UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ATLAS EAGLE VISION 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 VISION+, DJI PHANTOM 3 & DJI INSPIRE 1

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

(PUBLIC LAW 112-95)

THE FAA MODERNIZATION AND REFORM ACT OF 2012

Submitted on May 30, 2015

ATLAS Eagle Vision LLC

5205 13th Ave S

Gulfport, FL 33707

727-755-3842
Petition for Exemption Page 1 of 26

TABLE OF CONTENTS

SUMMARY.........................................................................................................................................................................................2

INTRODUCTION AND INTERESTS OF THE PETITIONER ........................................................................................2

BACKGROUND...............................................................................................................................................................................2

BASIS FOR PETITION..................................................................................................................................................................3

A. NAME AND ADDRESS OF THE PETITIONER...........................................................................................................4

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ATLAS EAGLE VISION LLC SEEKS 

EXEMPTION. ...........................................................................................................................................................................5

C. THE EXTENT OF RELIEF SOUGHT BY ATLAS EAGLE VISION LLC:.............................................................8

D. THE REASONS WHY GRANTING ATLAS EAGLE VISION LLC REQUEST WOULD BE IN THE 

PUBLIC INTEREST; THAT IS, HOW IT WOULD BENEFIT THE PUBLIC AS A WHOLE..........................10

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 ATLAS EAGLE VISION LLC SEEKS EXEMPTION............12

F. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF SECTION 61.113(A) AND (B)

WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................................................19

G. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF SECTION 91.7(A) WOULD NOT 

ADVERSELY AFFECT SAFETY.......................................................................................................................................21

H. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF SECTION 91.121 WOULD NOT 

ADVERSELY AFFECT SAFETY.......................................................................................................................................21

I. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS OF SECTION 91.151(B) WOULD 

NOT ADVERSELY AFFECT SAFETY............................................................................................................................21

J. 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.

22

K. THE FAA MAY PRESCRIBE ANY OTHER CONDITIONS FOR SAFE OPERATION. .................................23

L. CONCLUSION........................................................................................................................................................................25

M. APPENDICES: ........................................................................................................................................................................26
Petition for Exemption Page 2 of 26

SUMMARY

ATLAS EAGLE VISION LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 

91.119 (c), 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 ATLAS EAGLE VISION LLC to operate an Unmanned Aircraft System (UAS) for the 

commercial purpose of conducting aerial video and photography of real estate, commercial properties and landscapes 

over certain areas within the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

ATLAS EAGLE VISION LLC seeks to establish and provide a service provider based company capable of 

providing high quality aerial images and videos to its clients with the safest and most cost effective means available. 

The focus of ATLAS EAGLE VISION LLC is to provide these services to the following commercial markets:

 Aerial Photography and Videography

 Real Estate Marketing and Promotions

 Commercial Advertising and Marketing

 Residential and Commercial Property Inspections, Appraisals and Survey

 Commercial Agriculture 

. BACKGROUND

ATLAS EAGLE VISION LLC seeks an exemption to operate DJI systems for compensation or hire within the 

NAS. The DJI Phantom 2 Vision+, Phantom 3, DJI Inspire platforms are VTOL (vertical takeoff and landing) 

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

The DJI Phantom 2 Vision+ and Phantom 3 have a maximum gross weight of approximately 2 pounds 11 ounces, 

with the dimensions of 16x16 inches wide, height of 8 inches, and a maximum speed of approximately 31 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 Vision+, Phantom 3, 

DJI Inspire systems are driven by rechargeable Lithium Polymer battery powered electric motors that drive four main 

rotors.
Petition for Exemption Page 3 of 26

The DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs that will be operated by ATLAS EAGLE VISION 

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, ATLAS EAGLE VISION LLC, 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 Vision+, 

DJI Inspire 1 UAs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 

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

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

its operation, ATLAS EAGLE VISION LLC operation of DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 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, ATLAS EAGLE VISION LLC 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. 

ATLAS EAGLE VISION LLC submits that the requested relief is proper since an equivalent level of safety will 

be ensured. ATLAS EAGLE VISION LLC 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 Vision+, DJI Inspire 1, Phantom 3 

Instruction Manuals). Furthermore, ATLAS EAGLE VISION LLC will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in 

command, is requested by ATLAS EAGLE VISION LLC 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 

Vision+, Phantom 3, 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. 
Petition for Exemption Page 4 of 26

ATLAS EAGLE VISION LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI 

Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, ATLAS EAGLE VISION LLC submits that he will ensure that the DJI Phantom 

2 Vision+, Phantom 3, DJI InspireUAs are in an airworthy condition, prior to every flight, by determining that the 

UAs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+, 

Phantom 3, DJI Inspire Instruction Manual), and that the aircraft are in a condition for safe flight. 

ATLAS EAGLE VISION LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+, Phantom 3, DJI InspireUAs 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 ATLAS EAGLE VISION LLC’s operation of the DJI Phantom 2 Vision+, Phantom 3, 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. 

Additionally, ATLAS EAGLE VISION LLC seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. ATLAS EAGLE VISION LLC submits that safety will not be 

affected by operation of the DJI Phantom 2 Vision+, Phantom 3, 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, ATLAS EAGLE VISION LLC 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:

Jason Rizzuto

ATLAS EAGLE VISION LLC

5205 13th Ave S

Gulfport, FL 33707

(434)713-0060

Email: admin@atlaseaglevision.com
Petition for Exemption Page 5 of 26

B. The Specific Sections Of 14 C.F.R. From Which ATLAS EAGLE VISION LLC Seeks Exemption. 

B.01 ATLAS EAGLE VISION LLC 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. 

B.02 ATLAS EAGLE VISION LLC 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. 

B.03 ATLAS EAGLE VISION LLC Seeks Exemption From The Requirements Of Section 91.119 (b). Section 

91.119(b) establishes safe altitudes for operations of civil aircraft over congested areas and is defined as follows:

“(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air 

assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet 

of the aircraft.”

ATLAS EAGLE VISION LLC seeks relief from this exemption as our main operating within the Tampa Bay 

community is widely considered a “congested area” depicted on a VFR Sectional Chart by a “yellow” color 

shade. The UAS will be operating within a restricted area around our point of interest preventing nonparticipating people to be well clear and safe of our operations. ATLAS EAGLE VISION LLC has no 

intention of operating our UAS above 400 feet in height above and not beyond the area of interest. This 

confined operating work space will support that safe operations within a congested community can be safely 

accomplished. We also plan to have placards or self-standing signs notifying the general public that UAS 

operations are operating overhead and please stand clear. ATLAS EAGLE VISION is focused on 

maintaining a high degree of safety in all aspects of our flight operations and any foreign body such as person 

or vehicle which enters our restricted area of operation would cause an immediate suspension of flight 

operations until that obstacle can be cleared. 
Petition for Exemption Page 6 of 26

B.04 ATLAS EAGLE VISION LLC 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. 

B.05 ATLAS EAGLE VISION LLC 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 30 minutes. 

B.06 ATLAS EAGLE VISION LLC 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—

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[.] 

B.07 ATLAS EAGLE VISION LLC 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[.] 

B.08 ATLAS EAGLE VISION LLC 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 --
Petition for Exemption Page 7 of 26

(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. 

B.09 ATLAS EAGLE VISION LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 

91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

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

shall keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, 

progressive, and other required or approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

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

(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 completed project.

(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. 
Petition for Exemption Page 8 of 26

(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 Sought by ATLAS EAGLE VISION LLC:

C.01 Extent Of Relief ATLAS EAGLE VISION LLC Seeks And The Reason ATLAS EAGLE VISION LLC 

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, ATLAS EAGLE VISION LLC submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+, Phantom 3, or DJI Inspire 1 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 Vision+, 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, ATLAS EAGLE VISION LLC submits that all flights of the DJI Phantom 2 Vision+, Phantom 3, DJI 

Inspire 1 UAs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to ATLAS EAGLE 

VISION LLC ‘s business; and (2) will not carry passengers or property for compensation or hire. 

C.02 Extent Of Relief ATLAS EAGLE VISION LLC Seeks And The Reason ATLAS EAGLE VISION LLC 

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 ATLAS 

EAGLE VISION LLC to determine that the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs are in 

airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., 

ATLAS EAGLE VISION LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+, 

Phantom 3, DJI Inspire Instruction Manual). 
Petition for Exemption Page 9 of 26

ATLAS EAGLE VISION LLC seeks the requested relief because the DJI Phantom 2 Vision+, Phantom 3, DJI 

Inspire 1 UAs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

ATLAS EAGLE VISION LLC will ensure that the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs are in 

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

DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 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.

C.03 Extent Of Relief ATLAS EAGLE VISION LLC Seeks And The Reason ATLAS EAGLE VISION LLC 

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 Vision+, Phantom 3, DJI Inspire 1 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), ATLAS EAGLE VISION LLC seeks the requested 

relief because the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 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 Vision+, Phantom 3, 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. 

C.04 Extent Of Relief ATLAS EAGLE VISION LLC Seeks And The Reason ATLAS EAGLE VISION LLC 

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 Vision+, Phantom 3, 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. ATLAS EAGLE VISION LLC seeks the requested relief because without an exemption from Section 

91.151(b), the flight time duration of the battery powered DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs will 

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

LLC proposes to conduct pursuant to this Petition. 
Petition for Exemption Page 10 of 26

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision+, Phantom 3, DJI 

Inspire 1 UAs, the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire operating documents, and ATLAS EAGLE 

VISION LLC’s proposed operating limitations, ensure that ATLAS EAGLE VISION LLC will safely operate the 

battery powered DJI Phantom 2 Vision+, Phantom 3, 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.

C.05 Extent Of Relief ATLAS EAGLE VISION LLC Seeks And The Reason ATLAS EAGLE VISION LLC 

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, ATLAS EAGLE VISION LLC requests relief from these Sections because the DJI Phantom 

2 Vision+, Phantom 3, DJI Inspire 1 UAs do not require airworthiness certificates. As set forth more fully below, the 

DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, ATLAS EAGLE VISION LLC 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 ATLAS EAGLE VISION LLC Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3, DJI Inspire Instruction Manual). Furthermore, 

ATLAS EAGLE VISION LLC will document and maintain all maintenance records for the DJI Phantom 2 Vision+, 

Phantom 3, DJI Inspire 1 UAs. 

D. The Reasons Why Granting ATLAS EAGLE VISION LLC 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 ATLAS EAGLE VISION LLC to safely, 

efficiently, and economically perform commercial aerial photography and videography services to the general public 

and local government entities. As tourism is a major economical factor in the State of Florida, the ability to effectively 

market our state not only boosts our local economy but also the national economy as well. We look to work with 

local Florida tourism boards to help provide stunning aerial photography and videography at cost effective price 

points that will promote our state as a magnet for tourism for years to come.

Additionally, use of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs will decrease congestion of the 

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of ATLAS EAGLE 
Petition for Exemption Page 11 of 26

VISION LLC’s proposed operation of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire platforms will be realized 

without implicating any privacy issues. 

D.01 The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Phantom 2 Vision+, Phantom 3, 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 

Vision+ 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 Vision+, Phantom 3, DJI Inspire

platforms 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.

D.02 The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+ & DJI Inspire 1 

UAs. 

Conducting aerial photography operations with the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 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 Vision+, Phantom 3, DJI Inspire 1 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 of leaded 

aviation fuel. The DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs, while reducing the carbon footprint of 

aerial photography operations, 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 Vision+, Phantom 3, DJI Inspire 1 UAs to perform aerial photography operations, 

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 and/or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 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 
Petition for Exemption Page 12 of 26

fuel on board), has far less kinetic and 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). 

D.03 Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+, Phantom 3, DJI 

Inspire Platforms Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs are also an 

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

Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs will allow United States based companies, like ATLAS EAGLE 

VISION LLC, 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 Vision+, Phantom 3, DJI Inspire 1 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 Vision+, Phantom 3, DJI Inspire 1 UAs, companies such as ATLAS EAGLE 

VISION LLC, can remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. 

companies, through commercial use of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 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. 

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 ATLAS EAGLE VISION LLC Seeks Exemption. 

E.01 Reasons Why The DJI Phantom 2 Vision+, Phantom 3, 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, ATLAS EAGLE VISION LLC’s operation of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 

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. 
Petition for Exemption Page 13 of 26

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.--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, ATLAS EAGLE VISION LLC submits that the DJI Phantom 2 Vision+, Phantom 3, 

DJI Inspire 1 UAs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs; (b) the pilot certification requirement; 

and (c) the specific operating limitations.

(a). The Specifications Of The DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs Demonstrate Its Safe 

Characteristics.

The DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 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 Vision+, Phantom 3, DJI Inspire 1 UAs. 
Petition for Exemption Page 14 of 26

The technical specifications of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs are set forth by the 

DJI Phantom 2 Vision+, Phantom 3, DJI Inspire Specifications and Data Sheet, attached hereto as Appendix M.01, 

M.02 and M.03. 

ii. The DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs Autonomous Flight And Navigation Modes 

Enable The UAs To Remain Within A Defined Operational Area. 

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

Vision+, Phantom 3, DJI Inspire 1 UAs is provided in the User Manuals. 

iii. The DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 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 Vision+, Phantom 3, DJI Inspire 1 UAs will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+, Phantom 3, 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 Vision+ UAS are set forth in the DJI 

Phantom 2 Vision+, Phantom 3, DJI Inspire 1 User Manuals, attached hereto in the Appendix M.01-M.03. 

A complete description of the operation and specifications of the DJI Phantom 2 Vision+, Phantom 3, DJI 

Inspire 1 GCS and flight control software is provided in the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 User 

Manuals are attached hereto as Appendix M.01-M.03. 

(b). Flight Operations Of DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs are limited to the line of 

sight of a certificated pilot in command with a safety observer.

ATLAS EAGLE VISION LLC will only utilize certificated Commercial pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 

1 UAs. Additionally, a safety observer will assist all pilots during flight time. 

(c). Flights Of DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs Will Be Conducted Pursuant To 

Specific Operating Limitations. 

Both of our pilots are FAA Certified 

Pilots – one holding a Commercial Multi Engine Airplane rating and the other one an Airline Transport Pilot rating.

In seeking this exemption, ATLAS EAGLE VISION LLC proposes to commercially operate the DJI Phantom 2 

Vision+, Phantom 3, DJI Inspire platforms for the special purpose of conducting aerial video and photography over 

certain areas of United States, pursuant to the following specific operating limitations:
Petition for Exemption Page 15 of 26

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

operating documents, rotorcraft UAs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 

Vision+, Phantom 3, DJI Inspire 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 35 mph.

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 
Petition for Exemption Page 16 of 26

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 UAs operated under this exemption must comply with all manufacturer Safety Bulletins. 

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

discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class medical 

certificate. 
Petition for Exemption Page 17 of 26

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria 

and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will 

be made at the FAA office closest to proposed area of operations. Flights under special visual flight rules 

(SVFR) are not authorized. 

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 pre- determined 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 
Petition for Exemption Page 18 of 26

less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace 

requirements in the ATO issued COA including class of airspace, altitude level and potential transponder 

requirements. 

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

accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 

C.F.R. part 45, Subpart C. Markings must be as large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA 

must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

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

Ground Control Station of the UAS any time the UAS is operating. These documents must be made available 

to the Administrator or any law enforcement official upon request. 

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). 
Petition for Exemption Page 19 of 26

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. 

F. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety.

ATLAS EAGLE VISION LLC 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 Vision+, Phantom 3, 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 Vision+ 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. 

Considering ATLAS EAGLE VISION LLC’s proposed area of operations, and the operating limitations set 

forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 

Vision+, DJI Phantom 3, and DJI Inspire 1 UAS, ATLAS EAGLE VISION LLC submits that the additional manned 

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

ATLAS EAGLE VISION LLC’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).

ATLAS EAGLE VISION LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 

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

Vision+ or DJI Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 2 Vision+ 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. 
Petition for Exemption Page 20 of 26

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 ATLAS EAGLE VISION 

LLC’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in 

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

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

picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 

CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a 

multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a 

minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than 

additive; i.e. 5 hours make and model time may be included in the 10 hours of multi-rotor time and the 10 hours may 

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

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in 

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

Accordingly, ATLAS EAGLE VISION LLC will ensure safe operations by not allowing any PIC to operate the 

DJI Phantom 2 Vision+ or 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 Vision+ 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. 
Petition for Exemption Page 21 of 26

G. 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, 

ATLAS EAGLE VISION LLC will ensure that the DJI Phantom 2 Vision+ 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). 

H. 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 Vision+, Phantom 3, 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 ATLAS EAGLE VISION LLC’s operation of the 

DJI Phantom 2 Vision+, Phantom 3, 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 

UAs at ground level. 

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

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

11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

I. 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 Vision+, Phantom 3, DJI Inspire 1 UAs; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, 
Petition for Exemption Page 22 of 26

ATLAS EAGLE VISION LLC will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+, 

Phantom 3, 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 Vision+, Phantom 3, DJI 

Inspire 1 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 Vision+, Phantom 3, DJI Inspire 1 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 Vision+ and DJI Inspire 1 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). 

J. 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, ATLAS EAGLE VISION LLC 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 ATLAS EAGLE VISION LLC 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 ATLAS EAGLE VISION LLC Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 2 Vision+, Phantom 3, DJI Inspire Instruction Manual). Furthermore, ATLAS 

EAGLE VISION LLC will document and maintain all maintenance records for the DJI Phantom 2 Vision+, 

Phantom 3, DJI Inspire 1 UAs. 

Since the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs will be inspected as prescribed by the operating 

documents, ATLAS EAGLE VISION LLC will maintain the equivalent level of safety established by Sections 
Petition for Exemption Page 23 of 26

91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire User 

Manuals are attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 

UAs Maintenance LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because ATLAS EAGLE VISION LLC 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 Vision+, Phantom 3, DJI Inspire 1 UAs will 

be performed by trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. 

In consideration of ATLAS EAGLE VISION LLC‘s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs, ATLAS EAGLE VISION 

LLC 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). 

K. 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, ATLAS EAGLE VISION LLC requests that the FAA prescribe special conditions 

for the intended operation of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs, which contain such safety

standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 

C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the 

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

or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of 
Petition for Exemption Page 24 of 26

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 Vision+, Phantom 3, DJI Inspire 1 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 of the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 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).

This exemption will permit ATLAS EAGLE VISION LLC to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States. 

Any Additional Information, Views, Or Arguments Available To Support ATLAS EAGLE VISION LLC. 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, ATLAS EAGLE VISION LLC 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. 
Petition for Exemption Page 25 of 26

As discussed in detail above, ATLAS EAGLE VISION LLC will operate the DJI Phantom 2 Vision+, Phantom 

3, DJI Inspire 1 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.

L. CONCLUSION

As set forth herein, ATLAS EAGLE VISION LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI 

Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs commercially, without an airworthiness certificate, for the limited 

purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, 

the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 

2012, while also advancing the interests of the public, by allowing ATLAS EAGLE VISION LLC to safely, efficiently, 

and economically operate the DJI Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs commercially within the NAS. 

Wherefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 

2012, Section 333, ATLAS EAGLE VISION LLC 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 ATLAS EAGLE VISION LLC to operate the DJI 

Phantom 2 Vision+, Phantom 3, DJI Inspire 1 UAs commercially for the purpose of conducting aerial photography

and videography over certain areas of the United States.

Dated: May 30, 2015

Respectfully submitted

Jason Rizzuto ATP Certif. No. 3104598

ATLAS EAGLE VISION LLC
Petition for Exemption Page 26 of 26

M. Appendices:

(Click on title to jump to User Manual/Specs)

M.01 DJI Phantom 2 Vision+ User Manual

M.01a Specifications

M.02 DJI Phantom 3 User Manual

M.02a Specifications 

M.03 DJI Inspire 1 User Manual

M.03a Specifications