UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

NATALIE CONTRACTING, LLC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 91.9(b), 91.203(a), 91.203(b), 45.23(b) AND 21.185

CONCERNING OPERATION OF AN UNMANNED AIRCRAFT SYSTEM 

OVER THE STATE OF ILLINOIS AND INDIANA

PURSUANT TO SECTION 333 OF THE

FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on December 22, 2014

Ryan E. Hill

Natalie Contracting, LLC.

2128 Gould Ct.

Rockdale, Illinois 60436-9531

Tel: (708) 259-0009

Fax: (708) 429-0795

Petitioner
2

TABLE OF CONTENTS

Page

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

SUMMARY.........................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER .................................................4

BACKGROUND .................................................................................................................5

BASIS FOR PETITION ......................................................................................................6

NAME AND ADDRESS OF PETITIONER.................................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH NATALIE 

CONTRACTING, LLC. SEEKS EXEMPTION. .........................................................7

THE EXTENT OF RELIEF NATALIE CONTRACTING, LLC. SEEKS AND THE 

REASON NATALIE CONTRACTING, LLC. SEEKS THE RELIEF.....................9

THE REASONS WHY GRANTING NATALIE CONTRACTING, LLC.'S

REQUEST WOULD BE IN THE PUBLIC INTEREST ............................................12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

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

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

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT NATALIE CONTRACTING, LLC.'S REQUEST. ............................29

CONCLUSION.................................................................................................................30
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

NAS National Airspace System

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

SMS Safety Management System 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules

VMC Visual Meteorological Conditions
4

SUMMARY

Natalie Contracting, LLC. seeks exemption from the requirements of 14 C.F.R. §§ 

91.9(b),

91.203(a), 91.203(b), 45.23(b) and 21.185. This exemption will permit Natalie Contracting, 

LLC. to operate an Unmanned Aircraft System (“UAS”) over areas of the States of Illinois and 

Indiana, while keeping the documents required by the regulations at the ground control station 

and immediately accessible to the pilot in command. Furthermore, the exemption will relieve

Natalie Contracting, LLC. from the airworthiness certificate standards and the requirement to 

have a certificate of airworthiness issued for its UAS. This exemption will also permit any

required markings concerning the operational status of the UAS to be displayed on the fuselage

of the unmanned aircraft.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Natalie Contracting, LLC. (hereinafter referred to as “Natalie”) is a startup contracting 

firm servicing the transportation and infrastructure industries as well as the motion picture 

industry. Natalie has recently acquired a DJI Phantom II Unmanned Aircraft System (hereinafter

referred to as the “DJI Phantom II UAS”). As set forth in this Petition, Natalie seeks to operate 

its DJI Phantom II UAS for the special purpose of aerial videography and cinematography,

jobsite pre-construction video documentation, infrastructure and railroad inspection, and post-job 

as-built video documentation.
5

BACKGROUND

Unmanned Aircraft System: DJI Phantom II UAS

Natalie seeks an exemption to operate a DJI Phantom II UAS, Serial No.

PH645423185 V2.0, registration number

1

to be determined, for compensation or hire within 

the national airspace system (“NAS”). The DJI Phantom II UAS is comprised of an 

unmanned quad-rotor aircraft and a transportable ground station. The DJI Phantom II UAS

has a maximum gross weight of approximately 4.4 pounds (2000 grams), while having a

diagonal length of 13.7 inches (350mm). The DJI Phantom II unmanned quad-rotor is 

equipped with four independent electric motors turning fixed pitch rotors powered by a single

Lithium Polymer battery.

Figure 1: The DJI Phantom II UAS

1 Natalie has not reserved a registration number, but will submit an Aircraft Registration

Application upon the grant of the exemptions sought by this Petition.
6

Proven Operational History of the DJI Phantom II UAS in the NAS

The DJI Phantom II UAS is a common, commercially available, model of remote multirotor aircraft. It is currently operating safely within the NAS pursuant to Advisory Circular 91-

57, June 9, 1981. The DJI Phantom family of aircraft has been operating worldwide since 2006.

BASIS FOR PETITION

Petitioner, Natalie Contracting, LLC., by and through undersigned, pursuant to the 

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

and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems, 

hereby petitions the Administrator for an exemption from the requirements of 14 C.F.R. §§

91.9(b), 91.203(a), 91.203(b), 45.23(b), as well as the restricted category airworthiness 

certification standards specified in 14 C.F.R. § 21.185, including the requirement to have a 

certificate of airworthiness as contemplated by 14 C.F.R. Part 21.

In the alternative, and in accordance with Federal Aviation Regulation (“FAR”) Section

21.16, entitled Special Conditions (14 C.F.R. § 21.16), Natalie respectfully requests that the 

Administrator prescribe special conditions for the intended operation of the DJI Phantom II UAS

that contain such safety standards as the Administrator finds necessary to establish a level of 

safety equivalent to that established by the restricted category airworthiness certification 

standards specified in 14 C.F.R. § 21.185. In the alternative, Natalie seeks an exemption from
7

the requirement to have a certificate of airworthiness issued for its DJI Phantom II UAS, as 

otherwise contemplated by 14 C.F.R. Part 21.

In accordance with 14 C.F.R. § 11.81, Natalie provides the following information in 

support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is: 

Natalie Contracting, LLC

2128 Gould Ct.

Rockdale, IL 60436-9531

The point of contact for this Petition and specific contact information is as 

follows:

Ryan Hill

UAS Project Manager

Natalie Contracting, LLC

1101 Ryehill Drive

Joliet, Illinois 60431-8640

Tel: (708) 259-0009

Fax: (708) 429-0795

Email: ryan@nataliecontracting.com

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

1. Natalie Seeks Exemption From The Requirement Of Section 91.9(b).

Natalie seeks an exemption from 14 C.F.R. § 91.9(b). Section 91.9 entitled Civil 

aircraft flight manual, marking, and placard requirements, subsection (b) states the following:

(b) No person may operate a U.S.-registered civil aircraft--

(1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of this 

chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft 

Flight Manual or the manual provided for in § 121.141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this 

chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any combination 

thereof.
8

2. Natalie Seeks Exemption From The Requirements Of Sections 91.203(a)

and 91.203(b).

Natalie seeks an exemption from 14 C.F.R. § 91.203(a) and (b). Section 91.203 

entitled Civil aircraft: Certifications required, subsections (a) and (b) state the following:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has 

within it the following:

(1) An appropriate and current airworthiness certificate. Each U.S. airworthiness 

certificate used to comply with this subparagraph (except a special flight permit, a copy 

of the applicable operations specifications issued under § 21.197(c) of this chapter, 

appropriate sections of the air carrier manual required by parts 121 and 135 of this 

chapter containing that portion of the operations specifications issued under § 21.197(c), 

or an authorization under § 91.611) must have on it the registration number assigned to 

the aircraft under part 47 of this chapter. However, the airworthiness certificate need not 

have on it an assigned special identification number before 10 days after that number is 

first affixed to the aircraft. A revised airworthiness certificate having on it an assigned 

special identification number, that has been affixed to an aircraft, may only be obtained 

upon application to an FAA Flight Standards district office.

(2) An effective U.S. registration certificate issued to its owner or, for operation within 

the United States, the second copy of the Aircraft registration Application as provided for 

in § 47.31(c), or a registration certification issued under the laws of a foreign country.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by 

paragraph (a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

3. Natalie Seeks Exemption From The Requirements Of Section 45.23(b).

Natalie seeks an exemption from 14 C.F.R. § 45.23(b). Section 45.23 entitled Display of 

marks; general, subsection (b), states the following:

(b) When marks include only the Roman capital letter "N" and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or 

"provisional," as applicable.
9

4. Natalie Requests Relief To Exempt The DJI Phantom II UAS From The

Restricted Category Airworthiness Certification Standards Specified In

14 C.F.R. §21.185.

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

14 C.F.R. § 21.16 entitled Special Conditions, Natalie seeks to exempt the DJI Phantom II UAS

from the restricted category airworthiness certification specified in 14 C.F.R. § 21.185, or the 

requirement to have a certificate of airworthiness issued, as contemplated by 14 C.F.R. Part

21. Section 21.185 entitled Issue of airworthiness certificates for restricted category aircraft, 

states the following, in part:

(a) Aircraft manufactured under a production certificate or type certificate. An applicant 

for the original issue of a restricted category airworthiness certificate for an aircraft type 

certificated in the restricted category, that was not previously type certificated in any 

other category, must comply with the appropriate provisions of § 21.183.

C. The Extent Of Relief Natalie Seeks And The Reason Natalie Seeks The Relief.

1. Extent Of Relief Natalie Seeks And The Reason Natalie Seeks Relief

From Section 91.9(b).

Relief is requested because the DJI Phantom II UAS weighs approximately 4.4 pounds

(2000 grams) at its maximum gross weight and cannot carry the approved Airplane Flight 

Manual onboard. Furthermore, since the DJI Phantom II UAS is unmanned, the aircrew 

member is located at a ground control station. As such, Natalie proposes the following

conditions and limitations to its request for exemption from Section 91.9(b):

The approved Airplane Flight Manual must be kept at the ground control station, where it 

is immediately available for reference by the aircrew member (pilot in command) of the 

DJI Phantom II UAS any time the unmanned aircraft is operating.

The approved Airplane Flight Manual must be made available within 10 days to any

FAA, U.S. Department of Defense, or law enforcement official upon request.
10

2. The Extent Of Relief Natalie Seeks And The Reason Natalie Seeks Relief

From Section 91.203(a) and (b).

Natalie requests relief from the requirement of Section 91.203(a) (i.e., that an appropriate

and current airworthiness certificate and an effective U.S. registration certificate be carried 

within the aircraft), and further, requests relief from the requirement of Section 91.203(b) (i.e., 

that the airworthiness certificate be displayed at the cabin or cockpit entrance so that it is legible

to passengers or crew). As the DJI Phantom II UAS is unmanned, it has no cabin,

cockpit, pilot station, or entrances thereto. Therefore, the aircrew member is located at a ground 

control station and no passengers are carried at any time. As such, Natalie proposes the 

following conditions and limitations to its request for exemption from Sections 91.203(a) and 

(b):

The documents required by Sections 91.203(a) and (b) must be kept at the ground control 

station, where it is immediately available to the aircrew member (pilot in command) of 

the DJI Phantom II UAS any time the unmanned aircraft is operating.

The documents required by 91.203(a) and (b) must be made available within 10 days to 

any FAA, U.S. Department of Defense, or law enforcement official upon request.

3. The Extent Of Relief Natalie Seeks And The Reason Natalie Seeks Relief

From 14 C.F.R. § 45.23(b).

Natalie requests relief from the requirement of Section 45.23(b), if applicable, that the 

word “Restricted” be displayed on the DJI Phantom II UAS near each entrance to the cabin, 

cockpit, or pilot station. As the DJI Phantom II UAS is unmanned, it has no cabin, cockpit, pilot 

station, or entrances thereto. Natalie proposes that, if required, the word “Restricted” be

displayed in letters two (2) inches high, horizontally on both sides of the fuselage between the 

outrunner arms on all sides of the DJI Phantom II UAS.
11

4. The Extent Of Relief Natalie Seeks And The Reason Natalie Seeks Relief

From 14 C.F.R. § 21.185.

Natalie seeks relief from the airworthiness certificate requirements of the Federal 

Aviation Regulations and proposes to commercially operate the DJI Phantom II UAS, without an 

airworthiness certificate, for the special purpose of conducting aerial videography services over

the States of Illinois and Indiana. Natalie seeks relief from the airworthiness certificate 

requirements of 14 C.F.R. § 21.185 to the extent that the DJI Phantom II UAS, which has not yet 

been type certificated by the FAA, may be operated as if it were a restricted category aircraft for a

single, defined, special purpose operation (i.e., aerial videography).

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

333”), Natalie seeks relief from the airworthiness certificate requirements of the FAR because 

operation of the DJI Phantom II UAS will not create a hazard to users of the NAS, or the public, 

or otherwise pose a threat to national security.

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

hazard to users of the NAS or the public or pose a threat to national security. Further, Section

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

Specifically, Section 333 states the following, in part:

(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).
12

As set forth below, numerous factors, including the proven safe operational history of 

the DJI Phantom II UAS in the NAS, as well as the specific parameters of Natalie’s intended 

operation pursuant to this exemption, demonstrate that the DJI Phantom II UAS has in the 

past, and will continue in the future, to operate safely in the NAS without creating a hazard to 

other aircraft or people on the ground. Accordingly, the FAA may approve operation of the 

DJI Phantom II UAS, without an airworthiness certificate, by setting forth specific operating

limitations to ensure a level of safety equivalent to what would be provided by

airworthiness certification.

D. The Reasons Why Granting Natalie’s Request Would Be In The Public

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

Granting the present Petition will further the public interest by allowing Natalie to 

safely, efficiently, and economically perform aerial videography services over the States of 

Illinois and Indiana in support of government entities, transportation and water infrastructure

entities, and the motion picture industry. Additionally, use of the DJI Phantom II UAS will 

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

economy. Notably, the benefits of the proposed operation of the DJI Phantom II UAS will

be realized without implicating any privacy issues.

1. The Public Will Benefit From Aerial Videography

Natalie submits this Petition to perform aerial videography throughout the States of 

Illinois and Indiana, in support of government entities, transportation and water 

infrastructure entities, and the motion picture industry. The DJI Phantom II UAS will 

provide safe, efficient, and economical aerial videography operations to further each of 

these fields, all of which are critical to the well-being of the general public.

The specific operations that Natalie will perform with the DJI Phantom II UAS 
13

demonstrate how the requested exemption will directly benefit the above-referenced 

industries and the public. In the transportation and water infrastructure industry, the DJI 

Phantom II UAS will be used to aid in facility inspections, surveying and planning new 

worksites, and performing right of way analysis. The DJI Phantom II UAS can carry various 

cameras for day and night inspection, can be equipped with additional sensors such as sniffers 

and are programmable to fly specific routes regularly. The DJI Phantom II UAS can inspect 

larger areas, in different ways, in less time and at lower costs. In addition, the more frequent

regular inspections facilitate faster problem recognition, resulting in fewer negative 

externalities. In the motion picture industry, the DJI Phantom II UAS will be used to gather 

video footage not otherwise attainable by traditional means. The advantage of unmanned 

systems is that they provide overviews which normally require several cameras, can enter 

narrow and confined spaces and produce little noise. The DJI Phantom II UAS provides a 

great alternative to helicopters in that they can provide images from similar altitudes, with 

gyro stabilized cameras and modular platforms at a fraction of the cost. This solution can 

dramatically increase the applicability, improve the quality and decrease the costs of aerial 

videography for the motion picture industry.

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

The DJI Phantom II UAS is a battery powered UAS that serves as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

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

an exemption allowing the use of a DJI Phantom II 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, 
14

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

DJI Phantom II UAS does not require an airport to takeoff or land. Likewise, a reduction of

manned aircraft conducting aerial survey missions would result in fewer aircraft that must be 

handled by air traffic control facilities during the ground, takeoff, departure, arrival, and 

landing phases of flight operations.

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

Phantom II UAS.

Conducting aerial videography with the DJI Phantom II UAS, instead of manned 

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

pollution generated during traditional aerial videography flight operations. By using battery

power and electric motors, the DJI Phantom II UAS produces no air pollution, and is the most

viable environmentally conscious alternative to piston or turbine powered rotorcraft. The DJI 

Phantom II UAS, while reducing the carbon footprint of aerial videography, also eliminates 

noise pollution as its battery powered electric motors are barely audible during the take-off 

phase, and cannot be heard when operating more than 100 feet above ground level.

By using the DJI Phantom II UAS to perform aerial videography, 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 aircrew members located onboard the aircraft, the DJI 

Phantom II UAS (weighing approximately 4.4pounds (2000 grams) at its maximum gross 

weight with a diagonal length of 13.7 inches (350mm), 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 aerial videography (weighing approximately 4,450pounds with a
15

rotor diameter of approximately 34 feet, and a fuel capacity of 110 gallons).

The DJI Phantom II UAS has several safety features which will minimize the 

potential for fly-aways and maximize the safe and efficient use of the aircraft in the 

NAS. The DJI Phantom II UAS Naza-M-V2 controller provides Intelligent Orientation 

control (Home Lock and Course Lock features). The Home Lock feature allows for a 

safe return should the operator (i.e. Pilot in Command) get disoriented as to the 

direction the aircraft is moving. Once activated on the remote control, the operator can 

simply pull back on the right control stick and the DJI Phantom II UAS will return to 

the remote control regardless of the aircraft’s location from the remote control. The 

Course Lock feature will allow the operator to maintain a specific course regardless of 

aircraft orientation. The Naza-M-V2 controller also provides for fail safe and lost-link 

safeguards. The fail safe feature means that when the controller link is lost all outputs 

of the command sticks from the controller will go the center point. An example would 

be if the aircraft is in a climbing right turn and the communication link is lost, the 

aircraft would go into a level hover and not continue with the last assigned controller 

instructions. After 3 seconds of the lost-link scenario, the aircraft will climb or descent 

(based on altitude the lost-link occurs) to a pre-assigned altitude and return to the point 

of departure and land itself. A more detailed description of each system is attached as 

Exhibit A.

4. Performing Aerial Videography Operations With The DJI Phantom 

II UAS Will Benefit The Economy.

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

alternative to using manned aircraft to conduct aerial videography. As such, operation of the 

DJI Phantom II UAS will allow United States based companies, like Natalie, to remain 
16

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 fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive.

Operating the battery powered DJI Phantom II 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 II UAS, companies such as Natalie 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 II

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.

5. There Are No Privacy Issues.

Like the manned aerial videography flight operations that have been conducted for 

decades, the proposed operation of the DJI Phantom II UAS will not implicate any privacy 

issues. Specifically, the DJI Phantom II UAS will be operated over the public right-of-way 

or above private property with the property owner/controllers consent, and in accordance

with all Federal Aviation Regulations. 

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 Natalie Seeks Exemption.

1. Reasons Why An Exemption From The Requirements Of Section 

91.9(b) Would Not Adversely Affect Safety.
17

This exemption would maintain the level of safety established by Section 91.9(b)

because Natalie will keep the approved Airplane Flight Manual at the ground control station 

where the pilot in command flying the DJI Phantom II UAS will have immediate access to

the document.

Previous exemptions granted by the FAA concerning Section 91.9(b) establish that 

safety is not adversely affected when the approved Aircraft Flight Manual is kept at the

ground control station of a UAS, where it can be immediately accessed by the pilot in 

command. Section

91.9(b) “requires aircraft to carry the flight manual so the pilot would have ready access to 

the aircraft limitations while in flight.” Exemption No. 8607. However, the FAA has also 

found that UAS will always be operated without any passengers or crew onboard, and that 

“requiring these special-use aircraft [UAS] to carry superfluous paper documents may

present a safety hazard to the integrity of the [UAS].” Id.

The FAA has previously granted exemptions in circumstances similar, in all 

material respects, to those presented herein (e.g., Exemption Nos. 8607, 8737, 8738, 9299,

9430, 9554,

9564, 9565, 10167, 10602, 10673, 10835, 10869, 10968).

2. Reasons Why An Exemption From The Requirements Of Section 

91.203(a) And (b) Would Not Adversely Affect Safety.

This exemption would maintain the level of safety established by Sections 91.203(a) 

and (b) because Natalie will keep the required documents at the ground control station where

the pilot in command flying the DJI Phantom II UAS will have immediate access.

Previous exemptions granted by the FAA concerning Sections 91.203(a) and (b)

establish that safety is not adversely affected when the Airworthiness Certificate and U.S. 
18

registration certificate are kept at the ground control station of the UAS, where it can be

immediately accessed by the pilot in command. Specifically, the FAA has held that the intent 

of Sections

91.203(a) and (b) is better served by having the required documents in the control of the UAS

operator (pilot in command), reasoning as follows:

The original intent of the subject regulation was to display the airworthiness and 

registration documents so they would be easily available to FAA inspectors and 

passengers for inspection and verification of the airworthiness and registration of

the aircraft . . . In this case, the aircraft will always be operated without any

passengers or crew.

The missions for which UASs are intended will prevent the aircraft from being

available for the inspections normally prescribed for civil aircraft. Further, it will be

operated on strictly confined missions from a known departure and arrival point, 

under the constant control of a pilot-in-command. We also find that requiring these

special-use aircraft to carry superfluous paper documents may present a safety

hazard to the integrity of the [UAS].

FAA operating limitations and special arrangements with Air Traffic Control (ATC) 

for surveillance of [UAS] flights adequately compensate for the requirements for

carrying airworthiness and registration documents. We find the intent of the 

regulation is better served by having the required documents in the control of the

aircraft operator and available for inspection under the special conditions prescribed 

in this exemption.

The FAA has previously granted exemptions in circumstances similar, in all 

material respects, to those presented herein (e.g., Exemption Nos. 8607, 8737, 8738, 9299, 

9564, 9565,

10167, 10602, 10673, 10835, 10869, 10968).

3. Reasons Why An Exemption From The Requirements Of 14 C.F.R.

§ 45.23(b) Would Not Adversely Affect Safety.

This exemption would maintain the level of safety established by Section 45.23(b) 

because if required, displaying the word “Restricted” with two (2) inch high letters, 

horizontally between outrunners on all four sides of the DJI Phantom II UAS, will inform all 
19

parties of the unmanned aircraft’s overall operating status.

Significantly, Natalie will display the word “Restricted” in two (2) inch high letters 

in compliance with size requirement of Section 45.23(b) (i.e., “letters not less than 2 inches 

nor more than 6 inches high”). By placing the letters horizontally between outrunners on 

all four sides of the DJI Phantom II UAS, will ensure that the word “Restricted” is the in 

most visible location, so that all parties will be informed of the unmanned aircraft’s overall

operating status. 

The FAA has previously granted exemptions in circumstances similar, in all 

material respects, to those presented herein (e.g., Exemption Nos. 8737, 10167, 10167A, 

10700, 10810).

4. Reasons Why An Exemption From The Requirements Of 14 C.F.R. § 

21.185, Including The Requirement To Have A Certificate Of

Airworthiness, Would Not Adversely Affect Safety.

In seeking this exemption, Natalie submits that the DJI Phantom II UAS can operate 

safely in the NAS above the States of Illinois and Indiana without creating a hazard to other 

aircraft or people on the ground. Accordingly, the FAA may approve its use without an 

airworthiness certificate as demonstrated by: (i) the safe operational history and current use of

the DJI Phantom II UAS in the NAS; (ii) the characteristics of the DJI Phantom II UAS; (iii) 

the limited area of Natalie’s intended operation; (iv) the Safety Management System Natalie

has developed for DJI Phantom II UAS operations and maintenance; (v) the commercial pilot

requirement; (vi) the specific operating limitations; and (vii) any other conditions that the 

Administrator may prescribe.

i. The DJI Phantom II UAS Has A Proven History Of Operation In

The

NAS Pursuant To Advisory Circular 91-57, June 9, 1981.
20

The DJI Phantom II UAS is currently operating safely in the NAS pursuant to 

Advisory Circular 91-57, Model Aircraft Operating Standards. The DJI Phantom II UAS 

has been operated worldwide since 2006.

ii. The Specifications Of The DJI Phantom II UAS Demonstrate

Its Safe

Characteristics.

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

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

or operational capability. The specifications of the DJI Phantom II UAS are as follows:

Unmanned Aircraft

System

The DJI Phantom II is an Unmanned Aircraft System that is 

comprised of an unmanned quad-rotor aircraft and a transportable 

ground station. Model Number P330Z

Serial No. PH45423185 V2.0

Unmanned Aircraft

Dimensions

Diagonal Length: 

13.7 inches (350mm)

Engine

(Propulsive Unit)

Engine (Propulsive Unit)

(4) Multistar P/N : 2212 (Electric) FAA

Engine Type Cert: None

Propulsive Unit Type: (1) 11.1V 5200mAh, Lithium polymer

battery powered, brushless electric motors
21

Motor, Controller Sub-Assembly:

Manufacturer: DJI Innovations

Model: Naza-M

Type: Motor Controller

3.15W (0.25A@12.6V) Maximum

27 grams Wt.

Motor, Battery:

Manufacturer: DJI Innovations

Type: 3S Lithium Polymer

5200 milliamp hour

11.1V (nominal)

Fuel Not Applicable.

NOTE: The DJI Phantom II UAS is powered by a Lithium

Polymer rechargeable battery, DJI, Inc. P/N 733496-

5200mAh-11.1V.

Engine (Propulsive Unit) 

Limits

Maximum Power Output: 130 Watts

Maximum RPM: 920Kv (rpm/v)

Propeller and

Propeller Limits

(4) DJI Innovations

FAA Propeller Type Certificate: None

Propeller Type: 2-blade, ABS plastic, fixed pitch

Propeller Sub-Assembly: 

Manufacturer: DJI Innovations

Model: 9450 10x4.5mm

Diameter (Nominal): 10 in.

Battery Command & 

Control

DJI Innovations battery powers the motor, and internal battery

powers the command and control ground station (remote).

Airspeed Limits Vne (Never Exceed Speed) 29 knot (15 m/s)

Vno (Maximum Structural Cruising Speed) Not Applicable

Va (Maneuvering Speed) Not Applicable

Landing Speed: Not Applicable

Mean Aerodynamic

Chord (MAC)

Not Applicable
22

Leveling Means Not Applicable.

Maximum Weights Ramp 4.4 lbs (2000 grams)

Takeoff 4.4 lbs (2000 grams)

Landing 4.4 lbs (2000 grams)

Empty Weight 2.2 lbs. (1000 grams)

NOTE: Empty Weight Includes weight of battery and 

Excludes payload modules.

Frequencies 902-928 MHz (ISM Band)

2.4 GHz (ISM Band)

NOTE: FCC license is not required to utilize the above 

frequencies; uplink and downlink are on the 900Mhz band. If 

video is utilized, uplink, downlink, and video are all on

2.4 Ghz.

Computer Software Ground Station software, iOS

Minimum Crew (1) The DJI Phantom II UAS can be operated by a single operator.

Number of Seats (0) Not Applicable.

Fuel Capacity Not Applicable.

Oil Capacity Not Applicable.

Max. Operating Altitude 393 ft. AGL (120 M)

Control Surface

Movements

Not Applicable
23

Nominal Endurance 25 minutes 14° - 122° F (-20° - 50° C)

Ambient Outside Air

Temperature (OAT)

Maximum OAT: 122° F (50° C)

Minimum OAT At Altitude: 14° F (-10° C)

Wind Limitation Not Applicable

Maintenance This DJI Phantom II UAS must be maintained in accordance with 

the DJI Phantom II Maintenance Operation Manual, or later FAA 

accepted revision.

iii. Flight Operations Pursuant To The Exemption Sought 

Would Be Limited To Areas Over The States Of Illinois

and Indiana That Are Not In The Proximity Of Airports 

Or Over Populated Areas.

Natalie proposes to only conduct aerial videography flight operations over areas of 

the States of Illinois and Indiana that are not near populated areas, airports, helipads, or 

state roads. Specifically, Natalie’s proposed area of flight operations over the States of 

Illinois and Indiana includes areas that are:

1. Not within five (5) miles of any airport or helipad, without the consent of the 

affected air traffic control facility. Continuous two-way radio communication will be 

established and maintained at all times during flights in this area;

2. Not below one hundred fifty (150) feet over of state roads having more than two 

lanes; and

3. Not below seventy-five (75) feet over state roads having two lanes or less.

Since this platform is capable of hovering, slewing laterally, and ascending/descending over 

a point, we are considering the DJI Phantom II UAS a “helicopter” for the purposes of 

91.119(d). Furthermore, all flight operations will be conducted in accordance with 14
24

C.F.R. § 91.119. Minimum safe altitudes: General. 

In summary, Natalie seeks to operate its DJI Phantom II UAS over areas of

Illinois and Indiana, while maintaining safe distances from any populated areas, airports, 

helipads, and roadways.

iv. Operation Of The DJI Phantom II UAS Will Be Conducted

Pursuant

To A Safety Management System.

A Safety Management System (“SMS”) will control Natalie’s operation of the DJI 

Phantom II UAS and will significantly contribute to maintaining the level of safety

contemplated by the airworthiness certificate requirements from which Natalie now seeks 

relief.

Pursuant to the SMS and 14 C.F.R. § 43.13, entitled Performance Rules (general),

each person performing maintenance, alteration, or preventive maintenance on the DJI 

Phantom II UAS, motor, propeller, or appliance shall use the methods, techniques, and

practices prescribed in the current manufacturer's maintenance manual or Instructions for

Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and 

practices acceptable to the

Administrator. Each person shall use the tools, equipment, and test apparatus necessary to

assure completion of the work in accordance with accepted industry practices.
25

v. Flight Operations Of The DJI Phantom II UAS Are Limited To 

The Line Of Sight Of A Commercial Certificated Pilot in

Command With A Safety Observer.

Natalie will only utilize Commercial Pilots with a valid First or Second Class Airman

Medical certificate to act as pilot in command of the DJI Phantom II UAS. Additionally, all

pilots will be assisted by a safety observer. The pilot in command and safety observer must 

meet the requirements as set forth by the SMS and Standard Operating Procedures adopted 

by Natalie for flight operations of the DJI Phantom II UAS. A copy of the Standard 

Operating Procedures, which is proprietary information, is attached hereto as Exhibit B, and 

is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

4

vi. Flights Will Be Conducted Pursuant To Specific

Operating

Limitatio

ns.

In seeking this exemption, Natalie proposes to commercially operate the DJI Phantom

II UAS without satisfying the restricted category airworthiness certification process specified

in

14 C.F.R. § 21.185, or otherwise having a certificate of airworthiness issued by the FAA, as 

contemplated by 14 C.F.R. Part 21. Natalie proposes to operate the DJI Phantom II UAS, 

for the special purpose of conducting aerial videography over the States of Illinois and 

Indiana, pursuant to the following specific operating limitations:

1. Flight operations are permitted only over the States of Illinois and Indiana.

2. The DJI Phantom II UAS will be operated at or below 400 ft. above ground level

(AGL), except as necessary to comply with the requirements of 14 C.F.R. §

91.119.

3. The DJI Phantom II UAS shall be operated within one mile, and within line of 
26

sight, of the pilot in command and safety observer.

4. The DJI Phantom II UAS shall be operated pursuant to Day Visual Flight 

Rules

(VFR) in visual meteorological conditions (VMC). The DJI Phantom II UAS

shall be operated only during daylight hours (i.e. between the end of morning civil 

twilight

and the beginning of evening civil twilight, as published in the American

Air

Almanac, converted to local time).

5. The duration of each flight shall not exceed 25 minutes or upon reaching 25% 

battery

 power, whichever is less.

6. The DJI Phantom II UAS shall operate from on-site takeoff/landing locations 

directly next to the pilot in command and co-located safety observer. If the operation 

is from a watercraft, the pilot in command and safety observer shall remain co-located 

on the same watercraft.

7. Operations shall be conducted by commercially certificated airmen who have 

completed training, checking, currency, and recency of experience requirements as 

approved by the FAA Administrator.

8. Operation of the DJI Phantom II UAS with any inoperative instruments or 

equipment shall be prohibited.

9. The DJI Phantom II UAS shall be maintained in accordance with the 

Manufacturer’s Maintenance Manual.

4 Exhibits to this Petition are proprietary information, and in accordance with 14 C.F.R.

11.35(b), are not to be included in the Federal Docket Management System (FDMS).
27

10. The DJI Phantom II UAS shall be operated pursuant to 14 C.F.R. Part 91, 

operating requirements.

11. For the proposed flight operation, only one DJI Phantom II UAS shall be

airborne at any given time.

12. Prior to flight operations, Natalie shall coordinate and establish two 

way communications with the nearest Air Traffic Control facility.

13. For any flight operations over U.S. Government or state managed lands, Natalie

shall coordinate with the appropriate authority and ensure that the property owners 

have at least twelve (12) hours of advance notice prior to the proposed flight 

operations. Coordination shall include anticipated periods of operation, purpose of 

the flights, and contact information for the operator should questions or issues arise.

vii. Any Other Conditions The FAA May Prescribe For Safe

Operation.

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

and

14 C.F.R. § 21.16 entitled Special Conditions, Natalie requests that the FAA prescribe special 

conditions for the intended operation of the DJI Phantom II UAS, which contain such safety 

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

that established by Section 21.185, and which will permit safe operation of the DJI Phantom 

II UAS for the special purpose of conducting aerial videography over the State of Ohio. 

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 
28

accordance with any requirements that must be established for the safe operation of the 

aircraft systems in the NAS.

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

§ 21.16, for operation of the DJI Phantom II 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 Section 333 and 14 C.F.R. § 21.16, the FAA may

prescribe special conditions for Natalie’s intended operation of the DJI Phantom II UAS, 

which contain such safety standards that the Administrator finds necessary to establish a level 

of safety equivalent to that established by Section 21.185, and which will permit safe 

operation of the DJI Phantom II UAS for the special purpose of conducting aerial

videography over the States of Illinois and Indiana.

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

stating: The Rules From Which Natalie Seeks Exemption:

Natalie Contracting, LLC. seeks exemption from the requirements of 14 C.F.R. §§ 

91.9(b), 91.203(a), 91.203(b), 45.23(b) and 21.185.

A Brief Description Of The Nature Of The Exemption Natalie Seeks:

This exemption will permit Natalie Contracting, LLC. to operate an Unmanned Aircraft
29

System over certain rural areas of the State of Illinois, while keeping the documents 

required by the regulations at the ground control station and immediately accessible 

to the pilot in command. Furthermore, the exemption will relieve Natalie Contracting, 

LLC. from the airworthiness certificate standards and the requirement to have a 

certificate of airworthiness for its Unmanned Aircraft System. This exemption will 

also permit any required markings concerning the operational status of the UAS to be 

displayed on the fuselage of the unmanned aircraft.

G. Any Additional Information, Views, Or Arguments Available To Support

Natalie’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012, 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may 

operate safely in the NAS. As such, Natalie’s request for exemption may be granted 

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

Sec. 333 sets forth the requirements for considering whether a UAS will create a

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

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

333 states the following:

(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).
30

(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.

As discussed in detail above, the DJI Phantom II UAS has in the past, and will

continue in the future, to operate 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 above, Natalie seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012, which will permit safe 

operation of the DJI Phantom II UAS commercially, without an airworthiness certificate, for

the special purpose of conducting aerial videography over areas in the States of Illinois and 

Indiana. By granting this Petition, the FAA Administrator will be fulfilling the 

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing Natalie to safely, efficiently, and 

economically operate the DJI Phantom II UAS commercially within the NAS.
31

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

Modernization and Reform Act of 2012, Section 333, Natalie respectfully requests that the 

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

91.9(b), 91.203(a), 91.203(b), 45.23(b), as well as the restricted category airworthiness 

certification standards specified in 14 C.F.R. § 21.185, including the requirement to have a 

certificate of airworthiness issued for the DJI Phantom II UAS, as contemplated by 14 C.F.R.

Part 21.

Dated:

December 22, 2014 Respectfully submitted,

Natalie Contracting, LLC.

/s/ Ryan E. Hill

Ryan E. Hill

UAS Project Manager

1101 Ryehill Drive

Joliet, Illinois 60431-8640

Tel: (708) 259-0009

Fax: (708) 429-0795

Petitioner

cc: Timothy Harris, DPA FSDO