UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

JOHN D HANSARD

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 and 

INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on December 15, 2015 4pm

JOHN D HANSARD

207 N. Wieser Street

Hamilton, TX 76531

Tel: (817) 821-5000
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.............................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH JOHN D HANSARD

SEEKS EXEMPTION ..............................................................................................6

THE EXTENT OF RELIEF AND THE REASON JOHN D HANSARD SEEKS 

THE RELIEF ............................................................................................................9

THE REASONS WHY GRANTING JOHN D HANSARD’S REQUEST WOULD 

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

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................13

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

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT JOHN D HANSARD’S REQUEST.......................25

CONCLUSION....................................................................................................................26

APPENDICES........................................................................................27
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 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
4

SUMMARY

JOHN D HANSARD 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 

JOHN D HANSARD to operate Unmanned Aircraft Systems (UAS) for the commercial 

purpose of conducting aerial video and photography of real estate, agriculture, ranch and 

wildlife surveys and wedding and private parties over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

JOHN D HANSARD will provide his clients with aerial photos and videos.

JOHN D HANSARD is an experienced UA pilot and videographer/photographer.

He holds a private pilot certificate and has an excellent knowledge of aviation safety, 

airspace and altitude regulations. The UAS will be used to produce aerial video and 

photographs for:

 Real estate 

 Commercial Sites

 Agriculture

 Ranch and Wildlife Surveys

 Weddings and Private Parties

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS

and DJI Inspire 1 UAS

JOHN D HANSARD seeks an exemption to operate DJI systems for compensation 

or hire within the NAS. The DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS 

are vertical takeoff and landing (VTOL) Unmanned Aircraft UA with Ground Control 

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 

Professional has a maximum gross weight of approximately 2.82 pounds (1280 grams), 

while having a length of 23.22 inches, width of 23.22 inches, height of 7.25 inches

(including propellers) and a maximum speed of approximately 31 knots (16m/s). The DJI 

Inspire 1 has a maximum gross weight of approximately 6.46 pounds (2935 grams), while 

having a length of 23.74 inches, width of 24.25 inches, height of 11.85 inches (including 

propellers) and a maximum speed of approximately 42 knots (22m/s). The DJI Phantom 3 

Professional (UA) and DJI Inspire 1 (UA) are equipped with four main rotors; driven by 

Lithium Polymer battery powered electric motors.
5

BASIS FOR PETITION

Petitioner, JOHN D HANSARD, 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 UA

and the DJI Inspire 1 UA 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, JOHN D HANSARD’s DJI Phantom 3 

Professional UAS and the DJI Inspire 1 UAS meet the conditions of FMRA Section 333 

and therefore, will not require airworthiness certificates in accordance with 14 C.F.R. Part 

21, Subpart H. 

Accordingly, JOHN D HANSARD 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. 

JOHN D HANSARD submits that the requested relief is proper since an equivalent 

level of safety will be ensured. JOHN D HANSARD will use experienced personnel and/or 

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

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

Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction Manual and the 

DJI Inspire 1 Instruction Manual). Furthermore, JOHN D HANSARD will document and 

maintain all maintenance records for the DJI Phantom 3 Professional (UA) and the DJI 

Inspire 1 (UA). 

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

privileges and limitations: Pilot in command is requested by JOHN D HANSARD to the 

extent necessary to allow a Pilot in Command (PIC) holding at least the FAA minimum 

pilot requirements in effect for commercial drones at the time of operations. Currently, the 

PIC must hold a private pilot or higher level certificate, as well as an airman medical 

certificate, and must demonstrate by meeting minimum the flight-hour and currency

requirements that he or she is able to safely operate the DJI Phantom 3 Professional (UA) 

and/or the DJI Inspire 1 (UA) in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

JOHN D HANSARD seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS do 

not require airworthiness certificates in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, JOHN D HANSARD submits that he will ensure that the DJI Phantom 3 Professional

(UA) and the DJI Inspire 1 (UA) are in airworthy condition, prior to every flight, by

determining that the UASs are in compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3 Professional (UA) and the DJI Inspire 1 (UA)

Instruction Manual), and that the aircraft is in a condition for safe flight. 

JOHN D HANSARD also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS and the DJI 

Inspire 1 UAS will not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Phantom 3 Professional (UA) and DJI Inspire 1 (UA) will be 

provided to the PIC via Global Positioning System (GPS) equipment and radio 
6

communications telemetry data link, which downlinks from the UA to the ground control 

station (GCS) for active monitoring of the flight path. This altitude information, combined 

with the visual line of sight (VLOS), at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, JOHN D HANSARD seeks an exemption from the requirements of 

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

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

Professional (UA) and the DJI Inspire 1 (UA) during daylight hours in visual 

meteorological conditions (VMC) under visual flight rules (VFR), with 20 percent battery

power remaining or sufficient battery power to return to the home point (RTH). The low 

battery warning will be set to 30 percent battery remaining prior to takeoff.

In accordance with 14 C.F.R. § 11.81, JOHN D HANSARD 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:

John D. Hansard

207 N. Wieser Street

Tel: (817) 821-5000

Email: john_hansard@yahoo.com

B. The Specific Sections Of 14 C.F.R. From Which JOHN D HANSARD Seeks 

Exemption and The Extent Of Relief And The Reason For Seeking Relief

1. Section 61.113(a) And (b). 

a. Private pilot privileges and limitations: Pilot in command, subsections (a) and 

(b) prescribe the following, in relevant part: 

(1) 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. 

(2) 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. Section 91.7(a).

a. Civil aircraft airworthiness, subsection (a), states the following: 

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

3. Section 91.121.

a. Altimeter settings, subsection (a), states the following, in part: 

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

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

when operating—
7

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

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

within 100 nautical miles of the aircraft;

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. Section 91.151(b).

a. 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. Section 91.405(a).

a. 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. Section 91.407(a)(1) 

a. Operation after maintenance, preventive maintenance, rebuilding, or 

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

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

maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter[.] 
8

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

a. Inspections, subsection (a), states the following:

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

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

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

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter.

8. Sections 91.417(a) And 91.417(b). 

a. Maintenance records, subsections (a) and (b), state the following: 

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

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 

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

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

inspections, as appropriate, for each aircraft (including the airframe) and 

each engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

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

the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

each rotor. 

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

propeller, rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 
9

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

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or 

safety directive number and revision date. If the AD or safety directive 

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

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

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

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

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

approved for return to service.

C. The Extent Of Relief JOHN D HANSARD Seeks And The Reason JOHN D 

HANSARD Seeks The Relief. 

1. Extent of Relief JOHN D HANSARD Seeks And The Reason JOHN D 

HANSARD 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 conduct the 

proposed UAS flight operations for compensation or hire. 

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

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

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

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

compensation or hire. 

As set forth more fully below, JOHN D HANSARD submits that an equivalent 

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

Phantom 3 Professional UA or the DJI Inspire 1 UA unless that PIC has met certain flighthour and currency requirements, demonstrating that the PIC is able to safely operate either 
10

UA in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.

Further, JOHN D HANSARD submits that all flights of the DJI Phantom 3 

Professional UA and the DJI Inspire 1 UA, conducted by the PIC pursuant to the grant of 

this Petition: (1) will be incidental to JOHN D HANSARD’s business; and (2) will not 

carry passengers or property for compensation or hire.

2. Extent Of Relief JOHN D HANSARD Seeks And The Reason JOHN D 

HANSARD 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 JOHN D HANSARD to determine that the DJI Phantom 3 

Professional (UA) and the DJI Inspire 1 (UA) are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the 

JOHN D HANSARD Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 3 Professional or DJI Inspire 1 Instruction Manual). 

JOHN D HANSARD seeks the requested relief because the DJI Phantom 3 

Professional UA and the DJI Inspire 1 UA do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. Therefore, JOHN D HANSARD will ensure 

that the DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS are in airworthy 

condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3 Professional or the DJI Inspire 1 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 JOHN D HANSARD Seeks And The Reason JOHN D 

HANSARD 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 and the DJI Inspire 1 UAS, 

which utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry data link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information concerning 

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

JOHN D HANSARD seeks the requested relief because the DJI Phantom 3 Professional

UA’s and the DJI Inspire 1 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 both UASs are equipped with a barometric pressure sensor and GPS 

equipment, which automatically ensures that a ground level pressure setting will be 

established prior to each flight, and provides the PIC with altitude information of the UA 

on the heads-up display of the GCS.
11

4. Extent Of Relief JOHN D HANSARD Seeks And The Reason JOHN D 

HANSARD 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 and the DJI Inspire 1 UA during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with 20 percent battery

power remaining or sufficient battery power to return to the home point (RTH). The low 

battery warning will be set to 30 percent battery remaining prior to takeoff.

JOHN D HANSARD seeks the requested relief because without an exemption 

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

Professional UA and the DJI Inspire 1 UA will severely constrain the practicality of any

aerial video or still photo flight operations that JOHN D HANSARD proposes to conduct 

pursuant to this Petition.

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

Professional UAS and the DJI Inspire 1UAS operating documents, and JOHN D 

HANSARD’s proposed operating limitations ensure that JOHN D HANSARD will safely

operate the both battery powered UASs during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with 20 percent battery power 

remaining or sufficient battery power to return to the home point (RTH). The low battery

warning will be set to 30 percent battery remaining prior to takeoff.

5. Extent Of Relief JOHN D HANSARD Seeks And The Reason JOHN D 

HANSARD 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, JOHN D HANSARD requests relief 

from these Sections because the DJI Phantom 3 Professional UAS and the DJI Inspire 1 

UAS do not require airworthiness certificates. As set forth more fully below, the DJI 

Phantom 3 Professional UAS and the DJI Inspire 1 UAS meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, JOHN D 

HANSARD will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the 

UAS operating documents (i.e., the JOHN D HANSARD Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 Professional UA and the DJI Inspire 1 UA

Instruction Manual). Furthermore, JOHN D HANSARD will document and maintain all 

maintenance records for the DJI Phantom 3 Professional UA and the DJI Inspire1 UA. 
12

D. The Reasons Why Granting JOHN D HANSARD’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 public interest by allowing JOHN D 

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

of real estate, construction sites, agriculture, ranch and wildlife, weddings and private 

parties over certain areas of the United States. 

Additionally, use of the DJI Phantom 3 Professional(UA) and the DJI Inspire 1 

(UA) will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of JOHN D HANSARD’s proposed 

operation of the both 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) and the DJI Inspire1 (UA) are battery

powered and serve as a safe, efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft 

needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 

Professional (UA) and the DJI Inspire 1 (UA) will reduce the amount of manned aircraft in 

the NAS, reduce noise and air pollution, as well as increase the safety of life and property 

in the air and on the ground. 

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

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

DJI Phantom 3 Professional (UA) and the DJI Inspire 1 (UA) do not require an airport to 

takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and 

photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight 

operations.

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

Phantom 3 Professional UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS and/or 

the DJI Inspire 1 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 and the DJI Inspire 1 UAS produce no air pollution, 

and is the most viable environmentally conscious alternative to the cabin class, six cylinder 

internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. 

The DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS, while reducing the 

carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are 

propelled by battery powered electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS to 

perform aerial acquisitions, the substantial risk to life and property in the air and on the 

ground, which is usually associated with traditional manned aircraft flight operations, will 

be substantially reduced or completely eliminated. Aside from the lack of flight crew 

members located onboard the aircraft, the DJI Phantom 3 Professional (UA) and the DJI 

Inspire 1 (UA) small size and with no fuel on board have 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 
13

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

of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 3 Professional UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 Professional (UA) and 

the DJI Inspire 1 (UA) are also an economical alternative to using manned aircraft to 

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

UA and the DJI Inspire 1 UA will allow United States based companies 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 and the DJI Inspire 1 UAS will include the 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 and the DJI Inspire 1 UAS, 

companies 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 (UA) and the DJI Inspire 1 (UA), provides a stable 

workforce that increases consumer spending; improves local, state, and federal tax 

revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

decades, JOHN D. HANSARD’s proposed operation of the DJI Phantom 3 Professional 

(UA) and the DJI Inspire 1 (UA) will not implicate any privacy issues. Specifically, the 

DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS will be operated only in 

compliance with operating documents (i.e., the John D. Hansard’s Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 Professional and the DJI Inspire 1

Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, 

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

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

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

Provided By The Rule From Which JOHN D HANSARD Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 Professional UA and the DJI Inspire 1

UA Meet The Conditions Of The FAA Modernization and Reform Act of 

2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated 

with the unmanned aircraft and its operation, JOHN D. HANSARD’s operation of the DJI 

Phantom 3 Professional (UA) and the DJI Inspire 1 (UA) 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.
14

Section 333 provides authority for a UAS to operate without airworthiness 

certification and sets forth requirements for considering whether a UAS will create a 

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

Specifically, FMRA Section 333 states the following, in part: 

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

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

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required by 

section 334 of this Act. 

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

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

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

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 

a hazard to users of the national airspace system or the public or pose a 

threat to national security; and

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

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this 

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, JOHN D. HANSARD submits that the DJI Phantom 3 

Professional (UA) and the DJI Inspire 1 (UA) can operate safely in the NAS pursuant to 

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

Professional and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the 

specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 Professional 1 UAS and the 

DJI Inspire 1 UAS Demonstrate Their Safe Characteristics.

The DJI Phantom 3 Professional UA and the DJI Inspire 1 UA do not create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security 

considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 UAS and the 

DJI Inspire 1 UAS. 

The technical specifications of the DJI Phantom 3 Professional UAS and the DJI 

Inspire 1 UAS are set forth by their respective Professional Specifications and Data Sheet.
15

ii. The DJI Phantom 3 Professional UAS and the DJI the DJI Inspire 1 

UAS Autonomous Flight And Navigation Modes Enable The UASs 

To Remain Within A Defined Operational Area. 

The DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS may be operated 

in both manual and fully autonomous flight modes. A complete description of the flight 

and navigational modes of both UASs are provided in their respective operation manuals.

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 and the DJI

Inspire 1 UA will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the 

DJI Phantom 3 Professional UA or the DJI Inspire 1 UA do not reacquire control link data 

from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to 

the home point (RTH) (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown. 

The Failsafe Functions for each of the UASs are set forth in their respective User 

Manuals.

iv. The DJI Phantom 3 Professional and the DJI Inspire 1 GCS and 

Their Operation.

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

Professional and the DJI Inspire 1 GCS and flight control software is provided in their 

respective User Manuals. 

b. Flight Operations Of DJI Phantom 3 Professional UAS and the DJI 

Inspire 1 UAS Are Limited To The Line Of Sight Of A Certificated Pilot 

in Command With A Safety Observer. 

JOHN D HANSARD 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 

Professional UAS or the DJI Inspire 1 UAS. Additionally, a safety observer will assist the 

PIC during flight time.

c. Flights of DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS

Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, JOHN D HANSARD proposes to commercially operate

the DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS for the special purpose of 

conducting aerial video and photography over certain areas of United States, pursuant to 

the following specific operating limitations:

1. UAS’s Authorized Under This Exemption

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

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Phantom 3 

Professional and the DJI Inspire 1 Unmanned Aircraft Systems. 
16

 Proposed operations of any other aircraft will require a new petition or a petition 

to amend this grant. 

 

2. UAS Operations Under This Exemption 

 UAS operations under this exemption will be limited to conducting operations 

for the purpose of aerial video and photography.

3. Speed Limitations

 The UAs may not be flown at an indicated airspeed exceeding 30 knots

4. Altitude Limitation

 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. Visual Line Of Site (VLOS) Limitation

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

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

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

medical certificate. 

6. First Person View (FPV) Not Permitted

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

permitted. 

7. Safety Observer Requirement

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

the VLOS requirement as long as the PIC always maintains VLOS capability. 

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

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

designated before the flight and cannot transfer his or her designation for the 

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

functions prescribed in the operating documents. 

8. Safety Observer Limitations

 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. Operator’s Responsibilities

 The operating documents and the grant of exemption must be accessible during 

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

discrepancy exists between the conditions and limitations contained in the grant 

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

conditions and limitations contained in the grant of exemption take precedence 

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

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

operating documents. It is the operator’s responsibility to track such revisions 
17

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

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

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

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

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

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

questions arise regarding updates or revisions to the operating documents. 

10. PIC Requirement for Inspection

 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. Functional Flight Test After Maintenance or Alterations

 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. Pre-flight Inspections

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

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

relevant sections of the operating documents. 

13. UAS Manufacturer’s Life Cycle Requirements

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

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

14. Maintenance and Record Keeping

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

requirements, in accordance with the operating documents. Maintenance, 

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

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

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

UAS to service. 

15. Manufacturer Safety Bulletins

 Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

16. Corrective Action Entries

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

corrective action taken against discrepancies discovered between inspections.
18

17. PIC Requirements

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

third- class medical certificate or adhere to all commercial drone PIC FAA 

requirements at the time of operations.

18. UAS Training and Proficiency Requirements

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

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

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, 

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

operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 

91.119. 

19. Prohibited Night Operations

 UAS operations may not be conducted during night, as defined in 14 C.F.R. § 

1.1. All operations must be conducted under visual meteorological conditions 

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

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

rules (SVFR) are not authorized. 

20. Restricted Airport Operations

 The UA may not operate within 5 nautical miles of an airport reference point as 

denoted on a current FAA-published aeronautical chart unless a letter of 

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA.

The letter of agreement with the airport management must be made available to 

the Administrator upon request. 

21. Cloud and Visibility Limitations

 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. Loss of Signal

 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. Unpredicted Obstacles and Emergencies

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

emergencies in accordance with the operating documents. 
19

24. PIC Requirement to be Able to Return Home Safely

 The PIC is prohibited from beginning a flight unless he has considered the wind 

and forecast weather conditions and unless he is confident that the UA can 

return the intended landing point and land. The UA’s have a return-to-home 

(RTH) failsafe which will be used only in emergencies.

25. COA and NOTAM Requirements

 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. Registration and Serial Number Requirements

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

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

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

Subpart C. Markings must be as large as practicable. 

27. Radio Frequency Spectrum Compliance

 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. Documents Available to PIC at the Ground Control Station (GCS)

 The documents used by the operator to ensure the safe operation and flight of 

the UA and any documents required under 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. Yield Right of Way

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

operations and activities at all times. 

30. Operation from Moving Vehicle 

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

31. Operating Limitations near Persons

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

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

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect 

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

accident. The operator must ensure that nonparticipating persons remain 

under such protection. If a situation arises where nonparticipating 
20

persons leave such protection and are within 500 feet of the UA, flight 

operations must cease immediately and/or; 

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

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

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

do not present an undue hazard to those persons per § 91.119(a). 

32. Operating Limitations over Property

 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. Incident or Accident Reporting

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

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

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

hours. Accidents must be reported to the National Transportation Safety Board 

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

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

And (b) Would Not Adversely Affect Safety.

JOHN D HANSARD submits that the equivalent level of safety established by

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

DJI Phantom 3 Professional (UA) or the DJI Inspire 1 (UA) unless that PIC has 

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

able to safely operate the UAS’s in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering JOHN D HANSARD’s proposed area of operations and the operating 

limitations set forth above and the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the DJI Phantom 3 Professional (UA)

and/or the DJI Inspire 1 (UA), JOHN D HANSARD submits that the additional manned 

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

airmanship skills necessary for JOHN D HANSARD 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). 
21

JOHN D HANSARD will not allow any PIC to operate the DJI Phantom 3 

Professional UAS or the DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting 

minimum flight-hour requirements of the UAS training and currency requirements, that the 

PIC is able to safely operate the UAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

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

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

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

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

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

purposes). 

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

experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during JOHN D HANSARD’s proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

included in the 10 hours of multi-rotor time and the 10 hours may be included in 

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

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

currency purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 

Accordingly, JOHN D HANSARD will ensure safe operations by not allowing any 

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

PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that 

the PIC is able to safely operate the specified UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.
22

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, JOHN D HANSARD will ensure that the DJI Phantom 3 

Professional (UA) and the DJI Inspire 1 (UA) are in an airworthy condition based upon the 

UAS’s compliance with its operating documents and as stated in the conditions and 

limitations herein. 

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

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

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

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

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

because the altitude information of the DJI Phantom 3 Professional (UA) and the DJI 

Inspire1 (UA) will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the 

flight path and altitude. This altitude information, combined with JOHN D HANSARD’s 

operation of the DJI Phantom 3 Professional (UA) and the DJI Inspire 1 (UA) within visual 

line of sight (VLOS), at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. The altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically

established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

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

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

Would Not Adversely Affect Safety.

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

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

Phantom 3 Professional UAS and the DJI Inspire 1 UAS; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, JOHN D HANSARD will ensure that it will safely operate the battery

powered DJI Phantom 3 Professional (UA) and the DJI Inspire 1 (UA) during daylight 

hours in VFR conditions, with 20 percent battery power remaining or sufficient battery

power to return to the home point (RTH). The low battery warning will be set to 30 percent 

battery remaining prior to takeoff.
23

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

Professional UAS and the DJI Inspire 1 UAS; the limitations on the proposed flight 

operations; and the location of the proposed operations, will ensure an equivalent level of 

safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as 

the DJI Phantom 3 Professional UAS provide audible and visual warnings to the PIC at the 

GCS when the UAs experiences low battery voltage, the first warning occurring at 

approximately 30% remaining battery power, and again at approximately 10% remaining 

battery power. At the critically low battery level, the DJI Phantom 3 (UA) and the DJI 

Inspire 1 (UA) will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

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

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

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

Not Adversely Affect Safety. 

In seeking this exemption, JOHN D HANSARD 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 JOHN D HANSARD will use trained technicians to perform maintenance, 

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

practices prescribed in the operating documents (i.e., the JOHN D HANSARD Aerial 

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

DJI Inspire 1 Instruction Manuals). Furthermore, JOHN D HANSARD will document and 

maintain all maintenance records for both UASs. 

Since the both UASs will be inspected as prescribed by the operating documents, 

JOHN D HANSARD will maintain the equivalent level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). 

Likewise, the exemption sought will not adversely affect safety because JOHN D 

HANSARD 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 

both the DJI Phantom 3 Professional UAS and the DJI Inspire1 UAS will be performed by 

trained technicians. Maintenance will be documented and maintained utilizing the monthly 

maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 
24

In consideration of JOHN D HANSARD proposed operating limitations, the 

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

and the DJI Inspire 1 UAS JOHN D HANSARD submits that safety will not be adversely

affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and 

(a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific 

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

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

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

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

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, JOHN D HANSARD requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

Professional UAS and the DJI Inspire 1 UAS, which contain such safety standards that the 

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

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

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

special conditions will permit safe operation of the UAs for the limited purpose of 

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

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

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

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 3 Professional UAS and DJI Inspire 1 UAS, 

since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or 

appropriate safety standards, due to the novel or unusual design features of the aircraft. 

Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

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

may prescribe special conditions for the intended operation of the DJI Phantom 3 

Professional UAS and the DJI Inspire 1 UAS, which contain such safety standards that the 

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

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

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).
25

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

From Which JOHN D HANSARD Seeks Exemption: 

JOHN D HANSARD 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 JOHN D HANSARD

Seeks: 

This exemption will permit JOHN D HANSARD to commercially operate an 

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

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support 

JOHN D HANSARD’s Request. 

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

(FMRA), Section 333. The act directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, JOHN D HANSARD request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above. 

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

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

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

certification. 

As discussed in detail above, JOHN D HANSARD will operate the DJI Phantom 3 

Professional UAS and the DJI Inspire 1 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.
26

CONCLUSION

As set forth herein, JOHN D HANSARD 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 UA and the DJI Inspire 

1 UA commercially, without an airworthiness certificate, for the limited purpose of 

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

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate 

of the FAA Modernization and Reform Act of 2012, while also advancing the interests of 

the public, by allowing JOHN D HANSARD to safely, efficiently, and economically 

operate the DJI Phantom 3 Professional UAS and the DJI Inspire 1 UAS commercially

within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, JOHN D HANSARD 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 JOHN D. HANSARD to operate 

the DJI Phantom 3 Professional UA and the DJI Inspire 1 UA commercially for the 

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

Dated: December 15, 2015

Respectfully submitted,

John D. Hansard

_________________________

John D. Hansard

207 N. Wieser Street

Hamilton, TX 76531

Tel: (817) 821-5000
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Appendices:

A – DJI Phantom 3 Professional Specifications Data Sheet

B – DJI Inspire1 Specifications Data Sheet

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

DJI is an industry leader in small UAS production. DJI UASs are loaded with ground 

breaking software enabling the user to set parameters which will not allow flight into 

controlled airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set distance. In 

addition, DJI software provides real-time altitude and location information to the PIC via 

the linked monitor (smart phone/tablet devices).

A – DJI Phantom 3 Professional Specifications Data Sheet may be found at:

 http://www.dji.com/product/phantom-3pro/info#specs

B – DJI Inspire1 Specifications Data Sheet may be found at:

 http://www.dji.com/product/inspire-1/info#specs