1

Jason D Damman

713 Wedgewood Dr.

Avon Lake, OH 44012

(419) 699-6010

jddamman@gmail.com

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 

C.F.R. Part 11, Jason Dennis Damman, a professional airline pilot, hereby applies for an exemption from 

the Federal Aviation Regulations (FARs) listed below to allow operation of my Small Unmanned Aircraft 

System (sUAS) commercially in airspace regulated by the Federal Aviation Administration (FAA) so long 

as such operations are conducted with and under the conditions outlined herein or as may be established by 

the FAA as required by Section 333.

The requested exemption would permit Jason D Damman to pursue his commercial interests in providing

services to clients using a DJI Phantom 3 in the following areas: real estate, marketing, land

management/surveying, motion picture filming, special events, and search and rescue. 

Jason D Damman has demonstrated the ability to safely and effectively fly the DJI Phantom 3 which will 

be used for all commercial and private purposes. Jason D Damman complies with local ordinances and 

laws regarding the operation of sUAS, and adheres to all weather and environmental restrictions or 

limitations in reference to the operations of sUAS.

The following contains my list of regulations from which I am seeking exemption, my qualifications as an 

Operator, and a complete list of the responsibilities I assume as Operator; it also contains information 

regarding the aircraft, public benefit and safety features, and similar petitions requests granted.

Thank You for your Consideration,

Jason D. Damman
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TABLE OF CONTENTS

GLOSSARY OF 

ABBREVIATIONS.........................................................................................................2

SUMMARY.....................................................................................................................3

INTRODUCTION AND INTERESTS OF 

PETITIONER...................................................................................................................3

BACKGROUND..............................................................................................................3

BASIS FOR 

PETITION........................................................................................................................4

NAME AND ADDRESS OF PETITIONER...................................................................5

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH 

Jason Dennis Damman SEEKS EXEMPTION................................................5

THE EXTENT OF RELIEF Jason Dennis Damman SEEKS AND THE REASON

Jason Dennis Damman SEEKS THE RELIEF...............................................................8

THE REASONS WHY GRANTING Jason Dennis Damman's

REQUEST WOULD BE IN THE PUBLIC INTEREST .............................................9

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY.................................................................................12

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.............22

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT Jason Dennis Damman's REQUEST.............................22

CONCLUSION...............................................................................................................23

APPENDICES.....................................................................................24
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

Jason Dennis Damman seeks exemption from the requirements of 14 C.F.R §§, 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 Jason Dennis Damman to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography of construction sites, 

real estate, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Jason Dennis Damman is a licensed and current Airline Transport Pilot with a current 

First Class medical certificate that would like to provide clients with expertise and 

knowledge in advanced technologies and solutions to increase efficiency, productivity

and effectiveness. Jason Dennis Damman has been building and flying radio-controlled 

airplanes and helicopters since 1990 and also has over 15 years of professional flying 

experience (Over 10,000 hours of logged flight time) as an airline transport pilot, 

including 10 years as Captain/PIC, with Expressjet Airlines on the Embraer 135/145 

aircraft. Jason Dennis Damman is highly trained and experienced in airspace 

infrastructure, airport operations, and aircraft flight patterns. The objective of Jason 

Dennis Damman’s aerial video and photography operation is to provide high quality

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

 Construction sites before and after

 Appraisals

 Real-estate marketing

 Motion Picture Filming

 Aerial acquisitions used for inspections of public and private property/structures.

 Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Advanced/Professional UASs

Jason Dennis Damman seeks an exemption to operate DJI systems for compensation

or hire within the NAS. The DJI Phantom 3 Advanced/Professional UASs 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 3 

Advanced/Professional has a maximum gross weight of approximately 2 pounds 12 

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

maximum speed of approximately 29 knots.

The DJI Phantom 3 Advanced/Professional UAs are equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 3 Advanced/Professional UAs that will be operated by Jason Dennis 

Damman 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
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BASIS FOR PETITION

Petitioner, Jason Dennis Damman, 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 3

Advanced/Professional UASs in the National Airspace System (NAS), and for an 

exemption from the requirements of 14 C.F.R §§, 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, Jason Dennis Damman’s operation of DJI

Phantom 3 Advanced/Professional 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, Jason Dennis Damman 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.

Jason Dennis Damman submits that the requested relief is proper since an

equivalent level of safety will be ensured. Jason Dennis Damman 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 3 Advanced/Professional

Instruction Manual). Furthermore, Jason Dennis Damman will document and maintain all

maintenance records for the DJI Phantom 3 Advanced/Professional UASs.

Jason Dennis Damman seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 3 Advanced/Professional UASs do not require 

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

Jason Dennis Damman submits that he will ensure that the DJI Phantom 3 

Advanced/Professional 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 3 Advanced/Professional Instruction Manual), and 

that the aircraft are in a condition for safe flight.

Jason Dennis Damman also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Advanced/Professional UAs 

will not have a typical barometric altimeter onboard. However, altitude information of the 

DJI Phantom 3 Advanced/Professional UAs will be provided to the PIC via Global 

Positioning System (GPS) equipment and radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path. 

This altitude information, combined with Jason Dennis Damman's operation of the DJI 

Phantom 3 Advanced/Professional UASs within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 91.121.
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Additionally, Jason Dennis Damman seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Jason Dennis 

Damman submits that safety will not be affected by operation of the DJI Phantom 3

Advanced/Professional 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, Jason Dennis Damman 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 Dennis Damman

713 Wedgewood Dr.

Avon Lake, OH 44012

Email: jddamman@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Jason Dennis Damman Seeks 

Exemption.

1. Jason Dennis Damman 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.

2. Jason Dennis Damman 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.
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3. Jason Dennis Damman 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.

4. Jason Dennis Damman 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[.]

5. Jason Dennis Damman 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[.]

6. Jason Dennis Damman 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.
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7. Jason Dennis Damman 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

work is performed.

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

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

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

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

approved for return to service.
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C. The Extent Of Relief Jason Dennis Damman Seeks And The Reason Jason 

Dennis Damman Seeks The Relief.

1. Extent Of Relief Jason Dennis Damman Seeks And The Reason Jason Dennis 

Damman 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 Jason Dennis Damman to determine that the DJI Phantom 3

Advanced/Professional 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 3 Advanced/Professional Instruction Manual).

Jason Dennis Damman seeks the requested relief because the DJI Phantom 3 

Advanced/Professional l UASs do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, Jason Dennis Damman will ensure that the 

DJI Phantom 3 Advanced/Professional UASs are in airworthy condition based upon its 

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

Phantom 3 Advanced/Professional 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

2. Extent Of Relief Jason Dennis Damman, Seeks From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow

flight operations of the DJI Phantom 3 Advanced/Professional 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), 

Jason Dennis Damman seeks the requested relief because the DJI Phantom 3 

Advanced/Professional UA’s altimeter may beset 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 3 Advanced/Professional 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.

3. Extent Of Relief Jason Dennis Damman Seeks And The Reason Jason Dennis 

Damman 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 3 Professional 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. 
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Jason Dennis Damman seeks the requested relief because without an exemption

from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3

Professional UAs will severely constrain the practicality of any aerial video or still photo

flight operations that Jason Dennis Damman proposes to conduct pursuant to this Petition. 

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

Professional UASs, the DJI Phantom 3 Advanced/Professional operating documents, and 

Jason Dennis Damman’s proposed operating limitations, ensure that Jason Dennis 

Damman will safely operate the battery powered DJI Phantom 3 Advanced/Professional

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.

4. Extent Of Relief Jason Dennis Damman Seeks And The Reason Jason Dennis 

Damman 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, Jason Dennis Damman requests

relief from these Sections because the DJI Phantom 3 Advanced/Professional UASs do

not require airworthiness certificates. As set forth more fully below, the DJI Phantom 3

Advanced/Professional UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, Jason Dennis Damman 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., the Jason Dennis Damman Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 3 Advanced/Professional Instruction Manual). Furthermore, Jason 

Dennis Damman will document and maintain all maintenance records for the DJI 

Phantom 3 Advanced/Professional UASs.

D. The Reasons Why Granting Jason Dennis Damman 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 Jason Dennis 

Damman to safely, efficiently, and economically perform aerial video and

photography of construction sites, real estate, and landscape over certain areas of the

United States. Additionally, use of the DJI Phantom 3 Advanced/Professional UASs will

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

the economy. Notably, the benefits of Jason Dennis Damman's proposed operation of the

DJI Phantom 3 Advanced/Professional UASs will be realized without implicating any

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

The DJI Phantom 3 Advanced/Professional 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 3 Advanced/Professional 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 3 

Advanced/Professional UAs do not require an airport to takeoff or land. Likewise, 

a reduction of manned aircraft conducting aerial video and photography missions 

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

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

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

Phantom 3 Advanced/Professional UASs.

Conducting aerial acquisitions with the DJI Phantom 3 Advanced/Professional

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 3 Advanced/Professional 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 3 Advanced/Professional 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 3 Advanced/Professional

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 3 Advanced/Professional UAs (weighing approximately 2 pounds 12 

ounces, at their maximum gross weights with lengths and widths of 16 inches, and 

with no fuel on board), has less physical potential for collateral damage to life and

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

typically conduct similar operations (weighing approximately 6,000 pounds with 

a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 

180 gallons).
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3. Performing Aerial Video and Photography Operations With The DJI

Phantom 3 Professional UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Advanced/Professional

UASs are also an economical alternative to using manned aircraft to conduct 

similar aerial operations. As such, operation of the DJI Phantom 3 

Advanced/Professional UASs will allow United States based companies, like 

Jason Dennis Damman, 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 3 

Advanced/Professional 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 3 Advanced/Professional UASs, 

companies and individuals such as Jason Dennis Damman, 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 3 Advanced/Professional 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, Jason Dennis Damman's proposed operation of the DJI

Phantom 3 Advanced/Professional UASs will not implicate any privacy issues. 

Specifically, the DJI Phantom 3 Advanced/Professional UASs will be operated 

only in compliance with operating documents (i.e., Monthly Maintenance Log, 

and DJI Phantom 3 Advanced/Professional 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.
13

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 Jason Dennis Damman Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Advanced/Professional 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, Jason Dennis Damman operation of the DJI

Phantom 3 Professional 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.

(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.
14

In seeking this exemption, Jason Dennis Damman submits that the DJI Phantom 3

Advanced/Professional UASs can operate safely in the NAS pursuant to FMRA Section

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

Advanced/Professional UASs; (b) the pilot certification requirement; and (c) the specific 

operating limitations.

a. The Specifications Of The DJI Phantom 3 Advanced/Professional UASs

Demonstrate Its Safe Characteristics.

The DJI Phantom 3 Advanced/Professional 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 3 

Advanced/ProfessionalUASs.

The technical specifications of the DJI Phantom 3 Advanced/Professional

UASs are set forth by the DJI Phantom 3 Advanced/Professional

Specifications, attached hereto as Exhibit A.

ii. The DJI Phantom 3 Advanced/Professional UASs Autonomous 

Flight And Navigation Modes Enable The UASs To Remain Within A 

Defined Operational Area. 

The DJI Phantom 3 Advanced/Professional 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 3Advanced/Professional

UASs is provided at pages 39-47 of the DJI Phantom 3 

Advanced/Professional User Manual, attached hereto as Exhibit B.

iii. The DJI Phantom 3 Advanced/Professional 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 3 Advanced/Professional

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

seconds, the DJI Phantom 3 Advanced/Professional 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 3 

Advanced/Professional UAS are set forth at page 14 of the DJI Phantom 3 

Advanced/Professional User Manual, attached hereto as Exhibit B.
15

iv. The DJI Phantom 3 Advanced/Professional GCS And Its 

Operation.

A complete description of the operation and specifications of the DJI 

Phantom 3 Advanced/Professional GCS and flight control software is 

provided at pages 35 through 39 of the DJI Phantom 3 

Advanced/Professional User Manual. DJI Phantom 3

Advanced/Professional User Manual is attached hereto as Exhibit B.

b. Flight Operations Of DJI Phantom 3 Advanced/Professional UASs Are 

Limited To The Line Of Sight Of A Pilot in Command With A Safety 

Observer.

Jason Dennis Damman will only utilize pilots who have at least 25 hours flight 

time to act as a pilot in command (PIC) of the DJI Phantom 3 

Advanced/Professional UASs. Additionally, a safety observer will assist all pilots 

during flight time.

c. Flights Of DJI Phantom 3 Advanced/Professional UASs Will Be 

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, Jason Dennis Damman proposes to commercially

operate DJI Phantom 3 Advanced/Professional 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 3 

Advanced/Professional 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 30 knots.

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

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

operating documents unless a special request is made and approved by 

ATC. All altitudes reported to ATC must be in feet AGL.

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.
16

6. The use of first person view (FPV) by the PIC or safety observer (SO) is 

not permitted.

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

to satisfy the VLOS requirement as long as the PIC always maintains 

VLOS capability. The SO and PIC must be able to communicate verbally

at all times. Electronic messaging or texting is not permitted during flight 

operations. The PIC must be designated before the flight and cannot 

transfer his or her designation for the duration of the flight. The PIC must 

ensure that the SO can perform the functions prescribed in the operating 

documents.

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

with seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other 

instruments.

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

during UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the grant 

of exemption take precedence and must be followed. Otherwise, the 

operator must follow the procedures as outlined in its operating documents. 

The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must 

also present updated and revised documents if it petitions for

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

determines that any update or revision would affect the basis upon which 

the FAA granted the exemption, then the operator must petition for 

amendment to its grant of exemption. The FAA’s UAS Integration Office 

(AFS-80) may be contacted if questions arise regarding updates or 

revisions to the operating documents.

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

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

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

until the necessary maintenance has been performed and the UAS is found 

to be in a condition for safe flight. The Ground Control Station must be 

included in the preflight inspection. All maintenance and alterations must 

be properly documented in the aircraft records.
17

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 have completed at least 25 hours of flight time.

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

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

operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a 

manner consistent with 14 C.F.R. § 61.51(b). 

Flights for the purposes of training the operator’s PICs are permitted under 

the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, 

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

operations are considered nonparticipants, and the PIC must operate the 

UA with appropriate distance from nonparticipants in accordance with 14 

C.F.R. §91.119.
18

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 2 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’ 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 400 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.
19

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

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government

oversight agency requirements.

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

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

the UAS is operating. These documents must be made available to the

Administrator or any law enforcement official upon request.

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

aviation operations and activities at all times.

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

vehicle.

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

nonparticipating persons (persons other than the PIC, SO, operator 

trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect 

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

an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

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

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

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

has granted permission and the PIC has made a safety assessment 

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

it does not present an undue hazard, and;

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

persons do not present an undue hazard to those persons per 

§91.119(a).

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

property with permission from the land owner/controller or authorized 

representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.
20

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 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, Jason Dennis Damman will ensure that the DJI Phantom 3

Advanced/Professional 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).

3. 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 3 Advanced/Professional 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 Jason Dennis Damman's operation 

of the DJI Phantom 3 Advanced/Professional UAs within visual line of sight, at or below 

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

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

each flight, a zero altitude initiation point is automatically established by the 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).

4. 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 3 Professional UASs; (2) the limitations on the proposed flight operations; and

(3) the location of the proposed flight operations. Accordingly, Jason Dennis Damman

will ensure that it will safely operate the battery powered DJI Phantom 3 

Advanced/Professional 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.
21

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3

Advanced/Professional 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 

3 Advanced/Professional 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 3 

Advanced/Professional 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).

5. 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, Jason Dennis Damman 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 Jason Dennis Damman 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 3 Advanced/Professional Instruction Manual). Furthermore, Jason Dennis 

Damman will document and maintain all maintenance records for the DJI Phantom 3 

Advanced/Professional UASs.

Since the DJI Phantom 3 Advanced/Professional UASs will be inspected as prescribed by 

the operating documents, Jason Dennis Damman 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 3 Advanced/Professional User Manual is attached hereto as Exhibit B; a 

copy of the DJI Phantom 3 Advanced/Professional UAS Maintenance LOG is attached 

hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety 

because Jason Dennis Damman 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 3 Advanced/Professional UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the monthly maintenance log.
22

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 Jason Dennis Damman's proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 3 

Advanced/Professional UASs, Jason Dennis Damman 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).

6. 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, Jason Dennis Damman

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

Phantom 3 Advanced/Professional 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 3 Advanced/Professional 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:

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.)
23

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA

may prescribe special conditions for Jason Dennis Damman’s intended operation of the 

DJI Phantom 3 Advanced/Professional 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 Jason Dennis Damman Seeks Exemption:

Jason Dennis Damman 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 Jason Dennis Damman

Seeks:

This exemption will permit Jason Dennis Damman 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

Jason Dennis Damman's Request.

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

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

certain UAS may operate safely in the NAS. As such, Jason Dennis Damman's request 

for exemption may be granted pursuant to the authority of FMRA Section 333 and 14 

C.F.R. Part 11, as set forth above. FMRA Section 333 sets forth the requirements for 

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

otherwise pose a threat to national security; and further, provides the authority for such 

UAS to operate without airworthiness certification. As discussed in detail above, Jason 

Dennis Damman will operate the DJI Phantom 3 Advanced/Professional 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.
24

CONCLUSION

As set forth herein, Jason Dennis Damman 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 3 Advanced/Professional

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 Jason Dennis Damman to safely, efficiently, and

economically operate the DJI Phantom 3 Advanced/Professional UASs commercially

within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Jason Dennis Damman 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 Jason Dennis Damman to operate 

the DJI Phantom 3 Advanced/Professional UASs commercially for the purpose of 

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

Dated: August 18, 2015

Respectfully submitted,

Jason Dennis Damman
25

Jason Dennis Damman

713 Wedgewood Dr.

Avon Lake, OH 44012

(419) 699-6010

Email: jddamman@gmail.com

Appendices:

A – DJI Phantom 3 Advanced/Professional Specifications Data Sheet

B – DJI Phantom 3 Advanced/Professional Manufacturer’s User Manual

C – Monthly Maintenance Log
26

APPENDIX – A

DJI Phantom 3 Advanced/Professional TECHNICAL SPECIFICATIONS

Jason Dennis Damman 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 realtime altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices)

1.1 DJI Phantom 3 Advanced/Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 4480mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 12oz 1280g

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: 0.1m; Horizontal: 1m

1.1.1.4 Max Flight time - Approximately 23 minutes

1.1.1.5 Max Tilt Angel - 35

1.1.1.6 Max Ascent Speed – 5m/s

1.1.1.7 Max Descent Speed – 3m/s

1.1.1.8 Max Flight Speed – 16m/s (NOT RECOMMENDED)

1.1.1.9 Operating Temperature - 0oC - 40oC

1.1.1.10 Max Flight Altitude - 6000m

1.1.1.11 GPS Mode - GPS/GLONASS

1.1.2 Gimbal

1.1.2.1 Controllable Range – Pitch: -90 +30

1.1.3 Camera

1.1.3.1 Sensor - Sony EXMOR 1/2.3"

1.1.3.2 Lens - FOV 94o 20mm (35mm format equivalent) f/2.8

1.1.3.3 Effective Pixels – 12.4M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 4K, 1080p & 720p

4.1.3.6 Image Max Size - 4000 x 3000

1.1.4 Remote Controller

1.1.4.1 Operating Frequency – 2.400GHz – 2.483GHz

1.1.4.2 Communication Distance (unobstructed) - 2000m

1.1.4.3 Battery - 6000 mAh LiPo 2s

1.1.4.4 Transmitter Power – FCC: 20dbm CE: 16 dbm

1.1.4.5 Working Voltage – 1.2 A @7.4 V
27

APPENDIX – B

The DJI Phantom 3 Advanced/Professional Manufacturer’s User Manual

can be found at:

http://www.dji.com/product/phantom-3/download
28

APPENDIX – C

MONTHLY MAINTENANCE LOG

Month:_________ Year:_________

Date Discovered Date Corrected Discrepancy Mx Action Performed

Software Update

Airframe

Propellors

Camera/Gimbal

Landing Gear

Other