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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. ______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

GHOSTRIDERS 

AERIAL 

PHOTOGRAPHY 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 AND DJI INSPIRE 1 UNMANNED AIRCRAFT 

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on June 8, 2015

GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC

216 Squirrel Hollow Drive

Enterprise, Al 36330

334-447-6251
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC SEEKS EXEMPTION 7

THE EXTENT OF RELIEF GHOSTRIDERS AERIAL PHOTOGRAPHY LLC SEEKS

AND THE REASON GHOSTRIDERS AERIAL PHOTOGRAPHY LLC SEEKS THE 

RELIEF 10

THE REASONS WHY GRANTING GHOSTRIDERS AERIAL PHOTOGRAPHY 

LLC’S REQUEST WOULD BE IN THE PUBLIC INTEREST 13

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY 15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 27

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT GHOSTRIDERS AERIAL PHOTOGRAPHY LLC’S REQUEST 27

CONCLUSION 28

APPENDICES 28
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012

(FMRA) 

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

GHOSTRIDERS AERIAL PHOTOGRAPHY 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 

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC to operate an Unmanned Aircraft 

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

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC provides their clients with expertise

and knowledge in advanced technologies and solutions to increase efficiency, productivity

and effectiveness. The objective of GHOSTRIDERS AERIAL PHOTOGRAPHY LLC is 

to provide high quality aerial imaging for a variety of commercial, public, and residential 

uses, specifically targeting:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Motion Picture Filming

• Aerial acquisitions used for inspections of public and 

private structures.

• Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC seeks an exemption to operate DJI

systems for compensation or hire within the NAS. The DJI Phantom 3 and DJI Inspire 1 

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

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

gross weight less than 10 pounds, a diagonal length of 23 inches, and a maximum speed of

approximately 36 knots. The DJI Inspire 1 has a maximum gross weight less than 10 

pounds, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a

maximum speed of approximately 42 knots. The DJI Phantom 3 and DJI Inspire 1 UAs are

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

motors.
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The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by GHOSTRIDERS 

AERIAL PHOTOGRAPHY 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. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC, pursuant to the

provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for 

Certain Unmanned Aircraft Systems, hereby petitions the Administrator to 

commercially operate the DJI Phantom 3, DJI Inspire 1 UASs 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, GHOSTRIDERS AERIAL PHOTOGRAPHY 

LLC operation of DJI Phantom 3 and DJI Inspire 1 UASs meets the conditions of

FMRA Section 333 and therefore, will not require an airworthiness certificate in 

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

Accordingly, GHOSTRIDERS AERIAL PHOTOGRAPHY 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.

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC submits that the requested relief is 

proper since an equivalent level of safety will be ensured. GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC will use experienced personnel or technicians to perform 

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

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

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

Furthermore, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will document and 

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

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

privileges and limitations: Pilot in command, is requested by GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC to the extent necessary to allow a Pilot in Command (PIC)

holding a private pilot or higher level certificate, as well as an airman medical certificate, 

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

that the PIC is able to safely operate the DJI Phantom 3 and DJI Inspire 1 UASs in a
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manner consistent with this exemption, including evasive and emergency maneuvers and

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

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC seeks relief from Section 91.7(a), 

entitled Civil aircraft airworthiness, because the DJI Phantom 3 and DJI Inspire 1 UASs 

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

H. As such, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will ensure that the DJI

Phantom 3 and DJI Inspire 1 UASs are in an airworthy condition, prior to every flight, by

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

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual), and that the

aircraft are in a condition for safe flight.

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC also seeks an exemption from the

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

Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude

information of the DJI Phantom 3 and DJI Inspire 1 UAs will be provided to the PIC via

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

link, which downlinks from the UA to the GCS for active monitoring of the flight path. 

This altitude information, combined with GHOSTRIDERS AERIAL PHOTOGRAPHY

LLC’s operation of the DJI Phantom 3 and DJI Inspire 1 UASs within visual line of sight, 

at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC seeks an exemption 

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

conditions. GHOSTRIDERS AERIAL PHOTOGRAPHY LLC submits that safety will 

not be affected by operation of the DJI Phantom 3 and DJI Inspire 1 UAs during daylight 

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

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

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

4.5 minutes.

In accordance with 14 C.F.R. § 11.81, GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC provides the following information in support of its 

petition for exemption:

A. Name and Address of GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Owners/Operators

SCOTT W. NISSEN PATRICK R. BACKMANN

603 Westbrook Road 216 Squirrel Hollow Road

Dothan, AL 36303 Enterprise, AL 36360

334-655-8010 334-447-6251

scottynissen@gmail.com patrick.r.backmann@gmail.com
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B. The Specific Sections Of 14 C.F.R. From Which GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC Seeks

Exemption.

1. GHOSTRIDERS AERIAL PHOTOGRAPHY 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. GHOSTRIDERS AERIAL PHOTOGRAPHY LLC Seeks Exemption

From The Requirements Of

Section 91.7(a).

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

states the following:

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

condition.

3. GHOSTRIDERS AERIAL PHOTOGRAPHY 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;
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(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. GHOSTRIDERS AERIAL PHOTOGRAPHY 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. GHOSTRIDERS AERIAL PHOTOGRAPHY 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. GHOSTRIDERS AERIAL PHOTOGRAPHY LLC Seeks Exemption

From The Requirements Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive

maintenance, rebuilding, or alteration, subsection (a)(1), states the

following:

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

maintenance, preventive maintenance, rebuilding, or alteration 

unless--

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

authorized under § 43.7 of this chapter.

7. GHOSTRIDERS AERIAL PHOTOGRAPHY 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:
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(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. GHOSTRIDERS AERIAL PHOTOGRAPHY LLC Seeks Exemption

From The Requirements Of Sections 91.417(a) And 91.417(b).

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

state the following:

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

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

periods specified in paragraph (b) of this section:

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

alteration and records of the 100-hour, annual, progressive, and

other required or approved inspections, as appropriate, for each

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

and appliance of an aircraft. The records must include--

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

Administrator) of the work performed; and

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

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

approving the aircraft for return to service.

(2) Records containing the following information:

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

each propeller, and each rotor.

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

airframe, engine, propeller, rotor, and appliance.

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

the aircraft which are required to be overhauled on a

specified time basis.
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(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 GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Seeks And The Reason GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Seeks The Relief.

1. Extent Of Relief GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Seeks And The Reason GHOSTRIDERS AERIAL PHOTOGRAPHY 

LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private 

pilot or higher level certificate, as well as a current and valid airman medical certificate, 
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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, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

submits that an equivalent level of safety will be maintained because no PIC will be

allowed to operate the DJI Phantom 3 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 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, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC submits that all flights of

the DJI Phantom 3 and DJI Inspire 1 UASs, conducted by the PIC pursuant to the

grant of this Petition: (1) will be incidental to GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC’s business; and (2) will not carry passengers or property for

compensation or hire.

2. Extent Of Relief GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Seeks And The Reason GHOSTRIDERS AERIAL PHOTOGRAPHY 

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 GHOSTRIDERS AERIAL PHOTOGRAPHY LLC to determine that the

DJI Phantom 3 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

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC Aerial Operations Manual, Monthly

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

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC seeks the requested relief because the

DJI Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC will ensure that the DJI Phantom 3 and DJI Inspire 1 UASs are in 

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

Monthly Maintenance Log, and DJI Phantom 3 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.
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3. Extent Of Relief GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Seeks And The Reason GHOSTRIDERS AERIAL PHOTOGRAPHY 

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 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), GHOSTRIDERS 

AERIAL PHOTOGRAPHY LLC seeks the requested relief because the DJI Phantom 3

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 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.

4. Extent Of Relief GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Seeks And The Reason GHOSTRIDERS AERIAL PHOTOGRAPHY 

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 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. 

GHOSTRIDERS AERIAL PHOTOGRAPHY 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 and DJI Inspire 1 UAs will severely constrain the practicality of

any aerial video or still photo flight operations that GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC proposes to conduct pursuant to this Petition.

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

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

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC’s proposed operating limitations, 

ensure that GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will safely operate the
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battery powered DJI Phantom 3 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.

5. Extent Of Relief GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

Seeks And The Reason GHOSTRIDERS AERIAL PHOTOGRAPHY 

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, GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC requests relief from these Sections because the DJI Phantom 3

and DJI Inspire 1 UASs do not require airworthiness certificates. As set forth more fully

below, the DJI Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 

333 for operation without an airworthiness certificate. Accordingly, GHOSTRIDERS 

AERIAL PHOTOGRAPHY LLC will use trained technicians to perform maintenance,

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

practices prescribed in the UAS operating documents (i.e., the GHOSTRIDERS 

AERIAL PHOTOGRAPHY LLC Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, 

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will document and maintain all 

maintenance records for the DJI Phantom 3 and DJI Inspire 1

UASs.

D. The Reasons Why Granting GHOSTRIDERS AERIAL PHOTOGRAPHY

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

GHOSTRIDERS AERIAL PHOTOGRAPHY 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 and DJI Inspire 1 UASs will decrease congestion

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

benefits of GHOSTRIDERS AERIAL PHOTOGRAPHY LLC’s proposed operation of the

DJI Phantom 3 and DJI Inspire 1 UASs will be realized without implicating any privacy

issues.

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

The DJI Phantom 3 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 
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acquisitions, an exemption allowing the use of a DJI Phantom 3 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 and DJI Inspire 1 UAs do not require an airport to takeoff or land. Likewise, a reduction

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

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

arrival, and landing phases of flight operations.

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

Phantom 3 and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 3 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 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 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 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 and DJI Inspire 1 UAs (weighing less than 10 pounds 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 and DJI Inspire 1 UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 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 and DJI Inspire 1 UASs will allow United States 

based companies, like GHOSTRIDERS AERIAL PHOTOGRAPHY LLC, to remain 
15

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 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 and DJI Inspire 1 UASs, companies such as 

GHOSTRIDERS AERIAL PHOTOGRAPHY 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 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.

4. There Are No Privacy Issues.

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

decades, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC’s proposed operation of the

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

the DJI Phantom 3 and DJI Inspire 1 UASs will be operated only in compliance with 

operating documents (i.e., the GHOSTRIDERS AERIAL PHOTOGRAPHY LLC Aerial 

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

Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. §

91.119.

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 GHOSTRIDERS AERIAL PHOTOGRAPHY 

LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 3 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 associated with the 

unmanned aircraft and its operation, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC’s 

operation of the DJI Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA 
16

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, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC submits 

that the DJI Phantom 3 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 and 

DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific operating

limitations.

a. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs

Demonstrate Its Safe Characteristics.
17

The DJI Phantom 3 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.

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1

UASs.

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

the DJI Phantom 3 and DJI Inspire 1 User Manuals, attached hereto as Appendix A and B.

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous Flight 

And Navigation Modes Enable The UASs To Remain Within A 

Defined Operational Area.

The DJI Phantom 3 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 and DJI Inspire 1 UASs is provided in the DJI Phantom and DJI

Inspire 1 User Manuals, attached hereto as Appendix A and B.

iii. The DJI Phantom 3 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 and DJI Inspire 1 UAs will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 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 DJI Phantom 3 and DJI Inspire 1 

UASs is provided in the DJI Phantom and DJI Inspire 1 User Manuals, attached hereto as 

Appendix A and B

iv. The DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation.

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

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

1 User Manuals, attached hereto as Appendix A and B

b. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UASs Are 

Limited To The Line Of Sight Of A Certificated Pilot in Command With 

A Safety Observer.

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC operators operating under this 

exemption will be the only operators to act as a pilot in command (PIC) of the DJI Phantom 

3 and DJI Inspire 1 UASs. Additionally, a safety observer will assist him during flight time.
18

c. Flights Of DJI Phantom 3 and DJI Inspire 1 UASs Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC proposes 

to commercially operate DJI Phantom 3 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 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 35 knots.

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

ground level (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. 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.

7. 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 
19

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.
20

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

corrective action taken against discrepancies discovered between inspections.

17. 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.

18. 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.

19. 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.

20. 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.

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

pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

23. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 
21

speed to the intended landing point and land the UA with 25% battery power 

remaining.

24. 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.

25. 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.

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

operations and activities at all times.

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

vehicle.

28. 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).

29. 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.
22

30. 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.

GHOSTRIDERS AERIAL PHOTOGRAPHY 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 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 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 GHOSTRIDERS AERIAL PHOTOGRAPHY 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 or DJI Inspire 1 UAS, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC

submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for GHOSTRIDERS AERIAL 

PHOTOGRAPHY 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).

GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will not allow any PIC to operate the

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

minimum flight-hour requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and 

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

Inspire 1 UAS in a manner consistent with this exemption, including evasive and emergency

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

structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

C.F.R. § 61.51(b), 25 hours of total time as a UAS 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).
23

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 GHOSTRIDERS AERIAL PHOTOGRAPHY 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 

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.

Accordingly, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will ensure safe

operations by not allowing any PIC to operate the DJI Phantom 3 or DJI Inspire 1 UAS

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

requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS

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

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

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

Would Not Adversely Affect Safety.

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

prior to every flight, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will ensure

that the DJI Phantom 3 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.
24

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 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 GHOSTRIDERS AERIAL PHOTOGRAPHY 

LLC’s operation of the DJI Phantom 3 and DJI Inspire 1 UAs within visual line of sight,

at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The

altitude information will be generated by GPS equipment installed onboard the aircraft. 

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

UASs at ground level.

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

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

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

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

5. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

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

2 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC will ensure that it will safely operate the battery powered DJI

Phantom 3 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 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 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 
25

critically low battery level, the DJI Phantom Vision+ 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).

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, GHOSTRIDERS AERIAL PHOTOGRAPHY 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 GHOSTRIDERS AERIAL PHOTOGRAPHY 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 GHOSTRIDERS AERIAL PHOTOGRAPHY LLC Aerial Operations 

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

Manual). Furthermore, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will document 

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

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

operating documents, GHOSTRIDERS AERIAL PHOTOGRAPHY LLC will maintain 

the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

1.409(a)(2). A copy of the DJI Phantom 3 and DJI Inspire 1 User Manuals are attached 

hereto as Appendix A and B.

Likewise, the exemption sought will not adversely affect safety because

GHOSTRIDERS AERIAL PHOTOGRAPHY 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 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),
26

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 GHOSTRIDERS AERIAL PHOTOGRAPHY LLC’s proposed 

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

Phantom 3 and DJI Inspire 1 UASs, GHOSTRIDERS AERIAL PHOTOGRAPHY 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, GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC requests that the FAA prescribe special conditions for the

intended operation of the DJI Phantom 3 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.

§ 21.16, for operation of the DJI Phantom 3 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. 
27

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

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), 91.405(a),

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

• A Summary That Can Be Published In The Federal Register, 

stating: The Rules From Which GHOSTRIDERS AERIAL 

PHOTOGRAPHY LLC Seeks Exemption:

GHOSTRIDERS AERIAL PHOTOGRAPHY 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 GHOSTRIDERS 

AERIAL PHOTOGRAPHY LLC Seeks:

This exemption will permit GHOSTRIDERS AERIAL PHOTOGRAPHY 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 GHOSTRIDERS AERIAL PHOTOGRAPHY 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, GHOSTRIDERS AERIAL 

PHOTOGRAPHY 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.