May 18, 2015

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave.,

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Reform Act of2012

Dear Sir or Madam

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

requirements contained within 14 C.F.R. Part 11, Prestige Aerial requests an exemption

from Federal Aviation Regulations (FARs) detailed below for the 3D Robotics Inc.

(3DR) SOLO, aircraft system.

The requested exemption would support an application for a commercial Certificate of

Authorization to provide aerial photography and videography services (real estate

photography) The 3DR SOLO utilizes the same internal electronics and flight systems for

consistency and compatibility, with the difference being different airframe configurations

adapted for specialized applications and environments. Each vehicle carries a georeferenced camera that allows it to conduct precision photography and videography

services.

The managing principal of our company, I have extensive experience in flight operations.

The unmanned aircraft included in this exemption will be operated in the field with both

a Pilot in Command (PIC) and a ground-based Visual Observer (VO) in accordance with

the FAA Policy N 8900.227 Section 14 "Operational Requirements for UAS" with the

following additional operating restrictions:

1. All operations will occur in Class G airspace at no more than 200FT AGL

2. Operations will be operated over private property with the permission of the land

owner

3. All required permits will be obtained from state and local government prior to

operation

4. The aircraft will not be operated over urban or populated areas

5. The aircraft will not be operated at air shows or over an open-air assembly of people

6. The aircraft will not be operated over heavily trafficked roads

7. Operations will be limited to day and visual meteorological conditions (“VMC”) 8.

Aircraft will remain within visual line of sight at all times
9. While the aircraft is airborne, the VO will be positioned within voice distance to the

PIC

10. PIC will file a NOTAM providing radial/DME, radius, and a date/time group for each

operation

The PIC and VO will meet the requirements outlined in the FAA Policy N 8900.227

Section 16 Personnel Qualifications. The PIC and VO will perform maintenance on the

system along with completing an in-service on maintenance, safety procedures, and

operator conduct (See Attachments) as part of their initial training. We do not anticipate

the need for a supplemental pilot, due to the simplicity of the system.

We submit that the combination of strict operation under the guidelines established in

8900.227 and the aircraft's light weight, historically demonstrated flight performance, and

a fully qualified flight crew, the FAA can have confidence that the operation will have an

equivalent or greater level of safety of a manned aircraft performing the same mission.

Table of Contents

GLOSSARY OF ABBREVIATIONS

SUMMARY

INTRODUCTION AND INTERESTS OF THE PETITIONER

BACKGROUND

BASIS FOR PETITION

Name And Address Of The Petitioner.

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption.

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The Relief.

The Reasons Why Granting Applicant Request Would Be In The Public Interest; That Is,

How It Would Benefit The Public As A Whole.

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 Applicant Seeks Exemption.
CONCLUSION 

The name and contact information of the applicant are:

Tré Loren Photography

Attn: Tré Loren Fields

Phone: 850-461-7116

Email: treloren@gmail.com

SUMMARY

The regulations from which the exemption is requested are listed below:

14 CFR Part 21

14 CFR 91.203

14 CFR 45.23, 45.29

14 CFR 91.9

14 CFR 61.113(a) & (b), 61.133(a)

14 CFR 91.109, 91.119

14 CFR 91.121, 91.151

14 CFR Subpart E (91.401-91.417)

FAA Policy 8900.227 Paragraph 16(c)(4) and Paragraph 16(e)(1)

This exemption will permit Applicant to operate an Unmanned Aircraft System (UAS)

for the commercial purpose of conducting aerial video and photography of to be used in

television commercials, weather traffic and news reports, and sporting events over certain

areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Tre L. Fields; I am 22 years old, with an Associates Degree in Arts. I have

over 5 years experience in film and photography,

I wish to provide high quality imaging for a variety of commercial and public uses,

specifically targeting:

 Aerial Survey

 Commercial Photography/videography

 Inspections of Commercial Real Estate

 Commercial Real Estate videography
BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3Vision, 3DRobotics (3DR) UASs

Applicant seeks an exemption to operate 3DR Solo & DJI Phantom systems for

compensation or hire within the NAS. The DJI Phantom 3Vision+ and 3DR Solo 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

3Vision+ 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 3DR Solo has a maximum gross weight of 3

pounds 3 ounces, a length of 18 inches, width of 17. inches, height of 10 inches, and a

maximum speed of approximately 55 knots. The DJI Phantom 3Vision+ 3DR Solo UAs

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

motors.

The DJI Phantom 3Vision+ 3DR Solo UAs that will be operated by Applicant 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, Applicant, 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 3Vision+, 3DR Solo UASs in

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

C.F.R §§ 61.23(a), 61.101(e4) 61.113(a) & (b), 61.315 (a), 91.7(a), 91.119 (c), 91.119

(c), 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, Applicant operation of DJI Phantom 3Vision+ and

3DR Solo UASs meets the conditions of FMRA Section 333 and therefore, will not

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

Accordingly, Applicant 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.
Applicant submits that the requested relief is proper since an equivalent level of safety

will be ensured. Applicant will use experienced personnel or technicians to perform

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

techniques, and practices prescribed in the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3Vision+ and = 3DR Solo Instruction Manual).

Furthermore, Applicant will document and maintain all maintenance records for the DJI

Phantom 3Vision+ and 3DR Solo UASs.

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

privileges and limitations: Pilot in command, is requested by Applicant 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 3Vision+ and 3DR Solo UASs in a manner consistent with this

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.

Applicant seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because

the DJI Phantom 3Vision+ and 3DR Solo UASs do not require an airworthiness

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

that he will ensure that the DJI Phantom 3Vision+ and 3DR Solo UASs 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 3Vision+ and 3DR Solo Instruction Manual), and that the aircraft are in a

condition for safe flight.

Applicant also seeks an exemption from the requirements of Section 91.119 (c), entitled

Minimum Safe Altitudes: General, as the DJI Phantom 3Vision+ and 3DR Solo UAs

operate at low altitudes of 400 feet or less.

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

Altimeter Settings, as the DJI Phantom 3Vision+ and 3DR Solo UAs will not have a

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

3Vision+ and 3DR Solo UAs will be provided to the PIC via Global Positioning System

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

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

combined with Applicant’s operation of the DJI Phantom 3Vision+ and 3DR Solo UASs

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

equivalent to Section 91.121.

Additionally, Applicant seeks an exemption from the requirements of Section 91.151(b),

entitled Fuel requirements for flight in VFR conditions. Applicant submits that safety will

not be affected by operation of the DJI Phantom 3Vision+ and 3DR Solo 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, Applicant provides the following information in

support of its petition for exemption:
Name And Address Of The Petitioner.

Tre L Fields

1607 Resort Drive

Orlando, FL 32817

850-461-7116

Email: treloren@gmail.com

The Specific Sections Of 14 C.F.R. From Which Applicant Seeks Exemption.

Applicant Seeks Exemption From The Requirements Of Section 61.23(a). Medical

certificates: Requirement and duration.

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and

(c) of this section.

Applicant Seeks Exemption From The Requirements Of Section 61.101(e4)

Recreational pilot privileges and limitations.

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may

not act as pilot in command of an aircraft—

(iv) With retractable landing gear;

Applicant 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.

Applicant Seeks Exemption From The Requirements Of Section 315 (a).

61.315 What are the privileges and limits of my sport pilot certificate?

(a) If you hold a sport pilot certificate you may act as pilot in command of a light-sport

aircraft, except as specified in paragraph (c) of this section.
Applicant 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.

Applicant Seeks Exemption From The Requirements Of Section 91.119 (c).

Except when necessary for takeoff or landing, no person may operate an aircraft below

the following altitudes:

Applicant 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.

Applicant 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.

Applicant 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[.]

Applicant 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[.]
Applicant 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.

Applicant Seeks Exemption From The Requirements Of Sections 91.417(a) And

91.417(b).

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

following:

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

owner or operator shall keep the following records for the periods specified in paragraph

(b) of this section:

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

100-hour, annual, progressive, and other required or approved inspections, as appropriate,

for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance

of an aircraft. The records must include--

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

performed; and

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

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

to service.

(2) Records containing the following information:

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

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

appliance.

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

to be overhauled on a specified time basis.

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

inspection required by the inspection program under which the aircraft and its appliances

are maintained.

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

including, for each, the method of compliance, the AD or safety directive number and

revision date. If the AD or safety directive involves recurring action, the time and date

when the next action is required.
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration

to the airframe and currently installed engines, rotors, propellers, and appliances.

(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.

The Extent Of Relief Applicant Seeks And The Reason Applicant Seeks The

Relief.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From

Section 61.23(a).

Medical certificates: Requirement and duration. (a) Operations requiring a medical

certificate. Except as provided in paragraphs (b) and (c) of this section. The PIC will not

be operating a aircraft which is capable of carrying passengers or the pilot.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From

Section 61.101(e4).

61.101 Recreational pilot privileges and limitations. (e) Except as provided in paragraphs

(d) and (i) of this section, a recreational pilot may not act as pilot in command of an

aircraft— (iv)

Extent Of Relief Applicant Seeks And The Reason Applicant 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, Applicant submits that an equivalent level of safety will be

maintained because no PIC will be allowed to operate the DJI Phantom 3Vision+ UAS or

3DR Solo 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 3Vision+ or

3DR Solo 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, Applicant submits that all flights of the DJI Phantom 3Vision+ and 3DR Solo

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

to Applicant's business; and (2) will not carry passengers or property for compensation or

hire.

Extent Of Relief Applicant Seeks And The Reason Applicant 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 Applicant to determine that the DJI Phantom 3Vision+ and 3DR Solo

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

compliance with the operating documents (i.e., the Applicant Aerial Operations Manual,

Monthly Maintenance Log, and DJI Phantom 3Vision+ and 3DR Solo Instruction

Manual).

Applicant seeks the requested relief because the DJI Phantom 3Vision+ and 3DR Solo

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

Subpart H. Therefore, Applicant will ensure that the DJI Phantom 3Vision+ and 3DR

Solo UASs are in airworthy condition based upon its compliance with the operating

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3Vision+ and 3DR Solo

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.

Extent Of Relief Applicant Seeks And The Reason Applicant Seeks Relief From

Section 91.119 (c).

Relief from Section 91.119 (c), entitled Minimum Safe Altitudes: General, as the DJI

Phantom 3Vision+ and 3DR Solo UAs operate at low altitudes of 400 feet or less.

Extent Of Relief Applicant Seeks And The Reason Applicant 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 3Vision+ and 3DR Solo UASs, which utilize a barometric

pressure sensor, GPS equipment, and a radio communications telemetry data link to

downlink altitude information from the UA to the PIC at the ground control station

(GCS). Since the FAA requires that any altitude information concerning UAS operations

be reported to air traffic control (ATC) in feet above ground level (AGL), Applicant

seeks the requested relief because the DJI Phantom 3Vision+ and 3DR Solo 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 3Vision+ and 3DR Solo 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.
Extent Of Relief Applicant Seeks And The Reason Applicant 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

3Vision+ and 3DR Solo 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. Applicant seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the battery powered DJI Phantom

3Vision+ and 3DR Solo UAs will severely constrain the practicality of any aerial video

or still photo flight operations that Applicant proposes to conduct pursuant to this

Petition.

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

3Vision+ and 3DR Solo UASs, the DJI Phantom 3Vision+ and 3DR Solo operating

documents, and Applicant’s proposed operating limitations, ensure that Applicant will

safely operate the battery powered DJI Phantom 3Vision+ and 3DR Solo 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.

Extent Of Relief Applicant Seeks And The Reason Applicant 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, Applicant requests relief from these

Sections because the DJI Phantom 3Vision+ and 3DR Solo UASs do not require

airworthiness certificates. As set forth more fully below, the DJI Phantom 3Vision+ and

3DR Solo UASs meet the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, Applicant will use trained technicians to perform

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

techniques, and practices prescribed in the UAS operating documents (i.e., the Applicant

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3Vision+ and

3DR Solo Instruction Manual). Furthermore, Applicant will document and maintain all

maintenance records for the DJI Phantom 3Vision+ and 3DR Solo UASs.

The Reasons Why Granting Applicant 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 Applicant to

safely, efficiently, and economically perform aerial video and photography of, real

estate/commercial properties (with their written permission) and landscape over certain

areas of the United States.

Additionally, use of the DJI Phantom 3Vision+ and 3DR Solo UASs will decrease

congestion of the NAS, reduce pollution, and provide significant benefits to the economy.
Notably, the benefits of Applicant’s proposed operation of the DJI Phantom 3Vision+

and 3DR Solo UASs will be realized without implicating any privacy issues.

The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3Vision+ and 3DR Solo 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 3Vision+ or 3DR Solo

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 3Vision+ and 3DR Solo 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.

The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom

3Vision+ and 3DR Solo UASs.

Conducting aerial acquisitions with the DJI Phantom 3Vision+ and 3DR Solo UASs,

instead of manned aircraft, will greatly benefit the public by drastically reducing the

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

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

Phantom 3Vision+ and 3DR Solo UASs produce no air pollution, and is the most viable

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

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

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

and 3DR Solo UAs, while reducing the carbon footprint of aerial acquisitions, also

eliminates noise pollution, as the UAs are propelled by battery powered electric motors,

rather than an internal combustion engine.

By using the DJI Phantom 3Vision+ and 3DR Solo UASs to perform aerial acquisitions,

the substantial risk to life and property in the air and on the ground, which is usually

associated with traditional manned aircraft flight operations, will be substantially reduced

or completely eliminated. Aside from the lack of flight crew members located onboard

the aircraft, the DJI Phantom 3Vision+ and 3DR Solo 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).

Performing Aerial Video and Photography Operations With The DJI Phantom

3Vision+ and 3DR Solo UASs Will Benefit The Economy.
In addition to being safe and efficient, the DJI Phantom 3Vision+ and 3DR Solo UASs

are also an economical alternative to using manned aircraft to conduct similar aerial

operations. As such, operation of the DJI Phantom 3Vision+ and 3DR Solo UASs will

allow United States based companies, like Applicant, 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 3Vision+ and 3DR Solo UASs is one such technology that not only allows

companies greater operational flexibility compared to manned aircraft, but provides such

flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3Vision+ and 3DR Solo UASs, companies such as

Applicant, 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 3Vision+ and 3DR Solo UASs, provides a stable workforce that

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

companies to invest in research and development in order to remain competitive both in

the United States and abroad.

There Are No Privacy Issues.

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

decades, Applicant’s proposed operation of the DJI Phantom 3Vision+ and 3DR Solo

UASs will not implicate any privacy issues. Specifically, the DJI Phantom 3Vision+ and

3DR Solo UASs will be operated only in compliance with operating documents (i.e., the

Applicant Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom

3Vision+ and 3DR Solo 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.

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 Applicant Seeks

Exemption.

Reasons Why The DJI Phantom 3Vision+ and 3DR Solo 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, Applicant’s operation of the DJI Phantom 3Vision+

and 3DR Solo UASs meet the conditions of FMRA Section 333, and will not require an

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

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

and sets forth requirements for considering whether a UAS will create a hazard to users
of the NAS or the public, or otherwise pose a threat to national security. Specifically,

FMRA Section 333 states the following, in part:

(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, Applicant submits that the DJI Phantom 3Vision+ and 3DR

Solo UASs can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Phantom 3Vision+ and 3DR Solo

UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3Vision+ and 3DR Solo UASs

Demonstrate Its Safe Characteristics.

The DJI Phantom 3Vision+ and 3DR Solo 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 3Vision+ and 3DR Solo

UASs.

The technical specifications of the DJI Phantom 3Vision+ and 3DR Solo UASs

are set forth by the DJI Phantom 3Vision+ and 3DR Solo Specifications and

Data Sheet, attached hereto as Exhibit A and B.

ii. The DJI Phantom 3Vision+ and 3DR Solo UASs Autonomous Flight And

Navigation Modes Enable The UASs To Remain Within A Defined

Operational Area.

The DJI Phantom 3Vision+ and 3DR Solo UASs may be operated in both

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

and navigational modes of the DJI Phantom 3Vision+ and 3DR Solo UASs is
provided at pages 25-35 of the DJI Phantom 3Vision+ and pages 12-16 and 45-

50 of the 3DR Solo User Manuals, attached hereto as Exhibit C and D.

iii. The DJI Phantom 3Vision+ and 3DR Solo UASs Are Designed For

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

Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 3Vision+ and 3DR Solo UAs

will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the

DJI Phantom 3Vision+ and 3DR Solo UAs do not reacquire control link data

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

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

to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3Vision+

UAS are set forth at pages 27 through 29 and for the 3DR Solo at pages 13

through 15 of the DJI Phantom 3Vision+ and 3DR Solo User Manuals, attached

hereto as Exhibit C and D.

iv. The DJI Phantom 3Vision+ and 3DR Solo GCS And Its Operation.

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

3Vision+ and 3DR Solo GCS and flight control software is provided at pages 32

through 43 of the DJI Phantom 3Vision+ User Manual and pages 40 through 47

of the 3DR Solo User Manual. DJI Phantom 3Vision+ and 3DR Solo User

Manuals are attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 3Vision+ and 3DR Solo UASs Are Limited To

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

Applicant 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 3Vision+ and

3DR Solo UASs. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3Vision+ and 3DR Solo UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, Applicant proposes to commercially operate DJI Phantom

3Vision+ and 3DR Solo UASs for the special purpose of conducting aerial video and

photography over certain areas of United States, pursuant to the following specific

operating limitations:

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

following aircraft described in the operating documents, rotorcraft UASs

weighing less than 55 pounds maximum gross weight: DJI Phantom 3Vision+

and 3DR Solo Unmanned Aircraft Systems. Proposed operations of any other

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

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

for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.
4. The UA must be operated at an altitude of no more than 500 feet above

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

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

reported to ATC must be in feet AGL.

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

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

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

medical certificate.

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

permitted.

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS

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

Electronic messaging or texting is not permitted during flight operations. The

PIC must be designated before the flight and cannot transfer his or her

designation for the duration of the flight. The PIC must ensure that the SO can

perform the functions prescribed in the operating documents.

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

seeing and avoiding other air traffic and other ground based

obstacles/obstructions and is not permitted to operate the camera or other

instruments.

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

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

a discrepancy exists between the conditions and limitations contained in the

grant of exemption and the procedures outlined in the operating documents, the

conditions and limitations contained in the grant of exemption take precedence

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

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

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

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

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

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

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

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

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

questions arise regarding updates or revisions to the operating documents.

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

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

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

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

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

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.
11. Any UAS that has undergone maintenance or alterations that affect the UAS

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

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

functional test flight must make an entry in the aircraft records.

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

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

sections of the operating documents.

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

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

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

requirements, in accordance with the operating documents. Maintenance,

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

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

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

UAS to service.

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

manufacturer Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

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

third- class medical certificate.

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

operator’s qualification criteria and demonstrates the ability to safely operate the

UAS in a manner consistent with how the UAS will be operated under the

exemption, including evasive and emergency maneuvers and maintaining

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

qualification flight hours must be logged in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted

under the terms of the exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and

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

considered nonparticipants, and the PIC must operate the UA with appropriate

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

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

§ 1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

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

rules (SVFR) are not authorized.

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

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

agreement with that airport’s management is obtained, and 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

pre- determined 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 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.

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

Would Not Adversely Affect Safety.

Applicant 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

3Vision+ and 3DR Solo UASs unless that PIC has demonstrated, by meeting minimum

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

Phantom 3Vision+ or 3DR Solo UAS in a manner consistent with the exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

Considering Applicant’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 3Vision+ or 3DR Solo UAS,

Applicant submits that the additional manned airmanship experience of a commercially

certificated pilot would not correlate to the airmanship skills necessary for Applicant’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).

Applicant will not allow any PIC to operate the DJI Phantom 3Vision+ or 3DR Solo UAS

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the
DJI Phantom 3Vision+ or 3DR Solo UAS training and currency requirements, that the

PIC is able to safely operate the DJI Phantom 3Vision+ or 3DR Solo 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 Applicant’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 multi-rotor

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

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

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

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

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

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90

days (for currency purposes). The FAA finds that at a minimum, the flight-hour

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in

the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also

finds that prior documented flight experience that was obtained in compliance with

applicable regulations would satisfy this requirement. Training, proficiency, and

experience-building flights can also be conducted under the grant of exemption to

accomplish the required flight time. During training, proficiency, and experience-building

flights the PIC is required to operate the UA with appropriate distances in accordance

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Applicant will ensure safe operations by not allowing any PIC to operate

the DJI Phantom 3Vision+ or 3DR Solo 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 3Vision+ or 3DR Solo UAS in a manner consistent with the

exemption, including evasive and emergency maneuvers and maintaining appropriate

distances from people, vessels, vehicles and structures.
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, Applicant will ensure that the DJI Phantom 3Vision+ or 3DR Solo

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).

Reasons Why An Exemption From The Requirements Of Section 91.119 (c)

and91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Sections 91.119 (c) and 91.121 will be

maintained because the altitude information of the DJI Phantom 3Vision+ and 3DR Solo

UAs will be provided to the PIC via GPS equipment and a radio communications

telemetry data link, which downlinks from the UA to the GCS for active monitoring of

the flight path and altitude. This altitude information, combined with Applicant’s

operation of the DJI Phantom 3Vision+ and 3DR Solo 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 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).

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

3Vision+ and 3DR Solo UASs; (2) the limitations on the proposed flight operations; and

(3) the location of the proposed flight operations. Accordingly, Applicant will ensure that

it will safely operate the battery powered DJI Phantom 3Vision+ and 3DR Solo UAs

during daylight hours in VFR conditions, with enough battery power to fly for a total

duration of 20 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

3Vision+ and 3DR Solo UASs; 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

3Vision+ and 3DR Solo UASs 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 3DR Solo

UASs 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).

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, Applicant 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

Applicant 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 Applicant Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 3Vision+ and 3DR Solo Instruction Manual).

Furthermore, Applicant will document and maintain all maintenance records for the DJI

Phantom 3Vision+ and 3DR Solo UASs.

Since the DJI Phantom 3Vision+ and 3DR Solo UASs will be inspected as prescribed by

the operating documents, Applicant 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 3Vision+ and 3DR Solo User Manuals are attached hereto as Exhibit C and D; a

copy of the DJI Phantom 3Vision+ and 3DR Solo UAS Maintenance LOG is attached

hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because Applicant 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 3Vision+ and 3DR Solo UASs 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 Applicant’s proposed operating limitations, the operating documents,

and the technical aspects of the DJI Phantom 3Vision+ and 3DR Solo UASs, Applicant
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).

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, Applicant requests that the

FAA prescribe special conditions for the intended operation of the DJI Phantom

3Vision+ and 3DR Solo 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 §§ 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 3Vision+ and 3DR Solo 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 the Applicant intended operation of the DJI Phantom

3Vision+ and 3DR Solo 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 Applicant Seeks Exemption:
Applicant 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 Applicant Seeks:

This exemption will permit Applicant 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

Applicant’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, Applicant’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, Applicant will operate the DJI Phantom 3Vision+ and 3DR

Solo 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, Applicant 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 3Vision+ and 3DR Solo UASs commercially,

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

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

FAA Administrator will be fulfilling the Congressional mandate of the FAA

Modernization and Reform Act of 2012, while also advancing the interests of the public,

by allowing Applicant to safely, efficiently, and economically operate the DJI Phantom

3Vision+ and 3DR Solo UASs commercially within the NAS.
WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Applicant 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 the Applicant to operate the DJI

Phantom 3Vision+ and 3DR Solo UASs commercially for the purpose of conducting

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

Respectfully submitted,

Tre L. Fields

1607 Resort Drive

Orlando, Fl 32817

treloren@gmail.com

850-461-7116