UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, D.C.

Regulatory Docket No.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

EAGLE VISION DRONES, LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

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

OPERATION OF DJI PHANTOM 2, DJI PHANTOM 3 AND DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on July 6, 2015

Eagle Vision Drones, LLC

11427 Jeffords Ave

Choctaw, OK 73020

Tel: (405) 290 8597
 2

TABLE OF CONTENTS

Page

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

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

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

BACKGROUND.................................................................................................................... 4

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH EAGLE VISION DRONES, 

LLC SEEKS EXEMPTION................................................................................................... 6

THE EXTENT OF RELIEF EAGLE VISION DRONES, LLC SEEKS AND THE 

REASON EAGLE VISION DRONES, LLC SEEKS THE RELIEF.................................. 10

THE REASONS WHY GRANTING EAGLE VISION DRONES, LLC REQUEST 

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY............................................................................................................... 14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.................. 25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT EAGLE VISION DRONES, LLC REQUEST.................................................. 25

CONCLUSION..................................................................................................................... 27

APPENDIX..............................................................................................28
 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
 4

SUMMARY

Eagle Vision Drones, LLC seeks exemption from the requirements of 14 C.F.R 

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

& (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to 

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

This exemption will permit Eagle Vision Drones, LLC to operate an 

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

video and photography for wedding videography, real estate photography, special 

events, film sets, and landscape over certain areas of the Unites States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Eagle Vision Drones, LLC (hereinafter referred to as “Eagle Vision Drones”) 

provides its clients with expertise and knowledge in advanced technologies and solutions 

to increase efficiency, productivity and effectiveness. Eagle Vision Drones also provides 

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

non-profit multimedia projects. Eagle Vision Drones has professional experience in 

wedding and special event videography and photography and is recognized as an expert 

this field. Eagle Vision Drones has recreational/hobby experience in all aspects of aerial 

video and photography. The objective of Eagle Vision Drones aerial video and 

photography operations is to provide high quality imaging for a variety of wedding, 

commercial, public, and residential uses, specifically targeting:

• Wedding Videography and Photography

• Motion Picture Filming

• Real Estate Videography and Photography

• Construction sites before and after

• Search and Rescue operations

• Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1 UASs

Eagle Vision Drones seeks an exemption to operate DJI systems for compensation 

or hire within the NAS. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 are vertical 

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

(GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 and DJI 

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 a 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 approximately 42 knots. The DJI Phantom 2, DJI Phantom 3, 

and DJI Inspire 1 UAs are equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors.
 5

The DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 UAs that will be operated by 

Eagle Vision Drones, LLC will be registered in accordance with 49 U.S.C. 44103, 

Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in 

accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Eagle Vision Drones, pursuant to the provisions of the Federal Aviation 

Regulations (14C.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, DJI Phantom 3, DJI 

Inspire 1 UASs in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

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

associated with the unmanned aircraft and its operation, Eagle Vision Drones 

operation of DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 UASs meets the 

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

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

Accordingly, Eagle Vision Drones requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 

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

Eagle Vision Drones submits that the requested relief is proper since an equivalent

level of safety will be ensured. Eagle Vision Drones will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

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

Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 

Instruction Manual). Furthermore, Eagle Vision Drones will document and maintain all 

maintenance records for the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs.

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

privileges and limitations: Pilot in command, is requested by Eagle Vision Drones 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, DJI Phantom 3 and DJI Inspire 1 UASs in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Eagle Vision Drones seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs do not 

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

such, Eagle Vision Drones submits that they will ensure that the DJI Phantom 2, DJI 

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

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

Maintenance Log, and DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 Instruction 

Manual), and that the aircraft are in a condition for safe flight.
 6

Eagle Vision Drones also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 2, DJI Phantom 3, and DJI 

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

information of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1UAs will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GCS for 

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

Vision Drones operation of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121.

Additionally, Eagle Vision Drones seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Eagle Vision

Drones submits that safety will not be affected by operation of the DJI Phantom 2, DJI 

Phantom 3 and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions 

(VMC) under visual flight rules (VFR), with enough battery power to fly for a total 

duration of approximately 13.5 minutes to the first point of intended landing and, assuming 

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

In accordance with 14 C.F.R. § 11.81, Eagle Vision Drones 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 

Eagle Vision Drones, LLC

11427 Jeffords Ave

Choctaw, OK 73020

Tel: (405) 290-8597

Email: admin@eaglevisiondrones.com

B. The Specific Sections Of 14 C.F.R. from Which Eagle Vision Drones Seeks 

Exemption.

1. Eagle Vision Drones 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.
 7

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

in connection with any business or employment if—

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

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

2. Eagle Vision Drones Seeks Exemption From The Requirements Of Section 

91.7(a).

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

the following:

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

3. Eagle Vision Drones Seeks Exemption From The Requirements Of Section 

91.121.

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

in part:

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

level of that aircraft, as the case may be, by reference to an altimeter that is set, 

when operating--

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

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

100 nautical miles of the aircraft;

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

section, the current reported altimeter setting of an appropriate available 

station; or

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

departure airport or an appropriate altimeter setting available before departure.

4. Eagle Vision Drones Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 20 minutes.
 8

5. Eagle Vision Drones Seeks Exemption From The Requirement Of Section 

91.405(a).

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

Each owner or operator of an aircraft—

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

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

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

6. Eagle Vision Drones Seeks Exemption From The Requirements Of Section 

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following:

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

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of 

this chapter[.]

7. Eagle Vision Drones Seeks Exemption From The Requirements Of 

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

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

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

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

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

approved for return to service by a person authorized by § 43.7 of this 

chapter; or

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with part 21 of this chapter.

8. Eagle Vision Drones Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b).

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

the following:

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

registered owner or operator shall keep the following records for the 

periods specified in paragraph (b) of this section:

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

records of the 100-hour, annual, progressive, and other required or approved 
 9

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) of this chapter for each 

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

propellers, and appliances.

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

periods prescribed:

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

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

the work is performed.

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

and transferred with the aircraft at the time the aircraft is sold.
 10

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

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

approved for return to service.

C. The Extent Of Relief Eagle Vision Drones Seeks And The Reason Eagle Vision

Drones Seeks The Relief.

1. Extent Of Relief Eagle Vision Drones Seeks And The Reason 

Eagle Vision Drones 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, Eagle Vision Drones submits that an equivalent level 

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

UAS or DJI Phantom 3 UAS or DJI Inspire 1 UAS unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate either 

the DJI Phantom 2 or DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with the 

operations specifications as described in this exemption, including evasive and emergency 

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

structures.

Further, Eagle Vision Drones submits that all flights of the DJI Phantom 2, DJI 

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

Petition: (1) will be incidental to Eagle Vision Drones business; and (2) will not carry 

passengers or property for compensation or hire.

2. Extent Of Relief Eagle Vision Drones Seeks And The Reason 

Eagle Vision Drones 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 Eagle Vision Drones to determine that the DJI Phantom 2, DJI 

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

ensuring that the UAS is in compliance with the operating documents (i.e. Monthly 

Maintenance Log, and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 Instruction 

Manual).

Eagle Vision Drones seeks the requested relief because the DJI Phantom 2, DJI 

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

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Eagle Vision Drones will ensure 

that the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs are in airworthy condition 
 11

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

and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 Instruction Manual) prior to every 

flight, and further, determine that the aircraft are in condition for safe flight, as stated in the 

conditions and limitations below.

3. Extent Of Relief Eagle Vision Drones Seeks And The Reason 

Eagle Vision Drones 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, DJI Phantom 3 and DJI Inspire 1 UASs, which 

utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry data link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information concerning 

UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL),

Eagle Vision Drones seeks the requested relief because the DJI Phantom 2, DJI Phantom 3 

and DJI Inspire 1 UA’s altimeter may be set on the ground to zero feet AGL, rather than 

the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 

14 CFR 91.121 is sought to the extent necessary to comply with the applicable 

conditions and limitations stated below. As more fully set forth herein, an equivalent 

level of safety will be maintained since the DJI Phantom 2, DJI Phantom 3 and DJI 

Inspire 1 UAs are equipped with a barometric pressure sensor and GPS equipment, 

which automatically ensures that a ground level pressure setting will be established 

prior to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS.

4. Extent Of Relief Eagle Vision Drones Seeks And The Reason 

Eagle Vision Drones Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered 

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration 

of 13.5 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes. Eagle Vision Drones seeks the requested 

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

the battery powered DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs will 

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

Eagle Vision Drones proposes to conduct pursuant to this Petition.

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

DJI Phantom 3 and DJI Inspire 1 UASs, the DJI Phantom 2, DJI Phantom 3 and DJI 

Inspire 1 operating documents, and Eagle Vision Drones proposed operating limitations, 

ensure that Eagle Vision Drones will safely operate the battery powered DJI Phantom 2, 

DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes.
 12

5. Extent Of Relief Eagle Vision Drones Seeks And The Reason 

Eagle Vision Drones Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

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

only apply to aircraft with an airworthiness certificate, Eagle Vision Drones requests relief 

from these Sections because the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 

do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 

2, DJI Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, Eagle Vision Drones will use 

trained technicians to perform maintenance, alterations, or preventive maintenance on the 

UASs using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3 and DJI 

Inspire 1 Instruction Manual). Furthermore, Eagle Vision Drones will document and 

maintain all maintenance records for the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 

UASs.

D. The Reasons Why Granting Eagle Vision Drones 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 Eagle 

Vision Drones to safely, efficiently, and economically perform aerial video and 

photography for wedding films, real estate, special events, film sets, and landscape 

over certain areas of the United States.

Additionally, use of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs

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

the economy. Notably, the benefits of Eagle Vision Drones proposed operation of the DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will be realized without implicating 

any privacy issues.

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

The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs are battery powered and 

serve as a safe, efficient, and economical alternative to the manned aircraft traditionally 

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

perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2, DJI 

Phantom 3 or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, 

reduce noise and air pollution, as well as increase the safety of life and property in the air 

and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

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

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs do not require an airport to takeoff 

or landing. 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.
 13

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

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs.

Conducting aerial acquisitions with the DJI Phantom 2, DJI Phantom 3 and DJI 

Inspire 1 UASs, instead of manned aircraft, will greatly benefit the public by drastically 

reducing the levels of air and noise pollution generated during traditional aerial video and 

still photography flight operations. By using battery power and electric motors, the DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs produce no air pollution, and is the 

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

combustion engine aircraft that are typically utilized for aerial video and photography, 

while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs, while reducing the carbon footprint of 

aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs to perform

aerial acquisitions, the substantial risk to life and property in the air and on the ground, 

which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew members 

located onboard the aircraft, the DJI Phantom 2, DJI Phantom3 and DJI Inspire1. 

UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces

respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches 

respectively, widths of 16 inches and 17.7 inches respectively, 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, DJI Phantom 3 and DJI Inspire 1 UASs Will 

Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2, DJI Phantom 3 and 

DJI Inspire 1 UASs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the DJI Phantom 2, DJI Phantom 

3 and DJI Inspire 1 UASs will allow United States based companies, like Eagle Vision 

Drones, 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, DJI Phantom 3 and DJI 

Inspire 1 UASs is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft.

By operating the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs, 

companies such as Eagle Vision Drones, can remain competitive and profitable, and 

therefore, provide greater job stability to employees and contractors, which will ultimately 
 14

contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 

1 UASs, provides a stable workforce that increases consumer spending; improves local, 

state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, Eagle Vision Drones proposed operation of the DJI Phantom 2, DJI Phantom 3 

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

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will be operated only in compliance 

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

Phantom 3 and DJI Inspire 1 Instruction Manual) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the 

Federal Aviation Regulations, including the minimum altitude requirements of 14 

C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, 

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Eagle Vision Drones Seeks Exemption.

1. Reasons Why The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs 

Meet The Conditions Of The FAA Modernization and Reform Act of 

2012 (FMRA) Section 333.

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

with the unmanned aircraft and its operation, Eagle Vision Drones operation of the DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 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.
 15

(b) Assessment of Unmanned Aircraft Systems.--In making the determination 

under subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not 

create a hazard to users of the national airspace system or the public 

or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system

In seeking this exemption, Eagle Vision Drones submits that the DJI Phantom 2, DJI 

Phantom 3 and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA Section 

333, as demonstrated by: (a) the characteristics of the DJI Phantom 2, DJI Phantom 3 and DJI 

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

limitations.

a. The Specifications Of The DJI Phantom 2, DJI Phantom 3 and 

DJI Inspire 1 UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs do not create a 

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

considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 2, DJI Phantom 3 and

DJI Inspire 1 UASs.

The technical specifications of the DJI Phantom 2, DJI Phantom 3 and DJI 

Inspire 1 UASs are set forth by the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 

Specifications and Data Sheet, attached hereto as Appendix A, B and C.

ii. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 

Autonomous Flight And Navigation Modes Enable The UASs 

To Remain Within A Defined Operational Area.

The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs may be operated in 

both manual and fully autonomous flight modes. A complete description of the flight 

and navigational modes of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 

is provided at pages 24-30 of the DJI Phantom 2, pages 11-17 of the DJI Phantom 3 and 

45-50 of the DJI Inspire 1 User Manuals, attached hereto as Appendix D, E and F.
 16

iii. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 

Are Designed For Automatic Return To Home Point Or Hover 

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

When the Control Link is lost, the DJI Phantom 2, DJI Phantom 3 and DJI 

Inspire1UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the 

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs do not reacquire control link data from 

the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the 

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

shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 UAS are set

forth at pages 25 through 26, for the DJI Phantom 3 pages 12-14 and for the DJI 

Inspire 1 at pages 13 through 15 of the respective User Manuals, attached hereto as 

Appendix D, E and F.

iv. The DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 GCS And Its

Operation.

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

2 and DJI Inspire 1 GCS and flight control software is provided at pages 31 through 45

of the DJI Phantom 2 User Manual, pages 31 through 45 of the DJI Phantom 2 User 

Manual pages 35 through 56 of the DJI Phantom 3 User Manual and pages 40 through 

62 of the DJI Inspire 1 User Manual. DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

User Manuals are attached hereto as Appendix D, E and F.

b. Flight Operations Of DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

UASs Are Limited To The Line Of Sight Of A Certificated Pilot in

Command With A Safety Observer.

Eagle Vision Drones will only utilize certificated pilots who possess a current and 

valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2, 

DJI Phantom 3 and DJI Inspire 1 UASs. Additionally, a safety observer will assist all 

pilots during flight time.

c. Flights Of DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs Will

Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Eagle Vision Drones proposes to commercially operate 

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs for the special purpose of 

conducting aerial video and photography over certain areas of United States, pursuant to 

the following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: DJI Phantom 2, DJI Phantom 3 and DJI

Inspire 1 Unmanned Aircraft Systems. Proposed operations of any other aircraft 

will require a new petition or a petition to amend this grant.
 17

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 500 feet above ground 

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

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

reported to ATC must be in feet AGL.

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

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

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate.

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

permitted.

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

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

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

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

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

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

prescribed in the operating documents.

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

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

is not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in the grant 

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

conditions and limitations contained in the grant of exemption take precedence 

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

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

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

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

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

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

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

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

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

questions arise regarding updates or revisions to the operating documents.

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

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

safe operation of the UAS, the aircraft is prohibited from operating until the 
 18

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 

third-class medical certificate.

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

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

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

exemption, including evasive and emergency maneuvers and maintaining 

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

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

§ 61.51(b). Flights for the purposes of training the operator’s PICs are

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. §

91.119.
 19

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

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

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

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

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

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

the Administrator upon request.

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

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

PIC.

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

in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

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

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

remaining.

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

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

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

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

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

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

altitude level and potential transponder requirements.

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

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

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

Subpart C. Markings must be as large as practicable.

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

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements.
 20

28. The documents required under 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.

Eagle Vision Drones 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, DJI Phantom 3 and DJI Inspire 1 UASs unless that PIC has 

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

is able to safely operate the DJI Phantom 2 or DJI Phantom 3 or DJI Inspire 1 UAS in a 
 21

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

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

Considering Eagle Vision Drones proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); 

and the airmanship skills necessary to safely operate the DJI Phantom 2 or DJI Phantom 

3 or DJI Inspire 1 UAS, Eagle Vision Drones submits that the additional manned 

airmanship experience of a commercially certificated pilot would not correlate to the 

airmanship skills necessary for Eagle Vision Drones 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).

Eagle Vision Drones will not allow any PIC to operate the DJI Phantom 2, 

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

flight-hour requirements or the DJI Phantom 2 or DJI Phantom 3 or DJI Inspire 1 UAS 

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

or DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

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

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes).

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 Eagle Vision Drones proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for

the purpose of motion picture filming (or similar operations), the PIC must have accumulated 

and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS 

rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. 

Prior to operations under Exemption No. 11062, the PIC must also have accumulated and 

logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to 

be used for operations under the exemption. For clarification, the FAA considers these 

minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model

time may be included in the 10 hours of multi-rotor time and the 10 hours may be included in

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The 

FAA finds that at a minimum, the flight-hour requirements in Exemption No. 11062 are 

appropriate to practice and build proficiency in the skills necessary to safely conduct the 

petitioner’s proposed operations. The FAA also finds that prior documented flight experience 

that was obtained in compliance with applicable regulations would satisfy this requirement. 
 22

Training, proficiency, and experience-building flights can also be conducted under the grant 

of exemption to accomplish the required flight time. During training, proficiency, and

experience building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119.

Accordingly, Eagle Vision Drones will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 2 or DJI Phantom 3or DJI Inspire 1 UAS unless that PIC has

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

able to safely operate the DJI Phantom 2 or DJI Phantom 3 or DJI Inspire 1 UAS in a manner 

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

appropriate distances from people, vessels, vehicles and structures.

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

Would Not Adversely Affect Safety

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

because prior to every flight, Eagle Vision Drones will ensure that the DJI Phantom 2 or 

DJI Phantom 3 or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and limitations 

herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

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

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

Would Not Adversely Affect Safety.

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

because the altitude information of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1

UAs will be provided to the PIC via GPS equipment and a radio communications telemetry

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

and altitude. This altitude information, combined with Eagle Vision Drones operation of the 

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs within visual line of sight, at or 

below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude 

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

each flight, a zero altitude initiation point is automatically established by the UASs at 

ground level.

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

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

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

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

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

Would Not Adversely Affect Safety.

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

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

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs; (2) the limitations on the proposed
 23

flight operations; and (3) the location of the proposed flight operations. Accordingly, 

Eagle Vision Drones will ensure that it will safely operate the battery powered DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 13.5 minutes to the 

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

at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom

2, DJI Phantom 3 and DJI Inspire 1 UASs; the limitations on the proposed flight

operations; and the location of the proposed operations, will ensure an equivalent level of 

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as 

the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs provide audible and visual 

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

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

approximately 10% remaining battery power. At the critically low battery level, the DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, Eagle Vision Drones submits that the equivalent level 

of safety with regard to the regulatory maintenance and alteration requirements 

established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b) will be met because Eagle Vision Drones will use trained technicians to perform 

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

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

Maintenance Log, and DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 Instruction 

Manual). Furthermore, Eagle Vision Drones will document and maintain all 

maintenance records for the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs.

Since the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will be inspected 

as prescribed by the operating documents, Eagle Vision Drones will maintain the 

equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). 

A copy of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 User Manuals are attached 

hereto as Appendix D, E and F; a copy of the DJI Phantom 2, DJI Phantom 3 and DJI 

Inspire 1 UAS Maintenance Log is attached hereto as Appendix G.
 24

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

Vision Drones will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents.

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

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

DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs will be performed by trained 

technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the

UAS are considered.

In consideration of Eagle Vision Drones proposed operating limitations,

the operating documents, and the technical aspects of the DJI Phantom 2, DJI 

Phantom 3 and DJI Inspire 1 UASs, Eagle Vision Drones submits that safety 

will not be adversely affected by granting exemption from 14 C.F.R. Sections 

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

FAA has previously granted relief specific to UAS in circumstances similar, in 

all material respects, to those presented herein (e.g. Exemption Nos. 11062, 

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

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

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

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

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Eagle Vision Drones

requests that the FAA prescribe special conditions for the intended operation of the DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs, which contain such safety standards 

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

established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 

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

Such special conditions will permit safe operation of the UAs for the limited purpose of 

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

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

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

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS.

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

§21.16, for operation of the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs, 

since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following:
 25

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 Eagle Vision Drones intended operation of 

the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs, which contain such safety 

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

to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & 

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

91.417(a) & (b).

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

The Rules From Which Eagle Vision Drone seeks Exemption:

Eagle Vision Drones 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 Eagle Vision Drones

Seeks:

This exemption will permit Eagle Vision Drones to commercially operate an 

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

photography over certain areas of the United States.

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

Eagle Vision Drones Request.

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

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Eagle Vision Drones request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as 

set forth above.

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

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

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

certification.
 26

As discussed in detail above, Eagle Vision Drones will operate the DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs 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, Eagle Vision Drones 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, DJI Phantom 3 and DJI 

Inspire 1 UASs 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 FAA Modernization and Reform Act of 2012, while also 

advancing the interests of the public, by allowing Eagle Vision Drones to safely, 

efficiently, and economically operate the DJI Phantom 2, DJI Phantom 3 and DJI Inspire 

1 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Eagle Vision Drones respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

Phantom 2, DJI Phantom 3 and DJI Inspire 1 UASs commercially for the purpose of 

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

Dated: July 6, 2015

Respectfully Submitted,

Eagle Vision Drones, LLC

 

 

Joe Hartpence, MGMR 

Eagle Vision Drones, LLC

11427 Jeffords Ave

Choctaw, OK 73020

Tel: (405) 290 8597

Appendices:

A – DJI Phantom 2 Specifications Data Sheet 

B – DJI Phantom 3 Specifications Data Sheet 

C – DJI Inspire 1 Specifications Data Sheet

D – DJI Phantom 2 Manufacturer’s User Manual

E – DJI Phantom 3 Manufacturer’s User Manual

F – DJI Inspire 1 Manufacturer’s User Manual

G – Monthly Maintenance Log
 28

APPENDIX – A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

Eagle Vision Drones 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 (smart phone/tablet 

devices)

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 - 350

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 - ±0.030

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

1.1.3.5 HD Video Recording – 1080p30 & 720p

1.1.3.6 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
 29

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 3 TECHNICAL SPECIFICATIONS

Eagle Vision Drones 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 (smart phone/tablet 

devices)

2.1 DJI Phantom 3

2.1.1 Aircraft

2.1.1.1 Supported Battery – DJI 6000mAh LiPo 2S

2.1.1.2 Weight (Battery & Propellers Included) – 1280 g

2.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: 10cm; Horizontal: 1m

2.1.1.4 Max Ascent Speed – 5m/s

2.1.1.5 Max Descent Speed – 3m/s

2.1.1.6 Max Flight Speed – 16m/s (ATTI mode, no wind)

2.1.2 Gimbal

2.1.2.1 Controllable Range – Pitch: -900 + 300

2.1.2.2 Stabilization – 3-zxis (pitch, roll, yaw)

2.1.3 Camera

2.1.3.1 Sensor – Sony EXMOR

2.1.3.2 Sensor Size – 1/2.3”

2.1.3.3 Effective Pixels – 12.4M

2.1.3.4 Video Recording Mode – 4096x2160p, 3840x2160p, 1920x1080p,

1280x720p

2.1.4 Remote Controller

2.1.4.1 Operating Frequency – 2.400GHz – 1.483GHz

2.1.4.2 Max Distance – 2000m

2.1.4.3 Receiver Sensitivity (1%PER) -101dBm+/-2dBm

2.1.4.4 Transmitter Power (EIRP) – FCC: 20dBm, CE: 16dBm

2.1.4.5 Working Voltage – 12A@7.4V
 31

APPENDIX – C

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Eagle Vision Drones 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 (smart phone/tablet 

devices)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3.2 DJI Inspire 1 

 

3.2.1 Aircraft 

3.2.1.1 Model – T600 

3.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

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

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

3.2.1.5 Max Tilt Angle --‐ 350 

3.2.1.6 Max Ascent Speed – 5m/s 

3.2.1.7 Max Descent Speed – 4m/s 

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

3.2.1.9 Max Flight Altitude – 4500m 

3.2.1.10 Max Wind Resistance – 10m/s 

3.2.1.11 Max Flight Time – Approximately 18 minutes 

3.2.1.12 Motor Model – DJI 3510 

3.2.1.13 Propeller Model – DJI 1345 

3.2.1.14 Operating Temperature Range – 140F to 1040F (--‐100C to 400C) 

3.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

 

3.2.2 Gimbal 

 

 

 

 

 

 

 

 

 

 

 

 

3.2.2.1 Model - ZENMUSE X3

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

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

3.2.2.4 Angular Vibration Range --‐ ±0.030 

3.2.2.5 Mounting – Detachable 

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

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

3.2.2.8 Max Controllable speed – Pitch: 1200/s; Pan: 1800/s

 

 

 

 

3.2.3 Camera 

3.2.3.1 Name – X3 

3.2.3.2 Model – FC350 

3.2.3.3 Total Pixels – 12.76M

3.2.3.4. Effective Pixels – 12.4M
 32

 

 

 

 

 

 

 

 

 

 

 

 

 

3.2.3.5 Image Max Size – 4000x3000 

3.2.3.6 ISO Range – 100--‐3200 

3.2.3.7 Field of View --‐ 940 

3.2.3.8 CMOS - Sony EXMOR 1/2.3”

3.2.3.9 HD Video Recording – 

UHD(4K): 4096x2160p24/25 

3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60; 

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

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

 

3.2.4 Transmitter 

3.2.4.1 Name – C1 

3.2.4.2 Operating Frequency –5.728--‐5.850GHz; 2.400--‐2.483GHz 

3.2.4.3 Communicating Distance (unobstructed) – 2000m 

3.2.4.4. Output Power – 9W 

3.2.4.5. Operating Temperature Range - -100C to 400C) 

3.2.4.6. Battery – 600mAh LiPo 2S

3.2.5 Battery 

3.2.5.1 Name – Intelligent Flight Battery

3.2.5.2 Model -- TB47 

3.2.5.3 Capacity – 4500 mAh

3.2.5.4. Voltage – 22.2V

3.2.5.4. Battery Type – LiPo 6S 

3.3.5.5. Net Weight – 570g

3.2.5.6. Operating Temperature Range - -140C to 400C

3.2.5.7. Max Charging Power – 180 W
 33

APPENDIX – D

DJI PHANTOM 2 MANUFACTURER’S USER MANUAL

User manual can be found at:

http://download.dji-innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf
 34

APPENDIX – E

DJI PHANTOM 3 MANUFACTURER’S USER MANUAL

User manual can be found at:

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Advanced_User_Manual_v1.2_en.pdf
 35

APPENDIX – F

DJI INSPIRE 1 MANUFACTURER’S USER MANUAL

User manual can be found at:

http://download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf
 36

APPENDIX – G

MONTHLY MAINTENANCE LOG 

month: year:

UAS #: Date Issue 

Discovered

Date Issue 

Addressed Issue Description & Maintenance Conducted Maintenance Performed By: 

Print & Sign 

Software Updates 

Airframe

Engines

Propellers

Camera Gimbal 

Landing Gear 

Vibration Dampening 

Other: