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UNITED STATES OF AMERICA

DEPARTEMNT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Original Submitted January 5th, 2016 

REVISION January 16th, 2016 Replaces the January 5th, 2016 Submittal

Comment Tracking Number: 1K0-8n7s-hzic

Regulatory Docket No. _____________________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

OHIO SPECIAL RESPONSE TEAM

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 14 CFR PART 21, 45.23(b),61.113 (a)&(b), 91.7 (a), 91.9 (b)(2)

91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a)&(b), 91.405 (a), 401 (a)(1), 409 (a)(2),

And 417 (a)&(b) CONCERNING COMMERCIAL OPERATION OF THE

DJI PHANTOM 2 VISION+, DJI PHANTOM 3, DJI INSPIRE 1, AND DJI MATRICE 100

UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on January 5th, 2016

Revised January 16th, 2016

Ohio Special Response Team, Inc

Elvin W. Burnell, President

597 Park Ave East

Mansfield, OH 44905

Ph: 419-528-0041 (O) / Elvin Burnell 419-512-3709 (C)
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January 5th, 2016

U. S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations 

from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) & (b);91.7 (a);91.9 (b) (2);91.103(b);91.109;91.119; 

91.121; 91.151(a);91.203(a) & (b);91.405(a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b).

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. 

Part 11, Ohio Special Response Team (See Footnote 1), operator of Small Unmanned Aircraft Systems 

(sUAS) equipped to offer on-demand commercial UAS operations for a host of industries and applications. 

These include:

• Public Safety Support Operations

• Search and Rescue – lost or missing individuals

Ohio Special Response Team hereby applies for an exemption from the listed Federal Aviation Regulations 

(“FARs”) to allow commercial operation of its sUASs, so long as such operations are conducted within and 

under the conditions outlined herein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned 

and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined 

3) controlled as to access and 4) would provide safety enhancements to the already safe operations using 

conventional aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of

Transportation’s (the FAA Administrator’s) responsibilities to “...establish requirements for the safe 

operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act.

Footnote 1. The Ohio Special Response Team is a non-profit organization with the dedicated mission of 

saving lives. The Federal Internal Revenue Employer Identification Number (EIN) 74-3106323. All members 

are volunteers. The organization doesn’t charge for its services.

The name and address of the petitioner is:

Ohio Special Response Team, Inc.

Attn: Elvin W. Burnell, President

597 Park Ave. East

Mansfield, OH 44905

Ph: 419-528-0041 (O) / Elvin W. Burnell 419-512-3709 (C)

Email: osrtince@yahoo.com (O) / Elvin W. Burnell e-mail: ewburnell@embarqmail.com\

Regulations from which the exemption is requested:

14 CFR Part 21

14 C.F.R. 45.23(b)

14 CFR 61.113 (a) & (b)
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14 C.F.R. 91.7 (a)

14 CFR 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F. R. 91.119

14 C.F.R. 91.121

14 CFR 91.151 (a)

14 CFR 91.203 (a) & (b)

14 CFR 91.405 (a)

14 CFR 407 (a) (1)

14 CFR 409 (a) (2)

14 CFR 417 (a) & (b)

This exemption application is expressly submitted to fulfill Congress’ goal in passing Section 333(a) through 

(c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain 

unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of 

the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary 

is required to determine which types of UASs do not create a hazard to users of the NAS or the public or 

pose a threat to national security in light of the following:

• The UAS’s size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the operator.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft 

in the national airspace system.” Id. §333(c) (emphasis added)

Applicant interprets this provision to place the duty on the Administrator to not only process applications 

for exemptions under section 333, but for the Administrator to craft conditions for the safe operation of 

the UAS, if it should be determined that the conditions set forth herein do not fulfill the statutory 

requirements for approval.

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act that 

includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection 

(a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in 

the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).

The Ohio Special Response Team sUASs are rotorcraft, weighting 55 or fewer lbs. including payload. They

operate, under normal conditions at a speed of no more than 50 knots and have the capability to hover, 

and move in the vertical and horizontal plane simultaneously. They will operate only in line of sight and will 

operate only within a sterile area. Such operations will insure that the sUAS will “not create a hazard to 

users of the national airspace system or the public.” Specific operational sUASs are the DJI Phantom 2 

Vision+, DJI Phantom 3, and DJI Inspire 1. The DJI Phantom 2 Vision+, DJI Phantom 3, DJI Inspire 1, and DJI 

Matrice 100 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station

(GCS) utilizing electronic tablet or smart phone systems. 
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 *The DJI Phantom 2 Vision+ and Phantom 3 have a maximum gross weight of approximately 2 

pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and maximum 

speed of approximately 29 knots. 

*The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 

17.7 inches, height of 11.8 inches, and a maximum speed of approximately42 knots. 

*The DJI Phantom 2 Vision+, Phantom 3, and the DJI Inspire 1 UAs are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. The DJI Phantom2 Vision+, Phantom 3, DJI 

Inspire 1, and DJI Matrice 100 has a wheel base diagonal 650mm, gross weight 243 g, max speed 42 KTSUAs 

that will be operated by Ohio Special Response Team 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.

Reform Act Section 333 (b).

Given the small size of the sUASs involved and the restricted sterile environment within which they will 

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to commence 

immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will 

operate, approval of the application presents no national security issue. Given the clear direction in Section 

333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong 

equivalent level of safety surrounding the proposed operations, and the significant public benefit, including 

enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing 

UASs, the grant of the requested exemptions is in the public interest.

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the exemption requested herein apply to civil aircraft that have the 

characteristics and that operate with the limitations listed herein. These limitations provide for at least an 

equivalent or even higher level of safety to operations under the current regulatory structure because the 

proposed operations represent a safety enhancement to the already safe operations conducted with 

conventional aircraft. These limitations and conditions to which HYSight Technologies agrees to be bound 

when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.3. Maximum total flight time for 

each operational flight will be 45 minutes. Flights will be terminated at 25% battery power reserve should 

that occur prior to the 45 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an 

elevated platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual Observer, and/or the Camera 

Operator.

6. sUAS pilot will be an FAA licensed airman with at least a private pilot’s certificate and 3rd class medical 

certificate.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who 

possess the necessary PIC qualifications, is also present (i.e. the Visual Observer), that person can also be 

designated as the PIC.

8. The UAS will only operate within a confined “Sterile Area” of the flight operations area.
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9. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s activities. It will 

be mandatory that all personnel who will be performing duties within the boundaries of the safety 

perimeter be present for this briefing.

10. The operator will obtain the consent of all persons involved and ensure that only consenting persons 

will be allowed within 100 feet of the flight operation, and this radiusmay be reduced to 30 feet based upon

an equivalent level of safety determination.

11. Pilot and observer will have been trained in operation of UAS generally and received up-to-date 

information on the particular UAS to be operated.

12. Observer and pilot will at all times are able to communicate by voice and/or text.

13. Written and/or oral permission from the relevant property holders will be obtained.

14. All required permissions and permits will be obtained from territorial, state, county or city jurisdictions, 

including local law enforcement, fire, or other appropriate governmental agencies.

15. If the sUAS loses communications or loses its GPS signal, the UAS will have capability to return to a predetermined location within the Security Perimeter and land.

16. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled 

Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness 

certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the 

aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an

equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 

U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the 

requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of 

these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted

environment and under the conditions proposed will be at least as safe, or safer, than a conventional 

aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate

without the restrictions and conditions proposed.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, 

carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as 

set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled 

and monitored by both the operator, pursuant to the Manual’s requirements, and under the requirements 

and in compliance with local public safety requirements, to provide security for the area of operation as is 

now done with conventional filming. The FAA will have advance notice of all operations. These safety 

enhancements, which already apply to civil aircraft operated in connection with motion picture and 

television production, provide a greater degree of safety to the public and property owners than 

conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart 

H. Lastly, application of these same criteria demonstrates that there is no credible threat to national 

security posed by the UAS, due to its size, speed of operation, location of operation, lack of explosive 

materials or flammable liquid fuels, and inability to carry a substantial external load. The FAA has issued the 

following exemptions to this regulations Exemptions Nos. 11251.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

The regulation requires:

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 
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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.

Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will 

have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. 

Given the size of the sUAV, two-inch lettering will be impossible. The word “Experimental” will be placed on 

the fuselage in compliance with §45.29 (f).

The equivalent level of safety will be provided by having the sUAV marked on its fuselage as required by 

§45.29 (f) where the pilot, observer and others working with the sUAV will see the identification of the UAS 

as “Experimental.” The FAA has issued the following exemptions to this regulation to Exemptions, but not 

limited to, Nos. 10700, 8738, 10167 and 10167A, 11256, 11251.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command.

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. Because the sUAS will not carry 

a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a 

commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot 

and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is 

controlled and restricted, and all flights are planned and coordinated in advance. The level of safety

provided by the requirements included in the Manual exceeds that provided by a single individual holding a 

commercial pilot’s certificate operating a conventional aircraft. The risks associated with the operation of 

the sUAS are so diminished from the level of risk associated with commercial operations contemplated by 

Part 61 when drafted, that allowing operations of the sUAS as requested with a private pilot as the PIC 

exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).

14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA 

regulatory standard will exist for determining airworthiness. Given the size of the aircraft and the 

requirements contained in the Manual for maintenance and use of safety check lists prior to each flight, as 

set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides:

No person may operate a U.S.-registered civil aircraft ... (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. The sUAS, given its size and configuration has no ability or place to carry such a

flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or 

capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping 

the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to 

it. The FAA has issued the following exemptions to this regulation, but not limited to: ExemptionNos. 8607, 

8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, 10700, 11251, and 11256.
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14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight to insure the safety of 

flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be 

needed. The PIC will take all actions including reviewing weather, flight battery requirements, landing and 

takeoff distances and aircraft performance data before initiation of flight.

14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls UASs and remotely 

piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished 

through the use of a control box that communicates with the aircraft via radio communications. The FAA 

has approved exemptions for flight training without fully functional dual controls for a number of aircraft

and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level 

of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the 

size and speed of the aircraft.

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters 

to be operated at less than the minimums prescribed, provided the person operating the helicopter 

complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS 

that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not 

more than 200 above an elevated platform from which filming is planned, an exemption may be needed to 

allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the UAS 

will never operate at higher than 400 AGL. It will however be operated in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their pre-obtained 

consent. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well 

as the location where it is operated. No flight will be taken without the required permission of the property 

owner or local officials. Because of the advance notice to the property owner and participants in the aerial 

activity, all affected individuals will be aware of the planned flight operations. Compared to flight 

operations with aircraft or rotorcraft weighting far more than the maximum 55lbs. proposed herein and the 

lack of flammable fuel, any risk associated with these operations is far less than those presently presented

with conventional aircraft operating at or below 500 AGL other industries. In addition, the low-altitude 

operations of the sUAS will ensure separation between these small-UAS operations and the operations of 

conventional aircraft that must comply with Section91.119.

14 C.F.R. §91.121 Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an 

altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting 

available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude 

read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, 

pursuant to the Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS

altitude indicator before flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, to fly after that for at least 30 

minutes; or (2) At night, to flyafter that for at least 45 minutes.”
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The battery powering the sUAS provides approximately 30-50 minutes of powered flight. To meet the 30-

minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes 

in length. Given the limitations on the UAS’s proposed flight area and the location of its proposed 

operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable. Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior 

exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance 

with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property 

owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of 

reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to alleviate given the 

size and speed of the small UAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the 

utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 45 minutes or 25% 

of battery power whichever happens first. This restriction would be more than adequate to return the sUAS 

to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been 

granted to other operations, including Exemptions 2689F, 5745, 10673, 10808, and 11251.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part:

(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. . . .

(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.

The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there 

is no ability or place to carry certification and registration documents or to display them on the sUAS.

An equivalent level of safety will be achieved by keeping these documents at the ground control point 

where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the 

sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other 

exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11251, and 

11256. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. These 

regulations require that an aircraft operator or owner “shall have that aircraft inspected as prescribed in 

subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or 

maintain the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these sections 

will not apply to the applicant. The operator pursuant to the flight manual and operating handbook will 

accomplish maintenance. An equivalent level of safety will be achieved because these small UASs are very 

limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. 

If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet 

AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating 

flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the 

operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an 

airworthy condition to provide the equivalent level of safety.

*********
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Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, 

should it be determined that publication is needed: Applicant seeks an exemption from the following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b); 

91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) 

and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less).

Approval of exemptions allowing commercial operations of sUASs, will enhance safety by reducing risk. 

Conventional operations, using jet or piston power aircraft, operate at extremely low altitudes just feet 

from the subjects being filmed and in extreme proximity to people and structures and present the risks 

associated with vehicles that weigh in the neighborhood of 4,000lbs, carrying large amounts of jet A or 

other fuel. Such aircraft must fly to and from the operational location. In contrast, a sUAS weighing fewer 

than 55lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of 

combustible fuel carried on board. The sUAS is carried to the operation site and not flown. The sUAS will 

carry no passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights.

The operation of small UASs, weighting less than 55 lbs., conducted in the strict conditions outlined above, 

will provide an equivalent level of safety supporting the grant of the exemptions requested herein, 

including exempting the applicant from the requirements of Part 21 and allowing commercial operations. 

These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as 

a result, are far safer than conventional operations conducted with turbine helicopters

operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner’s prior consent and 

knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to 

be in the area where filming will take place. The grant of this exemption request will provide improved 

safety in both day and night operations. Satisfaction of the criteria provided in Section 333 of the Reform 

Act of 2012- -size, weight, speed, operating capabilities, proximity to airports and populated areas and 

operation within visual line of sight and national security – provide more than adequate justification for the 

grant of the requested exemptions allowing commercial operation of applicant’s UAS. It is of note that 

certain public safety operations may involve advanced monitoring technology such as Infrared Red, Night 

Vision, etc. These specific operations will be governed pursuant to all applicable Local, State, and Federal 

laws regarding search and seizure including court approval of said operations via search warrant.

Conclusion

As set forth herein, Ohio Special Response Team 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 Vision+, DJI Phantom 3, DJI Inspire 1, and Matrice 100 UASs commercially, without an 

airworthiness certificate, for the limited purpose of conducting the aforementioned on-demand 

commercial sUAS operations that include:

• Public Safety Support Operations

• Search and Rescue – lost or missing individuals

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 Ohio 

Special Response Team to safely, efficiently, and economically operate sUASs commercially within the NAS.
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WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of 2012, section 333, Ohio Special Response Team respectfully requests that the Administrator grant 

this Petition for an exemption from the requirements of 14 C.F.R Sections 45.23(b); Part 21; 61.113(a) & (b), 

91.7(a); 91.9(b); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a); 91.405(a), 91.407(a)(1); 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Ohio Special Response Team to operate the DJI 

Phantom 2 Vision+, DJI Phantom 3, DJI Inspire 1, and Matrice 100 commercially in the United States. It is 

further noted that granting this exemption is not precedent setting and it is in the interest of the general 

public of the United States and public safety. 

Respectfully Submitted,

Ohio Special Response Team, Inc.

Elvin W. Burnell. President

597 Park Ave East

Mansfield, OH 44905

419-528-0041 (O) / Elvin W. Burnell 419-512-3709 

E-mail: osrtinc@yahoo.com / Elvin W. Burnell ewburnell@embarqmail.com

Appendices:

A – DJI Phantom 2 Vision+/Phantom 3 – Specifications Data Sheet

B – DJI Inspire 1 Specifications Data Sheet

C – DJI Matrices 100 - Specifications Data Sheet

D – Link to DJI Phantom 2 Vision+ Manufacturer’s User Manual

E – Link to DJI Inspire 1 Manufacturer’s User Manual

F _ Link to DJI Matrice 100 Manufacturer’s User Manual

APPENDIX – A

DJI PHANTOM 2 VISION+/PHANTOM 3 TECHNICAL SPECIFICATIONS

Ohio Special Response Team utilizes safe and reliable sUASs. DJI is an industry leader in small UAS 

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

will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices)

1.1 DJI Phantom 2 Vision+/Phantom 3

. 1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 43oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350 1.1.1.6 Max Ascent Speed – 6m/s
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1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED)

1.1.2 Gimbal

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

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording – 1080p30 & 720p 4.1.3.6 Recording Field of 

View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Ohio Special Response Team utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

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

will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model – T600

2.2.1.2 Weight (Battery Included) – 6lbs 103oz (2935g)

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

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

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s
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2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED)

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 20 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 2.2.1.15 Dimensions – 17 1⁄4” x 17 

3⁄4” x 12”

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

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

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

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable

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

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

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

2.2.3 Camera

2.2.3.1 Name – X3

2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M 2.2.3.4 Effective Pixels – 12.4M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD:1920x1080p225/

30/48/50/60; HD: 1280x720p24/25/30/48/50/60

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

2.2.4 Transmitter

2.2.4.1 Name – C1

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

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W

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

2.2.4.6 Battery – 600mAh LiPo 2S

APPENDIX – C

DJI Matrice 100 TECHNICAL SPECIFICATIONS

Ohio Special Response Team utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

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

which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher 

than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In 
13

addition, DJI software provides real-time altitude and location information to the PIC via the linked 

monitor (smart phone/tablet devices)

2.2 DJI Matrice 

2.2.1 Aircraft

2.2.1.1 Model – 100

2.2.1.2 Weight (Battery Included) – 5lbs/ 87oz (2431g)

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

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

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s

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

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 45 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 2.2.1.15 Dimensions – 17 1⁄4” x 

17 3⁄4” x 12”

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

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

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

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable

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

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

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

2.2.3 Camera

2.2.3.1 Name – X3

2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M 2.2.3.4 Effective Pixels – 12.4M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD:1920x1080p225/

30/48/50/60; HD: 1280x720p24/25/30/48/50/60

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

2.2.4 Transmitter

2.2.4.1 Name – C1

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

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C)
14

2.2.4.6 Battery – 600mAh LiPo 2S

APPENDIX - D

DJI Phantom 2 Vision+ Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User

_Manual_v1.8_en.pdf

APPENDIX – E

DJI Inspire 1 Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf

AOOENDIX – F

DJI Matrice 100 Manufacture’s User Manual

http://download.dji-innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.4__en.pdf