software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices)

1.1 DJI Phantom 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 -2000 /s 

1.1.1.5 Max Tilt Angel -350 

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 -±0.030 

1.1.2.3 Controllable Range –Pitch: -900 -00 

1.1.2.4 Maximum Angular Speed –Pitch: 900 /s 

 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range -320 F - 1040 F (00 C -400 C)

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution –4384x3288 

1.1.3.5 HD Video Recording – 1080p30 & 720p 

1.1.3.6 Recording Field of View - 1100 /850

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 –2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed) –500-700m 

1.1.5.3 Transmitter Power –20dBm 

1.1.5.4 Power Consumption –2W

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APPENDIX –B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

SkyPOV Media, LLC only utilizes safe and reliable UAS. DJI is an industry leader in small UAS 

production. DJI UAS are loaded with ground breaking software enabling the user to set parameters 

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

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

In addition, DJI software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft 

2.2.1.1 Model –T600 

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

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

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

2.2.1.5 Max Tilt Angle -350 

2.2.1.6 Max Ascent Speed –5m/s 

2.2.1.7 Max Descent Speed –4m/s 

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

2.2.1.9 Max Flight Altitude –4500m 

2.2.1.10 Max Wind Resistance – 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 -±0.030 

2.2.2.5 Mounting –Detachable 

2.2.2.6 Controllable Range –Pitch: -900to +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 – 100-3200 

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2.2.3.7 Field of View -940 

2.2.3.8 CMOS –Sony EXMOR 1/2.3” 

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

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

2.2.3.10 Operating Temperature Range -320F - 1040F (00C -400C) 

2.2.4 Transmitter 

2.2.4.1 Name –C1 

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

2.2.4.3 Communicating Distance (unobstructed) –2000m 

2.2.4.4 Output Power –9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 2.2.4.6 Battery –600mAh LiPo 

2S 

APPENDIX -C

DJI PHANTOM 2 VISION+ Manufacturer’s User Manual

User manual can be found at:

http://www.dji.com/product/phantom-2-vision/download

APPENDIX -D

DJI Inspire 1 Manufacturer’s User Manual

User manual can be found at:

http://www.dji.com/product/inspire-1/download

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