1

US Department of Transportation 

Docket Management Facility 

1200 New Jersey Avenue, SE (West Building)

Building Ground Floor Room W12-140 

Washington, DC 20590 

RE: Petition of NetMoby, Inc., for Exemption Pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012.

Dear Sir or Madam: 

Pursuant to 14 C.F.R. § 11.81, NetMoby, Inc., (hereinafter referred to as “NetMoby”

or “Petitioner”) hereby petitions for an exemption from Federal Aviation Regulations (FARs) 

identified below, to allow commercial operations of unmanned aircraft systems (UAS)

pursuant to Section 333 of the FAA Modernization and Reform Act of 2012, Public Law 

112-95 (P.L. 112-95), Special Rules for Certain Unmanned Aircraft Systems (hereinafter 

“FMRA”). 

Specifically, this exemption would permit commercial operations by NetMoby, which 

will use the DJI Phantom 3 UAS Advanced to conduct UAS flight training, education, and 

Aerial Data Collection. 

NetMoby’s operation under the exemption will be subject to strict operating 

requirements and conditions to ensure a level of safety equivalent to that of currently 

authorized operations using manned aircraft and under conditions as may be modified by the 

FAA as required by Section 333.

1

 NetMoby believes that the enhanced safety achieved 

using an unmanned aircraft (UA) with the specifications described by the Petitioner will 

provide a pathway for safe and legal entry into the National Airspace System (NAS) and 

provide the FAA good cause to find that the UAS operation enabled by this requested 

exemption is in the public interest.

In accordance with 14 C.F.R. § 11.81(a), NetMoby provides the following information in 

support of its Petition for Exemption. The name and contact information for the Petitioner is

as follows:

NetMoby, Inc., 

5636 Connecticut Ave, NW

No. 6300

Washington, DC 20015

Contact Person: Peter T. Lewis, President

Telephone: (202) 683-6060, ext 140

Email: netmobyinc@gmail.com

 1 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

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 you seek exemption. 
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Web Site: www.netmoby.net

NetMoby respectfully submits that this Petition for Exemption qualifies for approval, as the 

Federal Aviation Administration (FAA) has previously issued grants of exemption in 

circumstances similar in all material respects to those presented herein, as noted specifically 

herein.

This Petition For Exemption was prepared For NetMoby, Inc., by:

Robert E. Kelly, Esq.*

4229 Lafayette Center Drive

Suite 1500

Chantilly, VA 20151

Ph.: 703/447-3117

Email: rekellyrek@verizon.net

Counsel To NetMoby, Inc.

__________________

*Admitted to Practice in Virginia, Maryland 

and the District of Columbia
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TABLE OF CONTENTS

Page 

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

I. SUMMARY.................................................................................... 6

II. INTRODUCTION ........................................................................... 6

III. NETMOBY’S PROPOSED UAS OPERATIONS ................................... 7

A. UNMANNED AIRCRAFT SYSTEM ................................................ 7

1. DESIGN AND OPERATIONAL CHARACTERISTICS ........................... 7

2. NETMOBY PROCEDURES TO ENSURE 

CONDITIONS FOR SAFE FLIGHT ................................................... 7

3. RADIO FREQUENCY (RF) SPECTRUM USED FOR CONTROL ................ 8

IV. RELIEF SOUGHT IN PETITION ................................................ 8

A. THE SPECIFIC SECTIONS OF TITLE 14 OF THE CODE OF FEDERAL 

REGULATIONS FROM WHICH NETMOBY, INC., 

SEEKS EXEMPTION ..................................................................... 10

B. THE EXTENT OF RELIEF NETMOBY, INC., SEEKS AND THE 

REASON NETMOBY, INC., SEEKS THE REQUESTED RELIEF ................. 13

C. THE REASONS WHY GRANTING NETMOBY, INC.'S

REQUEST WOULD BE IN THE PUBLIC INTEREST ................................. 16

D. THE REASONS WHY GRANTING THE REQUESTED EXEMPTION 

WOULD NOT ADVERSELY AFFECT SAFETY ....................................... 17

E. SUMMARY OF REQUESTED EXEMPTION THAT CAN BE PUBLISHED 

IN THE FEDERAL REGISTER ......................................................... 26

V. CONCLUSION ....................................................................... 27

APPENDICES ............................................................................ 29
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GLOSSARY OF ABBREVIATIONS AND TERMS 

ADMINISTRATOR Director of the Federal Aviation Administration. The current 

Administrator is Michael P. Huerta.

AERIAL DATA Any remote sensing and measuring by an instrument(s) aboard the 

COLLECTION UAS. Examples include imagery (photography, video, infrared, 

etc.), electronic measurement (precision surveying, RF analysis, 

etc.), chemical measurement (particulate measurement, etc.), or any 

other gathering of data by instruments aboard the UAS. Specific 

services would include, but not be limited to, general photography 

and videography, real estate photography and videography, film and 

movie production, wildlife surveys, pipeline and power-line 

inspection, infrastructure and industrial inspections, news gathering, 

agricultural surveys, demonstration flights, research and 

development, educational/academic uses, aiding certain rescue 

operations in otherwise inaccessible areas, and any other related 

entities/activities that can utilize the safe and efficient operation of 

UAS aircraft.

AFD FAA Airport/Facility Directory

AGL Above Ground Level

AIRCRAFT Any contrivance invented, used, or designed to navigate, or fly in, the 

air (Title 49, United States Code (49 USC) § 40102) 

AOI Area of Interest

ARP Airport Reference Point

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

C.F.R Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System - the common network of U.S. airspace; air 

navigation facilities, equipment and services, airports or landing areas; 

aeronautical charts, information and services; rules, regulations and 

procedures, technical information, and manpower and material 

NOTAM Notice to Airman

OPERATING Any exemption received from the FAA and all documents needed to 

DOCUMENTS operate the UAS and conduct its operations in accordance with the 

conditions and limitations stated in the grant any of

exemption

OPERATIONAL With respect to a flight, means the exercise of authority over initiating, 

CONTROL conducting or terminating a flight (14 C.F.R § 1.1) 

PIC Pilot In Command - the person who has final authority and 

responsibility for the operation and safety of the flight; has been 

designated as PIC before or during the flight; and holds the appropriate 
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category class and type-rating, if appropriate, for the conduct of the 

flight (14 C.F.R § 1.1) 

SECTION 333 Section 333 of the FAA Modernization and Reform Act of 2012, 

Public Law 112-95 (P.L. 112-95), Special Rules for Certain 

Unmanned Aircraft Systems

SOP Standard OperatingProcedures

UA Unmanned Aircraft - any aircraft that is operated without the 

possibility of direct human intervention from within or on the aircraft 

(P.L. 112-95, Section 331) 

UAS Unmanned Aircraft System – an unmanned aircraft and associated 

elements, including communication links and the components that 

control the unmanned aircraft, that are required for the pilot in 

command to operate safely and efficiently in the national airspace

UAS CERTIFICATE OF An authorization issued by the Air Traffic Organization to an operator

WAIVER OR for a specific unmanned aircraft activity system (P.L. 112-95,

AUTHORIZATION (COA) Section 331) 

VFR Visual Flight Rules

VLOS Visual Line of Site - unaided (corrective lenses and/or sunglasses 

excepted) visual contact between a pilot in command and an unmanned 

aircraft sufficient to maintain safe operational control of the aircraft, 

know its location, and be able to scan the airspace in which it is 

operating to see and avoid other air traffic or objects aloft or on the 

ground 

VMC Visual Meteorological Conditions

VO Visual Observer (Synonymous with Safety Observer or Spotter)

VTOL Vertical Takeoff and Landing
6

I. SUMMARY

NetMoby, Inc., seeks exemption from the requirements of 14 C.F.R § 61.23 (a) & 

(c), 14 C.F.R § 61.101(e)(4) and (5), 14 C.F.R § 61.113(a) & (b), 14 C.F.R § 91.7(a), 14 

C.F.R § 91.121, 14 C.F.R § 91.151(b), 14 C.F.R § 91.405(a), 14 C.F.R § 91.407(a)(1), 14 

C.F.R § 91.409(a) (1) & (a) (2), and 14 C.F.R § 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 NetMoby, Inc., to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of UAS flight training, education and Aerial Data 

Collection over certain areas of the United States. Aerial Data Collection includes any remote 

sensing and measuring by an instrument(s) aboard the UAS. Examples include imagery 

(photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering 

of data by instruments aboard the UAS. See full definition in Glossary of Terms and 

Abbreviations, supra.

II. INTRODUCTION

NetMoby is an emerging technology company with over 100 years’ collective 

experience in a myriad of technical areas. Most notably, and as concerns this exemption 

request, NetMoby has extensive background and experience in wireless telecommunications, 

embedded systems (single board computers) and rotorcraft aviation which gives the 

corporation standing in this matter since the great majority of UAS vehicles are multi-rotor 

aircraft which (1) are controlled using radio links for system control, location determination 

and reporting, (2) possess embedded computer intelligence containing programs to store 

flight information, regulate electronic speed control (“ESC”) revolutions per minute 

(“RPM”), input and output to and from general purpose in/out ports and supply logged 

diagnostic data which can be used to determine and correct problems and (3) utilize shared 

airspace which requires consideration of helicopters, fixed wing aircraft, airport operations, 

notices to airmen (“NOTAMs”), restricted areas, the public (road traffic, events), vertical 

appurtenances (e.g., buildings, monuments, radio towers, trees, water towers) and flight 

hazards (wirelines, guide wires).

The President of NetMoby, Peter T. Lewis, was one of the five original co-founders 

of Cellular One, the first commercial cellular telephone company in the United States which 

changed the way America communicates, is an inactive helicopter pilot who has held a 

rotorcraft commercial flight rating, was the owner of Jet One Systems which owned and 

operated two McDonnell 500-series helicopters which were stationed in the DC area. Mr. 

Lewis was the project manager with oversight for the design, manufacture and certification 

of the Hitachi-MobyTEL hardware architecture reference platform (“HARP”) that was the 

leading embedded systems circuit board used as the progenitor to quickly develop single 

board computers for test equipment manufacturers, automobile companies, control systems 

and telecommunications sub-systems. 

NetMoby’s UAS business unit was established to better merge cutting edge 

engineering techniques with the near-term and future regulatory structure that will permit 

safe operation of UAS vehicles in urban and rural areas. NetMoby and its engineering, law, 

embedded systems, drone and telecommunications UAS solutions consortium have 

responded to the challenges foreseen in the expansion of UAS operations and is working on 
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drone designs, on-board embedded computer and attendant software systems, links and 

centralized operations, visible to the FAA, which will avert any chance of a regulated UAS 

colliding with an in-flight fixed wing or helicopter aircraft. NetMoby believes this will assist 

the development of the commercial operation of UAS vehicles beyond visual line of sight in 

a manner likely to be envisioned by the such companies as Amazon, Domino’s Pizza, Giant 

Food, Safeway, CVS, Department of Homeland Security, forestry services, law enforcement 

entities and others as the industry matures and the benefits and conveniences provided by 

UAS vehicles are realized by consumers, governments at all levels and commercial 

companies in the business of providing goods.

On August 25, 2014, NetMoby, as the prime in a joint venture, responded to the 

FAA’s Request for Information (“RFI”) for an Aeronautical Mobile Communications 

System (“AeroMACS”) which is specified to use a WIMAX 5 GHz design. Therein, 

NetMoby provided the FAA with granular knowledge and input on establishing AeroMACS 

at each tower controlled airport in the US as a means to replace the aging and inefficient 

methods of airport communications currently in place for navigation aids, 

baggage/security/fire/fuel/maintenance/food vendor vehicles, control tower and camera 

apparatus. NetMoby, in near future filings with the FAA, will leverage some of its 

recommended AeroMACS architecture for UAS operations.

III. NETMOBY’S PROPOSED UAS OPERATIONS

A. UNMANNED AIRCRAFT SYSTEM

1. DESIGN AND OPERATIONAL CHARACTERISTICS

a. Unmanned Aircraft System: DJI Phantom 3 Advanced UAS 

NetMoby, Inc., seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 3 Advanced UAS (hereinafter “DJI Phantom 3”) is a 

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

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a 

maximum gross weight of approximately 2.8 pounds (1280 g), with a diagonal size of 

approximately 23 inches and a maximum speed of approximately 36 MPH. See the DJI 

Phantom 3 technical specifications in the DJI Phantom 3 User Manual, appended hereto as 

Exhibit B. 

The DJI Phantom 3 UAS that will be operated by NetMoby, Inc., 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.

B. NETMOBY PROCEDURES TO ENSURE CONDITIONS FOR SAFE FLIGHT.

NetMoby, Inc., acknowledges and actively supports the FAA’s primary role of 

promoting safety in the NAS. NetMoby, Inc., submits that the requested relief herein is 

appropriate since an equivalent level of safety as required in the mission of the FAA will 

be ensured. NetMoby, Inc., will use experienced personnel or technicians to perform 
8

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

techniques, and practices prescribed in the Operating Documents. Furthermore, 

NetMoby, Inc., will document and maintain all maintenance records for the DJI Phantom 

3 UAS. 

NetMoby, Inc., will ensure that any repairs required as a result of regular 

maintenance inspections will be performed prior to the resumption of any flight activity 

by the DJI Phantom 3 UAS requiring such repair. 

More specifically, NetMoby, Inc., prior to each flight, will inspect the small UAS to 

ensure that it is in a condition for safe operation, performing a manufacturer-recommended 

preflight inspection and/or performing an on-the-ground test of the small UAS to determine 

whether safety-critical systems and components are working properly. Because NetMoby, 

Inc., believes that the safety of the general public is crucial, NetMoby, Inc., will conduct an 

inspection before each flight and log the results in the UAS flight manual for inspection by 

the FAA if needed. Safety procedures are the key to accident prevention and such 

procedures would help minimize the risk to the public, as mandated by the FAA rules, both 

current rules and the Proposed UAS rules in proposed § 107.21(b). 

3. RADIO FREQUENCY (RF) SPECTRUM USED FOR CONTROL

The Radio Frequency (RF) spectrum used for control of the UAS and associated 

equipment with respect to the DJI Phantom 3 remote controller is the spectrum located in the 

2.4 gigahertz frequency band, specifically 2.400 GHz – 2.483 GHz. The DJI Phantom 3 is 

FCC compliant with part 15 of the FCC rules which govern equipment certification with 

respect to unlawful emissions in electronic equipment. 

IV. RELIEF SOUGHT IN PETITION

Petitioner, NetMoby, Inc., pursuant to the provisions of the Federal Aviation 

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

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Phantom 3 UAS in the 

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

§§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 1.409(a)(1) &

(a)(2), and 91.417(a) & (b). NetMoby, Inc., believes the following information provided in 

its Petition will demonstrate that the operations proposed by NetMoby, Inc., in conjunction 

with the requested relief, meet the requirements and qualify for expedited approval 

pursuant to Section 333 of the FRMA. 

This Petition for Exemption is submitted pursuant to Section 333(a) through (c) of the 

Reform Act. Congress has directed the FAA “to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system.” Pursuant to Section 333 of the 

Reform Act, the FAA Administrator is to permit unmanned aircraft systems to operate in the 

NAS where it is safe to do so based on the following considerations: 

• The UAS’s size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated 

areas; and 
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• Operation of the UAS within the visual line of sight of the operator. 

Additionally, the FAA Administrator has general authority to grant exemptions from 

the agency’s safety regulations and minimum standards when the Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of 

the Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and 

§§ 44702 – 44716, et seq.). A party requesting an exemption will explain the reasons why the 

exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety 

(or how it would provide a level of safety at least equal to the existing rules). See 14 C.F.R. § 

11.81 (petitions for exemption).

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

the unmanned aircraft and its operation, NetMoby, Inc.'s operation of the DJI Phantom 3 

UAS meets the conditions of FMRA Section 333 and therefore, will not require an 

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

NetMoby, Inc., requests relief from 14 C.F.R § 61.23 (a) & (c), 14 C.F.R. § 91.405(a), 14 

C.F.R. § 91.407(a) (1), 14 C.F.R. § 91.409(a) (1) & (a) (2), and 14 C.F.R. § 91.417(a) & (b), 

as these sections set forth requirements for maintenance that only apply to aircraft with an

airworthiness certificate.

The FAA has proposed in the Federal Aviation Administration (FAA), Department of 

Transportation’s Notice of Proposed Rulemaking in Docket No. FAA-2015-0150, 80 Fed. 

Reg. 9,544 (February 23, 2015) that traditional FAA medical certification may not be 

warranted for small UAS operators subject to this proposed rule mainly because small UAS 

operators and visual observers are operating within a ‘‘confined area of operation,’’ and 

subject to other operational limitations. This is because the proposed visual-line-of-sight 

requirement for the operator and/or visual observer to be able to see the aircraft’s direction 

and attitude of flight in the proposed rule is preferable to a vision standard. Even with normal 

vision it is foreseeable that a small unmanned aircraft may be so small that the operational 

space must be reduced to meet the operational requirements proposed in this rule. As such, 

prescriptive medical standards may not be as critical as they are for individuals exercising 

pilot privileges and therefore may be waived in exempt requests such as the instant 

application. Consequently, NetMoby, Inc., seeks relief from the requirements of 14 C.F.R §

61.23 (a) & (c).

NetMoby, Inc., seeks exemption from 14 C.F.R § 61.101(e)(4) and (5), entitled 

Private and Recreational Pilot Privileges and Limitations, which restricts a person who holds 

a recreational pilot certificate from acting as pilot in command of an aircraft for 

compensation or hire or in furtherance of a business. The purpose of Part 61 is to ensure that 

the skill and competency of any PIC matches the airspace in which the PIC will be operating, 

as well as requiring certifications if the private pilot is carrying passengers or cargo for hire. In 

this case, while the UAS will be operated as part of a commercial operation, it carries neither 

passengers nor cargo.

Relief from certain requirements of 14 C.F.R. § 61.113(a) and (b), entitled Private 

Pilot Privileges And Limitations: Pilot In Command, is requested by NetMoby, Inc., 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 met minimum flight-hour 

and currency requirements, to operate the DJI Phantom 3 UAS in a manner consistent with 
10

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

NetMoby, Inc., seeks relief from 14 C.F.R. § 91.7(a), entitled Civil Aircraft 

Airworthiness, because the DJI Phantom 3 UAS does not require an airworthiness 

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

submits that it will ensure that the DJI Phantom 3 UAS is in an airworthy condition, prior 

to every flight, by determining that the UAS is in compliance with the Operating 

Documents and that the aircraft is in a condition for safe flight.

NetMoby, Inc., also seeks an exemption from the requirements of 14 C.F.R. § 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 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 NetMoby, Inc.,’s 

operation of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, 

will ensure a level of safety equivalent to 14 C.F.R § 91.121.

Additionally, NetMoby, Inc., seeks an exemption from the requirements of 14 

C.F.R § 91.151(b), entitled Fuel Requirements For Flight In VFR Conditions. NetMoby, 

Inc., submits that safety will not be affected by operation of the DJI Phantom 3 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 23 minutes.

In accordance with 14 C.F.R. § 11.81, NetMoby, Inc., providesthe following 

information in support of its petition for exemption:

A. The Specific Sections Of 14 C.F.R. from Which NetMoby, Inc.

Seeks Exemption.

1. NetMoby, Inc., Seeks Exemption From The Requirements 

Of 14 C.F.R § 61.23 (a) & (c)

14 C.F.R § 61.23 (a), entitled Operations Requiring A Medical Certificate, 

prescribes that a person must hold a first-class medical certificate, a second-class medical 

certificate and a third-class medical certificate when exercising certain, specific privileges 

relating to pilot certificates.

14 C.F.R § 61.23 (c), entitled Operations requiring either a medical certificate or 

U.S. driver's license, prescribes that a person must hold either a medical certificate or U.S. 

driver's license when exercising certain, specific privileges relating to student pilot 

certificates, sport pilot certificates, flight instructor certificate or as an Examiner and 

administering a practical test for the issuance of a sport pilot certificate. 

2. NetMoby, Inc., Seeks Exemption From The Requirements 

Of 14 C.F.R § 61.101(e)(4) and (5)

14 C.F.R § 61.101(e)(4) and (5), entitled Private and Recreational Pilot 
11

Privileges and Limitations, which restricts a person who holds a recreational pilot 

certificate from acting as pilot in command of an aircraft for compensation or hire or 

in furtherance of a business. 

3. NetMoby, Inc., Seeks Exemption From The Requirements

Of 14 C.F.R § 61.113(a) And (b).

14 C.F.R 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 employmentif—

(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.

4. NetMoby, Inc., Seeks Exemption From The Requirements 

 Of 14 C.F.R § 91.7(a).

14 C.F.R 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.

5. NetMoby, Inc., Seeks Exemption From The Requirements 

Of 14 C.F.R. § 91.121.

14 C.F.R. § 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.

6. NetMoby, Inc., Seeks Exemption From The Requirements 
12

Of 14 C.F.R 91.151(b).

14 C.F.R. §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.

7. NetMoby, Inc., Seeks Exemption From The Requirement 

Of 14 C.F.R. § 91.405(a).

14 C.F.R. § 91.405, entitled Maintenance Required, subsection (a), states the

following: 

Each owner or operator of anaircraft—

(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[.]

8. NetMoby, Inc., Seeks Exemption From The Requirements 

Of 14 C.F.R. § 91.407(a)(1)

14 C.F.R. § 91.407, entitled Operation After Maintenance, Preventive

Maintenance, Rebuilding, Or Alteration, subsection (a)(1), states thefollowing:

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

preventive maintenance, rebuilding, or alterationunless—

(b) It has been approved for return to service by a person authorized 

under§ 43.7 of this chapter. 

9. NetMoby, Inc., Seeks Exemption From The Requirements 

Of 14 C.F.R. § 91.409(a)(1) And14 C.F.R. § 91.409(a)(2).

14 C.F.R. § 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.

10. NetMoby, Inc., Seeks Exemption From The Requirements 

Of 14 C.F.R. § 91.417(a) And 14 C.F.R. § 91.417(b).
13

14 C.F.R. § 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 will

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 approvingthe 

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 aremaintained.

(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.

B. The Extent Of Relief NetMoby, Inc., Seeks And The Reason NetMoby, Inc., 
14

Seeks The Relief.

1. Extent Of Relief NetMoby, Inc., Seeks And The Reason NetMoby, 

Inc., Seeks Relief From 14 C.F.R. § 61.23 (a) & (c).

Relief from 14 C.F.R § 61.23 (a) & (c) is sought to the extent that traditional FAA 

medical certification may not be warranted for small UAS operators subject to this 

proposed rule mainly because small UAS operators and visual observers are operating 

within a ‘‘confined area of operation,’’ and subject to other proposed operational 

limitations. This is because the proposed visual-line-of-sight requirement for the operator 

and/or visual observer to be able to see the aircraft’s direction and attitude of flight in the 

proposed rule is preferable to a vision standard. As such, prescriptive medical standards 

may not be as critical as they are for individuals exercising pilot privileges and therefore 

may be waived in exempt requests such as the instant application. Consequently, 

NetMoby believes relief from the requirements of 14 C.F.R § 61.23 (a) & (c) are 

appropriate.

2. Extent Of Relief NetMoby, Inc., Seeks And The Reason NetMoby, 

Inc., Seeks Relief From 14 C.F.R. § 61.101(e) (4) and (5) and 14 C.F.R. 

§ 61.113(a) And (b).

Relief from 14 C.F.R. § 61.101(e) (4) and (5)14 C.F.R. §§ 61.113(a) and (b) both of 

which address private and recreational pilot privileges and limitations, especially for pilots

in command (PIC), 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 14 C.F.R. §§ 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, NetMoby, Inc., submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3

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

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

consistent with the operations specifications as described in this exemption, including 

evasive and emergency maneuvers, as well as maintaining appropriate distances from 

people, vessels, vehicles and structures.

Further, NetMoby, Inc., submits that all flights of the DJI Phantom 3 UAS, 

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

NetMoby, Inc.’s business; and (2) will not carry passengers or property for compensation 

or hire.

3. Extent Of Relief NetMoby, Inc., Seeks And The Reason NetMoby, 

Inc., Seeks Relief From 14 C.F.R. §91.7(a).

Relief from 14 C.F.R. § 91.7(a) entitled Civil aircraft airworthiness, is requested to 
15

the extent required to allow NetMoby, Inc., to determine that the DJI Phantom 3 UAS are in 

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

Operating Documents.

NetMoby, Inc., seeks the requested relief because the DJI Phantom 3 UAS does

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

Therefore, NetMoby, Inc., will ensure that the DJI Phantom 3 UAS is in airworthy 

condition based upon its compliance with the Operating Documents prior to every flight, 

and further, determine that the aircraft is in condition for safe flight, as stated in the 

conditions and limitations below.

4. Extent Of Relief NetMoby, Inc., Seeks And The Reason NetMoby, 

Inc., Seeks Relief From 14 C.F.R. § 91.121.

Relief from 14 C.F.R. § 91.121, entitled Altimeter Settings, may be required to 

allow flight operations of the DJI Phantom 3 UAS, 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), NetMoby, Inc., seeks the 

requested relief because the DJI Phantom 3 UA’s altimeter may be set on the ground to 

zero feet AGL, rather than the local barometric pressure or field altitude, before each

flight.

Considering the limited altitude of the proposed operations, relief from 14 C.F.R

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Phantom 3 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 theGCS.

5. Extent Of Relief NetMoby, Inc., Seeks And The Reason NetMoby, Inc., 

Seeks Relief From 14 C.F.R. §91.151(b).

Relief from 14 C.F.R. § 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered THE 

DJI Phantom 3 UAS during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of approximately 23 minutes. 

NetMoby, Inc., seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 3 UAS will 

severely constrain the practicality of any aerial data collection operations that NetMoby, 

Inc., proposes to conduct pursuant to this Petition.

6. Extent Of Relief NetMoby, Inc., Seeks And The Reason NetMoby, Inc., 

Seeks Relief From 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), And 14 C.F.R. § 91.417(a) & (b).

Since 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 14 C.F.R. §

91.417(a) & (b) only apply to aircraft with an airworthiness certificate, NetMoby, Inc., 

requests relief from these Sections because the DJI Phantom 3 UAS does not require 
16

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 UAS meets

the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, NetMoby, Inc., 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. Furthermore, NetMoby, Inc., will 

document and maintain all maintenance records for the DJI Phantom 3 UAS .

C. The Reasons Why Granting NetMoby, Inc.’s Request Would 

Be In The Public Interest.

Granting the instant NetMoby Petition For Exemption will further the public 

interest by allowing NetMoby, Inc., to safely, efficiently, and economically perform 

UAS flight training, education and aerial data collection over certain areas of the United

States.

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of 

NetMoby, Inc.’s proposed operation of the DJI Phantom 3 UAS will be realized without 

implicating any privacy issues.

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

The DJI Phantom 3 UAS is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. 

By reducing the amount of manned aircraft needed to perform aerial acquisitions, an 

exemption allowing the use of a DJI Phantom 3 UAS would reduce the amount of manned 

aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and

property in the air and on the ground.

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

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

DJI Phantom 3 UAS does not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial data collection missions 

would result in fewer aircraft that will be handled by air traffic control during the 

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

2. The Public Will Benefit From The Safety And Efficiency 

Of The DJI Phantom 3 UAS.

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

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

pollution generated during traditional aerial data collection flight operations. By using 

battery power and electric motors, the DJI Phantom 3 UAS produces no air pollution, 

while reducing the carbon footprint of aerial data collection, and also eliminates noise 

pollution, as the UAS is propelled by battery powered electric motors, rather than an 

internal combustion engine typical of other aircraft.

By using the DJI Phantom 3 UAS to perform UAS flight training, education and 

aerial data 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. 
17

3. Performing Aerial Data Collection Operations With 

The DJI Phantom 3 UAS Will Benefit The Economy.

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

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

such, operation of the DJI Phantom 3 UAS will allow United States based companies, like 

NetMoby, Inc., 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 will adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Phantom 3 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 3 UAS, companies such as NetMoby, Inc., can 

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

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

financial performance of U.S. companies, through commercial use of the DJI Phantom 3 

UAS, provides a stable workforce that increases consumer spending; improves local, state, 

and federal tax revenues; and allows companies to invest in research and development in 

order to remain competitive both in the United States andabroad.

4. There Will Be No Privacy Issues.

NetMoby, Inc.,’s proposed operation of the DJI Phantom 3 UAS will not implicate 

any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in 

compliance with Operating Documents which requires property owner involvement as 

well as local law enforcement notification. In summary, all UAS operations under the 

requested exemption will be conducted in accordance with all applicable federal, state, or local 

laws regarding privacy.

D. 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 NetMoby, Inc., Seeks Exemption.

1. Reasons Why The DJI Phantom 3 UAS Meets 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, NetMoby, Inc.,’s operation of the Phantom 

3 UAS meets 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 
18

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, NetMoby, Inc., submits that the DJIPhantom 3 

UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated 

by: (a) the characteristics of the DJI Phantom 3 UAS; (b) the pilot certification 

requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate

Its Safe Characteristics.

The DJI Phantom 3 UAS does not create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 UAS.

The technical specifications of the DJI Phantom 3 UAS are set forth by the DJI 

Phantom 3 User Manual, attached hereto as Exhibit B.

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes 

Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 UAS may be operated in both manual and fully autonomous 

flight modes. A complete description of the flight and navigational modes of the DJI 

Phantom 3 UAS is provided in the DJI Phantom 3 User Manual, attached hereto as Exhibit 

B.

iii. The DJI Phantom 3 UAS Is Designed For Automatic Return To 
19

Home Point In The Event Of Loss Of The Control Link Or

Navigation.

The Return to Home Function (“RTH”) of the DJI Phantom 3 UAS brings the 

aircraft back to the last recorded Home Point. There are three types of RTH 

procedures: Smart RTH, Low Battery RTH, and Fail-Safe RTH. A complete 

description of the Failsafe Functions of the DJI Phantom 3 UAS is set forth at pages 

12 through 14 of the DJI Phantom 3 User Manual, attached hereto as Exhibit B.

iv. The DJI Phantom 3 GCS And Its Operation.

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

GCS and flight control software is provided at pages 23 through 38 of the DJI Phantom 3 

User Manual attached hereto as Exhibit B.

b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Visual Observer

(Where Appropriate).

NetMoby, Inc., will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 

3 UAS. Additionally, a Visual Observer will assist PICs during flight time where 

appropriate.

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

Specific OperatingLimitations.

In seeking this exemption, NetMoby, Inc., proposes to commerciallyoperate DJI 

Phantom 3 UAS for the special purpose of conducting aerial data collection over certain 

areas of United States, pursuant to the following specific operating limitations:

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

the following aircraft described in the Operating Documents, rotorcraft UASs weighing 

less than 55 pounds maximum gross weight: DJI Phantom 3 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 purposes requested and not closed-set motion picture and television 

filming.

3. The UA will not be operated at a speed exceeding 87 knots (100 miles per 

hour). NetMoby may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer.

4. The UA will be operated at an altitude of no more than 400 feet above 

ground level (AGL). All altitudes reported to ATC will be in feet AGL.
20

5. The UA will 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 or 

U.S. driver’s license. 

6. All operations will utilize a visual observer (VO). The UA will be operated 

within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be 

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

capability. The VO and PIC will be able to communicate verbally at all times; electronic 

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

before the flight and cannot transfer his or her designation for the duration of the flight. 

The PIC will ensure that the VO can perform the duties required of the VO.

7. The Operating Documents and the grant of exemption will 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 any exemption take precedence and will be followed. 

Otherwise, the operator will 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 or any law enforcement official upon request. The operator will also present 

updated and revised documents if it petitions for extension or amendment to the grant of 

any exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted the exemption, then the operator will 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.

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

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

undergo a functional test flight prior to conducting further operations under any 

exemption. Functional test flights may only be conducted by a PIC with a VO and must 

remain at least 500 feet from other people. The functional test flight must be conducted in 

such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure 

that it is in a condition for safe operation.

10. Prior to each flight the PIC will conduct a pre-flight inspection and determine 

the UAS is in a condition for safe flight. The pre-flight inspection must account for all

potential discrepancies, e.g., inoperable components, items, or equipment. If the

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is

prohibited from operating until the necessary maintenance has been performed and the UAS 

is found to be in a condition for safe flight.

11. The operator will follow the UAS manufacturer’s maintenance, overhaul,

replacement, inspection, and life limit requirements for the aircraft and aircraft components.
21

12. Each UAS operated under any exemption will comply with all manufacturer

safety bulletins.

13. Under any exemption, a PIC will hold either an airline transport,

commercial, private, recreational, or sport pilot certificate. The PIC will also hold a

current FAA airman medical certificate or a valid U.S. driver’s license issued by a

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal

government. The PIC will also meet the flight review requirements specified in

14 C.F.R § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. 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 this requested exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

persons, vessels, vehicles and structures. PIC qualification flight hours will 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 requested to be permitted under the terms of this requested 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 will operate the UA with 

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

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

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

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

16. The UA will not operate within 5 nautical miles of an Airport Reference Point 

(ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current

FAA-published aeronautical chart, unless a letter of agreement with that airport’s

management is obtained or otherwise permitted by a COA issued to the exemption

holder. The letter of agreement with the airport management will be made available to the 

Administrator or any law enforcement official upon request.

17. The UA will 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.

18. If the UA loses communications or loses its GPS signal, it will return to a predetermined location within the within the private or controlled-access property.

19. The PIC will abort the flight in the event of unpredicted obstacles or 

emergencies.

20. The PIC will be prohibited from beginning a flight unless (considering wind 

and forecast weather conditions) there is enough power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater.
22

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization 

(COA): All operations will be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct operations 

that cannot be conducted under the terms of a COA attached to the requested exemption.

22. All aircraft operated in accordance with the requested exemption will 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 will be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the 

UAS and any documents required under 14 C.F.R §§ 91.9 and 91.203 will be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. These 

documents will be made available to the Administrator or any law enforcement official upon 

request.

24. The UA will remain clear and yield the right of way to all manned aviation 

operations and activities at all times.

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

26. All flight operations will be conducted at least 500 feet from all

nonparticipating 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 

will 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 will cease immediately ensuring 

the safety of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects 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.

The PIC, VO, operator trainees or essential persons are not considered

nonparticipating persons under this exemption.

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

with permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each flight 

to beconducted.

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

vertical boundaries of the operational area as defined by the applicable COA will be reported 

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

to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB 

Web site: www.ntsb.gov.
23

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

NetMoby, Inc., submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI 

Phantom 3 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 3 UAS in a 

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

maintaining appropriate distances from people, vessels, vehicles andstructures.

Considering NetMoby, Inc.’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 3 UAS, 

NetMoby, Inc., submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary 

for NetMoby, Inc.’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, and most recently 

12928).

NetMoby, Inc., will not allow any PIC to operate the DJI Phantom 3 UAS 

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

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

operate the DJI Phantom 3 UAS in a manner consistent with this exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures.

Specifically, the PIC will 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 will 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 NetMoby, Inc.’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations. See Exemption 

No. 11138 at page 15.

Accordingly, NetMoby, Inc., will ensure safe operations by not allowing any PIC

to operate the DJI Phantom 3 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 3 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles andstructures.

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

Would Not Adversely Affect Safety.
24

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

because prior to every flight, NetMoby, Inc., will ensure that the DJI Phantom 3 UAS is in 

an airworthy condition based upon the UAS’s compliance with its Operating Documents

and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

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

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

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, and most 

recently 12928).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

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

because the altitude information of the DJI Phantom 3 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 NetMoby, Inc.’s operation of the DJI Phantom 3 

UAS within visual line of sight, at or below 400 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 and most recently 12928).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI 

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

of the proposed flight operations. Accordingly, NetMoby, Inc., will ensure that it will 

safely operate the battery powered DJI Phantom 3 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 and operating 

specifications of the DJI Phantom 3 UAS, the limitations on the proposed flight operations; 

and the location of the proposed operations, will ensure an equivalent level of safety 

established by 14 C.F.R. Section 91.151(b). 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, 
25

10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161 and most 

recently 12928).

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, NetMoby, Inc., 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 NetMoby, Inc., 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. Furthermore, NetMoby, Inc., will document and 

maintain all maintenance records for the DJI Phantom 3 UAS.

Since the DJI Phantom 3 UAS will be inspected as prescribed by the Operating 

Documents, NetMoby, Inc., will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 User 

Manual is attached hereto as Exhibit B; a copy of the Monthly Maintenance Log is attached 

hereto as Exhibit D.

Likewise, the exemption sought will not adversely affect safety because NetMoby, 

Inc., will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

Operating Documents.

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

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI

Phantom 3 UAS will be performed by trained technicians. Maintenance will be documented 

and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered.

In consideration of NetMoby, Inc.’s proposed operating limitations, the Operating 

Documents, and the technical aspects of the DJI Phantom 3 UAS, NetMoby, Inc., submits 

that safety will not be adversely affected by granting exemption from 14 C.F.R. §§ 

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 and most recently 12928).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.
26

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, NetMoby, Inc., requests that 

the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

UAS, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, 

and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAS for the limited purpose of conducting UAS flight training, education

and aerial data collection 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 will 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 3 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 thefollowing:

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 NetMoby, Inc.’s intended operation of the DJI 

Phantom 3 UAS, which contain such safety standards that the Administrator finds

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R 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).

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

From Which NetMoby, Inc., SeeksExemption:

NetMoby, Inc., seeks exemption from the requirements of 14 C.F.R Sections 

61.23 (a)&(c), 61.101(e)(4) and (5), 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).
27

A Brief Description Of The Nature Of The Exemption NetMoby, 

Inc., Seeks:

This exemption will permit NetMoby, Inc., to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting UAS flight 

training, education and aerial data collection over certain areas of the United

States.

F. Any Additional Information, Views, or Arguments Available To Support

NetMoby, Inc.’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, NetMoby, Inc.’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, NetMoby, Inc., will operate the DJI Phantom 3 UAS 

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

otherwise pose a threat to nationalsecurity.

V. CONCLUSION

As set forth herein, NetMoby, Inc., seeks an exemption pursuant to14

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA), which will permit safe operation of the DJI Phantom 3 UAS Advanced 

commercially, without an airworthiness certificate, for the limited purpose of UAS 

flight training, education and conducting aerial data collection 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 NetMoby, Inc., to safely, 

efficiently, and economically operate the DJI Phantom 3 UAS commercially within the

NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the

FAA Modernization and Reform Act of 2012, Section 333, NetMoby, Inc., respectfully 

requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R § 61.23 (a) & (c), 14 C.F.R § 61.101(e)(4) and (5), 14 C.F.R 

§ 61.113(a) & (b), 14 C.F.R § 91.7(a), 14 C.F.R § 91.121, 14 C.F.R § 91.151(b), 14 

C.F.R § 91.405(a), 14 C.F.R § 91.407(a)(1), 14 C.F.R § 91.409(a) (1) & (a) (2), and 14 

C.F.R § 91.417 (a) & (b) and permit NetMoby, Inc., to operate the DJI Phantom 3 UAS 

Advanced commercially for the purpose of conducting UAS flight training, education

and aerial data collection over 
28

certain areas of the UnitedStates.

Dated: October 5, 2015

Respectfully submitted,

Peter T. Lewis, President

NetMoby, Inc.,

5636 Connecticut Ave, NW 

No. 6300

Washington, DC 20015

Robert E. Kelly, Esq.*

4229 Lafayette Center Drive

Suite 1500

Chantilly, VA 20151

Ph.: 703/447-3117

Email: rekellyrek@verizon.net

Counsel To NetMoby, Inc.

*Admitted to Practice in Virginia, Maryland 

and the District of Columbia

EXHIBITS:

A – NetMoby Operations Checklist and 

Operations Manual

B – DJI Phantom 3 Manufacturer’s User 

Manual 

C – DJI Phantom 3 Quick Start Guide

D – Monthly Maintenance Log

The following attached items will be submitted under separate cover as they contain 

proprietary and commercial information exempt from disclosure under the Freedom of 

Information Act, 5 U.S.C. § 522 et seq., and should be held in a separate file pursuant to 14 

C.F.R. § 11.35(b).
29

EXHIBIT A

NETMOBY CHECKLIST AND OPERATIONS MANUAL 

NetMoby, Inc., only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. The DJI Phantom 3 UAS Advanced is equipped 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).

NetMoby will utilize the following specially-designed operations instruction checklist 

and manual for each UAS flight:

EXHIBIT A

NetMoby DJI Phantom UAV Preflight Checklist

And Operations Manual

INSPECTION ELEMENT ACTION

Pilot credentials FAA airman license & medical certificate (or in lieu of 

medical certificate, a valid US driver’s license) on 

hand

ATIS Listen to ATIS (dialup or ATC monitor radio) of 

airport controlling airspace in UAV operating area; 

note all NOTAMS and current weather conditions to 

include ceilings, wind speed/direction and 

temperature. Note information alphabet, e.g., 

information Kilo (“K”)

Visual Observer (“VO”) in position where 

he/she can physically see Pilot in 

Command (“PIC”).

Check to see if VO is physically able to see PIC. Radio 

communications check between PIC and VO using 

FRS, GMRS, PTT cellular CB app or other radio 

means.

Distance from closest airport Check to ensure UAV position and entire UAV area of 

operation is NO CLOSER than 5 nautical miles from 

closest airport. NetMoby PICs must use Google 

Maps, local Airchart, 1:250,000 scale USGS TOPO 

map or other accurate map to make this 

determination prior to UAV flight operation.
30

[ R E S E R V E D ] [ R E S E R V E D ]

Drone BATTERY LEVEL Ensure drone battery is fully charged

Drone BATTERY Ensure no leaks; connectors clean and intact; fully 

secured and locked into battery compartment

Remote Control Mobile Device BATTERY Ensure fully charged and that fully recharged spare 

or DC charge pack is on hand.

PIC-to-VO radio BATTERY Fully charged.

Drone Battery Failsafe Set. The battery failsafe will trigger a Return to Home 

(”RTH”) if the main battery:

- voltage drops below 10.5 volts (configurable) for 

more than 10 seconds

- remaining capacity falls below the configurable 

Reserved milliamp/hour (“MAH”)

Return to Home (“RTH”) Failsafe Set (upon control link failure, UAV will return to 

takeoff coordinate)

Remote control battery level Ensure remote battery is fully charged

Remote control battery No leaks; connectors clean and intact; fully secured 

and locked into battery compartment

SD memory card Installed – inserted until locking “click” heard; check 

for sufficient remaining memory

Camera lens cap Removed

Camera lens Clean

Gimbal clamp Removed

Gimbal Attached to UAV body securely

Gimbal functionality Power on phantom – maneuver gimbal, pan & tilt 

operation ok

Aircraft body and arms Inspect for integrity.

FAA Registration Number – Aircraft 

identification – Company identification

Clearly visible and not obstructed by tape, paint or 

other materials or equipment.

Landing gear Inspect for proper attachment and integrity.

[ R E S E R V E D ] [ R E S E R V E D ]

Propeller balance Attach prop balancer and calibrate.

Remote control start Turn on (note: power on remote before powering on 

the phantom).

Power On with Propellers removed.

[ R E S E R V E D ] [ R E S E R V E D ]

Compass Calibrate by physically rotating aircraft on all 3 axis 

several times (horizontal first); Power off.

Propellers Attached securely; rotation check; Black coded props 

on black drive shaft and Silver coded props on silver 

drive shaft for proper counter-rotation; Props free of 

excessive pitting and cracks. Replace if worn, not 

airworthy or pitch angle flattened.

Phantom start Turn on; ensure green power button led illuminates 

and telemetry sync with remote is activated (sync 

sound heard from UAV beeper speaker). Pigeon toe 
31

controls (left to far right simultaneous with right 

control to far left) to initiate rotor spin of all 4 props.

UAV LED marker lights Check that all are properly illuminating/operating.

Control responsiveness Check at 3 to 6 ft hover.

GPS satellites Ensure at least 5 satellites are participating in the 

GPS positioning fix.

Altitude Ensure ground level of topo data matches altitude of 

UAV when sitting on ground by plus/minus 3 ft.

Area clear of people Ensure pilot is 3-6 meters from active UAV; Ensure 

observers are 6+ meters from active UAV.

Hover check Bring to hover; Visually observe Phantom for 

smooth, normal motor and electronic speed control 

(“ESC”) operation; No unusual sound emitted from 

UAV; operate controls and check for proper 

responsiveness.

Conduct mission Take off over area clear of people; maintain visual 

eyesight of UAV

Complete flight log Log UAV flight operation area, start time, end time, 

name of PIC, name of VO, description of UAV work 

mission and any other pertinent information.

Note: PICs may not listen to music, eat or drink while operating a NetMoby UAV. PICs must be 

sufficiently rested and must not have consumed alcohol during a period of 24 hours prior to flight 

operations. 

~ ~ ~
32

EXHIBIT B

DJI Phantom 3 Advanced Manufacturer’s User Manual
33
34

EXHIBIT C

DJI Phantom 3 Advanced Manufacturer’s Quick Start Manual
35
36

EXHIBIT D

NetMoby’s Monthly Maintenance Log 

MONTHLY MAINTENANCE LOG

Month: _____Year: ______

UAS ID_______ Date Issue 

Discovered

Date Issue 

Addressed Issue Description & Maintenance Conducted Maintenance PerformedBy:

Print &Sign

Software Updates

Airframe

Engines

Electronic Speed 

Controllers

Propellers

Battery

Camera Gimbal & 

Camera

Landing Gear

Vibration Dampening

LED Marker Lights

Radio Telemetry Link

GPS

Other: