UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _____ _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Odyn Film and Video, INC. 

Federal Employer ID #: 54-1225246 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

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

OPERATION OF a) DJI PHANTOM 2 UNMANNED AIRCRAFT 

SYSTEMS PURSUANT TO SECTION 333 OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on Oct 01, 20 15 

Odyn Film and Video, INC 

Hans-Peter Schloemer 

President 

Falls Church, VA 22044 

703-941-6396 

peter.schloemer@gmail.com 
TABLE OF CONTENTS 

Page 

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH, ODYN FILM AND VIDEO, 

INC. 

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

THE EXTENT OF RELIEF ODYN FILM AND VIDEO, INC .. SEEKS AND THE 

REASON ODYN FILM AND VIDEO, INC. SEEKS THE RELIEF ..................... .10 

THE REASONS WHY GRANTING ODYN FILM AND VIDEO, INC.'S REQUEST 

WOULD BE IN THE PUBLIC INTEREST ................................................... .13 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY ........................................................................................................... 15 

CONCLUSION ...................................................................................................................... 28 

2 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PIC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

3 
SUMMARY 

Odyn Film and Video, Inc. 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 ofthe FAA Modernization and Reform Act of2012 (FMRA). This exemption will 

permit Odyn Film and Video, Inc. to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography for network television, 

real estate photography, special events, film sets and landscape over certain areas of the 

United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is Hans-Peter Schloemer, Owner/President of Odyn Film and Video, 

Inc. I am professionally trained photographer and Cameraman who has been working 

mostly for national and international network television stations for over 32 years. I 

provide my clients with expertise and knowledge in all aspects of video productions, as 

well as provide them with advanced technologies & solutions that will increase 

efficiency, productivity and effectiveness. Hans-Peter Schloemer over 3 years of 

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

objective ofOdyn Film and Video, Inc.'s aerial video and photography operations is to 

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

specifically targeting: 

• Television Network News Footage 

• Motion Picture Filming 

• Real Estate Videography and Photography 

• Construction sites before & after 

• Increase public knowledge ofUAS and promote safe UAS operations. 

4 
BACKGROUND 

Unmanned Aircraft System: DJI Phantom 2 UAS 

Odyn Film and Video, Inc. seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Phantom 2 is a vertical takeoff and 

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS). The 

DJI Phantom 2 has a maximum gross weight of approximately 2 pounds 11 ounces, 

while having a length of 16 inches width of 16 inches, height of 8 inches, and a 

maximum speed of approximately 29 knots. The DJI Phantom 2 is UAs equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 2 UAS that will be operated by Odyn Film and Video, Inc. is 

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, Odyn Film and Video, Inc., 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 UASs in 

the National Airspace System (NAS), and for an exemption from the requirements of 14 

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

91.407(a)(l), 91.409(a)(l) & (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, Odyn Film and Video, Inc. operation ofDJI 

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, Odyn Film and Video, Inc. requests relief from Sections 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Odyn Film and Video, Inc. submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Odyn Film and Video, Inc. 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 Instruction 

Manual). Furthermore, Odyn Film and Video, Inc. will document and maintain all 

maintenance records for the DJI Phantom 2 UAS. 

5 
Relieffrom certain requirements of Section 61.113(a) and (b), entitled Private 

pilot privileges and limitations: Pilot in command, is requested by Odyn Film and Video, 

Inc. to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or 

higher level certificate, as well as an airman medical certificate, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC 

is able to safely operate the DJI Phantom 2 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Odyn Film and Video, Inc. seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom 2 UAS do not require an airworthiness 

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

Video, Inc. submits that they will ensure that the DJI Phantom 2 UAS are in an airworthy 

condition, prior to every flight, by determining that the UAS is in compliance with the 

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

Manual), and that the aircraft are in a condition for safe flight. 

Odyn Film and Video, Inc. also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 UA 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 UAS to the GCS for 

active monitoring of the flight path. This altitude information, combined with Odyn Film 

and Video, Inc.'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, Odyn Film and Video, Inc. seeks an exemption from the 

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

conditions. Odyn Film and Video, Inc. submits that safety will not be affected by 

operation of the DJI Phantom 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 10.0 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, Odyn Film and Video, Inc. 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: 

Hans-Peter Schloemer c/o Odyn Film and Video, Inc .. 

3400 Rustic Way Lane 

Falls Church, VA 22044 

Tel: (703) 941-6396 

Email: Peter. Schloemer@gmail.com 

6 
B. The Specific Sections Of 14 C.F.R. From Which Odyn Film and Video, 

Inc. Seeks Exemption. 

1. Odyn Film and Video, Inc. Seeks Exemption From The Requirements Of 

Section Part 21, Subpart H 

14 C.F .R. Part 21, Subpart H, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(l) 

2. Odyn Film and Video, Inc. Seeks Exemption From The Requirements Of 

Section 61.113(a) And (b). 

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

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

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

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

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

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

connection with any business or employment if-

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

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

hire. 

3. Odyn Film and Video, Inc. Seeks Exemption From The Requirements Of 

Section 91.7(a). 

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

following: 

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

4. Odyn Film and Video, Inc. 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)Ifthere is no station within the area prescribed in paragraph (a)(l)(i) of 

this section, the current reported altimeter setting of an appropriate 

available station; or 

7 
(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. 

5. Odyn Film and Video, Inc. Seeks Exemption From The Requirements Of 

Section 91.15l(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. 

6. Odyn Film and Video, Inc. Seeks Exemption From The Requirement Of 

Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the 

following: Each owner or operator of an aircraft-

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections, except as provided in paragraph (c) of this 

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

7. Odyn Film and Video, Inc. Seeks Exemption From The Requirements Of 

Section 91.407(a)(l) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(l), 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[.] 

8. Odyn Film and Video, Inc. Seeks Exemption From The Requirements Of 

Sections 91.409(a)(l) And 91.409(a)(2). 

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

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

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

(l)An annual inspection in accordance with part 43 ofthis 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 ofthis chapter. 

8 
9. Odyn Film and Video, Inc. 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) ofthis section: 

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

records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include--

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

the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

and each rotor. 

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

propeller, rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 

(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) ofthis 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) ofthis 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. 

9 
C. The Extent Of Relief Odyn Film and Video, Inc. Seeks And The Reason Odyn 

Film and Video, Inc. Seeks The Relief. 

1. Odyn Film and Video, Inc. Seeks Exemption From The Requirements Of 

Section Part 21, Subpart H 

Given the size and limited operating area associated with the UAS to be utilized by Odyn 

Film and Video, Inc., 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 rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions ofthe proposed UAS 

operations. 

2. Extent Of Relief Odyn Film and Video, Inc. Seeks And The Reason 

Odyn Film and Video, Inc. Seeks Relief From Section 61.113(a) And 

(b). 

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

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

pilot or higher level certificate, as well as a current and valid airman medical certificate, 

and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state 

that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for compensation 

or hire. 

As set forth more fully below, Odyn Film and Video, Inc. 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 either 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. 

10 
Further, Odyn Film and Video, Inc. 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 Odyn 

Film and Video, Inc. business; and (2) will not carry passengers or property for 

compensation or hire. 

3. Extent Of Relief Odyn Film and Video, Inc. Seeks And The Reason 

Odyn Film and Video, Inc. 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 Odyn Film and Video, Inc. to determine that the DJI Phantom 2 UAS 

are in airworthy condition prior to every flight by ensuring that the UAS is in compliance 

with the operating documents (i.e., the Odyn Film and Video, Inc. Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Instruction Manual). 

Odyn Film and Video, Inc. seeks the requested relief because the DJI Phantom 2 UAS 

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

H. Therefore, Odyn Film and Video, Inc. will ensure that the DJI Phantom 2 UAS are 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 are in condition for safe flight, as stated in the 

conditions and limitations below. 

4. Extent Of Relief Odyn Film and Video, Inc .. Seeks And The Reason 

Odyn Film and Video, Inc. 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), Odyn Film and Video, Inc. 

seeks the requested relief because the DJI Phantom 2 UAS's altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or field altitude, 

before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations 

stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained sbce the DJI Phantom 2 UAS are equipped with 

a barometric pressure sensor and GPS equipment, which automatically ensures that a 

ground level pressure setting will be established prior to each flight, and provides the PIC 

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

11 
5. Extent Of Relief Odyn Film and Video, Inc. Seeks And The Reason 

Odyn Film and Video, Inc. Seeks Relief From Section 91.15l(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 10.0 minutes to the first point of intended 

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

Odyn Film and Video, Inc. seeks the requested relief because without an exemption from 

Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 2 U AS 

will severely constrain the practicality of any aerial video or still photo flight operations 

that Odyn Film and Video, Inc. 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 Odyn Film and Video, Inc.'s proposed 

operating limitations, ensure that Odyn Film and Video, Inc. 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 10.0 minutes to the first point of intended landing and, assuming normal 

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

6. Extent Of Relief Odyn Film and Video, Inc. Seeks And The Reason 

Odyn Film and Video, Inc. Seeks Relief From Sections 91.405(a), 

91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, Odyn Film and Video, Inc. requests 

relief from these Sections because the DJI Phantom 2 UAS do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 2 UAS meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Odyn 

Film and Video, Inc. 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., the Odyn Film and Video, Inc. Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Instruction Manual). 

Furthermore, Odyn Film and Video, Inc. will document and maintain all maintenance 

records for the DJI Phantom 2. 

12 
D. The Reasons Why Granting Odyn Film and Video, Inc. 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 Odyn Film and 

Video, Inc. to safely, efficiently, and economically perform aerial video and 

photography of, Network News aerials, real estate, film sets 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 ofOdyn 

Film and Video, Inc.'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 are battery powered and serve as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial 

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

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 do not require an airport to takeoff or land. 

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

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

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

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 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 produce no air pollution, and 

is the most viable environmentally conscious alternative to the cabin class, six cylinder 

internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour ofleaded 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. 

13 
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 

manned aircraft flight operations, will be substantially reduced or completely eliminated. 

Aside from the lack of flight crew members located on board the aircraft, the DJI Phantom 

2 UAS (weighing approximately 2 pounds 11 ounces, at their maximum gross weights 

with lengths of 16 inches, widths of 16 inches, and with no fuel on board), has less 

physical potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 

UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 UAS are 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 

Odyn Film and Video, Inc. 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 UAS is one such 

technology that not only allows companies greater operational flexibility compared to 

manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the DJI Phantom 2 UAS, companies such as Odyn Film and Video, Inc., 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 ofU.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, Odyn Film and Video, Inc.'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., the Odyn Film and Video, Inc. Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Instruction Manual) 

which requires 

14 
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 Odyn Film and Video, Inc. Seeks Exemption. 

5. Reasons Why The DJI Phantom 2 UAS Meet The Conditions Of The FAA 

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

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

unmanned aircraft and its operation, Odyn Film and Video, Inc.'s operation of the DJI 

Phantom 2 UAS meet the conditions of FMRA Section 333, and will not require an 

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

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

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

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

FMRA Section 333 states the following, in part: 

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

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

Transportation shall determine if certain unmanned aircraft systems may 

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

and 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.--Ifthe 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, Odyn Film and Video, Inc .. 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; 

15 
and (c) the specific operating limitations. 

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

Characteristics. 

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

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

operational capability. 

i. Technical Specifications Of The DJI Phantom 2 UAS. The technical specifications 

of the DJI Phantom 2 UAS are set forth by the DJI Phantom 2 Specifications and Data 

Sheet, attached hereto as Exhibit A and B. 

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 

VAS are provided of the DJI Phantom 2 User Manuals, attached hereto as Exhibit C and 

D. . 

iii. The DJI Phantom 2 UAS Are Designed For Automatic Return To Home Point 

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

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

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 UAS do not reacquire 

control link data from the GCS, the UAS will assume that the Control Link is lost and the 

UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to 

the takeoff position and shutdown. A complete description of the Failsafe Functions for 

the DJI Phantom 2 UAS are set forth in the User Manual, attached hereto as Exhibit C 

and D. 

iv. The DJI Phantom 2 GCS And Its Operation. 

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

flight control software is provided in the DJI Phantom User Manual. DJI Phantom 2 User 

Manuals are attached hereto as Exhibits C and D. 

b. Flight Operations OfDJI Phantom 2 UAS Are Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer. 

Odyn Film and Video, Inc. will only utilize certificated pilots who possess a current and 

valid 

16 
airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 UAS. 

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, Odyn Film and Video, Inc. 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 UASs 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 A TC. All altitudes reported to A TC must be in 

feetAGL. 

5. The UAs must be operated within visual line of sight (VLOS) ofthe PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC's FAA-issued airman medical certificate. 

6. 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 

17 
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, must 

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

make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents. 

13. The operator must follow the UAS manufacturer's aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, inspection, 

alterations, and status of replacement/overhaul component parts must be noted in the 

aircraft records, including total time in service, description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

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

Bulletins. 

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 a private pilot certificate and at least a current thirdclass medical certificate. 

18 
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.P.R.§ 61.51(b). Flights for the purposes oftraining 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.P.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. 

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 NOT AM 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 ofunpredicted 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 

(NOT AM) 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.P.R. part 47, and have identification (NNumber) markings in accordance with 14 C.P.R. part 45, Subpart C. Markings must be as 

large as practicable. 

20 
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. 

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. 

Odyn Film and Video, Inc. 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 

21 
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 appropriate distances from people, 

vessels, vehicles and structures. 

Considering Odyn Film and Video, Inc.'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. 

11 062); and the airmanship skills necessary to safely operate the DJI Phantom 2 UAS, 

Odyn Film and Video, Inc. submits that the additional manned airmanship experience of 

a commercially certificated pilot would not correlate to the airmanship skills necessary 

for Odyn Film and Video, Inc.'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). 

Odyn Film and Video, Inc. 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 oftotal time as a UAS rotorcraft pilot (with a 

minimum of5 hours ofthose 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 Odyn Film and Video, Inc. 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 ofUAS to be used for operations under the exemption. For clarification, the 

22 
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 total25 hours ofUAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

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

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

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

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

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

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

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

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

with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Odyn Film and Video, Inc. will ensure safe operations by not 

allowing any PIC 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 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 Odyn Film and Video, Inc. 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 relieffrom 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 1 UAS will be provided to the PIC 

via GPS equipment and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path and altitude. This 

altitude information, combined with Odyn Film and Video, Inc.' operation of the DJI 

Phantom 2 Odyn Film and Video, Inc. 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. 

23 
Prior to each flight, a zero altitude initiation point is automatically established by the 

UASs at ground level. 

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

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

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

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

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

Would Not Adversely Affect Safety. 

A grant ofthis exemption would ensure an equivalent level of safety established 

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

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

location of the proposed flight operations. Accordingly Odyn Film and Video, Inc. 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 10.0 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 ofthe 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)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect 

Safety. 

In seeking this exemption, Odyn Film and Video, Inc. submits that the equivalent 

level of safety with regard to the regulatory maintenance and alteration requirements 

established 

24 
by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be 

met because Odyn Film and Video, Inc. 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., the Odyn Film and 

Video, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Instruction Manual). Furthermore, Odyn Film and Video, Inc. will document and 

maintain all maintenance records for the DJI Phantom 2 UAS. 

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

documents, Odyn Film and Video, Inc. will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy ofthe DJI 

Phantom 2 User Manuals are attached hereto as Exhibit C and D; a copy of the DJI 

Phantom 2 UAS Maintenance LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Odyn 

Film and Video, Inc. will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe 

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 Odyn Film and Video, Inc.'s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2 UAS's, Odyn Film 

and Video, Inc. 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 ofthe FAA Modernization and Reform Act of 

2012 (FMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, Odyn Film and Video, 

Inc. 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 

25 
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)(l), 91.409(a)(l) & (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 ofthe 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 

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 ofthe 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). 

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

The Rules From Which Odyn Film and Video, Inc. Seeks 

Exemption: 

Odyn Film and Video, Inc. 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 Odyn Film and 

Video, Inc. Seeks: 

This exemption will permit Odyn Film and Video, Inc. to commercially operate an 

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

photography over certain areas of the United States. 

26 
Any Additional Information, Views, Or Arguments Available To Support Odyn Film and 

Video, Inc.'s Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) 

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

operate safely in the NAS. As such, Odyn Film and Video, Inc.'s request for exemption may be 

granted pursuant to the authority ofFMRA 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, Odyn Film and Video, Inc. 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. 

27 
CONCLUSION 

As set forth herein, Odyn Film and Video, Inc., 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 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 Congressional mandate of the F AAModernization 

and Reform Act of2012, while also advancing the interests of the public, by allowing Odyn Film and Video, Inc. to safely, 

efficiently and economically operate the DJI Phantom 2 UAS commercially with the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of2012, 

Section 333, Odyn Film and Video, Inc. respectfully requests that the Administrator grant this Petition for an exemption from 

The requirements of 14 C.F.R. Sections 6l.ll3(a) & (b), 91.7(a), 91.121, 9l.!Sl(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2) 

And 91.417(a) & (b), and permit Odyn Film and Video, Inc. to operate the DJI Phantom 2 commercially for the purpose of conducting 

aerial video and photography over certain areas of the United States. 

Appendices: 

A - DJI Phantom 2 Specification Data Sheet 

B - DJI Phantom 2 Manufacturer's User Manual 

C - Monthly Maintenance Log 

D- FAA Identification Number Assignment and Registration 

Date: October 1, 2015 

Respectfully submitted, 

ODYN FILM AND VIDEO, INC. 

Hans-Peter Schloemer, President 

ODYN FILM AND VIDEO, INC. 

3400 Rustic Way Lane 

Falls Church, VA 22044 

Tel.: 703-941-0DYN (6396) 

28 
APPENDIX-A 

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS 

Odyn Film and Video, Inc. only utilizes safe and reliable UASs. DJI is an industry 

leader in small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to limit flight to no higher than a predetermined and set 

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

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

monitor. 

1.1 DJI Phantom 2 

1.1.1 Aircraft 

1.1.1.1 Supported Battery- DJI 5200mAH LiPo Battery 

1.1.1.2 Weight (Battery & Propellers Included)- 2lbs 11.810oz (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- 35 D 

1.1.1.6 Max Ascent Speed- 6m/s 

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- ±0.03 D 

1.1.2.3 Controllable Range- Pitch: -90 D - 0 D 

1.1.2.4 Maximum Angular Speed- Pitch: 90 Dis 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range- 32DF- 104DF (ODC- 40DC) 

1.1.3.2 Sensor Size- 1/2.3" 

1.1.3.3 Effective Pixels- 14M 

1.1.3.4 Resolution- 4384x3288 

1.1.3.5 HD Video Recording- 1 080p30 & 720p 

1.1.3.6 Recording Field of View- 11 OD/85 D 

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: 1OOm W 

1.1.4.5 Working Voltage- 120mA@3.7V 

29 
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 

30 
APPENDIX-B 

DJI PHANTOM 2 Manufacturer's User Manual 

User manual can be found at: 

http://www.dji.com/product/phantom-2/download 

31 
APPENDIX- C 

MONTHL Y(MAINTENANCE(LOG 

month: 1 

---"year:" --- ... ·• .. Date'lssue' Date'lssue' Maintenance'Performed'by:'' .UASl#:l. ·.. ..... < .. lssue"Description'&'Maintenance'Conducted 

··· .• << •··. ............ Discovered Addressed Print'&'Sign 

Software'Updates 

Airframe 

Engines 

Propellers 

Camera'Gimbal 

Landing'Gear 

Vibration'Dampening 

Other: 

32 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

HANS PETER SCHLOEMER 

3400 RUSTIC WAY LN 

FALLS CHURCH VA 22044 

1 •• 1.1 •• 1.111 •••• 1 •• 1.1 •• 11 .. 1.1 

Flight Standards Service 

Aircraft Registration Branch, 

AFS-750 

P.O. Box 25504 

Oklahoma City, Oklahoma 73125-0504 

(405) 954-3116 

Toll Free 1-866-762-9434 

WEB Address: http://registry.faa.gov 

July 15, 2015 

Identification Number Assignment and Registration of Amateur-Built or 

Non-Type Certificated Aircraft Dn INC PHANTOM 2 SIN PH645208215 

U.S. identification number NT0052311 has been ASSIGNED. 

A U.S. identification number of our choice may be assigned to your aircraft when you submit a complete description of 

the aircraft. The attached form may be used as it meets our requirements for both description and registration purposes. 

Authority to use a number assigned free of charge expires 90 days after the date it is issued unless the aircraft is 

registered within that period. 

A U.S. identification number of vour choice may be reserved, if available, for one year by sending a written request and 

a $10 fee for each number to be reserved. Please list 5 numbers, in order of preference, in case your first choice is not 

available. If the number is not assigned to an aircraft prior to the end of the year, the reservation will expire but may be 

renewed from year to year upon request and payment of a $10 renewal fee. 

NOTICE: This number may not be assigned or painted on an aircraft until approval is received from this office. 

Your written request to assign the reserved number to a particular aircraft must include a complete description of the 

aircraft. The form attached to this letter may be used. 

The items checked below are required to complete registration of your aircraft: 

D Completed Aircraft Registration Application, signed in INK, including typed or printed name of signer in 

signature block. Form enclosed. 

D Registration fee of $5. 

D Affidavit of ownership, signed before a notary public, atJ.d showing a description of the aircraft. The form 

attached to tllis letter meets our requirements and may be used if you wish. 

D Submit bill of sale from manufacturer of the kit. 

*Show the manufactuer and model of the engines on the affidavit. 

IVONNE DRAKE 

Legal Instruments Examiner 

Aircraft Registration Bnmch 

Enclosure AFF 

AC Form 8050-88 (5/11) 
U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Flight Standards Service 

Aircraft Registration Branch, 

AFS-750 

P.O. Box 25504 

Oklahoma City, Oklahoma 73125-0504 

(405) 954-3116 

Toll Free 1-866-762-9434 

WEB Address: http://registry.faa.gov 

June 15,2015 

Identification Number Assignment and Registration of Amateur-Built or 

Non-Type Certificated Aircraft: ____ SIN _flf_C Y 5"2.CJ lt 2. I;-

({oo5"Z..>I{) U.S. identification number "N __ has been~ ASSIGNED 0 RESERVED. 

A U.S. identification number of our choice may be assigned to your aircraft when you submit a complete description of 

the aircraft. The attached form may be used as it meets our requirements for both description and registration purposes. 

Authority to use an assigned registration number expires 90 days after the date it is issued unless the aircraft is 

registered within that period. 

A U.S. identification number of your choice may be reserved, if available, for one year by sending a written request and 

a $1 0 fee for each number to be reserved. Please list 5 numbers, in order of preference, in case your first choice is not 

available. If the number is not assigned to an aircraft prior to the end of the year, the reservation will expire but may be 

renewed from year to year upon request and payment of a $1 0 renewal fee. 

NOTICE: This number may not be assigned or painted on an aircraft until approval is received from this office. 

Your written request to assign the reserved number to a particular aircraft must include a complete description of the 

aircraft. The form attached to this letter may be used. 

The items checked below are required to complete registration of your aircraft: 

Completed Aircraft Registration Application, signed in INK, including typed or printed name of signer in 

signature block. Form enclosed. 

Registration fee of$5. 

Affidavit of ownership, signed before a notary public, and showing a description of the aircraft. The form 

attached to this letter meets our requirements and may be used jfyou wjsh. ------·-~-··· 

lJ Submit bill of sale from manufacturer of the kit. 

Enclosure 
OMB Control No. 2120-0042 

Exp. 11/30/2014 

Paperwork Reduction Act ~tatement: The information collected on this form is necessary to ensure applicant eligibility. The 

mformat1on 1s used to determme that the applicant meets the necessary qualifications as owner of an amateur built aircraft. We 

estimate that it will take approximately 30 minutes to complete the form. The information collection is required to obtain a benefit. The 

mforma!ion collect~d becomes part of the aircraft registration system. Please note that an agency may not conduct or sponsor, and a 

person IS not reqwred to respond to, a collection of information unless it displays a currently valid OMB control number. OMB 2120-

0042. Comments covering the accuracy of this burden and suggestions for reducing the burden should be directed to the FAA at 800 

Independence Avenue SW, Washington, DC 20591. ATIN: Information Collection Clearance Officer, AES-200. 

U. S. Identification 

AFFIDAVIT OF OWNERSHIP FOR AMATEUR-BUILT AND OTHER 

NON-TYPE CERTIFICATED AIRCRAFT 

(does not include light-sport) 

Name of Amateur I Non TC'd builder OJ f ;J!VC 

Model 

Class (airplane, rotorcraft, glider, weight shift 

control, powered-parachute, etc.) 

Serial Number f If bY 5 ZO 5 2J ~ 

Type of Engine Installed (reciprocating, turboprop, 2 or 4 cycle, electric, etc.) -....:C::./:...'(_G..:..(v..:...:.., <-..::"=--------

Manufacturer, Model and Serial Number of each Engine Installed I"Y) o $( v, 'a..(_ ?'\ u J::n b~v> 

--------------------- Number of Engines Installed 

Built for Land or Sea Operation ------------- Number of Seats --"J?('=-· ---------

MUST CHECK ONE 

0 More than 50% of the above-described aircraft was built from miscellaneous parts and I am the owner. (This option is for aircraft 

eligible for amateur-built certification.) 

0 More than 50% of the above-described aircraft was built from a kit (prefabricated parts) and I am the owner. The bill of sale from 

the kit manufacturer is attached. (This option is for aircraft eligible for amateur-built certification.) 

0 I certify that the above-described aircraft is a newly built non-type certificated aircraft and is not currently registered in another 

country. (This option is for aircraft eligible for experimental certification other than amateur-built.) 

I certify that the above-described aircraft is a previously built (used) non-type certificated aircraft and is not currently registered in 

another country. (This option is for aircraft eligible for experimental certification other than amateur-built certification.) 

JEr Evidence of ownership from the aircraft builder through any intervening owners is attached (chain of ownership). 

O Unable to obtain complete chain of ownership. Statement as to ownership history and whereabouts of aircraft is attached. 

Address: 

Title of Signer 

(If Appropriate): 

City: "fq {( S ( h (,{ v c0 S te: Clt'n::1 (1-J ... "- Zip: 

Telephone: _w~~3~-~C~Y...sl"--.....:O:::.....ct..L.l:__J_r ____ ~ ____________ _ 

Notary Public: 

State of: 

~0)5 

AC Form 8050-88 (03/12)