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August 25, 2015

To who it may concern:

I am applying 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), to 

operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012 (FMRA). This exemption will permit Christy Lee Wooten to operate an 

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

photography for special events, construction sites, real estate, and landscape over certain areas of 

the United States. 

Sincerely,

Christy Lee Wooten
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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 Christy 

Lee Wooten SEEKS EXEMPTION....................................................................................6

THE EXTENT OF RELIEF Christy Lee Wooten SEEKS AND 

THE REASON Christy Lee Wooten SEEKS THE RELIEF..............................................9

THE REASONS WHY GRANTING Christy Lee Wooten’s

REQUEST WOULD BE IN THE PUBLIC INTEREST .................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD 

NOT ADVERSELY AFFECT SAFETY..........................................................................13

SUMMARY THAT CAN BE PUBLISHED IN THE

FEDERAL REGISTER.....................................................................................................24 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT Christy Lee Wooten’s

REQUEST.........................................................................................................................24 

CONCLUSION.............................................................................................................................24

APPENDICES...............................................................................................................................26
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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) Section 333

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

Christy Lee Wooten 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 Christy Lee Wooten to operate an 

Unmanned Aircraft System (UAS) for the the commercial purpose of conducting aerial video 

and photography for special events, construction sites, real estate, and landscape over certain 

areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Christy Lee Wooten provides her clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. She also 

provides clients with the highest quality digital content for use in their commercial, personal, and 

non-profit multimedia projects. Christy Lee Wooten has over 10 years of professional experience 

doing videography and photography for newspapers, real estate, commercial use, special events 

and private events as well as a Bachelor of Journalism, photo sequence, from the University of 

Texas at Austin. She is recognized as an expert in her field. Christy Lee Wooten has over 1 years 

of recreational/hobby experience in all aspects of aerial video and photography. The objective of 

Christy Lee Wooten’s aerial video and photography operations is to safely provide high quality 

imaging for a variety of commercial, public, and residential uses, specifically targeting: 

! Construction sites before and after 

! Appraisals 

! Real-estate marketing 

! Residential aerial portraits

! Motion Picture Filming 

! Aerial acquisitions used for inspections of public and private structures. 

! Special Event Filming 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 UAS

Christy Lee Wooten seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 2 UASs are a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone 

systems. The DJI Phantom 2 UAS has a maximum gross weight of approximately 2 pounds 4 

ounces, while having a length of 12 inches width of 12 inches, height of 8 inches, and a 
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maximum speed of approximately 29 knots. The DJI Phantom 2 UAS is equipped with four main 

rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 2 UAS that will be operated by Christy Lee Wooten 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, Christy Lee Wooten, 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 2 UAS in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

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

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

unmanned aircraft and its operation, Christy Lee Wooten’s operation of DJI Phantom 2 UAS 

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

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

Accordingly, Christy Lee Wooten 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. 

Christy Lee Wooten submits that the requested relief is proper since an equivalent level 

of safety will be ensured. Christy Lee Wooten will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

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

and DJI Phantom 2 UAS Instruction Manual). Furthermore, Christy Lee Wooten will document 

and maintain all maintenance records for the DJI Phantom 2 UAS. 

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

privileges and limitations: Pilot in command, is requested by Christy Lee Wooten to the extent 

necessary to allow a Pilot in Command (PIC) not holding a certificate, or 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 Phanton 2 UASs in a manner 

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

appropriate distances from people, vessels, vehicles and structures. 

Christy Lee Wooten seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 2 UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Christy Lee Wooten submits that she 

will ensure that the DJI Phantom 2 UAS is in an airworthy condition, prior to every flight, by 
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determining that the UAS is in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 2 UAS Instruction Manual), and that the aircraft is in a 

condition for safe flight.

Christy Lee Wooten also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 2 UAS will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Phantom 2 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 Christy Lee Wooten’s operation of the DJI Phantom 2 UAS 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. 

Additionally, Christy Lee Wooten, seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Christy Lee Wooten submits 

that safety will not be affected by operation of the DJI Phantom 2 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, Christy Lee Wooten 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 and point of contact is: 

Christy Lee Wooten

7568 CR 465D

Henderson, Texas 75654

Email: clwoot@yahoo.com

936-615-2515

B. The Specific Sections Of 14 C.F.R. From Which Christy Lee Wooten Seeks Exemption. 

1. Christy Lee Wooten 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—
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(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. Christy Lee Wooten Seeks Exemption from The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states t he following:

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

3. Christy Lee Wooten Seeks Exemption From The Requirements Of Section 91.121. 

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

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

that aircraft, as the case may be, by reference to an altimeter that is set, when operating--

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

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

100 nautical miles of the aircraft; 

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

section, the current reported altimeter setting of an appropriate available station; 

or 

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

departure airport or an appropriate altimeter setting available before departure. 

4. Christy Lee Wooten 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. Christy Lee Wooten 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 
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between required inspections, except as provided in paragraph (c) of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Christy Lee Wooten 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. Christy Lee Wooten Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

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

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

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

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

approved for return to service by a person authorized by § 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. Christy Lee Wooten 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 
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(iii) The signature, and certificate number of the person approving the 

aircraft for return to service. 

(2) Records containing the following information: 

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

and each rotor. 

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

propeller, rotor, and appliance. 

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

which are required to be overhauled on a specified time basis. 

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

the last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

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

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

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

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

required. 

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

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

propellers, and appliances. 

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

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

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

performed. 

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

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

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

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

approved for return to service. 

C. The Extent Of Relief Christy Lee Wooten Seeks And The Reason Christy Lee Wooten 

Seeks The Relief. 

1. Extent Of Relief Christy Lee Wooten Seeks And The Reason

Christy Lee Wooten Seeks Relief From Section 61.113(a) And (b). 
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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 not holding a private pilot 

or higher level certificate, or a current and valid airman medical certificate, but 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, Christy Lee Wooten submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 UAS 

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

PIC is able to safely operate the DJI Phantom 2 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, Christy Lee Wooten submits that all flights of the DJI Phantom 2 UAS, 

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

Wooten’s business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Christy Lee Wooten Seeks And The Reason Christy Lee Wooten 

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 Christy Lee Wooten to determine that the DJI Phantom 2 UAS is in airworthy 

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

documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Instruction Manual). 

Christy Lee Wooten seeks the requested relief because the DJI Phantom 2 UAS does not 

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

Christy Lee Wooten will ensure that the DJI Phantom 2 UAS is in airworthy condition based 

upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

Phantom 2 Instruction Manual) prior to every flight, and further, determine that the aircraft is in 

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

3. Extent Of Relief Christy Lee Wooten Seeks And The Reason Christy Lee Wooten 

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 2 UAS, which utilize a barometric pressure sensor, GPS 

equipment, and a radio communications telemetry data link to downlink altitude information 

from the UA to the PIC at the ground control station (GCS). Since the FAA requires that any 

altitude information concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), Christy Lee Wooten seeks the requested relief because the DJI 

Phantom 2 UAS altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. 
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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 2 UAS is equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Christy Lee Wooten Seeks And The Reason Christy Lee Wooten 

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 2 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. Christy Lee Wooten seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered DJI Phantom 2 UAS will severely constrain the practicality of any aerial 

video or still photo flight operations that Christy Lee Wooten proposes to conduct pursuant to 

this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 UAS, 

the DJI Phantom 2 operating documents, and Christy Lee Wooten’s proposed operating 

limitations, ensure that Christy Lee Wooten will safely operate the battery powered DJI Phantom 

2 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 Christy Lee Wooten Seeks And The Reason Christy Lee Wooten

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, Christy Lee Wooten requests relief from these 

Sections because the DJI Phantom 2 UAS does not require airworthiness certificates. As set forth 

more fully below, the DJI Phantom 2 UAS meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, Christy Lee Wooten will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using the 

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

Maintenance Log, and DJI Phantom 2). Furthermore, Christy Lee Wooten will document and 

maintain all maintenance records for the DJI Phantom 2 UAS. 

D. The Reasons Why Granting Christy Lee Wooten’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 Christy Lee 

Wooten too safely, efficiently, and economically perform aerial video and photography for 
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special events, construction sites, real estate, and landscape over certain areas of the United 

States. 

Additionally, use of the DJI Phantom 2 UAS will decrease congestion of the NAS, reduce 

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

Wooten’s proposed operation of the DJI Phantom 2 UAS will be realized without implicating 

any privacy issues. 

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

The DJI Phantom 2 UAS is battery powered and serves as a safe, efficient, and 

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

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

allowing the use of a DJI Phantom 2 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 2 UAS does not require an airport to takeoff or land. Likewise, a reduction of manned 

aircraft conducting aerial video and photography missions would result in fewer aircraft that 

must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing 

phases of flight operations. 

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

UAS. 

Conducting aerial acquisitions with the DJI Phantom 2 UAS, 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 2 UAS produces 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 2 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 2 UAS to perform aerial acquisitions, the substantial risk to 

life and property in the air and on the ground, which is usually associated with traditional access 

methods, will be substantially reduced or completely eliminated. Aside from the lack of flight 

crew members located onboard the aircraft, the DJI Phantom 2 UAS (weighing approximately 2 

pounds 4 ounces, at its maximum gross weight with a length of 12 inches width of 12 inches, 

height of 8 inches, and with no fuel on board), has less physical potential for collateral damage to 

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

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

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 
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3. Performing Aerial Video and Photography Operations With The DJI Phantom 2

UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 UAS is also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of 

the DJI Phantom 2 UAS will allow United States based companies, like Christy Lee Wooten’s, 

to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising 

cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions 

phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and 

alternative technology in order to remain competitive. Operating the battery powered DJI 

Phantom 2 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 2 UAS, companies such as Christy Lee Wooten’s, 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 2 UAS, provides a

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

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

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

decades, Christy Lee Wooten’s proposed operation of the DJI Phantom 2 UAS will not implicate 

any privacy issues. Specifically, the DJI Phantom 2 UAS will be operated only in compliance 

with operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 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 Christy Lee Wooten Seeks Exemption. 

1. Reasons Why The DJI Phantom 2 UAS Meets The Conditions Of The FAA 

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

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

unmanned aircraft and its operation, Christy Lee Wooten’s operation of the DJI Phantom 2 UAS 

meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in 

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

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

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

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

333 states the following, in part: 
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(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, Christy Lee Wooten submits that the DJI Phantom 2 UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Phantom 2 UAS; (b) the pilot certification requirement; and (c) the 

specific operating limitations. 

a. The Specifications Of The DJI Phantom 2 UAS Demonstrate Its Safe 

Characteristics. 

The DJI Phantom 2 UAS does not create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability. 

i. Technical Specifications Of The DJI Phantom 2 UAS. 

The technical specification of the DJI Phantom 2 UAS is set forth by the 

DJI Phantom 2 Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Phantom 2 UAS Autonomous Flight And Navigation Modes 

Enable The UAS To Remain Within A Defined Operational Area. 

The DJI Phantom 2 UAS may be operated in both manual and fully autonomous flight 

modes. A complete description of the flight and navigational modes of the DJI Phantom 2 UAS 

is provided at pages 24-30 of the DJI Phantom 2 User Manual, attached hereto as Exhibit B. 

iii. The DJI Phantom 2 UAS is Designed For Automatic Return To Home 
15

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

When the Control Link is lost, the DJI Phantom 2 UAS will remain stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 UAS does 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 2 UAS are set forth 

at pages 25 through 27 of the DJI Phantom 2 User Manual, attached hereto as Exhibit B. 

iv. The DJI Phantom 2 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 2 UAS 

GCS and flight control software is provided at pages 31 through 34 of the DJI Phantom 2 User 

Manual. DJI Phantom 2 User Manual is attached hereto as Exhibits B. 

b. Flight Operations Of DJI Phantom 2 UAS is Limited To The Line Of Sight 

Of A Pilot in Command With A Safety Observer. 

Christy Lee Wooten will only utilize pilots who have at least 20 hours flight time to act 

as a pilot in command (PIC) of the DJI Phantom 2 UASs. Additionally, a safety observer will 

assist all pilots during flight time. 

c. Flights Of DJI Phantom 2 UAS Will Be Conducted Pursuant To Specific 

Operating Limitations. 

In seeking this exemption, Christy Lee Wooten proposes to commercially operate DJI 

Phantom 2 UAS for the special purpose of conducting aerial video and photography over certain 

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

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

aircraft described in the operating documents, rotorcraft UAS weighing less than 

55 pounds maximum gross weight: DJI Phantom 2 Unmanned Aircraft Systems. 

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

to amend this grant. 

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

the purpose of aerial video and photography. 

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

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

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

unless a special request is made and approved by ATC. All altitudes reported to 

ATC must be in feet AGL. 
16

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

times. This requires the PIC to be able to use human vision unaided by any device 

other than corrective lenses. 

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

permitted. 

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

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

SO and PIC must be able to communicate verbally at all times. Electronic 

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

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the functions 

prescribed in the operating documents. 

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

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments. 

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

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. The 

operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that 

any update or revision would affect the basis upon which the FAA granted the 

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

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

questions arise regarding updates or revisions to the operating documents. 

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

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

of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station must be included in the preflight 

inspection. All maintenance and alterations must be properly documented in the 

aircraft records. 

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

operation or flight characteristics, e.g. replacement of a flight critical component, 
17

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 UAS operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

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

action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least 25 hours of flight time. 

18. The operator may not permit any PIC to operate unless the PIC meets the 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

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

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

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. 

19. 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. 
18

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

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

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

conducted in accordance with a NOTAM as required by the operator’s COA. The 

letter of agreement with the airport management must be made available to the 

Administrator upon request. 

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

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

PIC. 

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in 

accordance with the operating documents. 

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

in accordance with the operating documents. 

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

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

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

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

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

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

Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours 

prior to the operation. All operations shall be conducted in accordance with 

airspace requirements in the ATO issued COA including class of airspace, altitude 

level and potential transponder requirements. 

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

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

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

Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available 

to the PIC at the Ground Control Station of the UAS any time the UAS is 

operating. These documents must be made available to the Administrator or any 

law enforcement official upon request. 
19

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

operations and activities at all times. 

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

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

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

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of 

an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

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

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

granted permission and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential 

persons do not present an undue hazard to those persons per § 

91.119(a). 

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

permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

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

boundaries of the operational area as defined by the applicable COA must be 

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

Accidents must be reported to the National Transportation Safety Board (NTSB) 

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

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

(b) Would Not Adversely Affect Safety. 

Christy Lee Wooten 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 

2 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 2 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 
20

appropriate distances from people, vessels, vehicles and structures. 

Considering Christy Lee Wooten ’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 2 UAS, Christy Lee Wooten

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

would not correlate to the airmanship skills necessary for Christy Lee Wooten’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). 

Christy Lee Wooten will not allow any PIC to operate the DJI Phantom 2 UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 2

UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 2

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). 

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 Christy Lee Wooten’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 
21

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

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

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

accomplish the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15.

Accordingly, Christy Lee Wooten will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 2 UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 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, Christy Lee Wooten will ensure that the DJI Phantom 2 UAS is in an 

airworthy condition based upon the UAS’s compliance with its operating documents and as 

stated in the conditions and limitations herein. Additionally, the FAA has previously granted 

relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

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

Not Adversely Affect Safety. 

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

the altitude information of the DJI Phantom 2 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 Christy Lee Wooten’s operation of the DJI Phantom 2 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 UAS 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 
22

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2

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

flight operations. Accordingly, Christy Lee Wooten will ensure that it will safely operate the 

battery powered DJI Phantom 2 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 2

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

operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, safety will be ensured as the DJI Phantom 2 UAS provide audible and visual 

warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the DJI Phantom 2 UAS will 

descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at 

less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in 

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

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety. 

In seeking this exemption, Christy Lee Wooten 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 Christy 

Lee Wooten will use trained technicians to perform maintenance, alterations, or preventive 

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

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Instruction Manual). 

Furthermore, Christy Lee Wooten will document and maintain all maintenance records for the 

DJI Phantom 2 UAS. 

Since the DJI Phantom 2 UAS will be inspected as prescribed by the operating 

documents, Christy Lee Wooten will maintain the equivalent level of safety established by 

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

attached hereto as Exhibit B; a copy of the DJI Phantom 2 UAS Maintenance LOG is attached

hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Christy Lee 

Wooten will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 
23

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 2 UAS will be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered.

In consideration of Christy Lee Wooten’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 UAS, Christy Lee Wooten 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, Christy Lee Wooten requests that 

the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 UAS, 

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

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) 

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

& (b). Such special conditions will permit safe operation of the UAs for the limited purpose of 

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

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

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

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

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

of the UAS in the NAS. 

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

21.16, for operation of the DJI Phantom 2 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 
24

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 2 UAS, 

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

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

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

91.417(a) & (b). 

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

Which Christy Lee Wooten Seeks Exemption: 

Christy Lee Wooten 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 Christy Lee Wooten

Seeks: 

This exemption will permit Christy Lee Wooten to commercially operate an 

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

photography over certain areas of the United States. 

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

Wooten’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, Christy Lee Wooten’s request for exemption may be 

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

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

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

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

As discussed in detail above, Christy Lee Wooten will operate the DJI Phantom 2 UAS 

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

pose a threat to national security. 

CONCLUSION

As set forth herein, Christy Lee Wooten seeks an exemption pursuant to 14 C.F.R. § 

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

permit safe operation of the DJI Phantom 2 UAS commercially, without an airworthiness 

certificate, for the limited purpose of conducting aerial video and photography over certain areas 

of the United States. By granting this Petition, the FAA Administrator will be fulfilling the 
25

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

advancing the interests of the public, by allowing Christy Lee Wooten to safely, efficiently, and 

economically operate the DJI Phantom 2 UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Christy Lee Wooten respectfully requests 

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

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

(a)(2), and 91.417(a) & (b), and permit Christy Lee Wooten to operate the DJI Phantom 2 UAS 

commercially for the purpose of conducting aerial video and photography over certain areas of 

the United States.

Dated: August 25, 2015

Respectfully submitted, 

Christy Lee Wooten 

_________________________ 

Christy Lee Wooten 

7568 CR 465D

Henderson, Texas 75654

Email: clwoot@yahoo.com

936-615-2515

Appendices: 

A – DJI Phantom 2 Specifications Data Sheet 

B – DJI Phantom 2 Manufacturer’s User Manual

C – Monthly Maintenance Log 
26

APPENDIX – A 

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

Christy Lee Wooten only utilizes safe and reliable UAS. DJI is an industry leader in small UAS 

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

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

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

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

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

Specifications of Aircraft :

Operating environment temperature -10to 50

Power consumption 5.6W 

Supported Battery DJI Intelligent battery 

Weight (including the battery) 1000g 

Take-off Weight ≤1300g 

Hovering Accuracy (Ready to Fly) Vertical: 0.8m; Horizontal: 2.5m 

Max Yaw Angular Velocity 200°/s 

Max Tilt Angle 35° 

Max Ascent / Descent Speed Ascent: 6m/s; Descent: 2m/s 

Max Flight Speed 15m/s (Not Recommended) 

Wheelbase 350mm 

2.4GHz Remote Controller

Operating Frequency 2.4GHz ISM 

Communication Distance (open area) 1000m 

Receiver Sensitivity (1%PER) -97dBm 

Working Current/Voltage 120 mA@3.7V 

Built-in LiPo Battery Working 

 Current/Capacity 3.7V, 2000mAh 

DJI Intelligent Battery

Type 3S LiPo Battery 

Capacity 5200mAh, 11.1V 

Charging Environment Range 0to 40

Discharging Environment Range -20to 5027

APPENDIX – B 

DJI Phantom 2 UAS User’s Manual can be found at :

http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

or by clicking here:

DJI Phantom 2 Manufacturer’s User Manual
28

APPENDIX – C

MONTHLY MAINTENANCE LOG

month:_________ year:________ 

UAS:_______ Date Issue 

Discovered 

Date Issue 

Addressed 

Issue Description & 

Maintenance Conducted 

Maintenance Performed 

By: Print & Sign 

Software Updates 

Airframe

Engines 

Propellers 

Camera/Gimbal 

Landing Gear 

Vibration/Dampening 

Other: