UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERALAVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

VERSION 1.1

Updated January 19, 2016

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Christopher L Parrish 3331167 ATP CFI CFII

Droneography360 LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 61.113(a) & (b), 91.7(a), 91.119, 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 PROFESSIONAL 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submi&ed on Sept	1, 2015

Christopher	L	Parrish	ATP	CFI	CFII

Droneography360	LLC

6776	S.	Ivy	St.	#A3

Centennial	CO,	80112

Tel:	(303)	521-3611

Email:		Chris@Droneography360.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 7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Droneography360 LLC

SEEKS EXEMPTION 8

THE EXTENT OF RELIEF Droneography360 LLC SEEKS AND THE REASON

Droneography360 LLC SEEKS THE RELIEF 11

THE REASONS WHY GRANTING Droneography360 LLC’S REQUEST WOULD BE 

IN THE PUBLIC INTEREST 15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY

AFFECT SAFETY 19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO

SUPPORT Droneography360 LLC’S REQUEST 34

CONCLUSION 35 

APPENDICES 37
GLOSSARY OFABBREVIATIONS

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 UnmannedAircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
SUMMARY

Christopher L. Parrish ATP, CFI CFII 3331167, seeks exemption from the

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.119, 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 Droneography360 LLC to

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

aerial video and photography of construction sites, real estate, special events, film sets, 

farm & agriculture, insurance and natural disaster surveys as well as landscape over the

United States its territories and possessions.
INTRODUCTION AND INTERESTS OF THE PETITIONER

Droneography360 LLC seeks to provide its clients with the highest quality digital

content for use in their commercial, personal, and non-profit multimedia projects.

Christopher Parrish ATP, CFII, CFI has over 5 years aircraft based aerial photography 

experience, in all aspects of aerial video and aerial photography. The objective of

Droneography360 LLC, is to provide high quality imaging that includes both digital 

photography and filming for a variety of commercial, public, and residential uses,

specifically targeting:

¥ Special event’s

¥ Safety inspections

¥ Land and property surveying and scouting

¥ Real Estate appraisal and advertisement

¥ Commercial Real Estate appraisal and advertisement 

¥ Ongoing construction progress surveys

¥ Farm & Agriculture survey

¥ Natural disaster surveys

¥ Insurance claim surveys

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS

Droneography360 LLC seeks an exemption to operate the DJI Phantom 3 

Professional UAS for compensation or hire within the NAS. The DJI Phantom 3 

Professional is a 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 Professional has a maximum gross weight of approximately 2.82 lbs.,

while having a length of 19 1/4 inches width of 19 1/4 inches, height of 8 inches, and a

maximum speed of approximately 40 knots. The DJI Phantom 3 Professional UA is

equipped with four main rotors; driven by Lithium Polymer (LiPo 4S) battery powered

electric motors.

The DJI Phantom 3 Professional UA that will be operated by Droneography360 

LLC and 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, Droneography360 LLC, pursuant to the provisions of the Federal

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of

2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems,

hereby petitions the Administrator to commercially operate the DJI Phantom 3 

Professional 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, Droneography360 LLC operation of DJI 

Phantom 3 Professional 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, Droneography360 LLC requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth 
requirements for maintenance that only apply to aircraft with an airworthiness

certificate.

Droneography360 LLC submits that the requested relief is proper since an

equivalent level of safety will be ensured. Droneography360 LLC 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., Maintenance Log, and DJI Phantom 3 Professional Instruction Manual).

Furthermore, Droneography360 LLC will document and maintain all maintenance

records for the DJI Phantom 3 Professional UAS.

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

pilot privileges and limitations: Pilot in command, is requested by Droneography360 

LLC to the extent necessary to allow a Pilot in Command (PIC), holding a pilot’s license 

that would usually require a Commercial pilots license or better to operate for hire. Any 

pilot flying for Droneography360 LLC and acting as PIC of the UAS is able to safely

operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

Droneography360 LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Professional UAS do not require an

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

Droneography360 LLC submits that it will ensure that the DJI Phantom 3 Professional 

UAS is in an airworthy condition, prior to every flight, by determining that the UASs are

in compliance with the operating documents (i.e., Maintenance Log, and DJI Phantom 3 

Professional Instruction Manual), and that the UAS aircraft are in a condition that 
permits for safe flight.

Droneography360 LLC also seeks an exemption from the requirements of

Section 91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UA will

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

DJI Phantom 3 Professional UA 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 and altitude.

This altitude information combined with Droneography360 LLC’s operation of the DJI 

Phantom 3 Professional UAS within visual line of sight or an observer in constant 

contact with the PIC, at or below 200 feet AGL, will ensure a level of safety equivalent

to Section 91.121.

Additionally, Droneography360 LLC seeks an exemption from the requirements

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

Droneography360 LLC submits that safety will not be affected by operation of the DJI 

Phantom 3 Professional UA 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 18 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 5 minutes.

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

Christopher L Parrish 

3331167 ATP CFI CFII
Droneography360 

LLC

6776 S. Ivy St. # A3

Centennial CO, 80112

Tel: (303) 521-3611

Email:Chris@Droneography360.com

B. The Specific Sections Of 14 C.F.R. From Which Droneography360 LLC

Seeks Exemption.

1. Droneography360 LLC Seeks Exemption from The Requirements of

Section 61.113(a) And (b).

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

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

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

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

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

aircraft.

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

in connection with any business or employment if—

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

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

2. Droneography360 LLC Seeks Exemption From The Requirements Of

Section 91.7(a).

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

the following:

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

3. Droneography360 LLC Seeks Exemption From the Requirements of 

Section 91.119.

Sec. 91.119 — Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft 

below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface.
(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 1,000 

feet above the highest obstacle within a horizontal radius of 2,000 feet of the 

aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the 

surface, except over open water or sparsely populated areas. In those cases, 

the aircraft may not be operated closer than 500 feet to any person, vessel, 

vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If 

the operation is conducted without hazard to persons or property on the 

surface—

(1) A helicopter may be operated at less than the minimums prescribed in 

paragraph (b) or (c) of this section, provided each person operating the 

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less 

than the minimums prescribed in paragraph (c) of this section.

4. Droneography360 LLC 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) 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) the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure.

5. Droneography360 LLC 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.

6. Droneography360 LLC Seeks Exemption from The Requirement of

Section 91.405(a).

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

Each owner or operator of an aircraft—

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

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

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

7. Droneography360 LLC Seeks Exemption from The Requirements of

Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive

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

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

preventive maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter[.]

8. Droneography360 LLC Seeks Exemption from The Requirements of

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

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

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

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

(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.
9. Droneography360 LLC Seeks Exemption from The Requirements of

Sections 91.417(a) And 91.417(b).

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

following:

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

registered owner or operator shall keep the following records for the

periods specified in paragraph (b) of this section:

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

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

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

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

The records must include--

(i) 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.

C. The Extent of Relief; Droneography360 LLC Reasons for The Relief.

1. Extent of Relief; Droneography360 LLC Seeks Relief from Section

61.113(a) And (b).

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

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

an appropriate pilots license which includes any of the following: Sport Pilot, 

Recreational Pilot or Private Pilot or any license able to conduct commercial operations 

such as Commercial Pilot or ATP, to conduct the proposed UAS flight operations for

compensation or hire.

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

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

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

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

compensation or hire.

As set forth more fully below, Droneography360 LLC submits that an equivalent 

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

Phantom 3 Professional UAS UA 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 Professional 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, Droneography360 LLC submits that all flights of the DJI Phantom 3 

Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to Droneography360 LLC business; and (2) will not carry passengers or

property for compensation or hire.

2. Extent of Relief; Droneography360 LLC Seeks Relief from Section

91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the 

extent required to allow Droneography360 LLC to determine that the DJI Phantom 3 

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

UAS is in compliance with the operating documents (i.e., the Droneography360 LLC

Aerial Operations Manual, Maintenance Log, and DJI Phantom 3 Professional Instruction

Manual).

Droneography360 LLC seeks the requested relief because the DJI Phantom 3 

Professional UAS do not require an airworthiness certificate in accordance with 14

C.F.R. Part 21, Subpart H. Therefore, Droneography360 LLC will ensure that the DJI 

Phantom 3 Professional UAS are in airworthy condition based upon its compliance with

the operating documents (i.e., Maintenance Log, and DJI Phantom 3 Professional 

Instruction Manual) prior to every flight, and further, determine that the aircraft is in

condition for a safe flight, as stated in the conditions and limitations below.
3. Extent of Relief; Droneography360 LLC Seeks relief from Section 

91.119. 

Relief from Section 91.119, entitled Minimum Safe Altitudes: General, will be 

required in order to capture high quality digital images below 1,000 feet in congested 

areas and 500 feet in other than congested areas. Due to the nature of the operations the 

light weight nature of the DJI Phantom 3 Professional, and the low risk for damage or 

injury to persons, vessels, vehicles or structures in private or public areas and 

considering the low potential for personal injury to the general public, workers and 

bystanders as well as damage to property, Droneography360 LLC seeks relief of 91.119 

to the extent necessary to complete the operations while utilizing the PIC to exercise 

good judgment in determining that the UAS does not pose an undue risk to those in close 

proximity to the operations of the UAS. 

Furthermore, Droneography360 LLC will have adequate warning signs placed in 

and around the area of operations to alert the general public, workers and bystanders of 

the operations being conducted. It is Droneography360 LLC’s belief that information and 

public awareness and dialog will contribute to public safety and understanding.

4. Extent of Relief; Droneography360 LLC Seeks Relief from Section

91.121.

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

flight operations of the DJI Phantom 3 Professional 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),
Droneography360 LLC seeks the requested relief because the DJI Phantom 3 

Professional 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 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.

5. Extent of Relief; Droneography360 LLC Seeks Relief from Section

91.151(b).

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

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

Phantom 3 Professional UAs during daylight hours in visual meteorological conditions

(VMC), under visual flight rules (VFR), for a total duration of 18 minutes to the first

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

least 5 minutes. Droneography360 LLC 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 UA will severely constrain the practicality of any aerial video or

still photo flight operations that Droneography proposes to conduct pursuant to this

Petition.

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

3 Professional UAS, the DJI Phantom 3 Professional operating documents, and
Droneography360 LLC’s proposed operating limitations, ensure that Droneography360 

LLC will safely operate the battery powered DJI Phantom 3 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 18 minutes to the first

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

least 5 minutes.

6. Extent of Relief; Droneography360 LLC Seeks Relief from Sections

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

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

(b) only apply to aircraft with an airworthiness certificate, Droneography360 LLC

requests relief from these Sections because the DJI Phantom 3 Professional UAS does

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

Professional UAS meets the conditions of FMRA Section 333 for operation without an

airworthiness certificate. Accordingly, Droneography360 LLC 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 Maintenance Log, and DJI Phantom 3 Professional Instruction Manual).

Furthermore, Droneography will document and maintain all maintenance records for the

DJI Phantom 3 Professional UAS.

D. The Reasons Why Granting Droneography360 LLC Request Would Be in

The Public Interest;

Granting the present Petition will further the public interest by allowing

Droneography360 LLC to safely, efficiently, and economically perform aerial video and
photography of special events, film sets, real estate, safety inspections, farm & agriculture 

survey, insurance surveys, natural disaster surveys and landscape photography over the

United States its territories and possessions.

Additionally, use of the DJI Phantom 3 Professional UAS will decrease

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

economy by expanding who can take advantage of lower cost aerial filming & 

photography. 

The Public Will Benefit from Decreased Congestion of The NAS.

The DJI Phantom 3 Professional UA 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 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 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.

1. The Public Will Benefit from The Safety and Efficiency of The DJI 

Phantom 3 Professional UAS.

Conducting aerial photography and surveying with the DJI Phantom 3 

Professional UAS, instead of manned aircraft, will benefit the public by 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 Professional UAS produce no air pollution. The DJI Phantom 3 Professional 

UA, while reducing the carbon footprint of aerial film & photography acquisitions, also

reduce noise.

By using the DJI Phantom 3 Professional UAS to perform aerial film & 

photography acquisitions, the risk to life and property in the air and on the ground can be 

further mitigated. Aside from the lack of flight crew members located onboard the 

aircraft, the DJI Phantom 3 Professional UAS, 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.

2. Performing Aerial Video and Photography Operations with The

DJI Phantom 3 Professional UAS Will Benefit the Economy.

In addition to being safe and efficient, the DJI Phantom 3 Professional is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Phantom 3 Professional UAS will allow United States based 

companies, like Droneography360 LLC, to remain competitive and contribute to the 

growth of the U.S. economy. Operating the battery powered DJI Phantom 3 Professional 

UAS allows companies greater operational flexibility in conjunction with traditional

manned aircraft.

3. There Are No Privacy Issues.

Similar to the manned aerial acquisition photography flight operations that have

been conducted for decades, Droneography360 LLC proposed operation of the DJI 
Phantom 3 Professional UAS would not create any privacy issues. Specifically, the DJI 

Phantom 3 Professional UAS will be operated only in compliance with operating 

procedures, which would be at the instruction or discretion of property owners, lessee’s or 

their agents. 

4. Reasons Why The DJI Phantom 3 Professional UA 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, Droneography360 LLC operation of the

DJI Phantom 3 Professional 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, Droneography360 LLC submits that the DJI 

Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA

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

Professional UAS; (b) the pilot certification requirement; and (c) the specific

operating limitations.

a. The Specifications of The DJI Phantom 3 Professional UAS

Demonstrate Its Safe Characteristics.

The DJI Phantom 3 Professional UAS does 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 Professional UAS.

The technical specifications of the DJI Phantom 3 Professional UAS is set forth

by the DJI Phantom 3 Professional Specifications and Data Sheet, attached hereto as

Exhibit A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight And

Navigation Modes Enable The UAS To Remain Within A

Defined Operational Area.

The DJI Phantom 3 Professional UAS may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and navigational modes of 

the DJI Phantom 3 Professional UAS is provided in the DJI Phantom 3 Professional User

Manual, attached hereto as Exhibit B.

iii. e DJI Phantom 3 Professional 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 Professional UA will remain 
stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 

Professional UA does not reacquire control link data from the GCS, the UA will assume

that the Control Link is lost and the UA 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 Professional UAS are set

forth at pages 12 through 14 of the DJI Phantom 3 Professional User Manual, attached

hereto as B.

iv. The DJI Phantom 3 Professional GCS and Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 

Professional GCS and flight control software is provided at pages 22 through 29 of the

DJI Phantom 3 Professional User Manual. DJI Phantom 3 Professional User Manual is

attached hereto as Exhibit B.

b. Flight Operations of DJI Phantom 3 Professional UAS Are Limited to

The Line Of Sight Of A Certificated Pilot in Command Or With A

Safety Observer As Necessary.

Where the UAS will not be out of the direct line of sight of the PIC a safety 

observer would be optional. However, a safety observer will be utilized to assist the 

PIC during flight operations that the UAS potentially or will be out of site of the 

operator.

c. Flights of DJI Phantom 3 Professional UAS Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, proposes to commercially operate DJI Phantom 3 

Professional UAS for the special purpose of conducting aerial digital video and

photography over the United States its Territories and Possessions, 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 
Professional Unmanned Aircraft System. 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 100 MPH.

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.

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

is not permitted.

7. When operations are conducted out of view of the PIC, all operations must

utilize a safety observer (SO). The SO may be used to satisfy the VLOS

requirement as long as the PIC or SO maintains VLOS capability. The SO and

PIC must be able to communicate verbally at all times via phone or handheld 

radio’s. 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 with an emphasis on safety for persons and property 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 upon request. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and

the procedures outlined in the operating documents, the conditions and

limitations contained in the grant of exemption take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating

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

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

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

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

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

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

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

questions arise regarding updates or revisions to the operating documents.
10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a 

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

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

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

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

functional test flight must make an entry in the aircraft records.

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

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents.

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

maintenance, overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service.

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

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the 

corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess an appropriate pilots license as deemed by the FAA. 

(Sport Pilot, Recreational Pilot, Private Pilot, Commercial Pilot or ATP)

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 (Official sunset to sunrise),

as defined in 14 C.F.R. unless a special request is made and approved by the 

FAA. §

19.1. All operations must be conducted under visual meteorological conditions 

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

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

flight rules (SVFR) are not authorized.

20. The UAS may not be operated less than than 3 statute miles visibility as seen

from the PIC’s location.

21. If the UAS loses communications or loses its GPS signal, it must return to a

pre- determined location within the planned operating area and land or be

recovered in accordance with the operating documents.

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

or emergencies in accordance with the operating documents.

23. 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 at least 15%

battery power remaining.

24. 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.

25. 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.

26. No Operations are allowed in Class A (18,000 feet & above). Operation in 

Class B, C, D and E Airspace are allowed with the permission of the 

controlling ATC Facility. Operations in Class G airspace are allowed 

without ATC permission.

27. At all times the small unmanned aircraft must remain close enough to the 

operator for the operator to be capable of seeing the aircraft with vision 

unaided by any device other than corrective lenses, except when using a 

Visual Observer in constant contact with the PIC.

28. The UAV must remain clear and yield the right of way to all manned

aviation operations and activities at all times.

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

30. Flight operations must not be conducted directly over non-participating 

persons (persons other than the PIC, SO, operator trainees or essential
persons), vessels, vehicles, and structures unless:

a. 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;

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

persons do not present an undue hazard to those persons per §

91.119(a).

31. 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.

Droneography360 LLC submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate

the DJI Phantom 3 Professional 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 Professional UAS in a manner consistent with the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

Considering Droneography360 LLC 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 

Professional UAS, Droneography360 LLC submits that the additional manned

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

airmanship skills necessary for Droneography360 LLC 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).

Droneography360 LLC will not allow any PIC to operate the DJI Phantom 3 

Professional UAS unless that PIC has demonstrated, by meeting minimum flight-hour

requirements or the DJI Phantom 3 Professional UAS training and currency

requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional 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), 10 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).

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 Droneography360 LLC 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 flighthour 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, Droneography360 LLC will ensure safe operations by not allowing

any PIC to operate the DJI Phantom 3 Professional 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 Professional 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, Droneography360 LLC will ensure that the

DJI Phantom 3 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).

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 Professional UA 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 Droneography360 LLC’s operation of the DJI 

Phantom 3 Professional UA 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).

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 Professional UAs; (2) the limitations on the proposed flight operations; and

(3) the location of the proposed flight operations. Accordingly, Droneography360 LLC

will ensure that it will safely operate the battery powered DJI Phantom 3 Professional 
UA during daylight hours in VFR conditions, with enough battery power to fly for a total

duration of 18 minutes to the first point of intended landing and, assuming normal

cruising speed, to fly after that for at least 5 minutes.

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

3 Professional 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 

Professional 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 25%

remaining battery power, and again at approximately 10% remaining battery power. At

the critically low battery level, the DJI Phantom Vision+ 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, Droneography360 LLC submits that the equivalent

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

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

(b) will be met because Droneography360 LLC will use licensed pilots and trained

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

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

the Maintenance Log, and DJI Phantom 3 Professional Instruction Manual). Furthermore,

Droneography360 LLC will document and maintain all maintenance records for the DJI 

Phantom 3 Professional UAS.

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the 

operating documents, Droneography360 LLC 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 Professional User Manuals are attached hereto as Exhibit B.

Likewise, the exemption sought will not adversely affect safety because

Droneography360 LLC will use trained technicians to perform maintenance, alterations

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

prescribed by the operating documents.

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

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

DJI Phantom 3 Professional UAS will be performed by trained technicians. Maintenance

will be documented and maintained utilizing a standard aircraft 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 Droneography360 LLC proposed operating limitations, the 

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

Droneography360 LLC submits that safety will not be adversely affected by granting 

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

91.417(a) and (b). The FAA has previously granted relief specific to UAS in

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 

11138, 11150,

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

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, Droneography360 LLC

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

Phantom 3 Professional UAS, which contain such safety standards that the Administrator

finds necessary 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 the United States its territories and possessions 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 Professional 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 Droneography360 LLC intended operation of

the DJI Phantom 3 Professional UAS, which contain such safety standards that the

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

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121,

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

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

Rules From Which Droneography360 LLC Seeks Exemption:

Droneography360 LLC seeks exemption from the requirements of 14 C.F.R

Sections 61.113(a)&(b), 91.7(a), 91.119, 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 Droneography360 

LLC Seeks:

This exemption will permit Droneography360 LLC to commercially operate an 

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 
photography over the United States its territories and possessions.

F. Any Additional Information, Views, Or Arguments Available to Support

Droneography360 LLC 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, Droneography360 LLC request

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

C.F.R. Part 11, as set forth above.

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

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

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

airworthiness certification.

As discussed in detail above, Droneography360 LLC will operate the DJI 

Phantom 3 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.
CONCLUSION

As set forth herein, Droneography360 LLC seeks an exemption pursuant to 14

C.F.R.§ 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012

(FMRA), which will permit safe operation of the DJI Phantom 3 Professional UAS

commercially, without an airworthiness certificate, for the purpose of conducting aerial

video and photography over the United States its territories and possessions.

Respectfully submitted, 

Christopher L Parrish 

3331167ATP CFI CFII

Christopher L Parrish 

Droneography360 LLC

6776 S. Ivy St. #A3

Centennial, CO 80112

Tel: (303) 521-3611

Email:Chris@Droneography360.com

Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Phantom 3 Professional Manufacturer’s User Manual
APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

Droneography360 LLC 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)

DJI Phantom 2 Vision+

Aircraft

Supported Battery – DJI PH3-4480 mAh-15.2 V (LiPo 4S) Battery

Weight (Battery & Propellers Included) – 2.822lbs (1280g)

Max Ascent Speed – 5m/s

Max Descent Speed – 3m/s

Max Flight Speed – 16m/s (No Wind)

Transmitter

Operating Frequency – 2.400GHz – 2.483GHz

Transmitting Distance – 1.25 Miles (Outdoor and unobstructed)
APPENDIX – B

DJI Phantom 3 Professional Manufacturer’s User Manual