Joseph St.Pierre /JS Airimage, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS 

OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF DJI PHANTOM 3 UNMANNED 

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Joseph St.Pierre / JS Airimage, LLC

2 1/2 Beacon Street

Suite 125

Concord, NH 03301

603-731-1385

 Related documents attached
 UNITED STATES OF AMERICA

 DEPARTMENT OF TRANSPORTATION

 FEDERAL AVIATION ADMINISTRATION

 WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

 Joseph St.Pierre JS Airimage,LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

 TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF DJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEMS

 PURSUANT TO SECTION 333 OF

 THE FAA MODERNIZATION AND REFORM ACT OF 2012

 (PUBLIC LAW 112-95)

October 16, 2015

Joseph St.Pierre

JS Airimage,LLC

 2 1/2 Beacon Street

Suite 125

Concord, NH 03301

603 731 1385
SUMMARY

Joseph St.Pierre JS Airimage, LLC seeks exemption from the requirements of 14 C.F.R 

§§ 61.113(a) &

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

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit Joseph 

St.Pierre JS Airimage, LLC to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of construction sites, 

real estate, agriculture, architectural design, Increase public knowledge of UAS,

tourism.

search and rescue and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Joseph St.PIerre JS Airimage, LLC would like to provide clients with a cost effective 

alternative to traditional helicopter or fix wing aerial photography which in the the past 

10 years has become prohibitively expensive which impacts the petioners business of 

supplying aerial imagery in a cost effective manor to the market place.

Joseph St.Pierre (PIC) has over 38 years of professional aerial video and photography 

experience and is well versed in airport operations, safe zone, air exclusion areas, and 

air safety. He has over 125hrs of experience piloting DJI’s Phantom models 2 and 3. 

Joseph St.Pierre is the sole proprietor of JS Airimage. LLC. The intent of this application 

is to obtain the 333 exemption in order to provide aerial imagery for the following:

Real-estate

Construction sites 

Aerial acquisitions used for inspections of public and private structures.

Agriculture inspection

Private events coverage

Increase public knowledge of UAS and promote safe UAS operations

Search and Rescue operations

Architectural Design

Tourism
BACKGROUND

 Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS

Joseph St.Pierre JS Airimage, LLC, LLC seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 3 Professional 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 

Professional has a maximum gross 

weight of approximately 2 pounds 11 ounces, while having a length of 16 inches, width 

of 16 inches,height of 8 inches, and a maximum speed of approximately 29 knots. 

The DJI Phantom 3Professional UA is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors.The DJI Phantom 3 Professional UA that will

be operated by Joseph St.Pierre /JS Airimage, LLC {PIC} will be registered in 

accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking.
BASIS FOR PETITION

Joseph St.Pierre /JS Airimage, LLC {PIC}, 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 

Professional, UAS in the National Airspace System (NAS), and for an exemption from 

the requirements of 14

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

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

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

with the unmanned aircraft and its operation, Joseph St.Pierre (PIC) /JS Airimage, LLC 

DJI Phantom 3 Professional 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, Joseph St.Pierre (PIC) /JS Airimage, LLC requests relief 

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

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

airworthiness certificate.

Joseph St.Pierre (PIC) /JS Airimage, LLC submits that the requested relief is proper 

since an equivalent level of safety will be ensured. Joseph St.Pierre (PIC) /JS Airimage, 

LLC will use experienced personnel or technicians to perform maintenance, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

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

Phantom 3 Professional Instruction Manual). Furthermore, Joseph St.Pierre (PIC) /JS 

Airimage, LLC will document and maintain all maintenance records for the DJI Phantom 

3 Professional UAS.

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

privileges and limitations: Pilot in command, is requested by Joseph St.Pierre (PIC) /JS 

Airimage, LLC to has the experienced pilot hrs to operate the DJI Phantom 3 UAS in

a manner that is consistent with this exemption, including evasive and emergency 

maneuvers and maintaining FAA required distances from people, vehicles, vessels,and 

airports.
Joseph St.Pierre (PIC) /JS Airimage, LLC seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom 3 Professional UAS do not require an

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

Joseph St.Pierre (PIC) /JS Airimage, LLC submits that he will ensure that the DJI 

Phantom 3 Professional UAS is in an airworthy condition, prior to every flight, by 

determining that the UASs are in compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 3

Professional Instruction Manual), and that the aircraft is in a condition for safe flight.

Joseph St.Pierre (PIC) /JS Airimage, LLC also seeks an exemption from the 

requirements of Section 91.121,entitled Altimeter Settings, as the DJI Phantom 3 

Professional UA will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 3

Professional UA will be provided to the PIC via Global Positioning System (GPS)

equipment and radio communications telemetry data link, which downlinks from the UA 

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

with Joseph St.Pierre (PIC) /JS Airimage, LLC operation of the DJI Phantom 3 

Professional UAS within visual line of

sight, at or below 200 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

Additionally, Joseph St.Pierre (PIC) /JS Airimage, LLC seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR 

conditions. Joseph St.Pierre (PIC) /JS Airimage, LLC submits that safety will not be 

affected by operation of the DJI Phantom 3 UA during daylight hours in visual 

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

power to fly for a total duration of approximately 13.5 minutes.

In accordance with 14 C.F.R. § 11.81, Joseph St.Pierre (PIC) /JS Airimage, LLC 

provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

Joseph St.Pierre /JS Airimage,LLC 

2 1/2 Beacon Street

Suite 125

Concord, NH 03301

603 731 1385

jsp247@gmail.com
B. The Specific Sections Of 14 C.F.R. From Which Joseph St.Pierre (PIC) /JS Airimage, 

LLC Seeks Exemption.

1. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The 

Requirements Of Section 61.113(a) And (b).

 Section 61.113, entitled Private pilot privileges and limitations: Pilot in command,

 subsections (a) and (b) prescribe the following, in relevant part:

 (a) No person who holds a private pilot certificate may act as a pilot in command

 (PIC) of an aircraft that is carrying passengers or property for compensation or

 hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

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

 connection with any business or employment if—

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

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

 

 2. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The Requirements 

Of Section91.7(a).

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

following:

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

3. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The Requirements 

Of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the 

following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating—

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.

4. Joseph St.Pierre (PIC) /JS Airimage, 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.

5. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The Requirement 

Of Section 91.405(a).

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

following:

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

3. Joseph St.Pierre JS Airimage, LLC Seeks Exemption From The Requirements Of 

Section 91.121.

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in

part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight

level of that aircraft, as the case may be, by reference to an altimeter that is set,

when operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of

this section, the current reported altimeter setting of an appropriate

available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the

departure airport or an appropriate altimeter setting available before

departure.

4. Joseph St.Pierre JS Airimage, 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.

5. Joseph St.Pierre JS Airimage, 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[.]
6. Joseph St.Pierre (PIC) /JS Airimage, LLC Exemption From The Requirements Of 

Section91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(1), states the following:

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

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §

43.7 of this chapter[.]

7. Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Exemption From The Requirements 

Of Sections91.409(a)(1) And 91.409(a)(2).

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

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

aircraft unless, within the preceding 12 calendar months, it has had --

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

been approved for return to service by a person authorized by § 43.7 of this

chapter; or

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

with part 21 of this chapter.

8. Joseph St.Pierre (PIC) /JS Airimage, LLC Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b).

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

following:

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

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

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

(2) records of the 100-hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and

each engine, propeller, rotor, and appliance of an aircraft. The records must

include—

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

the work performed; and

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

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

aircraft for return to service.
(2) Records containing the following information:

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

each rotor.

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

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

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

directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

major alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods

prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained

until the work is repeated or superseded by other work or for 1 year after the

work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained

and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under § 43.11 of

this chapter shall be retained until the defects are repaired and the aircraft is

approved for return to service.

C. The Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The 

Reason Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks

The Relief.

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, Joseph St.Pierre (PIC) /JS Airimage, 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 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 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, Joseph St.Pierre (PIC) /JS Airimage, LLC submits that all flights of the DJI 

Phantom 3 Professional UAS, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to

Joseph St.Pierre (PIC) /JS Airimage, LLC business; and (2) will not carry passengers or 

property for compensation or hire.

2. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason 

Joseph St.Pierre (PIC) /JS Airimage, 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 Joseph St.Pierre (PIC) /JS Airimage, LLC

 to determine that the DJI Phantom 3 ProfessionalUAS is in airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with the operating documents 

(i.e., the Joseph St.Pierre (PIC) /JS Airimage, LLC Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional 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.
3. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason 

Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks Relief From Section 91.121.

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

flight operations of the DJI Phantom 3 Professional 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), Joseph St.Pierre 

(PIC) /JS Airimage, LLC seeks the requested relief because the DJI Phantom 3 

Professional UA’s altimeter may beset 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 UA is 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.

4. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason 4. 

Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason 

Joseph St.Pierre (PIC) /JS Airimage, 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 UA during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first

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

least 4.5 minutes. Joseph St.Pierre (PIC) /JS Airimage, 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 UAS will severely constrain the practicality of any aerial video or still photo

flight operations that Joseph St.Pierre (PIC) /JS Airimage, LLC proposes to conduct 

pursuant to this Petition. 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 UA during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first

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

least 4.5 minutes.
TABLE OF CONTENTS

Page

SUMMARY.........................................................................................................3

INTRODUCTION AND INTERESTS OF PETITIONER.................................................3

BACKGROUND...................................................................................................4

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Joseph St.Pierre JS Airimage, LLC

SEEKS EXEMPTION ...........................................................................................7

THE EXTENT OF RELIEF Joseph St.Pierre JS Airimage, LLC SEEKS AND THE REASON

Joseph St.Pierre JS Airimage, LLC SEEKS THE RELIEF ............................................10

THE REASONS WHY GRANTING Joseph St.Pierre JS Airimage, LLC REQUEST WOULD

BE IN THE PUBLIC INTEREST .............................................................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.............................................................................16

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.........................28

CONCLUSION...................................................................................................30

APPENDICES....................................................................................................31
5. Extent Of Relief Joseph St.Pierre (PIC) /JS Airimage, LLC Seeks And The Reason 

Joseph St.Pierre (PIC) /JS Airimage, 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, Joseph St.Pierre (PIC) /JS 

Airimage, LLC requests relief from these Sections because the DJI Phantom 3 

Professional UAS do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 3 Professional UAS meet the

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

Accordingly, Joseph St.Pierre (PIC) /JS Airimage, LLC will use trained technicians to 

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

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

St.Pierre (PIC) /JS Airimage, LLC Operations Manual, Monthly Maintenance Log, and 

DJI Phantom 3 Instruction Manual). Furthermore, Joseph St.Pierre (PIC) /JS Airimage, 

LLC will document and maintain all maintenance records for the

DJI Phantom 3 UAS.
D. The Reasons Why Granting Joseph St.Pierre (PIC) /JS Airimage, LLC Request 

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

Granting the present Petition will further the public interest by allowing Joseph St.Pierre 

(PIC) /JS Airimage, 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 UAS will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of Joseph St.Pierre (PIC) /JS Airimage, LLC 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 Professional and UA is 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 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. 

TheDJI Phantom 3 Professional UA does not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during 

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

2. The Public Will Benefit From The Safety And Efficiency Of The DJI

Phantom 3 Professional UAS.Conducting aerial acquisitions with the DJI Phantom 3 

Professional 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 ProfessionalUAS 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 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 UAS to perform aerial acquisitions, the

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

associated with traditional manned aircraft flight operations, will be substantially 

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

onboard the aircraft, the DJI Phantom 3 Professional UA (weighing approximately 3 

pounds 11 ounces,at their maximum gross weights with lengths of 16 inches, widths of 

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

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

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

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons).

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 3 Professional UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional UAS are

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

operations. As such, operation of the DJI Phantom 3 Professional UAS will allow United

States based companies, like Joseph St.Pierre (PIC) /JS Airimage, 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 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 Professional UAS, companies such as Joseph 

St.Pierre (PIC) /JS Airimage, 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 UAS, provides 

a stable workforce that increases consumer spending; improves local, state, and federal 

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

remain competitive both in the United States and abroad.
4. There Are No Privacy Issues.

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

decades, Joseph St.Pierre JS Airimage, LLC proposed operation of the DJI Phantom 3 

UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional 

UAS will be operated only in compliance with operating documents (i.e., the Joseph 

St.Pierre (PIC) /JS Airimage, LLC Aerial Operations

Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual)

which requires property owner involvement as well as local law enforcement notification,

and in accordance with the Federal Aviation Regulations, including the minimum altitude

requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which Kent H. Shore Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional UAS Meet The Conditions

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

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

with the unmanned aircraft and its operation, Joseph St.Pierre JS Airimage, LLC 

operation of the DJI Phantom 3 Professional UAS meet the conditions of FMRA Section 

333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. Section 333 provides authority for a UAS to operate without 

airworthiness certification and sets forth requirements for considering whether a UAS 

will create a hazard to users of the NAS or the public, or otherwise pose a threat to 

national security. Specifically, FMRA Section 333 states the following, in part:

 

 (a) In General.--Notwithstanding any other requirement of this subtitle, and not

later than 180 days after the date of enactment of this Act, the Secretary of

Transportation shall determine if certain unmanned aircraft systems may

operate safely in the national airspace system before completion of the plan

and rule making required by section 332 of this Act or the guidance required by

section 334 of this Act.

 (b) Assessment of Unmanned Aircraft Systems.--In making the determination under

subsection (a), the Secretary shall determine, at a minimum—
(1) which types of unmanned aircraft systems, if any, as a result of their

 size, weight, speed, operational capability, proximity to airports and

 populated areas, and operation within visual line of sight do not create

 a hazard to users of the national airspace system or the public or pose a

 threat to national security; and

 (2) whether a certificate of waiver, certificate of authorization, or

 airworthiness certification under section 44704 of title 49, United States

 Code, is required for the operation of unmanned aircraft systems

 identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this

 section that certain unmanned aircraft systems may operate safely in the

 national airspace system, the Secretary shall establish requirements for the safe

 operation of such aircraft systems in the national airspace system.

 In seeking this exemption, Joseph St.Pierre (PIC) /JS Airimage, LLC submits 

that the DJI Phantom 3 Professional UAS 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.

 a. The Specifications Of The DJI Phantom 3 Professional 1 UAS

 Demonstrate Its Safe Characteristics.

 The DJI Phantom 3 Professional UAS do not create a hazard to users of the 

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

weight, speed, and operational capability.

 i. Technical Specifications Of The DJI Phantom 3 UAS.

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

by the DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as

Exhibit A.
ii. The DJI Phantom 3 Professional UAS Autonomous Flight And

Navigation Modes Enable The UASs To Remain Within A Defined

Operational Area.

The DJI Phantom 3 Professional 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 Professional UAS is provided at pages 25-35 of the DJI Phantom 3

Professional User Manuals, attached hereto as Exhibit B.

 iii. The DJI Phantom 3 Professional UAS Is 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 UA will 

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

Professional UA do not reacquire control link data from the GCS, the UAS will assume

that the Control Link is lost and the UAS will return to the home position (i.e., failsafe 

mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3 Professional

UAS are set forth at pages 27 through 29 of the DJI Phantom 3 Professional User 

Manuals, attached hereto as Exhibit B.

iv. The DJI Phantom 3 Professional GCS And Its Operation.

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

Professional GCS and flight control software is provided at pages 32 through 43 of the 

DJI Phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manuals 

are attached hereto as Exhibits B.

b. Flight Operations Of DJI Phantom 3 Professional UAS Are Limited To

the Line Of Sight additionally, a safety observer will assist flight operations

dictated by the assignment to secure the safety of persons and or structures

on the ground.

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

 To Specific Operating Limitations.
In seeking this exemption, Joseph St.Pierre (PIC) /JS Airimage, LLC proposes to 

commercially operate DJI Phantom 3 Professional UAS for the special purpose of 

conducting aerial video and photography over certain areas of United States, pursuant 

to the following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less

than 55 pounds maximum gross weight: DJI Phantom 3 Professional 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 200 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.

6. 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.
7. 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.

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

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

9.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.

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

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

11. 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.

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

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

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 the

exemption, including evasive and emergency maneuvers and maintaining

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

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

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

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training,

proficiency, and experience-building flights, all persons not essential for flight

operations are considered nonparticipants, and the PIC must operate the UA

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

91.119.
15. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

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

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

rules (SVFR) are not authorized.

16. 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.

17. 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.

18. 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.

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

emergencies in accordance with the operating documents.

20. 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 30% battery power

remaining.
21. 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.

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

serial number, registered in accordance with 14 C.F.R. part 47, and have

identification (N- Number) markings in accordance with 14 C.F.R. part 45,

Subpart C. Markings must be as large as practicable.

23. 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.

24. 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.

25. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

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

27. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;
c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

28. 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.

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

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS-80) within 24

hours. Accidents must be reported to the National Transportation Safety Board

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

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

And (b) Would Not Adversely Affect Safety.

Joseph St.Pierre (PIC) /JS Airimage, 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 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 Professional UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Considering Joseph St.Pierre (PIC) /JS Airimage, LLC 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 UAS, Joseph St.Pierre (PIC) /JS Airimage, LLC submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate 

to the airmanship skills necessary forJoseph St.Pierre (PIC) /JS Airimage, LLC specific 

proposed flight operations.The FAA has previously granted relief from Section 61.113(a) 

and (b) specific toUAS, 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).
Joseph St.Pierre (PIC) /JS Airimage, LLC will not allow any PIC to operate the DJI 

Phantom 3 ProfessionalUAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the DJI Phantom 3 Professional UAS training and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional 

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

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

structures.Specifically, the PIC must have accumulated and logged, in a manner 

consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot 

(with a minimum of 5 hours of those hours as a UAS pilot operating the same make and 

model ofUAS 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 Joseph St.Pierre JS Airimage, LLC proposed 

operations. TheAdministrator has held that prior documented flight experience that was 

obtained in compliance with applicable regulations would ensure safe operations, 

stating as follows:

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

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

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS

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

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

operating the same make and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hour requirements

to be inclusive rather than additive; i.e. 5 hours make and model time may be

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

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the

PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

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

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

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

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

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

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

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

experience-building flights the PIC is required to operate the UA with appropriate

distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.

Accordingly, Joseph St.Pierre (PIC) /JS Airimage, LLC will ensure safe operations by 

not allowing any PIC to operate the DJI Phantom 3 Professional 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 Professional UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

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

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

Would Not Adversely Affect Safety.

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

because prior to every flight, Joseph St.Pierre (PIC) /JS Airimage, LLC will ensure that 

the DJI Phantom 3Professional UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations 

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

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

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

11112,11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

Would Not Adversely Affect Safety. The equivalent level of safety established by Section 

91.121 will be maintained because the altitude information of the DJI Phantom 3 

Professional UA will be provided to the PIC via GPS equipment and a radio 

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

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

Joseph St.Pierre (PIC) /JS Airimage, LLC operation of the DJI Phantom 3Professional 

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

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

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation 

pointis automatically established by the UASs at ground level.

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

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

Exemption

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

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

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

Would Not Adversely Affect Safety.
A grant of this exemption would ensure an equivalent level of safety established by

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

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

(3)the location of the proposed flight operations. Accordingly, Joseph St.Pierre (PIC) /JS 

Airimage, LLC will ensure that it will safely operate the battery powered DJI Phantom 3 

Professional UA during daylight hours in VFR conditions, with enough battery power to 

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

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

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

Professional UAS; the limitations on the proposed flight operations; and the location of 

the proposed operations, will ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 

Professional UAS provide audible and visual warnings to the PIC at the GCS when the 

UAs experiences low battery voltage, the first warning occurring at approximately 33%

remaining battery power, and again at approximately 10% remaining battery power. At 

the critically low battery level, the DJI Phantom 3 UAS will descend and land 

automatically. Significantly, previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical characteristics 

and operating limitations of the UAS are considered. Relief has been granted for 

manned aircraft to operate at less than the minimums prescribed in Section 91.151, 

including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously 

granted relief from Section 91.151 specific to UAS, in circumstances similar, in all 

material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 

11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 

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

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, Joseph St.Pierre (PIC) /JS Airimage, 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 Joseph St.Pierre (PIC) /JS Airimage, 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 Joseph St.Pierre (PIC) /JS Airimage, 

LLC Aerial Operations Manual,

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

Furthermore, Joseph St.Pierre (PIC) /JS Airimage, LLC will document and maintain all 

maintenance records for the DJI Phantom 3 Professional UAS.
Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the

operating documents, Joseph St.Pierre (PIC) /JS Airimage, 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 User Manuals are attached 

hereto as Exhibit A and B; a copy of the DJI Phantom 3 Professional UAS Maintenance 

LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely 

affect safety because Joseph St.Pierre JS Airimage, 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 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 Joseph St.Pierre (PIC) /JS Airimage, LLC 

proposed operating limitations, the operating documents, and the technical aspects of 

the DJI Phantom 3 Professional UASs, Joseph St.Pierre JS Airimage, LLC submits that 

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

91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

previously granted relief specific to UAS in circumstances similar, in all material 

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

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161).

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Joseph St.Pierre JS 

Airimage, LLC requests that the FAA prescribe special conditions for the intended 

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

that the Administrator finds necessary to establish a level of safety equivalent to that 

established by 14 C.F.R. Part 21,Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 

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

Such special conditions will permit safe operation of the UAs for the limited purpose of 

conducting aerial video and photography over certain areas of the United States for 

compensation or hire. FMRA
Section 333 sets forth the requirements for considering whether a UAS will create a 

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

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

certification in accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 3 Professional UAS, since the airworthiness

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

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

entitled Special Conditions, states the following:

If the FAA finds that the airworthiness regulations of this 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 Leading Edge’s intended operation of the DJI

Phantom 3 Professional 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).

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

From Which Joseph St.Pierre JS Airimage, LLC Seeks Exemption:

Joseph St.Pierre JS Airimage, 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 Joseph St.Pierre JS Airimage, LLC 

Seeks:This exemption will permit Joseph St.Pierre JS Airimage, 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.
G. Any Additional Information, Views, Or Arguments Available To Support Joseph 

St.Pierre (PIC) /JS Airimage, LLC 

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, Joseph St.Pierre (PIC) /JS 

Airimage, LLC 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, Joseph St.Pierre (PIC) /JS Airimage, LLC will operate the 

DJI Phantom 3 Professional UAS safely in the NAS, without creating a hazard to users 

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

As set forth herein, Joseph St.Pierre (PIC) /JS Airimage, LLC seeks an exemption 

pursuant to 14 C.F.R. §

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

which will permit safe operation of the DJI Phantom 3 Professional UAS commercially,

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

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

FAAAdministrator will be fulfilling the Congressional mandate of the FAA Modernization 

andReform Act of 2012, while also advancing the interests of the public, by allowing 

Joseph St.Pierre (PIC) /JS Airimage, LLC to safely, efficiently, and economically operate 

the DJI Phantom 3 Professional UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Joseph St.Pierre (PIC) /JS 

Airimage, 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 UAS commercially for 

the purpose of conducting aerial video and photography over certain areas of the United 

States.

Dated: October 16, 2015

Submitted by,

Joseph St.Pierre

Joseph St.Pierre (PIC) /JS Airimage, LLC 

2 1/2 Beacon Street #125

Concord, NH 03301

603-731-1385
Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Phantom 3 Professional Manufacturer’s User Manual
APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

Kent H Shore 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)

1.1 DJI Phantom 3 Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2.82lbs (1280g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .5m; Horizontal: 1.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 5m/s

1.1.1.7 Max Descent Speed – 3m/s

1.1.1.8 Max Flight Speed – 16m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m
1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

APPENDIX – B

DJI Phantom 3 Professional Manufacturer’s User Manual

Attachment Provided as PDF