February 2, 2016

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: TWO DOOR PRODUCTIONS, LLC

REQUEST AN EXEMPTION 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 3 & DJI INSPIRE PRO UNMANNED AIRCRAFT SYSTEMS PURSUANT 

TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Diego Torroija

President

TWO DOOR PRODUCTIONS, LLC

416 North Harper Avenue

Los Angeles, CA 90048

310-936-6194

diego@twodoorfx.com
TABLE OF CONTENTS

Page

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

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

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

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

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

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

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

PRODUCTIONS, LLC SEEKS EXEMPTION..............................................................7

THE EXTENT OF RELIEF TWO DOOR PRODUCTIONS, LLC SEEKS AND THE 

REASON TWO DOOR PRODUCTIONS, LLC SEEKS THE RELIEF....................10

THE REASONS WHY GRANTING TWO DOOR PRODUCTIONS, LLC’S REQUEST 

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

THE REASONS WHY GRANTING THE EXEMPTION TO TWO DOOR 

PRODUCTIONS, LLC WOULD NOT ADVERSELY AFFECT SAFETY..................14

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

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT TWO DOOR PRODUCTIONS, LLC’S REQUEST..................................25

CONCLUSION..........................................................................................25

APPENDICES......................................................................................... .26
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)

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
SUMMARY

TWO DOOR PRODUCTIONS, LLC hereafter referred to as TWO DOOR seeks 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a),

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

to operate an Unmanned Aircraft System (DJI Phantom 3 & DJI Inspire Pro) pursuant to 

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

will permit TWO DOOR to operate an Unmanned Aircraft System (UAS) for the 

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

residential and commercial real estate, civil landscapes and events over certain areas of 

the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

TWO DOOR has for over eleven years provided their clients (which include

private sector businesses and non-profits, along with local state and federal agencies) 

with expertise and knowledge in the area of commercial and film production, with 

specialities including cinematography and Visual FX. TWO DOOR has worked

on hundreds of productions over the past 11 years in all types of locations with a perfect 

client and employee safety record. In the past we have supplied our clients aerial video 

and photography using commercial aircraft. The objective of TWO DOOR and our 

Unmanned Aircraft System (DJI Phantom 3 & DJI Inspire Pro) aerial operations is to 

provide a more affordable, high-quality production system for a variety of governmental, 

commercial, public, and residential uses, specifically targeting

• Construction sites before and after

• Real-estate marketing

• Economic development

• Civic landmarks

• Special event coverage

• Commercial & Film Production

My staff has safely flown small RC electric Quadcopters recreationally for approximately 2 

years without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 & DJI Inspire Pro, UAS

TWO DOOR seeks an exemption to operate DJI Phantom 3 & DJI Inspire Pro systems 

for compensation or hire within the NAS. The DJI Phantom 3 & DJI Inspire Pro 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 has a maximum gross weight of approximately 2.8 lb. while having 

a diagonal dimension of 23.2”, a maximum speed of approximately 16.4 m/s and a 

maximum flying height of 400'. The DJI Phantom 3 is equipped

with four main rotors; driven by Lithium Polymer battery powered electric motors.
The DJI Inspire Pro has a maximum gross weight of approximately 6.33 lb. while having 

a diagonal dimension of 22.01”, a maximum speed of approximately 18 m/s and a 

maximum flying height of 15K’. The DJI Inspire Pro is equipped

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

The DJI Phantom 3 & DJI Inspire Pro that will be operated by TWO DOOR 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, TWO DOOR, 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 & DJI Inspire 

Pro, 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, TWO DOOR’S operation of DJI Phantom 3 & 

DJI Inspire Pro 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, TWO DOOR 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.

TWO DOOR submits that the requested relief is proper since an equivalent

level of safety will be ensured. TWO DOOR 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 3 & DJI Inspire Pro Instruction 

Manual). 

Furthermore, TWO DOOR will document and maintain all maintenance records for the 

DJI Phantom 3 & DJI Inspire Pro UAS. Relief from certain requirements of Section 

61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is 

requested by TWO DOOR to the extent necessary to allow a Pilot in Command (PIC) 

holding a recreational pilot or sport license and who has demonstrated, by meeting 

minimum flight hour and currency requirements, that the PIC is able to safely operate 

the DJI Phantom 3 & DJI Inspire Pro UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.
TWO DOOR seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3 & DJI Inspire Pro UAS do not require an airworthiness 

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

submits that they will ensure that the DJI Phantom 3 & DJI Inspire Pro UAS is 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 3 & DJI 

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

TWO DOOR also seeks an exemption from the requirements of Section 91.121,

entitled Altimeter Settings, as the DJI Phantom 3 & DJI Inspire Pro UAS will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Phantom 

3 & DJI Inspire Pro 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 TWO DOOR’s operation of the DJI Phantom 3 UAS within visual line of 

sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

Additionally, TWO DOOR seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. TWO DOOR submits 

that safety will not be affected by operation of the DJI Phantom 3 & DJI Inspire Pro 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 23 minutes. 

Battery power indicators are also able to show exactly how much battery power is left, 

as well as how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, TWO DOOR 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:

Diego Torroija

President

TWO DOOR PRODUCTIONS, LLC

416 North Harper Avenue

Los Angeles, CA 90048

310-936-6194

diego@twodoorfx.com
B. The Specific Sections Of 14 C.F.R. from which TWO DOOR seeks

Exemption.

1. TWO DOOR 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.

2. TWO DOOR seeks Exemption From The Requirements Of Section 91.7(a).

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

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

3. TWO DOOR seeks Exemption From The Requirements Of Section

91.121.

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

part:

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

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

when operating--

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

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

within 100 nautical miles of the aircraft;

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

this section, the current reported altimeter setting of an appropriate available

station; or

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

departure airport or an appropriate altimeter setting available before departure.
4. TWO DOOR 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.

5. TWO DOOR seeks Exemption From The Requirement Of Section

91.405(a).

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

following: Each owner or operator of an aircraft—

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

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

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

6. TWO DOOR seeks Exemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

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

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

preventive maintenance, rebuilding, or alteration unless--

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

of this chapter[.]

7. TWO DOOR seeks Exemption From The Requirements Of Sections

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

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

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

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

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

approved for return to service by a person authorized by § 43.7 of this chapter; or
(2) An inspection for the issuance of an airworthiness certificate in accordance

with part 21 of this chapter.

8. TWO DOOR 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 or 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.

C. The Extent Of Relief TWO DOOR seeks And The Reason TWO DOOR Seeks The 

Relief.

1. Extent Of Relief TWO DOOR Seeks And The Reason TWO DOOR Seeks Relief 

From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Recreational/Sport pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a recreational/sport pilot license, 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 recreational/sport 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, TWO DOOR submits that an equivalent level of

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 

& DJI Inspire Pro 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 3 & DJI Inspire Pro 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, TWO DOOR submits that all flights of the DJI Phantom 3 & DJI Inspire Pro 

UAS, conducted by the PIC pursuant to the grant of this Petition: 

(1) will be incidental to TWO DOOR’S business; and 

(2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief TWO DOOR Seeks And The Reason TWO DOOR 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 TWO DOOR to determine that the DJI Phantom 3 & DJI Inspire Pro 

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

compliance with the operating documents (i.e., TWO DOOR Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 & DJI Inspire Pro Instruction Manual).

TWO DOOR seeks the requested relief because the DJI Phantom 3 & DJI Inspire Pro 

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

Subpart H. Therefore, TWO DOOR will ensure that the DJI Phantom 3 & DJI Inspire Pro 

UAS are in airworthy condition based upon its compliance with the operating documents 

(i.e., Monthly Maintenance Log, and DJI Phantom 3 & DJI Inspire Pro) prior to every 

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

the conditions and limitations below.

3. Extent Of Relief TWO DOOR Seeks And The Reason TWO DOOR 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 3 & DJI Inspire Pro 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), TWO DOOR 

seeks the requested relief because the DJI Phantom 3 & DJI Inspire Pro 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 3 UAS are equipped 

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

that a ground level pressure setting will be established prior to each flight, and provides 

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

4. Extent Of Relief TWO DOOR Seeks And The Reason The TWO DOOR 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 & 

DJI Inspire Pro UAS during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 23 minutes. TWO DOOR seeks the 

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

duration of the 12 battery powered DJI Phantom 3 & DJI Inspire Pro UAS will severely 

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

DOOR proposes to conduct pursuant to this Petition.

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

Inspire Pro UAS, the DJI Phantom 3 operating documents, and TWO DOOR’s proposed 

operating limitations, ensure that TWO DOOR will safely operate the battery powered

DJI Phantom 3 & DJI Inspire Pro 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 23 minutes.

5. Extent Of Relief TWO DOOR Seeks And The Reason TWO DOOR 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, TWO DOOR requests relief from

these Sections because the DJI Phantom 3 & DJI Inspire Pro UAS do not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 & DJI Inspire 

Pro UAS meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, TWO DOOR 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 TWO DOOR Aerial Operations Manual, Monthly Maintenance Log,

and DJI Phantom 3 & DJI Inspire Pro Instruction Manual). 

Furthermore, TWO DOOR will document and maintain all maintenance records for the 

DJI Phantom 3 & DJI Inspire Pro UAS.

D. The Reasons Why Granting TWO DOOR 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 TWO DOOR to 

safely, efficiently, and economically perform aerial video and photography of

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

United States.

Additionally, use of the DJI Phantom 3 & DJI Inspire Pro UAS will decrease congestion 

of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, 

the benefits of TWO DOOR’S proposed operation of the DJI Phantom 3 & DJI Inspire 

Pro UAS will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.
The DJI Phantom 3 & DJI Inspire Pro 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 & DJI Inspire Pro 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 & DJI Inspire Pro 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 & DJI 

Inspire Pro UAS. Conducting aerial acquisitions with the DJI Phantom 3 & DJI Inspire 

Pro 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 3 & DJI Inspire Pro 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 3 & DJI Inspire Pro 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 & DJI Inspire Pro UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially 

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

onboard the aircraft, the DJI Phantom 3 & DJI Inspire Pro UAS (weighing approximately 

2.8/7.7 pounds at their maximum gross weight with diagonal dimension of 23.2/22.01 

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

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

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

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons).

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

Inspire Pro UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 & DJI Inspire Pro UAS are 

also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 & DJI Inspire Pro UAS will allow 
United States based companies, like TWO DOOR, 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 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 3 & DJI Inspire Pro UAS, companies such as TWO 

DOOR, 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 & DJI Inspire Pro UAS, provides a stable workforce that 

increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain competitive 

both in the United States and abroad.

4. There Are No Privacy Issues.

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

decades, TWO DOOR’s proposed operation of the DJI Phantom 3 & DJI Inspire Pro 

UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 & DJI Inspire 

Pro UAS will be operated only in compliance with operating documents (i.e., TWO 

DOOR Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 & DJI 

Inspire Pro Instruction Manual) which requires property owner involvement as well as 

local law enforcement notification, and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

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

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

By The Rule From Which TWO DOOR Seeks Exemption.

1. Reasons Why The DJI Phantom 3 & DJI Inspire Pro 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, TWO DOOR’s operation of the DJI

Phantom 3 UAS meet the conditions of FMRA Section 333, and will not require an 

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

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

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

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

FMRA Section 333 states the following, in part:

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

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

shall determine if certain unmanned aircraft systems may operate safely in the
national airspace system before completion of the plan and rulemaking required by

section 332 of this Act or the guidance required by section 334 of this Act.

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

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

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

weight, speed, operational capability, proximity to airports and populated areas, and 

operation within visual line of sight do not create a hazard to users of the national 

airspace system or the public or pose a threat to national security; and

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

certification under section 44704 of title 49, United States Code, is required for the 

operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--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, TWO DOOR submits that the DJI Phantom 3 & DJI Inspire 

Pro UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 & DJI Inspire Pro UAS; 

(b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 & DJI Inspire Pro UAS Demonstrate 

Its Safe Characteristics.The DJI Phantom 3 & DJI Inspire Pro 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 3 & DJI Inspire Pro UAS.

The technical specifications of the DJI Phantom 3 & DJI Inspire Pro UAS 

are set forth by the DJI Phantom 3 & DJI Inspire Pro User Manual, 

attached hereto as Appendix A.

ii. The DJI Phantom 3 & DJI Inspire Pro UAS Global Positioning Modes 

Enable The UAS To Remain Within A Defined Operational Area. The DJI 

Phantom 3 & DJI Inspire Pro UAS may be operated in both manual and 

global positioning flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 3 & DJI Inspire Pro UAS is 

provided at pages 11 of the DJI Phantom 3 & DJI Inspire Pro User Manual 

attached hereto as Appendix A.

iii. The DJI Phantom 3 & DJI Inspire Pro 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 3 & DJI 

Inspire Pro UAS will remain stationary, in flight, for 3 seconds or more. If, 

after 3 seconds, the DJI Phantom 3 & DJI Inspire Pro UAS does not 
reacquire control link data from the GCS, the UAS will assume that the 

Control Link is lost and the 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 & 

DJI Inspire Pro UAS are set forth at pages 12 through 14 of the DJI 

Phantom 3 & DJI Inspire Pro User Manual, attached hereto as AppendixA.

iv. The DJI Phantom 3 & DJI Inspire Pro GCS And Its Operation. A 

complete description of the operation and specifications of the DJI 

Phantom 3 & DJI Inspire Pro GCS and flight control software is provided 

at pages 23 through 29 of the DJI Phantom 3 & DJI Inspire Pro User 

Manual. DJI Phantom 3 User Manual is attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 & DJI Inspire Pro UAS Is Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer.

TWO DOOR’s video production staff will be the only persons to act as a pilot in 

command (PIC) of the DJI Phantom 3 & DJI Inspire Pro UAS. Additionally, a safety 

observer will assist him at all times during flight time.

c. Flights Of DJI Phantom 3 & DJI Inspire Pro UAS Will Be Conducted Pursuant To 

Specific Operating Limitations.

In seeking this exemption, TWO DOOR proposes to commercially operate DJI

Phantom 3 UAS for the special purpose of conducting aerial video and photography 

over certain areas of United States, pursuant to the following specific operating 

limitations.

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

aircraft described in the operating documents, rotorcraft UAS weighing less than 

55 pounds maximum gross weight: DJI Phantom 3 & DJI Inspire Pro Unmanned 

Aircraft Systems. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

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

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

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

reported to ATC must be in feet AGL.

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

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

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

medical certificate.

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

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

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

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

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

must be designated before the flight and cannot transfer his or her designation 

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

functions prescribed in the operating documents.

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

seeing and avoiding other air traffic and other ground based obstacles 

obstructions and is not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in the grant 

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

conditions and limitations contained in the grant of exemption take precedence 

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

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

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

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

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

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

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

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

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

questions arise regarding updates or revisions to the operating documents.

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

condition or 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.

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 

predetermined location within the planned operating area and land or be r

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 (NNumber) 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).

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

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. 

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b)

Would Not Adversely Affect Safety.

TWO DOOR 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 3 

& DJI Inspire Pro UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 

3 & DJI Inspire Pro UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering TWO DOOR’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 3 & DJI Inspire 

Pro UAS, TWO DOOR submits that the additional manned airmanship experience of a 

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

TWO DOOR’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).

TWO DOOR will not allow any PIC to operate the DJI Phantom 3 & DJI Inspire Pro UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 

DJI Phantom 3 & DJI Inspire Pro UAS training and currency requirements, that the PIC 

is able to safely operate the DJI Phantom 3 & DJI Inspire Pro UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers

and maintaining appropriate distances from people, vessels, vehicles and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 

C.F.R. §61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 

hours of those hours as a UAS pilot operating the same make and model of UAS to be 

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

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

purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that 

was obtained in compliance with applicable regulations will ensure an equivalent level of 

safety during TWO DOOR’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. Exemption No. 11138 at page 15.

Accordingly, TWO DOOR will ensure safe operations by not allowing any PIC

to operate the DJI Phantom 3 & DJI Inspire Pro 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 3 & DJI Inspire Pro UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety.

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

prior to every flight, TWO DOOR will ensure that the DJI Phantom 3 & DJI Inspire Pro 
UAS is in an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein.

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

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

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

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not

Adversely Affect Safety.

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

the altitude information of the DJI Phantom 3 & DJI Inspire Pro 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 TWO DOOR’s operation of the DJI Phantom 3 

& DJI Inspire Pro 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).

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

Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 

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

Phantom 3 & DJI Inspire Pro UAS; (2) the limitations on the proposed flight operations; 

and (3) the location of the proposed flight

operations. 

Accordingly, TWO DOOR will ensure that it will safely operate the

battery powered DJI Phantom 3 & DJI Inspire Pro UAS during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 23 minutes.

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

DJI Inspire Pro 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 3 & 

DJI Inspire Pro 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 3 & DJI Inspire Pro UAS will 

descend and land automatically. Significantly, previous exemptions granted by the FAA 

concerning Section 91.151 establish that safety is not adversely affected when the 

technical characteristics and operating limitations of the UAS are considered. Relief has 

been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 

10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to 

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

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely

Affect Safety.

In seeking this exemption, TWO DOOR 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 TWO DOOR 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., TWO DOOR Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 & DJI Inspire Pro Instruction Manual). 

Furthermore, TWO DOOR will document and maintain all maintenance records for the 

DJI Phantom 3 & DJI Inspire Pro UAS. Since the DJI Phantom 3 & DJI Inspire Pro UAS 

will be inspected as prescribed by the operating documents, TWO DOOR 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 & DJI Inspire Pro User Manuals are

attached hereto as Appendix A and B; a copy of the DJI Phantom 3 & DJI Inspire Pro 

UAS Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because TWO DOOR 

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 & DJI Inspire Pro 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 TWO DOOR’s proposed operating limitations, the operating

documents, and the technical aspects of the DJI Phantom 3 & DJI Inspire Pro UAS, 

TWO DOOR submits that safety will not be adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) 

and (b). The FAA has previously granted relief specific to UAS in circumstances similar, 

in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160,

11161).

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

with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 

C.F.R. § 21.16 entitled Special Conditions, TWO DOOR requests that the FAA prescribe 

special conditions for the intended operation of the DJI Phantom 3 & DJI Inspire Pro 

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 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 & DJI Inspire Pro 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 

3 & DJI Inspire Pro 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 25 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 Summary That Can Be Published In The Federal Register, stating: The Rules 

From Which TWO DOOR Seeks Exemption:

TWO DOOR 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 TWO DOOR Seeks:

This exemption will permit TWO DOOR 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

TWO DOOR’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, TWO DOOR’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, TWO DOOR will operate the DJI Phantom 3 & DJI Inspire 

Pro 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.

CONCLUSION

As set forth herein, TWO DOOR 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 & DJI Inspire Pro 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 TWO DOOR to safely, efficiently, and economically operate the DJI 

Phantom 3 & DJI Inspire Pro UAS commercially within the NAS.
WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, TWO DOOR respectfully

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

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

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading 

Edge to operate the DJI Phantom 3 & DJI Inspire Pro UAS commercially for the purpose 

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

Dated: February 2, 2016

Respectfully submitted,

Diego Torroija

President

TWO DOOR PRODUCTIONS, LLC

416 North Harper Avenue

Los Angeles, CA 90048

310-936-6194

diego@twodoorfx.com

Appendices:

A – Link to DJI Phantom 3 & DJI Inspire Pro Manual: Click on link below

http://download.djiinnovations.

com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2_en.pdf

B - Link to DJI Inspire Pro

http://dl.djicdn.com/downloads/inspire_1_pro/en/

Inspire_1_Pro_User_Manual_en_v1.0_1201.pdf