seeks Exemption 2

TABLE OF CONTENTS

Page 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER............................................................ 7

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

SEEKS EXEMPTION. ............................................................................................. 8

THE EXTENT OF RELIEF UASERVICES SEEKS ANDTHE REASON 

UASERVICES SEEKS THERELIEF.............. ................................................... 11

THE REASONS WHY GRANTING UASERVICES’ 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 FEDERALREGISTER. .... 34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT UASERVICESREQUEST....................................34

CONCLUSION ................................................................................................................... 35

APPENDICES........................................................................................37
seeks Exemption 3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard OperatingProcedures

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
seeks Exemption 4

SUMMARY

UAServices seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & 

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

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

UAServices to operate an Unmanned Aircraft System (UAS) for the commercial purpose

of conducting aerial video and photography of construction sites, real estate, and landscape 

over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

UAServices provides its clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness. 

UAServices is experienced in all aspects of aerial video and photography. The objective of 

UAServices’ aerial video and photography operations isto provide low cost, high quality 

imaging for a variety of commercial and residential customers.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS

UAServices seeks an exemption to operate DJI systemsfor compensation or hire 

within the NAS. The DJI Phantom 3 Professional is vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with a GroundControl Station (GCS) utilizing electronic tablet 

or smart phone systems. The DJI Phantom 3 Professional has a maximum gross weight of 

approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, 

height of 8 inches, and a maximum speedof
seeks Exemption 5

approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5

ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 inches, and a 

maximum speed of approximately 42 knots. The DJI Phantom 3 Professional UA is

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

motors.

The DJI Phantom 3 Professional UA that will be operatedby UAServices 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 markedin accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, UAServices, 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 fromthe 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, UAServices’ operation ofDJI Phantom 3 

Professional UAS meets the conditions of FMRA Section333 and therefore, will not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.
seeks Exemption 6

Accordingly, UAServices 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.

UAServices submits that the requested relief is proper since an equivalent level of 

safety will be ensured. UAServices will useexperienced 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., the 

UAServices Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

Professional Instruction Manual).

Furthermore, UAServices 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 UAServices to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by 

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

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

including evasive and emergency maneuvers and maintainingappropriate distances from

people, vessels, vehicles and structures.

UAServices seeks relief from Section 91.7(a), entitled Civilaircraft airworthiness, 

because the DJI Phantom 3 Professional UAS does notrequire an airworthiness certificate

in accordance with 14 C.F.R. Part 21, Subpart H. As such, UAServices submits that it will

ensure that the DJI Phantom 3 Professional
seeks Exemption 7

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

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

Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual), and that 

the aircraft are in a condition for safe flight.

UAServices 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. This altitude information, combined with 

UAServices’ operation of the DJI Phantom 3 Professional UAS within visual line of sight, 

at or below 400 feet AGL,will ensure a level of safety equivalent to Section91.121.

Additionally, UAServices seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. UAServices 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 13.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes.
seeks Exemption 8

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

Rick A. Hendrickson

UAServices

2062 State Hwy 9

Rothsay, MN 56579

Tel: (218)867-2592

Email: rhendrickson@rothsay.us

B. The Specific Sections of 14 C.F.R. From Which UAServices seeks Exemption

1. UAServices 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. UAServices seeks Exemption from the Requirements of Section

91.7(a).

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

following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.
seeks Exemption 9

3. UAServices 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 isset, 

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 anappropriate

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 availablebefore

departure.

4. UAServices 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. UAServices 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[.]
seeks Exemption 10

6. UAServices 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 thefollowing:

(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. UAServices 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 andhas

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. UAServices 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--
seeks Exemption 11

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

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

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

(ii) The current status of life-limited parts of each airframe,engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under whichthe

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 foreach

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 beretained 

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.
seeks Exemption 12

C.The Extent of Relief UAServices seeks and The Reason UAServices seeks The

Relief.

1. Extent of Relief UAServices seeks and The Reason UAServices seeks Relief

from Section 61.113(a) and (b).

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

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

private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conductthe 

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 tothat 

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

compensation or hire.

As set forth more fully below, UAServices submits that an equivalent level of 

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

Professional UAS or DJI Inspire 1 UAS unless that PIC has met certainflight-hour and 

currency requirements, demonstrating that the PIC is able to safely operate either the DJI 

Phantom 3 Professional or DJI Inspire 1 UAS in a manner consistent with theoperations

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

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

Further, UAServices submits that all flights of the DJI Phantom 3 Professional 

UAS, conducted by the PIC pursuant to the grant ofthis
seeks Exemption 13

Petition: (1) will be incidental to UAServices’ business; and (2) will not carry passengers 

or property for compensation or hire.

2. Extent of Relief UAServices seeks and The Reason UAServices 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 UAServices to determine that the DJI Phantom 3 Professional 

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

compliance with the operating documents (i.e., the UAServices Operations Manual, 

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

UAServices seeks the requested relief because the DJI Phantom 3 Professional

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

Subpart H. Therefore, UAServices will ensure that the DJI Phantom 3 Professional UAS is

in airworthy condition based uponits compliance with the operating documents (i.e., the 

UAServices Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

Professional Instruction Manual) prior to every flight, and further, determine that the

aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief UAServices Seeks And The Reason UAServices 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
seeks Exemption 14

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

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 UA is 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 theGCS.

4. Extent Of Relief UAServices Seeks And The Reason UAServices 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 UA during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first 

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

4.5 minutes. UAServices seeks the requested relief because withoutan 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 UAServices proposes to conduct pursuant to this Petition.
seeks Exemption 15

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

Professional UAS, the DJI Phantom 3 Professional operating documents, and UAServices’

proposed operating limitations, ensure that UAServices will safely operate the battery 

powered 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

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

fly after that for at least 4.5 minutes.

5. Extent of Relief UAServices Seeks and the Reason UAServices 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, UAServices 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 meet the conditions of FMRA Section 333 for operation without an airworthiness

certificate. Accordingly, UAServices will use trained technicians to perform maintenance, 

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

practices prescribed in the UAS operatingdocuments (i.e., the UAServices Aerial

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Professional

Instruction Manual).Furthermore, UAServices will document and maintain all

maintenance records for the DJI Phantom 3 Professional UAS.

D.The Reasons Why Granting UAServices’ Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole.
seeks Exemption 16

Granting the present Petition will further the public interest by allowing

UAServices to safely, efficiently, and economically perform aerial video and photography 

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

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

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

the benefits of UAServices’ proposed operation of theDJI Phantom 3 Professional UAS

will be realized without implicating any privacy issues.

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

The DJI Phantom 3 Professional UA is 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 orDJI 

Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and

air pollution, as well as increase the safety of life and property in the air and on the ground.

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

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

DJI Phantom 3 Professional UA does 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 Professional UAS.
seeks Exemption 17

Conducting aerial acquisitions with the DJI Phantom 3 Professional 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 Professional 

UAS produces no air pollution, and is themost

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

combustion engine aircraft that are typically utilized for aerial video andphotography,

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

Phantom 3 Professional UA, while reducing the carbon footprint ofaerial acquisitions, 

also eliminates noise pollution, as the UA is propelled by battery powered electric motors, 

rather than an internal combustionengine.

By using the DJI Phantom 3 Professional 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 memberslocated onboard the 

aircraft, the DJI Phantom 3 Professional UA (weighing approximately 2 pounds 11 

ounces at its maximum gross weight with a length of 16 inches, width of 16 inches and 

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

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

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

approximately 42 feet, a length of 34 feet, and afuel capacity of 180 gallons).
seeks Exemption 18

3. 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 UAS 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 UAServices, 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 Professional 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 Professional UAS, companiessuch as 

UAServices, 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 Professional UAS, provides astable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies 

to invest in research and development in order toremain competitive both in the United 

States andabroad.

4. There Are No Privacy Issues.

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

decades, UAServices’ proposed operation of the DJI Phantom 3 Professional
seeks Exemption 19

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

UAS will be operated only in compliance with operating documents (i.e., the UAServices

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

InstructionManual) 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 UAServices Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional UA Meets 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, UAServices’ operation ofthe 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 Secretaryof

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.
seeks Exemption 20

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

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 underthis 

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, UAServices submits that the DJI Phantom 3 

Professional UAS can operate safely in the NAS pursuant to FMRASection 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

Demonstrates 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 and B.
seeks Exemption 21

ii. The DJI Phantom 3 Professional UASAutonomous 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 flightand navigational modes of 

the DJI Phantom 3 Professional UAS is provided at pages 25-35 of the DJI Phantom 3 

Professional and pages 12-16 and 45-50 of the DJI Inspire 1 User Manuals, attached hereto 

as Exhibit C and D.

iii. The DJI Phantom 3 Professional UAS Is 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 27 through 29 and for the DJI Inspire 1 at pages 

13 through15 of the DJI Phantom 3 Professional User Manuals, attached hereto as Exhibit 

C and D.

iv. The DJI Phantom 3 Professional GCS andIts Operation.

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

Professional GCS and flight control software is provided at pages 32 through 43 of the DJI 

Phantom 3 Professional User Manual and pages 40 through 47 of the DJIInspire
seeks Exemption 22

1 User Manual. DJI Phantom 3 Professional User Manuals are attached hereto as Exhibits 

C and D.

b. Flight Operations of DJI Phantom 3 Professional UASAre Limited to

the Line Of Sight of a Certificated Pilot in Command with a Safety

Observer.

UAServices will only utilize certificated pilots who possess a current and valid 

airman medical certificate or a valid U.S. driver’s license issued by a state to act as a pilot 

in command (PIC) of the DJI Phantom 3 Professional UAS. Additionally, a safety observer 

will assist all pilots during flight time.

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

Pursuant To Specific Operating Limitations.

In seeking this exemption, UAServices proposes to commercially operate DJI

Phantom 3 Professional UAS for the special purposeof 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 weighingless than 

55 pounds maximum gross weight: DJI Phantom 3 Professional Unmanned

Aircraft Systems. Proposed operations of any other aircraft willrequire 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 UA 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 UA 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.
seeks Exemption 23

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

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 forthe 

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

functions prescribed in the operatingdocuments.

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. Ifa

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 operatordetermines

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.
seeks Exemption 24

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 recordkeeping

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 ofthe 

corrective action taken against discrepancies discovered between inspections.

17. The PIC must hold either an Airline Transport, Commercial, Private, 

Recreational, or Sport Pilot certificate. The PIC must also hold a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state. 

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. Duringtraining,

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. §

19.1. 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.
seeks Exemption 25

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

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

PIC.

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

in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

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

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

remaining.

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

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

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

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

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

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

altitude level and potential transponder requirements.

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

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

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

Subpart C. Markings must be as large as practicable.

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

and control of the UA must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

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

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

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

Administrator or any law enforcement official upon request.

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

operations and activities at all times.

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

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

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless:
seeks Exemption 26

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 leavesuch 

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) within24 

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.

UAServices submits that the equivalent level of safety establishedby 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 or DJI Inspire 1 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures.

Considering UAServices’ proposed area of operations, and the operating limitations 

set forth-above; the parallel nature of private pilot aeronautical
seeks Exemption 27

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 or DJI Inspire 1 UAS, UAServices submits that the additionalmanned 

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

airmanship skills necessary for UAServices’ 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).

UAServices will not allow any PIC to operate the DJI Phantom 3 Professional or 

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 3 Professional or DJI Inspire 1 UAS trainingand

currency requirements, that the PIC is able to safely operate the DJI Phantom 3 

Professionalor DJI Inspire 1 UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people,

vessels, vehicles and structures.

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

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

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

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

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

purposes).
seeks Exemption 28

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 UAServices’ 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, UAServices will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS unless that PIChas 

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

able to safely operate the DJI Phantom 3 Professional or DJI Inspire 1 UAS in amanner

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures.
seeks Exemption 29

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, UAServices will ensure that the DJI Phantom 3 Professional

or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s compliance with 

its operating documents and as stated in the conditions and limitations herein.

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

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

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

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

4. Reasons Why an Exemption from the Requirements of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will bemaintained

because the altitude information of the DJI Phantom 3 Professional UAwill 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 UAServices’ operation of the DJI Phantom 3 

Professional UA 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. Priorto 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
seeks Exemption 30

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 theDJI 

Phantom 3 Professional UAS; (2) the limitations on the proposed flight operations; and (3)

the location of the proposed flight operations. Accordingly, UAServices will ensure that it 

will safely operate the battery powered DJI Phantom 3 Professional UA during daylight 

hours in VFR conditions, withenough battery power to fly for a total duration of 13.5 

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

after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 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 provides audible and visual warnings to the PIC atthe

GCS when the UA experiences low battery voltage, the first warning occurringat

approximately 33% remaining battery power, and again at approximately 10% remaining

battery power. At the critically low battery level, the DJI Phantom 3 Professional 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 characteristicsand

operating limitations of the UAS are considered. Relief has been granted for manned
seeks Exemption 31

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, UAServices 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 UAServices will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS using themethods, techniques, and 

practices prescribed in the operating documents (i.e., theUAServices Operations Manual, 

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

Furthermore, UAServices 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, UAServices 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 C and D; a copy of the DJI Phantom 3 Professional UAS

Maintenance LOG is attached hereto as Exhibit E.
seeks Exemption 32

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

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 trainedtechnicians. Maintenance 

will be documented and maintained utilizing the monthly maintenancelog.

Significantly, previous exemptions granted by the FAA concerningSections

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 UAServices’ proposed operating limitations, the operating 

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

UAServices submits that safety will not be adverselyaffected 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 SafeOperation.

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, UAServices
33

seeks Exemption

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

Phantom 3 Professional UAS, which contain such safety standards thatthe 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 UA for the limited purpose of 

conducting aerial video and photography over certain areas of the United Statesfor 

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 thefollowing:

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.
seeks Exemption 34

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 Professional UAS, which contain such safety standards thatthe Administrator

finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 

21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b),

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

F. A Summary That Can Be Published in the Federal Register, stating: The Rules 

from Which UAServices Seeks Exemption:

UAServices 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 UAServices Seeks:

This exemption will permit UAServices to commercially operate an Unmanned 

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

over certain areas of the United States.

G. Any Additional Information, Views, or Arguments Available ToSupport 

UAServices’ 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, UAServices’ 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.
seeks Exemption 35

As discussed in detail above, UAServices will operate the DJI Phantom 3 

Professional 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, UAServices 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 limited purposeof 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 UAServices to safely, efficiently, and economically operate the DJI Phantom 3 

Professional UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, UAServices 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 Professional UAS commercially for the purpose ofconducting aerial video and 

photography over certain areas of the United States.

Dated: June 22, 2015
seeks Exemption 36

Respectfully submitted, 

UAServices

/s/ Rick A. Hendrickson

Rick A. Hendrickson

UAServices

2062 State Hwy 9

Rothsay, MN 56579

(218)867-2592

Appendices:

A – DJI Phantom 3 Professional Specifications Data

Sheet

B – DJI Phantom 3 Professional Manufacturer’s User

Manual

C – Monthly Maintenance Log
seeks Exemption 37

APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL

SPECIFICATIONS

UAServices only utilizes safe and reliable UAS. DJI is an industry leaderin small UAS 

production. DJI UAS is loaded with ground breaking software enabling the user to set

parameters which will not allow flight into controlled airspace. Parameters can also be set 

to limit flight to no higher than a predetermined and set altitude as well as limit flight to a 

predetermined and set distance. In addition, DJI software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 3 Professional

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 UHD Video Recording – 4096x2160p 24/25, 3840x2160p24/25/30

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 1.20A@7.2V
seeks Exemption 38

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W
seeks Exemption 41

APPENDIX – B

DJI Phantom 3 Professional Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.0_e

n.pdf
seeks Exemption 42

APPENDIX – C

MONTHLY$MAINTENANCE$LOG

month: (year:

UAS$#:$ Date(Issue(

Discovered

Date(Issue(

Addressed Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:(((

Print(&(Sign

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other: