Trinity Vision, LLC

Timothy S. and Gail M. Henderson

5256 Balsam Street

Colorado Springs, CO

(719) 522-3998

Email: TrinityVision@comcast.net

September 29, 2015

US Department of Transportation

Federal Aviation Administration

800 Independence Ave. S.W.

Washington, D.C. 20591

To the Director of Flight Standards Service:

Subject: Request for Exemption

Timothy and Gail Henderson of Trinity Vision LLC, requests an exemption of the requirements 

of TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) and (b), 91.7(a), 

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

operation of the DJI Phantom 3 Professional and the DJI Inspire 1 Unmanned Aircraft Systems 

(UAS) for SECTION 333 of the FAA MODERNIZATION AND REFORM ACT OF 2012 (Public Law 

112-95).

If approved this exemption will permit Trinity Vision, LLC (Timothy and Gail Henderson) to 

operate an unmanned aircraft system for commercial use of conducting aerial video and 

photography of construction sites, real estate and landscapes.

Timothy S. Henderson is a retired enlisted (E7) member of the United States Air Force. He 

served honorably for over 22 years. He is currently a manager in the Human Resources 

department of the United States Olympic Committee. Gail M. Henderson is also a retired 

enlisted (E8) member of the United States Air Force. She served honorably over 22 years. She 

is currently an Instructional Designer at The Boeing Company supporting the Ground-based 

Midcourse Defense program. She has worked in the aircraft industry for over 30 years. Timothy 

and Gail’s outstanding records of honor to the United States reflects integrity and respect for 

the laws that govern the country. Safety and respect of life and property are of the utmost 

importance to them.
The objective of the high quality video and photography is to provide aerial inspections of

commercial, public and private structures. Further objectives are to encourage public 

awareness of unmanned aircraft systems safe operation, observation of environmental 

concerns, and topology surveying.

Trinity Vision, LLC seeks an exemption to operate DJI systems for compensation or hire within 

the National Airspace System. 

The DJI Phantom 3 Professional and the DJI Inspire 1 are vertical lift takeoff and landing 

unmanned aircraft systems with ground control stations utilizing electronic tablet or smart 

phone systems. The two UASs are equipped with four main rotors, driven by Lithium Polymer 

Battery powered electronic motors. 

The DJI Phantom 3 Professional has a maximum gross weight of approximately 2.82 

pounds (including battery). It has a length of approximately 23 inches, width of 23 

inches, height of 11.8 inches, and max speed of approximately 31 knots per second. 

The DJI Inspire 1 has a maximum gross weight of approximately 6.47 pounds (including 

battery). It has a length up to 17.3 inches, width of 17.7 inches, height of 11.8 inches 

and maximum speed of approximately 42 knots.

All UASs that are operated by Trinity Vision, LLC 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., Identification and Registration Marking.

Trinity Vision, LLC requests authorization to commercially operate the DJI Phantom 3 

Professional and DJI Inspire 1 in the National Airspace System, and for exemption from the 

requirements of TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) and (b), 

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

(b).

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

unmanned aircraft and its operation, Trinity Vision, LLC’s operation of the aforementioned DJI 

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

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

Trinity Vision, LLC requests exemption from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) and 

(a)(2), and 91.417(a) and (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate. This exemption is appropriate since an 

equivalent level of safety will be ensured. Trinity Vision, LLC will use experienced personnel and 

technicians to perform corrective maintenance, alterations, preventative maintenance on the 

UASs using tactics, techniques and procedures as identified in the operating documents (Pre-
operational inspection checklists, monthly maintenance logs, and the DJI Phantom 3 

Professional and DJI Inspire 1 Instruction Manuals). A log of Pre-operational inspection checklist 

and maintenance activities will be maintained for assets referred to above.

Request exemption of Trinity Vision, LLC for requirements identified in Section 61.113(a) and 

(b), titled Private pilot privileges and limitations: Pilot in command, 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 UASs as identified above in 

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

maintaining appropriate distances from people, vessels, vehicles and structures.

Trinity Vision, LLC also seeks exemption from Section 91.7(a) titled Civil aircraft airworthiness, 

because the DJI UASs identified above do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Trinity Vision, LLC will ensure airworthiness condition prior to 

every flight by determining that the UASs are in compliance with operating documents ( Pre –

operational inspection checklists, monthly maintenance logs, and DJI Phantom 3 Professional, 

and DJI Inspire 1 Instruction Manuals), and that the UASs are in a safe condition for flight.

Trinity Vision, LLC also requests an exemption from the requirements of Section 91.121, titled 

Altimeter settings, as the DJI UASs as identified above will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI UASs will be provided to the PIC 

via Global Positioning System (GPS) equipment and radio communications telemetry data ink, 

which downlinks from the unmanned aircraft to the ground controller for monitoring the flight 

path. The altitude information combined with the DJI UASs within visual line of flight, at or 

below 500 feet above ground level, will ensure a level of safety equivalent to Section 91.121.

Additionally, Trinity Vision, LLC seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Trinity Vision, LLC submits that safety will 

not be affected by operation of the DJI Phantom 3 Professional and DJI Inspire1 unmanned 

aircraft 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.

Trinity Vision, LLC Seeks Exemption from the Requirements of Section 61.113(a) and (b).

Section 61.113, titled 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.

Trinity Vision, LLC Seeks Exemption from the Requirements of Section 91.7(a).

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

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

Trinity Vision, LLC Seeks Exemption from the Requirements of Section 91.121(a).

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.

Trinity Vision, LLC Seeks Exemption from the Requirements of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a 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.
Trinity Vision, LLC Seeks Exemption from the Requirement of Section 91.405(a).

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

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in 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.

Trinity Vision, LLC 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 sub section 

43.7 of this chapter.

Trinity Vision, LLC Seeks Exemption from the Requirements of Sections 91.409(a)(1) And 

91.409(a)(2).

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

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had –

(1) An annual inspection in accordance with part 43 of this chapter and has been 

approved for return to service by a person authorized by sub section 43.7 of this

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 

21 of this chapter.

Trinity Vision, LLC Seeks Exemption from the Requirements of Sections 91.417(a) and 

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following:
(a) Except for work performed in accordance with sub section 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 sub section 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 sub section 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 Trinity Vision, LLC Seeks and the Reason Trinity Vision, LLC Seeks The 

Relief.

Extent of Relief Trinity Vision, LLC Seeks and the Reason Trinity Vision, LLC 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, Trinity Vision, LLC submits that an equivalent level of safety will 

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

DJI Inspire 1 UAS unless that PIC has met certain flight-hour and currency requirements, 

demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional or DJI 

Inspire 1 UAS in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining appropriate 

distances from people, vessels, vehicles and structures.

Further, Trinity Vision, LLC submits that all flights of the DJI Phantom 3 Professional and DJI 

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

to Trinity Vision, LLC’s business; and (2) will not carry passengers or property for compensation 

or hire.

Extent of Relief Trinity Vision, LLC Seeks and the Reason Trinity Vision, LLC Seeks Relief From 

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

required to allow Trinity Vision, LLC to determine that the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the Trinity Vision, LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 

Instruction Manual).

Trinity Vision, LLC seeks the requested relief because the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. Therefore, Trinity Vision, LLC will ensure that the DJI Phantom 3 Professional, and 

DJI Inspire 1 UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, DJI Phantom 3 Professional and DJI Inspire 1 

Instruction Manual) prior to every flight, and further, determine that the aircraft are in 

condition for safe flight, as stated in the conditions and limitations below.

Extent of Relief Trinity Vision, LLC Seeks and the Reason Trinity Vision, LLC Seeks Relief From 

Section 91.121(a).

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight 

operations of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, which utilize a barometric 

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

altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA 

requires that any altitude information concerning UAS operations be reported to air traffic 

control (ATC) in feet above ground level (AGL), Trinity Vision, LLC seeks the requested relief 

because the DJI Phantom 3 Professional and DJI Inspire 1 UA’s altimeter may be set on the 

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

flight.

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

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

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

Phantom 3 Professional and DJI Inspire 1 UAs are equipped with a barometric pressure sensor 

and GPS equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS.

Extent of Relief Trinity Vision, LLC Seeks and the Reason Trinity Vision, LLC Seeks Relief From 

Section 91.151(b).

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

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

Professional, and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions 
(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of

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

Trinity Vision, LLC seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 3 Professional and DJI 

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

operations that Trinity Vision, LLC proposes to conduct pursuant to this Petition.

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

and DJI Inspire 1 UASs, the DJI Phantom 3 Professional and DJI Inspire 1 operating documents, 

and Trinity Vision, LLC’s proposed operating limitations, ensure that Trinity Vision, LLC will 

safely operate the battery powered DJI Phantom 3 Professional and DJI Inspire 1 UAs during 

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

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

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

Extent of Relief Trinity Vision, LLC Seeks and the Reason Trinity Vision, LLC Seeks Relief From 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, Trinity Vision, LLC requests relief from these Sections 

because the DJI Phantom 3 Professional and DJI Inspire 1 UASs do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 3 Professional and DJI Inspire 1 

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

certificate. Accordingly, Trinity Vision, LLC will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UASs using the methods, tactics, techniques, and 

procedures prescribed in the UAS operating documents (i.e., the Trinity Vision, LLC Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 

1 Instruction Manual). Furthermore, Trinity Vision, LLC will document and maintain all 

maintenance records for the DJI Phantom 3 Professional and DJI Inspire 1 UASs.

The Reasons Why Granting Trinity Vision, LLC’s Request Would be in the Public

Interest; That Is, How It Would Benefit The Public as a Whole.

Granting the present Petition will further the public interest by allowing Trinity Vision, LLC to

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

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

Additionally, use of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will decrease 

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

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

The Public Will Benefit From Decreased Congestion Of The NAS.

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

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

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

acquisitions, an exemption allowing the use of a DJI Phantom 3 Professional or DJI Inspire 1 UAS 

would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well 

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

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

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 

Professional and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would result in 

fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, 

arrival, and landing phases of flight operations.

The Public Will Benefit From The Safety And Efficiency of the DJI Phantom 3 Professional and 

DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 3 Professional and DJI Inspire 1 UASs, 

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

and noise pollution generated during traditional aerial video and still photography flight 

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

Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically 

utilized for aerial video and photography, while burning approximately 20-30 gallons per hour 

of leaded aviation fuel. The DJI Phantom 3 Professional and DJI Inspire 1 UAs, while reducing 

the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are 

propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 Professional and DJI Inspire 1 UASs to perform aerial acquisitions, 

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

with traditional manned aircraft flight operations, will be substantially reduced or completely 

eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI 

Phantom 3 Professional and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 ounces and 

6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches 

and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fuel 

on board), has less physical potential for collateral damage to life and property on the ground, 

and in the air, compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons).
Performing Aerial Video and Photography Operations With The DJI Phantom 3 Professional

and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional and DJI Inspire 1 UASs 

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

operations. As such, operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs will 

allow United States based companies, like Trinity Vision, LLC, to remain competitive and 

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

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

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

to remain competitive. Operating the battery powered DJI Phantom 3 Professional and DJI 

Inspire 1 UASs is one such technology that not only allows companies greater operational 

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

operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 Professional and DJI Inspire 1 UASs, companies such as Trinity 

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

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

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

3 Professional and DJI Inspire 1 UASs, provides a stable workforce that increases consumer 

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

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

abroad.

There Are No Privacy Issues.

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

decades, Trinity Vision, LLC’s proposed operation of the DJI Phantom 3 Professional and DJI

Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional

and DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., the 

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

Professional and DJI Inspire 1 Instruction Manual) which requires property owner involvement 

as well as local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. sub section 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 Trinity Vision, LLC Seeks Exemption.

Reasons Why The DJI Phantom 3 Professional and DJI Inspire 1 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 associate DJI Phantom 3 

Professional and DJI Inspire 1 UASs meet the conditions of FMRA Section 333, and will not 

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

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

forth requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states 

the following, in part:

(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, Trinity Vision, LLC submits that the DJI Phantom 3 Professional and 

DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional and DJI Inspire 1

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

Vision LLC personnel will download and use the B4UFLY app (when available) on their phones 

and tablets to constantly check they are within the approval fly area. 

The Specifications of the DJI Phantom 3 Professional and DJI Inspire 1 UASs Demonstrate Its 

Safe Characteristics.
The DJI Phantom 3 Professional and DJI Inspire 1 UASs do not create a hazard to users of the 

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

speed, and operational capability.

Technical Specifications of the DJI Phantom 3 Professional and DJI Inspire 1 UASs.

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

forth by the DJI Phantom 3 Professional and DJI Inspire 1 Specifications and Data Sheet, 

attached hereto as Exhibit A and B.

The DJI Phantom 3 Professional and DJI Inspire 1 UASs Autonomous Flight And Navigation 

Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3 Professional and DJI Inspire 1 UASs may be operated in both manual and 

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

the DJI Phantom 3 Professional located on pages 25-35 of the DJI Phantom 3 Professional Users 

Manuals, and 45-50 of the DJI Inspire 1 User Manuals, attached hereto as Exhibit C and D.

The DJI Phantom 3 Professional and DJI Inspire 1 UASs Are Designed For Automatic Return To 

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

When the Control Link is lost, the DJI Phantom 3 Professional and DJI Inspire 1 UAs will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional

and DJI Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that 

the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, 

and will descend to the takeoff position and shutdown. A complete description of the Failsafe 

Functions of the UAS are set forth in the DJI Phantom 3 Professional User Manual and the DJI 

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

The DJI Phantom 3 Professional and DJI Inspire 1 GCS and Its Operation.

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

and DJI Inspire 1 GCS and flight control software is provided in the DJI Phantom 3 Professional 

and DJI Inspire 1 43 of the User Manuals, and are attached hereto as Exhibits C and D.

Flight Operations of DJI Phantom 3 Professional and DJI Inspire 1 UASs

Are Limited to the Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

Trinity Vision, LLC will only utilize certificated pilots who possess a current and valid airman 

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

Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time.
Flights of DJI Phantom 3 Professional and DJI Inspire 1 UASs Will Be Conducted Pursuant To 

Specific Operating Limitations.

In seeking this exemption, Trinity Vision, LLC proposes to commercially operate DJI Phantom 3 

Professional and DJI Inspire 1 UASs for the special purpose of conducting aerial video and 

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

limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less than 55 

pounds maximum gross weight: DJI Phantom 3 Professional and DJI Inspire 1 Unmanned 

Aircraft Systems. Proposed operations of any other aircraft will require a new petition or 

a petition to amend this grant.

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

purpose of aerial video and photography.

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

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

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

special request is made and approved by ATC. All altitudes reported to ATC must be in 

feet AGL.

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

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

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

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

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

must be able to communicate verbally at all times. Electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before the flight and 

cannot transfer his or her designation for the duration of the flight. The PIC must ensure 

that the SO can perform the functions prescribed in the operating documents.

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

avoiding other air traffic and other ground based obstacles/obstructions and is not 

permitted to operate the camera or other instruments.

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

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

exists between the conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions and limitations 
contained in the grant of exemption take precedence and must be followed. Otherwise, 

the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to the grant of exemption. If the 

operator determines that any update or revision would affect the basis upon which the 

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

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

arise regarding updates or revisions to the operating documents.

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

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

UAS, the aircraft is prohibited from operating until the necessary maintenance has been 

performed and the UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations 

must be properly documented in the aircraft records.

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

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

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

make an entry in the aircraft records.

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

components, items, or equipment, not already covered in the relevant sections of the 

operating documents.

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

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

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

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service.

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

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.
18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

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

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. sub section 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. sub section 

91.119.

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

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

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

closest to proposed area of operations. Flights under special visual flight rules (SVFR) are 

not authorized.

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

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

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

accordance with a NOTAM as required by the operator’s COA. The letter of agreement 

with the airport management must be made available to the Administrator upon 

request.

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

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

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents.

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

in accordance with the operating documents. 24. The PIC is prohibited from beginning a 

flight unless (considering wind and forecast weather conditions) there is enough power 

to fly at normal cruising speed to the intended landing point and land the UA with 25% 

battery power remaining.

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

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

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

(NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the 
operation. All operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and potential 

transponder requirements.

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

number, registered in accordance with 14 C.F.R. part 47, and have identification (NNumber) 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 sub section 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.

Trinity Vision, LLC submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 

Professional and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum 

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

Professional or DJI Inspire 1 UAS in a manner consistent with the exemption, including evasive 

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

vehicles and structures.

Considering Trinity Vision, LLC’s proposed area of operations, and the operating limitations set 

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

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

necessary to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS, Trinity Vision, 

LLC submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for Trinity Vision, LLC’s specific 

proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

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

Trinity Vision, LLC will not allow any PIC to operate the DJI Phantom 3 Professional or DJI Inspire 

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

DJI Phantom 3 Professional or DJI Inspire 1 UAS training and currency requirements, that the 

PIC is able to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner 

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

appropriate distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. 

sub section 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 Trinity Vision, LLC’s proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations 

would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the 

purpose of motion picture filming (or similar operations), the PIC must have accumulated and 

logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS 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 experiencebuilding 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, Trinity Vision, LLC will ensure safe operations by not allowing any PIC to operate 

the DJI Phantom 3 Professional or DJI Inspire 1 UAS unless that PIC has demonstrated, by 

meeting minimum flight-hour and DJI Phantom 3 Professional currency requirements, that the 

PIC is able to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in a manner

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

appropriate distances from people, vessels, vehicles and structures.

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, Trinity Vision, LLC will ensure that the DJI Phantom 3 Professional or DJI Inspire 1 

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 91.121 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 Professional and DJI Inspire 1 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 Trinity Vision, LLC’s operation of the DJI Phantom 3 Professional

and DJI Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of

safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed 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 3 Professional and DJI Inspire 1 UASs; (2) the limitations on the proposed flight

operations; and (3) the location of the proposed flight operations. Accordingly, Trinity Vision, 

LLC will ensure that it will safely operate the battery powered DJI Phantom 3 Professional and

DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery power to fly for a 

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

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

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

and DJI Inspire 1 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 3 Professional and DJI 

Inspire 1 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 DJI Phantom 3 Professional and DJI Inspire 1 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, Trinity Vision, LLC submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Trinity 

Vision, LLC 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 Trinity Vision, LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 Professional and DJI Inspire 1 Instruction Manual). 

Furthermore, Trinity Vision, LLC will document and maintain all maintenance records for the DJI 

Phantom 3 Professional and DJI Inspire 1 UASs.

Since the DJI Phantom 3 Professional and DJI Inspire 1 UASs will be inspected as prescribed by 

the operating documents, Trinity Vision, LLC will maintain the equivalent level of safety 

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

Professional and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and D; a copy of

the DJI Phantom 3 Professional and DJI Inspire 1 UAS Maintenance LOG is attached hereto as 

Exhibit E.

Likewise, the exemption sought will not adversely affect safety because Trinity Vision, LLC 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 

Professional and DJI Inspire 1 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 Trinity Vision, LLC’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, 

Trinity Vision, LLC submits that safety will not be adversely affected by granting exemption from 

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

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances

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

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

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

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, Trinity Vision, LLC requests that the FAA prescribe 

special conditions for the intended operation of the DJI Phantom 3 Professional and DJI Inspire 

1 UASs, which contain such safety standards that the Administrator finds necessary to establish 

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

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. sub section 

21.16, for operation of the DJI Phantom 3 Professional and DJI Inspire 1 UASs, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety 

standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled 

Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. sub section 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. sub section 21.16, the FAA may 

prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 3 
Professional and DJI Inspire 1 UASs, which contain such safety standards that the Administrator 

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

Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 1.405(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 

Trinity Vision, LLC Seeks Exemption:

Trinity Vision, LLC seeks exemption from the requirements of 14 C.F.R Sections

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

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

A Brief Description Of The Nature Of The Exemption Trinity Vision, LLC Seeks:

This exemption will permit Trinity Vision, LLC to commercially operate an Unmanned

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

certain areas of the United States.

Any Additional Information, Views, or Arguments Available to Support Trinity Vision, LLC’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, Trinity Vision, LLC’s request for exemption may be granted 

pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

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

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Trinity Vision, LLC will operate the DJI Phantom 3 Professional and 

DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or the 

public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, Trinity Vision, LLC seeks an exemption pursuant to 14 C.F.R. sub section 

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 Professional and DJI Inspire 1 UASs commercially, 

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

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

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

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

LLC to safely, efficiently, and economically operate the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs commercially within the NAS.
WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization 

and Reform Act of 2012, Section 333, Trinity Vision, LLC respectfully requests that the 

Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 

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

91.417(a) & (b), and permit Leading Edge to operate the DJI Phantom 3 Professional and DJI 

Inspire 1 UASs commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

Dated: September 29, 2015

Respectfully submitted,

Trinity Vision, LLC

_________________________

Trinity Vision, LLC

Timothy S. and Gail M. Henderson

5256 Balsam Street

Colorado Springs, CO 80912

(719) 522-3998

TrinityVision@comcast.net

Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet

C – DJI Phantom 3 Professional Manufacturer’s User Manual

D – DJI Inspire 1 Manufacturer’s User Manual

E – Pre-Operational Checklists

F – Monthly Maintenance Log
APPENDIX – A

DJI Phantom 3 Professional Specifications Data Sheet

Trinity Vision, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small

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

parameters which will not allow flight into controlled airspace. Parameters can also be set to 

limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and

location information to the PIC via the linked monitor (smart phone/tablet devices)

1.2 DJI Phantom 3 Professional

1.2.1 Aircraft

1.2.1.1 Model CPPT000181

1.2.1.2 Weight (Battery Included) – 2.82lbs 45.1507oz (1280g)

1.2.1.3 Diagonal Size (Including Propellers) – 590mm

1.2.1.4 Hovering Accuracy (GPS Mode) – Vertical: 0.1m; Horizontal: 1.5m

1.2.1.5 Max Ascent Speed – 5m/s

1.2.1.6 Max Descent Speed – 3m/s

1.2.1.7 Max Speed – 16m/s (ATTI mode, no wind)

1.2.1.8 Max Flight Altitude – 6000m

1.2.1.9 Max Flight Time – Approximately 23 minutes

1.2.1.10 Operating Temperature – 320F - 1040F (00 to 400 C)

1.2.1.11 Motor Model – DJI 3510

1.2.1.12 Propeller Model – DJI 9450 

1.2.2 Gimbal

1.2.2.1 Controllable Range – Pitch: -900 to +300

1.2.2.2 3-axis (pitch, roll, yaw)

1.2.3 Camera

1.2.3.1 Model – FC350

1.2.3.2 Total Pixels – 12.76M

1.2.3.3 Image Max Size – 4000x3000

1.2.3.4 ISO Range – 100-3200 (video) 100-1600 (photo)

1.2.3.5 Field of View - 940

1.2.3.6 CMOS – Sony EXMOR 1/2.3”

1.2.3.7 HD Video Recording – UHD (4K): 4096x2160p24/25,

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD:

1280x720p24/25/30/48/50/60

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

1.2.4 Remote Controller

1.2.4.1 Name – C1

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

1.2.4.3 Communicating Distance (unobstructed) – 2000m

1.2.4.4 Output Power – FCC: 20 dBm CE: 16 dBm

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

1.2.4.6 Battery – 600mAh LiPo 2S
APPENDIX – B

DJI Inspire 1 Specifications Data Sheet

Trinity Vision, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small

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

parameters which will not allow flight into controlled airspace. Parameters can also be set to 

limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and

location information to the PIC via the linked monitor (smart phone/tablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model – T600

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

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

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

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s

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

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

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

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

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

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

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

2.2.3 Camera

2.2.3.1 Name – X3

2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

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

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD:
1280x720p24/25/30/48/50/60

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

2.2.4 Transmitter

2.2.4.1 Name – C1

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

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W

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

2.2.4.6 Battery – 600mAh LiPo 2S

APPENDIX – C

DJI Phantom 3 Profession Manufacturer’s User Manual

APPENDIX – D

DJI Inspire 1 Manufacturer’s User Manual

APPENDIX – E

Pre-Operational Inspection Checklist

APPENDIX – F

Monthly Maintenance Log