1 UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

JONATHAN S. CHERNEY

FOR AN EXEMPTION SEEKING R ELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL

OPERATION OF THE DJI PHANTOM 3 PRO UNMANNED AIRCRAFT SYSTEM PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC

LAW 112

- 95)

Submitted on November 15, 2015

JONATHAN CHERNEY

P.O. BOX 97 TRABUCO CANYON, CA 92678 (949) 525

- 05002 

### TABLE OF CONTENTS

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

............... .....3

SUMMARY......................................................................................................................

.. ....... 4

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

.. .......4

BACKGROUND................................................................................................................

.. .....5

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

........... .. ....5

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

. ..................... . ......6

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

JONATHAN CHERNEY SEEKS EXEMPTION..........................

..... . ................... ....... 7

THE EXTENT OF RELIEF JONATHAN CHERNEY SEEKS AND

THE REASON JONATHAN CHERNEY SEEKS THE RELIEF......

. ...................9

THE REASONS WHY GRANTING JONATHAN CHERNEY ’S REQUEST

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

. ............................ . 11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

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

. ..............................13

CONCLUSION....................................................

...................................... . .......................... . ...21

APPENDIX A................................................................................................................... ........22

APPENDIX B.................................... .......................................................................................233 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command Section 333 FAA Modernization and Reform Act of 2012 (FMRA)

SO Safety Observer

SOP Standar d Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing

DJI UAV manufactur er ESC Electronic speed control

FPV First Person View

LI

- PO Lithium Polymer B attery

RCV Radio Controlled V ehicle4 SUMMARY

JONATHAN CHERNEY , operating under the company title, Jonathan Cherney Consulting & Investigations, 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 JONATHAN CHERNEY to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography for traffic collision investigation & reconstructio n , real estate photography, commercials, special events, wedding cinematography, photogrammetry, marine photography, roofing inspection s , building construction site inspections and landscape imaging over certain areas of the United States.

INTRODUCTI ON AND INTERESTS OF THE PETITIONER

My name is JONATHAN CHERNEY , and I am a sole proprietor consultant who specializes in photography and traffic collision reconstruction and analysis. I’ve been a professional photographer for 33 years and have been cond ucting traffic collision investigations and reconstruction for the last 26 years. I have over 10 years of experience flying remote control aircraft and helicopters (four channel) and currently own the DJI Phantom 3 Professional edition. The DJI Phantom 3 Pro is a quad

- copter, which I would like to use for low altitude photography for various photo shoots as well as for traffic collision investigation and reconstruction analyses. I have owned the quad

- copter for approximately six months, and as an advance d remote control helicopter operator, I find it to b e very easy to control and fly these types of RCVs.5 BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Pro UAS

JONATHAN CHERNEY seeks an exemption to operate the DJI system for compensation or hire

within the NAS. The DJI Phantom 3 Pro 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 Pro has a maximum gross wei ght of approximately 2 pounds 14 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29

knots. The DJI Phantom 3 Pro UAS is equipped with four main rotors; driven by a Lithium Polymer

batt ery powered electric motor

.

The DJI Phantom 3 Pro UAS that will be operated by JONATHAN CHERNEY 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 Markings.

BASIS FOR PETITION

Petitioner, JONATHAN CHERNEY , 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 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, JONATHAN CHERNEY ’s operation of DJI Phantom 3 Pro UAS meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, JONATHAN CHERNEY 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.

JONATHAN CHERNEY submits that the requested relief is proper since an equivalent level of safety

will be ensured. JONATHAN CHERNEY will use experienced personnel or technicians to perform maintenance, alterations, or pr eventive maintenance on the UAS using the methods, techniques, and

pra ctices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3

Pro Manual). Furthermore, JONATHAN CHERNEY will document and maintain all maintenance

records for the DJI Phantom 3 Pro

.

Relief from certain requirements of Se ction 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by JONATHAN CHERNEY to the extent necessary to6 allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airm an 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 Pro UAS in a manner consistent with this exemption, including evasive and emergency maneuv ers and maintaining appropriate distances from people, vessels, vehicles and structures.

JONATHAN CHERNEY seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness,

because the DJI Phantom 3 Pro UAS do es not require an airworthiness certi ficate in accordance with 14 C.F.R. Part 21, Subpart H. As su ch, JONATHAN CHERNEY submits that he will ensure that the

DJI Phantom 3 Pro UAS is in an airworthy condition, prior to every flight, by determining

that the UAS is in compliance with the operati ng documents (i.e., Monthly Maintenance Log, and DJI

Phantom 3 Pro Instruction Ma nual), and that the aircraft is in a condition for safe flight.

JONATHAN CHERNEY also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Setting s, as the DJI Phantom 3 Pro UAS will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3 Pro UAS will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry da ta link, which downlinks

from the UA S to the GCS for active monitoring of the flight path. This altitude information, combined

with JONATHAN CHERNEY ’ s operation of the DJI Phantom UAS within visual line of sight, at or below 500 feet AGL, will ensure a lev el of safety equivalent to Section 91.121.

Additionally, JONATHAN CHERNEY seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. JONATHAN CHERNEY submits that safety will not be affected by operation of the DJI Phantom 3 Pro UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 15.5 minutes to the first point of intended land ing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

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

JONATHAN CHERNEY

P.O. BOX 97 TRABUCO CANYON, CA 92678 (949) 525

- 0500

Email: Jonathan@JCherneyConsulting.com7 A . The Specific Sections Of 14 C.F.R . From Which JONATHAN CHERNEY Seeks Exemption

.

1. JONATHAN CHERNEY 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; no r 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

em ployment; and (2) The aircraft does not carry passengers or property for compensation or hire.

2. JONATHAN CHERNEY 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. JONATHAN CHERNEY 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 t he cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter th at is set, w hen operating

-- Below 18,000 feet MSL, to

--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i ) of this section, the current reported altimeter setting of an appropriate available station;

or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before dep arture.

4. JONATHAN CHERNEY 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 rotorc raft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to t he first point of intended landing and, assuming normal cruising speed, to fly after that for at

least 20 minutes.8 5. JONATHAN CHERNEY Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each owner or operator of an aircraft

—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. JONATHAN CHERNEY Seeks Exemption Fr om The Requirements Of Section

91.4 07(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, reb uilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. JONATHAN CHERNEY 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 accordan ce with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

8. JONATHAN CHERNEY 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 r equired or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i ) A description (or reference to data acceptable to the Administrator) of the work performed; and (ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the

aircraft for return to serv ice.

2. Records containing the following information:9 (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 inspec tion 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.

3. The owner or operator shall retain the following records for the periods prescribed: (i ) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by ot her work or for 1 year after the work is performed. (ii ) 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. (iii ) A list of defects furnished to a registered o wner 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.

B

. The Extent Of Relief JONATHAN CHERNEY Seeks And The Reason JONATHAN

CHERNEY Seeks The Relief.

1. Extent Of Relief JONATHAN CHERNEY Seeks And The Reason JONATHAN

CHERNEY 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 a nd valid airman medical certificate, and who has met certain flight

- hour and currency requ irements, 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 bus iness 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, JONATHAN CHERNEY submits that an equivalent lev el of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Pro UAS unless that PIC has met certain flight

- h our and currency requirements, demonstrating that10 the PIC i s able to safely operate th e DJI Phantom 3 Pro UAS in a m anner consistent with the operations specifications a s described in this exemption, including evasive and emergency maneuvers, as well as maintain ing appropriate distances from people, vessels, vehicles and

structures.

Further more, JONATHAN CHERNEY submi ts that all flights of the DJI Phantom 3 Pro UAS

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

JONATHAN CHERNEY ' s business; and (2) will not ca rry passengers or property for compensation or hire.

2. Extent Of Re lief JONATHAN CHERNEY Seeks And The Reason JONATHAN

CHERNEY Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airw orthiness, is requested to the extent required to allow JONATHAN CHERNEY to determine that the DJI Phant om 3 Pro UAS is in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating do cuments (i.e., JONATHAN CHERNEY ’s Aerial Opera tions Manual, Monthly Maintenance Log, and DJI Phantom 3 Pro Instruction Manual

, Pre

- Flight Checklist ).

JONATHAN CHERNEY seeks the requested relief because the DJI Phantom 3 Pro UAS do es not require an airworthiness certificate in acco rdance with 14 C.F.R. Part 21, Subpart H. Therefore, JONATHAN CHERNEY will ensure that the DJI Phant om 3 Pro UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Pro Instruction Manual) prior to every flight, and further,

determine that the aircra ft is in condition for safe flight, as stated in the conditions and

limitations below.

3. Extent Of Relief JONATHAN CHERNEY Seeks And The Reason JONATHAN

CHERNEY 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 Pro UAS , which utilizes 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 t he FAA requires that any altitude information concerning UAS operations be reporte d to air traffic control (ATC) in feet above groun d level (AGL), JONATHAN CHERNEY seek s the requested relief because the DJI

Phantom 3 Pro UA S ’s altimeter may be set o n the g round 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 con ditions and limitations stated below. As more fully set forth herein, an equivalent level of safet y will be maintained since the

DJI Phantom 3 Pro UAS is equipped with a baro metric pressure sensor and GPS equipment, which automatically ensure s that a ground level pressu re setting will be established prior to each flight, and provides the PIC with altitude informat ion of the UA on the heads

- up d isplay of

the GCS.

4. Extent Of Relief JONATHAN CHERNEY Seeks And The Reason JONATHAN

CHERNEY See ks Relief From Section 91.151(b).11 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 D JI Phantom 3 Pro UAS during daylight hours in visual m eteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 15.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. JONATHAN CHERNEY seeks the request ed relief because without an exe mption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 Pro UAS w ill severely constrain the practicality of any aerial video or stil l photo flight operations that JONATHAN CHERNEY propose s to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifi cations of the DJI Phantom 3 Pro UAS , the

DJI Phantom 3 Pro UAS’s operating d ocuments, and proposed operating limitations, ensure that

JONATHAN CHERNEY will sa fely operate the battery powered DJI Phantom 3 Pro UAS during daylight hours in visual meteorological conditions (VMC), under visual flight ru les (VFR), with enough battery power to fly for a total dura tion of 15 .5 minutes to the first point of

intended landing an d, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief JONATHAN CHERNEY Seeks And The Reason JONATHAN

CHERNEY 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, JONATHAN CHERNEY requests relief from these

Sections because the DJI Phantom 3 Pro UAS does not require airw orthiness certificates. As set forth more fully below, the DJI Phantom 3 Pro UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certif icate. Accordingly, JONATHAN CHERNEY will

use trained techn icians to perform maintenance, alterations, or pr eventive maintenance on the

UAS usin g the methods, techniques, and practices prescribed in the UAS operating documents (i.e., JONATHAN CHERNEY Aerial Operations Manu al, Monthly Maintenance Log, D JI

Phantom 3 Pro Instruction Manual , Pre

- F light Checklist ). Furthermore, JONATHAN

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

UAS

.

C. The Reasons Why Granting JONATHAN CHERNEY ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the publi c interest by allowing JONATHAN

CHERNEY to safely, efficiently, and economically perform a erial video and ph otography of traffic collision investigation & reconstruction, real estate photography, commercials, special events, wedding cinematography, photogrammetry, marine photography, roofing inspections, building construction site inspections and landscape imagi ng over certain areas of the United

States.

Additionally, use of the DJI Phantom 3 Pro UAS will decrease congestion of the NAS, reduce pollution, crashes and accidents cau sed by pilot error and provide significant benefits to the

eco nomy. Notably, the ben efits of JONATHAN CHERNEY ’s proposed operation of the DJI

Phantom 3 Pro UAS will b e realized without implicating any privacy issues.12 1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 Pro UAS is battery powered and serves as a safe, efficient, and

economical alternative to the manned aircraft tradition ally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aeri al acquisitions, an exemption allowin g the use of a DJI Phantom 3 Pro UAS would reduce

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The

DJI Phantom 3 Pro do es not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photog raphy missions would result in fewer aircraft that must be handled by air traffic control during t he 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

Pro UAS

.

Conducting aerial acquisitions with the DJI Phantom 3 Pro UAS

, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and st ill photography flight operations. By using battery power and electric motors, the DJI Phantom 3 Pro UAS produces no air pollution, and is the most viable environmentally conscious a lternative to the cabin class, six cylinder internal combustion engine air craft that are typically

u tilized for aerial video and photography, while burning approximately 20

- 30 gallons per hour of lead ed aviation fuel. The DJI Phantom 3 Pro UAS , while reducing the carbon footprint of aerial acquisitions, also elimin ates noise pol lution, as the UAS is propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 Pro UAS to pe rform aerial acquisitions, the substantial risk to life and property in the air and on the groun d, whic h is usually associated with traditional manned aircraft flight operations, will be subst antially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the

DJI Phantom 3 Pro (weighing approximately 2 pou nds 14 ounces at its maximum gross weight, with a length of 16 inches, and a width of 16 inc hes , and with no fuel on board), has less physical potential for collateral damage to life a nd property on the ground, and in the air, compared to the manned aircra ft that typic ally conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phant om 3

Pro UAS Will Benefit The Economy.

I n addition to being safe and efficient, the DJI Phantom 3 Pro UAS is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 3 Pro UAS will allow United States based companies, like Jonathan Cherney Consulting & Investigations, to remain competitive

and contribute to growth of the U.S. economy. Specifically, with the rising cost of13 aviation fuel an d the Environmental Protection Agency (“ EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology i n order to remain competitive. Operating the battery powered DJI Phantom 3 Pro UAS is one such technology that not only allows companies greater operational flexibility co mpared to manned aircraft, but provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 Pro UAS, companies such as Jonathan Cherney

Con sulting & Investigations , can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately

co ntribute to growth of the U.S. economy. Improved financial performance of U.S. companies, th rough commercial use of the DJI Phantom 3 Pro UAS , provides a stable

wor kforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operation s that have been conducted for decades, JONATHAN CHERNEY ’s proposed operation of the DJI Phantom 3 Pro UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Pro UAS will be operated only in compliance with oper ating documents (i.e., JONATHAN CHERNEY Aerial Operations Manua l, Monthly Maintenance Log, DJI Phantom 3 Pro and

Instruction Manual , Pre

- Flight Checklist ) which requires property owne r 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 N ot Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety A t Least Equal To That Provided By The Rule

From Which JONATHAN CHERNEY Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Pro UAS Meet s 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, JONATHAN CHERNEY ’s operation of the DJI Pha ntom 3

Pro UAS meet s the conditions of FMRA Section 333, and w ill not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Su bpart H. Section 333 provides authority for a UAS to operate without airworthiness certificati on and sets fo rth requirements for considering

whether a UAS will create a hazard to user s of the NAS or the public, or otherwise pose a threat to national security. Specificall y, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any oth er requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Sec retary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the nationa l 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 under14 subsection (a), the Secretary shall determine, at a minimum

— (1) Which types of unmanned aircraft systems, if a ny, 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 n ational ai rspace system or the public or pose a threat to national security; and whether a certifi cate 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 a irspace system, the Secretary shall es tablish requirements for the safe operation o f such aircraft systems in the national airspace system. In seeking this exemption, JONATHAN CHERNEY submits that the DJI Phantom 3 Pro

UAS can operate safely in the NAS pu rsuant to FMRA Section 333, as demon strated by: (a) the

characteristics of the DJI Phantom 3 Pro UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specificatio ns Of The DJI Phantom 3 Pro UAS Demonstrates Its

Safe Characteristics.

The DJI Phantom 3 Pro UAS do es not create a haz ard to users of the NAS or the public, or otherwise pose a threat to national security considerin g its size, weight, speed, and operational capabilit y.

i. Technical Specifications Of The DJI Phantom 3 Pro UAS

.

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

Phantom 3 Pro Specifications and Data Sheet, att ached hereto as Appendix A

.

ii. The DJI Phantom 3 Pro UAS’ Autonomous Flight And Navigation Modes

Enable The UAS To Remain Within A Defined Operational Area.

The DJI Phantom 3 Pro UAS may be ope rated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI

Phantom 3 Pro UAS is provided starting on p age 40 of the DJI Phantom 3 Pro User

Manual. Please refer to A ppendix B for a link to the User Manual.

iii. The DJI Phantom 3 Pro 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 Pro UAS will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Pro UAS do es not reacquire control link data from the GCS, the UAS will assume that the Control Link i s lost and the UAS will return to the home position (i.e., failsafe mode ) via GPS, and will

descend to the takeoff position and shutdown. A complete description of the Failsafe

Functions of the DJI Phantom 3 Pro UAS is described on page 14 of the DJI Phant om 3

Pro User Manual . Please refer to Appendix B for a link to the User Manual.

iv. The DJI Phantom 3 Pro GCS And Its Operation.15 A complete description of the operation and specifications of the D JI Phantom 3 Pro GCS and flight control software is provided at pages 35 through 38 of the DJI Phantom

3 Pro User Manual

. Please refer to Appendix B for a link to the User Manual.

b. Flight Operations Of DJI Phantom 3 Pro UAS is Limited To The Line Of Sight

Of A Certific ated Pilot in Command With A Safety Observer.

JONATHAN CHERNEY will only utilize certificated pilots who possess a current and

valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom

3 Pro UAS . Additionally, a safety obse rver will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 Pro UAS Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, JONATHAN CHERNEY proposes to commercially operate

the DJI Phantom 3 Pro UAS for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant to th e 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 maxi mum gross weight: DJI Phantom 3 Pro Unmanned Aircraft System. Proposed operations of any other aircraft will require a new petiti on or a petition to

amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

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

4. The UA S must be operated at an alt itude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision un aided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued ai rman medical certificate.

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

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC mus t be able to communicate verbally at all times. Electronic messagi ng or texting is not permitted during flight operations. The PIC must be designated before the fli ght

and cannot transfer his or her designation for the duration of the flight. The PIC must

ensu re that the SO can perform the functions prescribed in the operating documents.16 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 re quest. If a discrepancy exists

between the conditions and limitations contained in the grant of exemption and the procedures outlined in the oper ating documents, the conditions and limitations contained in the grant o f exemption take precedence and must be followed. Otherwise , the operator

must follow the proced ures as outlined in its operatin g documents. The ope rator may update or revise its operating documents. It is the operator’s responsibility to t rack such revisions and present updated and revised documents to the Administrator upon request. The operator mu st also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determin es that any update or revision would affect the basis upon which the FAA granted the exe mption, then the operator mu st petition for amendment to its grant of exemption. The FAA’s

U AS 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 ens ure that it is in a condit ion

f or safe flight. If the inspection reveals a condition that affects the safe op eration of the UAS, the aircraft is prohibited from operating until the necessary main tenance has been performed and the UAS is found to be in a co ndition for safe flight. The Ground Control

Station must be included in the preflight inspection. All maintenance an d alterations must be properly documented in the aircraft records.

11. Any UAS that has undergone maintenance or a lterations 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 tes t flight must make an entry in the a ircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered i n the relevant sections of the

oper ating documents.

13. The operator must follow the UAS manu facture r’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, i nspections, and record keeping requirements, in accordance with the operating documents. Mainten anc e, inspection, alterations, and status of replacement/overhaul component parts must be noted in t he aircraft records, including total time in service, description of work accompli shed, and the signature of the authorized person returning the UAS to service

.

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

Bulletins.

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

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

class medical certificate.

18. The operator may not permit any PIC to operate unles s the PIC meets the operator’s qualification criteria and demonstrates the a bility to safe ly 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 f rom 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 operation s may only be conducted during dedicated trai ning sessions. During training, proficiency, and experience

- buildin g flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at th e FAA offi ce closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not

authorized.

20. The UA S 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 conduc ted in accordance with

a NOTAM as required by the operator’s COA. The letter of agreement wi th the airport

management must be made available to the A dministrator upon request.

21. The UA S 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 S loses communications or loses its GPS si gnal, it must return to a pre

determined location within the planned operating area and land or be recovered in

accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredict ed 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 land ing point and land the UA with 25% battery power remaining.

25. The operator must obtain an Air Traffic Organizati on (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 hou rs prior to the operation. All operations shall be conducted in accordance with airspace requ irements in

the ATO issued COA includin g class of airspace, altitude level and potential transponder requirements.18 26. All aircraft operated in accordance with the exemptio n must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

Numbe r) 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 s pectrum used for operation and control of the UA must comply with the Federal Communications Com mission (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

docum ents 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), ves sels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from t he UA and/or debris in the event of an accident. The operator must

ensure that nonparticipating persons remain under such protectio n. If a situation

arises w here nonparticipating persons leave such protection and are wit hin 500 feet of the UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, ve hicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission

and the PIC ha s 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 essentia l persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or c ontrolled

- 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 transg resses the lateral or vertical boundaries of the operational area as defined by the applicab le COA must be reported to

the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Acc idents must be reported to the National Transportation Safety Board (NTSB) per instructions c ontained

on the NTSB Web site: www.ntsb.gov.19 2. Reasons Why An Exempti on From The Requirements Of Section 6 1.113(a) And (b) Would Not Adversely Affect Safety.

JONATHAN CHERNEY submits that the equivalent level of saf ety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to oper ate the DJI

Phantom 3 Pro UAS unless that PIC has de monstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to sa fely operate the DJI Phantom 3 Pro UAS in a

manner consistent with the ex emption, including evasive and emer gency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering JONATHAN CHERNEY ’s proposed area of operations, and the operating

limitations set forth

- above; the parallel nature of privat e pilot aeronautic al knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 3 Pro UAS

, JONATHAN

CHERNEY submits that the additional manned airmanship experience of a c omme rcially certificated pilot would not correlate to the airmanship skills necessary for JONATHAN

CHERNEY ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in

circumstances similar, in all material respects, to those present ed herein (e.g. Exemption Nos.
11062, 11063, 11064, 11065, 11066, 11067, 11080, 111 09, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). JONATHAN CHERNEY will not allow any PIC to operate the DJI Phantom 3 Pro UAS unless that PIC has demonstrated, by meeting

min imum flight

- hour requirements and the DJI Phantom 3 Pro UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Pro UAS in a manne r consistent with this exemption, including evasive a nd emergency maneuvers and maintaining appropriate distances from people, vess els, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a ma nner 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 mus t accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applica ble regulations will ensure an equivalen t level of safety during JONATHAN CHERNEY ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and m odel 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 t he 10 hours may be included in the total 25 hours of UAS20 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 ho ur 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 complia nce 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

- b uilding flights the PIC is required to operate the UA with appropriate distances in acc ordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

Accordingly, JONATHAN CHERNEY will ensure safe operati ons by not allowing any PIC to operate the DJI Phan tom 3 Pro UAS unless that PIC has demonstrated, by meeting minimum flight

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

Pro UAS in a manner consistent with th e exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.21 CONCLUSION

JONATHAN CHERNEY seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of

the FAA Modernization and Reform Act of 2012 (F MRA), which will permit safe operation of

the DJI Phantom 3 Pro UAS commerci ally, without an airworthiness certificate, for the limited purpose of conducting aerial vide o and photography over certain areas of the Unit ed States. By granting this Petition, the FAA Admini strator 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 JONATHAN CHERNEY to safely, efficiently, and economically operate

the DJI Phantom 3 Pro UAS commercially within the NAS. Therefore , in accordance with the

Federal Av iation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, JONATHAN CHERNEY respectfully requests that the A dministrator grant this Petition for an exempti on 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 Jonathan Cherney Consulting & Investig ations to operate the DJI Phantom 3 Pro UAS commercially for the purpose of conductin g aerial video and photography over certain areas of

the United States.

Dated: November 15, 2015 Submitted by

JONATHAN CHERNEY22 APPENDIX

- A

DJI PHANTOM 3 PRO TECHNICAL SPECIFICATIONS

JONATHAN CHERNEY 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 prede termined 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)

Aircraft Weight (Battery & Propellers) 1280 g Max. Ascent Speed 5 m/s

Max. Des cent Speed 3 m/s Max. Speed 16 m/s (ATTI mode, no wind) Max Service Ceiling Above

Sea Level 6000 m (Software altitude limit: 120 m above takeoff point) Max. Flight Time Approximately 23 minutes Operating Temperature 0 ° C to 40° C

GPS Mode GPS/GLONA SS

Gimbal Controllable Range Pitch:

- 90 ° to + 30 °

Vision Positioning Velocity Range < 8 m/s (2 m above ground) Altitude Range 30 cm

- 300 cm Operating Range 30 cm

- 300 cm Operating Environment Brightly lit (lux > 15) patterned surfaces

Camera

Sensor Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens FOV 94 ° 20mm(35mm format equivalent) f/2.8 ISO Range 100

- 3200(video) 100

- 1600(photo) Electronic Shutter Speed 8s

– 1/8000s Image Max. Size 4000 x 3000,

Still Photography Modes Single shot, Burst shooting 3/5/7 frames Auto Exposure Bracketing (AEB): 3/5, Bracketed frames at 0.7EV Bias,

time

- lapse Supported SD Card Types Micro SD (Max capacity: 64 GB, Class 10 or UHS

- 1 rating required Video Recording Modes UHD: 4 096x2160p 24/25, 3840x2160p 24/25/30 FHD: 1920x1080p 24/25/40/48/50/60 HD: 1280x720p 24/25/30/48/50/60

Max. Bi t rate of Video Storage 60 Mbps23 Supported File Formats Fat32/exFAT, Photo: JPEG, DNG, Video: MP4/MOV (MPEG

- 4 AVC/H.264) Operating Temperature 0 ° C to 40 ° C

Remote Controller Operating Frequency 2.400 GHz

- 2.483 GHz Transmitting Distance Up to 5.0 km or 3.1 miles (unobstructed, free of interferences and FCC compliant) when it is FCC compliant Up to 3.5 km or 2.1 miles (unobstructed, free of interferences) when it is CE compliant Video Output Port USB Operating Temperature Range 0 ° C to 40° C Battery 6000 mAh LiPo 2S

Mobile Device Holder Tablets and smartphones Transmitter Power (EIRP) FCC: 20 dbm; CE: 16 dbm Working Voltage 1.2 A @7.4 V

Charger Voltage 17.4 V

Rated Power 100 W

Intelligent Flight Battery (PH3

- 4480 mAh

- 15.2 V) Capacity 4480 mAh Voltage 15.2 V Battery Type LiPo 4S Energy 68Wh Net Weight 365 g Operating Temperature

- 1 0 ° C to 40° C Max. Chargin g Power 100 W

APPENDIX

- B

D JI PHANTOM 3 PRO U S E R MA N UA L

Refer to the following link to view the User Manual for the DJI

Phantom 3 Pro: http://www.dji.com/product/phantom

- 3/download