UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Cellcom Inc.

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 2 VISION+ AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on November 20, 2015 

Cellcom Inc. 

42650 Long Lake Rd. 

Ottertail, MN 56571 

Tel: (218) 849-8087 

almw@eot.com 
2 

TABLE OF CONTENTS

Page 

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

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

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

BACKGROUND....................................................................................................................5 

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Cellcom Inc. SEEKS 

EXEMPTION.................................................................8 

THE EXTENT OF RELIEF Cellcom Inc. SEEKS AND THE REASON Cellcom 

Inc. SEEKS THE RELIEF.........................11 

THE REASONS WHY GRANTING Cellcom Inc.’S REQUEST WOULD BE IN 

THE PUBLIC INTEREST .........................................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..........................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT Cellcom Inc.’S REQUEST.........34 

CONCLUSION....................................................................................................................36 

APPENDICES........................................................................................38 
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

Cellcom Inc. 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 Cellcom Inc. to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

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

over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Cellcom Inc. provides its clients with expertise and knowledge in advanced technologies and solutions to increase efficiency, productivity and effectiveness. Cellcom Inc. 

has over 13 years of professional experience in Information Technology and is recognized 

as an expert in network infrastructure, project management and Construction management. 

Cellcom Inc. has over 3 years recreational/hobby experience in all aspects of aerial video 

and photography. The objective of Cellcom Inc.’s aerial video and photography operations 

is to provide high quality imaging for a variety of commercial, public, and residential uses, 

specifically targeting: 

• Sourcing GIS tagged aerial images for use in Computer Assisted Mass Appraisal (CAMA) systems.

• Motion Picture Filming

• Aerial acquisitions used for inspections of public and private structures.

• Increase public knowledge of UAS and promote safe UAS operations.

• Search and Rescue operations utilizing Thermal imaging
5 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs+ DJI Matrice 

100 Cellcom Inc. seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station 

(GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a 

maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 

inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 

knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 

17.3 inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of approximately 42 knots. The DJI Matrice 100+ has a maximum gross weight of approximately 5 

pounds 9 ounces, while having a length of 25 inches width of 25 inches, height of 8 inches, 

and a maximum speed of approximately 19 knots. The DJI Phantom 2 Vision+ and DJI Inspire 1+ Matrice 100 UAs are equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors. 

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs + DJI Matrice 100 that will be 

operated by Cellcom Inc. will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking. 
6 

BASIS FOR PETITION

Petitioner, Cellcom Inc., 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 2 Vision+, DJI Inspire 1 + DJI 

Matrice 100 UASs 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, Cellcom Inc.’s operation of DJI Phantom 2 

Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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, Cellcom Inc. 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. 

Cellcom Inc. submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Cellcom Inc. will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 Instruction 

Manual). Furthermore, Cellcom Inc. will document and maintain all maintenance records 

for the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs. 
7 

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

privileges and limitations: Pilot in command, is requested by Cellcom Inc. to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Cellcom Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, Cellcom Inc. submits that he will ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs are in an 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 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 Instruction Manual), and that the aircraft are in a condition for safe flight. 

Cellcom Inc. also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 

100 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring

of the flight path. This altitude information, combined with Cellcom Inc.’s operation of the 
8 

DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs within visual line of 

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Cellcom Inc. seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. Cellcom Inc. submits 

that safety will not be affected by operation of the DJI Phantom 2 Vision+ and DJI Inspire 

1 + DJI Matrice 100 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 13.5 minutes to the first point of intended landing and, assuming 

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

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

Cellcom Inc. 

42650 Long Lake Rd. 

Ottertail, MN 56571 

Tel: (218) 849-8087 

Email: almw@eot.com 

B. The Specific Sections Of 14 C.F.R. From Which Cellcom Inc. Seeks Exemption. 

1. Cellcom Inc. Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

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

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

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

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

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

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if— 

(1) The flight is only incidental to that business or employment; and 
9 

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

2. Cellcom Inc. 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. Cellcom Inc. Seeks Exemption From The Requirements Of Section 91.121. 

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

part: 

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

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

when operating-- 

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

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

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before departure. 

4. Cellcom Inc. Seeks Exemption From The Requirements Of Section 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection 

 (b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the 

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

that for at least 20 minutes. 

5. Cellcom Inc. 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— 
10 

(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. Cellcom Inc. Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: 

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

maintenance, rebuilding, or alteration unless-- 

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

43.7 of this chapter[.] 

7. Cellcom Inc. Seeks Exemption From The Requirements Of Sections 

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

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

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

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

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

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

chapter; or 

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

with part 21 of this chapter. 

8. Cellcom Inc. Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

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

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved 

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

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

include-- 

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

the work performed; and 

(ii) The date of completion of the work performed; and 
11 

(iii) The signature, and certificate number of the person approving the aircraft for return to service. 

(2) Records containing the following information: 

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

each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 

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

last inspection required by the inspection program under which the aircraft and its appliances are maintained. 

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

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

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

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

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

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

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

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

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

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

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

approved for return to service. 
12 

C. The Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. Seeks The 

Relief. 

1. Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. 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, Cellcom Inc. submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS or DJI Inspire 1 UAS+ DJI Matrice 100 UAS unless that PIC has met certain 

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

either the DJI Phantom 2 Vision+ or DJI Inspire 1+ DJI Matrice 100 UAS in a manner 

consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, 

vessels, vehicles and structures. 
13 

Further, Cellcom Inc. submits that all flights of the DJI Phantom 2 Vision+ and DJI

Inspire 1 + DJI Matrice 100 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Cellcom Inc.’s business; and (2) will not carry passengers or 

property for compensation or hire. 

2. Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. 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 Cellcom Inc. to determine that the DJI Phantom 2 Vision+ and DJI 

Inspire 1 + DJI Matrice 100 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Cellcom Inc. 

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and 

DJI Inspire 1+ DJI Matrice 100 Instruction Manual). 

Cellcom Inc. seeks the requested relief because the DJI Phantom 2 Vision+ and DJI 

Inspire 1 + DJI Matrice 100 UASs do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. Therefore, Cellcom Inc. will ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs are in airworthy condition based 

upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and 

DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 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 Cellcom Inc. Seeks And The Reason Cellcom Inc. 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs, 

which utilize a barometric pressure sensor, GPS equipment, and a radio communications
14 

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), 

Cellcom Inc. seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 

1 + DJI Matrice 100 UA’s altimeter may be set on the ground to zero feet AGL, rather than 

the local barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be 

maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs are 

equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. 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 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 

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

fly after that for at least 4.5 minutes. Cellcom Inc. seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered 

DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UAs will severely constrain 
15 

the practicality of any aerial video or still photo flight operations that Cellcom Inc. proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 operating documents, and Cellcom Inc.’s proposed operating limitations, ensure 

that Cellcom Inc. will safely operate the battery powered DJI Phantom 2 Vision+ and DJI 

Inspire 1+ DJI Matrice 100 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 13.5 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes. 

5. Extent Of Relief Cellcom Inc. Seeks And The Reason Cellcom Inc. 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, Cellcom Inc. requests relief from 

these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 

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

Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs meet the conditions of 

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Cellcom Inc. 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 Cellcom Inc. Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 Instruction Manual). Furthermore, Cellcom Inc. will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs. 
16 

D. The Reasons Why Granting Cellcom Inc.’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 Cellcom 

Inc. to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 

100 UASs will decrease congestion of the NAS, reduce pollution, and provide significant 

benefits to the economy. Notably, the benefits of Cellcom Inc.’s proposed operation of the 

DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs will be realized without 

implicating any privacy issues. 

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

The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs are battery 

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

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

needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 

Vision+ or DJI Inspire 1+ DJI Matrice 100 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs do not require an airport 

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

photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 
17 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1+ 

DJI Matrice 100 UASs, 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces and 

5 pounds 2 ounces respectively, at their maximum gross weights with lengths of 16 inches 

and 17.3 inches and 25.6 inches respectively, widths of 16 inches and 17.7 inches and 25.6 

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

damage to life and property on the ground, and in the air, compared to the manned aircraft 
18 

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

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

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs Will Benefit The 

Economy. 

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire 

1 + DJI Matrice 100 UASs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ and 

DJI Inspire 1+ DJI Matrice 100 UASs will allow United States based companies, like Cellcom Inc., 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 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 

UASs is one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational 

cost of a traditional manned aircraft. 

By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 

UASs, companies such as Cellcom Inc., 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 

UASs, provides a stable workforce that increases consumer spending; improves local, 
19 

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, Cellcom Inc.’s proposed operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 + 

DJI Matrice 100 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 

2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs will be operated only in compliance

with operating documents (i.e., the Cellcom Inc. Aerial Operations Manual, Monthly

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 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 Cellcom Inc. Seeks Exemption. 

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 

100 UAs Meet The Conditions Of The FAA Modernization and Reform Act 

of 2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, Cellcom Inc.’s operation of the DJI Phantom 

2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs meet the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 

21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to 
20 

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, Cellcom Inc. submits that the DJI Phantom 2 Vision+ 

and DJI Inspire 1+ DJI Matrice 100 UASs can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs; (b) the pilot certification requirement; 

and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1+ 

DJI Matrice 100 UASs Demonstrate Its Safe Characteristics. 

The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs 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. 
21 

i. Technical Specifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. 

The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI 

Matrice 100 UASs are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 Specifications and Data Sheet, attached hereto as Exhibit A and B and C. 

ii. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 

UASs Autonomous Flight And Navigation Modes Enable The UASs 

To Remain Within A Defined Operational Area. 

The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the 

flight and navigational modes of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs is provided at pages 25-35 of the DJI Phantom 2 Vision+ and pages 12-16 

and 45-50 of the DJI Inspire 1 + DJI Matrice 100 User Manuals, attached hereto as Exhibit 

D and E and F. 

iii. The DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100

UASs Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI 

Matrice 100 UAs will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs 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 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 2 Vision+ 

UAS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 
22 

of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 User Manuals, attached 

hereto as Exhibit D and E and F. 

iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100

GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1+ DJI Matrice 100 GCS and flight control software is provided at 

pages 32 through 43 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 

of the DJI Inspire 1 User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 

100 User Manuals are attached hereto as Exhibits D and E and F. 

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI 

Matrice 100 UASs Are Limited To The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer. 

Cellcom Inc. 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 2 Vision+ 

and DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight 

time. 

c. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100

UASs Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, Cellcom Inc. proposes to commercially operate DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs for the special purpose of conducting aerial 

video and photography over certain areas of United States, pursuant to the following specific operating limitations: 

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

aircraft described in the operating documents, rotorcraft UASs weighing less 

than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ and DJI Inspire 

1 + DJI Matrice 100 Unmanned Aircraft Systems. Proposed operations of any 

other aircraft will require a new petition or a petition to amend this grant. 
23 

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

for the purpose of aerial video and photography. 

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

 

4. The UA must be operated at an altitude of no more than 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 unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate. 

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

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

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

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

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

designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the SO can perform the functions 

prescribed in the operating documents. 

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

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

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

UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and 

must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating 

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

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

must also present updated and revised documents if it petitions for extension or 

amendment to the grant of exemption. If the operator determines that any update

or revision would affect the basis upon which the FAA granted the exemption, 

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

FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 
24 

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary

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

safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the 

aircraft records. 

 

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

operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents. 

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

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

requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must 

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

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

UAS to service. 

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

Safety Bulletins. 

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

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

third- class medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification 

flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). 

Flights for the purposes of training the operator’s PICs are permitted under the 

terms of the exemption. However, training operations may only be conducted 

during dedicated training sessions. During training, proficiency, and experi-
25 

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

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

1.1. All operations must be conducted under visual meteorological conditions 

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

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

rules (SVFR) are not authorized. 

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

denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The 

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

Administrator upon request. 

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

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

PIC. 

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

in accordance with the operating documents. 

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operating documents. 

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

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

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

remaining. 

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

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

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

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

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

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

altitude level and potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. 

Markings must be as large as practicable. 
26 

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

and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is 

operating. These documents must be made available to the Administrator or any 

law enforcement official upon request. 

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

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

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

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

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

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

owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and; 

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

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

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

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

Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 

 

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must 

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

Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 
27 

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

And (b) Would Not Adversely Affect Safety. 

Cellcom Inc. 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 2 Vision+ and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting 

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

DJI Phantom 2 Vision+ or DJI Inspire 1 + DJI Matrice 100 UAS in a manner consistent 

with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

Considering Cellcom Inc.’s proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1+ 

DJI Matrice 100 UAS, Cellcom Inc. submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Cellcom Inc.’s specific proposed flight operations. 

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

UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

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

Cellcom Inc. will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI 

Inspire 1+ DJI Matrice 100 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour requirements or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS training and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or 
28 

DJI Inspire 1+ DJI Matrice 100 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 Cellcom Inc.’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 experiencebuilding flights can also be conducted under the grant of exemption to accomplish 
29 

the required flight time. During training, proficiency, and experience-building 

flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Cellcom Inc. will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 2 Vision+ or DJI Inspire 1+ DJI Matrice 100 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 2 Vision+ or DJI Inspire 1+ DJI Matrice 100

UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Cellcom Inc. will ensure that the DJI Phantom 2 Vision+ or DJI 

Inspire 1+ DJI Matrice 100 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein. 

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

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

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

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

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

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the
30 

flight path and altitude. This altitude information, combined with Cellcom Inc.’s operation 

of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UAs within visual line 

of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

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

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

by the 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, 

Cellcom Inc. will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in VFR conditions, with enough battery 

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the 

location of the proposed operations, will ensure an equivalent level of safety established by 
31 

14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs provide audible and visual warnings to 

the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom Vision+ and 

DJI Inspire 1+ DJI Matrice 100 UASs 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, Cellcom Inc. 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 Cellcom Inc. 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 Cellcom Inc. Aerial Operations Manual, Monthly 
32 

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 Instruction Manual). Furthermore, Cellcom Inc. will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. 

Since the DJI Phantom 2 Vision+ and DJI Inspire 1 + DJI Matrice 100 UASs will 

be inspected as prescribed by the operating documents, Cellcom Inc. will maintain the 

equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 

User Manuals are attached hereto as Exhibit C and D; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Maintenance LOG is attached hereto as Exhibit E. 

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

Inc. will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating 

documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI 

Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs 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. 
33 

In consideration of Cellcom Inc.’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI 

Matrice 100 UASs, Cellcom Inc. 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, Cellcom Inc. requests that the 

FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision+ 

and DJI Inspire 1+ DJI Matrice 100 UASs, 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. 
34 

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

§ 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 

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

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

Section 21.16, entitled Special Conditions, states the following: 

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

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

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. 

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

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

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

the regulations. 

See 14 C.F.R. § 21.16. 

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

may prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs, 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). 

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

From Which Cellcom Inc. Seeks Exemption: 

Cellcom Inc. 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 Cellcom Inc. Seeks: 
35 

This exemption will permit Cellcom Inc. 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 Cellcom 

Inc.’s Request. 

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

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain 

UAS may operate safely in the NAS. As such, Cellcom Inc.’s request for exemption may 

be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set 

forth above. 

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

create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness 

certification. 

As discussed in detail above, Cellcom Inc. will operate the DJI Phantom 2 Vision+

and DJI Inspire 1+ DJI Matrice 100 UASs safely in the NAS, without creating a hazard to 

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

CONCLUSION

As set forth herein, Cellcom Inc. 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 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 

UASs 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 
36 

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

public, by allowing Cellcom Inc. to safely, efficiently, and economically operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs commercially within the 

NAS. 

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

Modernization and Reform Act of 2012, Section 333, Cellcom Inc. respectfully requests

that the Administrator grant this Petition for an exemption from the requirements of 14

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1+ DJI Matrice 100 UASs commercially for the purpose of conducting aerial video and photography over certain areas of the United States.

Dated: November 20, 2015 

 Respectfully submitted, 

 Cellcom Inc. 

 

 _________________________ 

 Cellcom Inc. 

 42650 Long Lake Rd. 

 Ottertail, MN 56571 

 Tel: (218) 849-8087 

 almw@eot.com 
37 

Appendices: 

A – DJI Phantom 2 Vision+ Specifications Data Sheet 

B – DJI Inspire 1 Specifications Data Sheet 

C – DJI Matrice 100 Specifications Data Sheet 

D – DJI Phantom 2 Vision+ Manufacturer’s User Manual 

E – DJI Inspire 1 Manufacturer’s User Manual 

F– DJI Matrice 100 Manufacturer’s User Manual 

G – Monthly Maintenance Log 

APPENDIX – A 

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS 

Cellcom Inc. only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

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

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

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

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

1.1 DJI Phantom 2 Vision+ 

1.1.1 Aircraft 

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 

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

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

1.1.1.4 Max Yaw Angular Velocity - 200/s 

1.1.1.5 Max Tilt Angel - 35

1.1.1.6 Max Ascent Speed – 6m/s 
38 

1.1.1.7 Max Descent Speed – 2m/s 

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

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

1.1.2.2 Control Accuracy - ±0.03

1.1.2.3 Controlable Range – Pitch: -90 - 0

1.1.2.4 Maximum Angular Speed – Pitch: 90/s 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 32F - 104F (0C - 40C) 

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M 

1.1.3.4 Resolution – 4384x3288 

4.1.3.5 HD Video Recording – 1080p30 & 720p 

4.1.3.6 Recording Field of View - 110/85

1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW 

1.1.4.5 Working Voltage – 120mA@3.7V 

1.1.5 Range Extender 

1.1.5.1 Operating Frequency – 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed) – 500-700m 

1.1.5.3 Transmitter Power – 20dBm 

1.1.5.4 Power Consumption – 2W 
39 

APPENDIX – B 

DJI INSPIRE 1 Pro TECHNICAL SPECIFICATIONS 

Cellcom Inc. only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

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

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

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

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

2.2 DJI Inspire 1 

2.2.1 Aircraft 

2.2.1.1 Model – T600 

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 4500m 

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X5 

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300
40 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 

2.2.3.1 Name – X3 

2.2.3.2 Model – FC350 

2.2.3.3 Total Pixels – 12.76M 

2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 

1280x720p24/25/30/48/50/60 

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

2.2.4 Transmitter 

2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 

2.2.4.6 Battery – 600mAh LiPo 2S 

APPENDIX – C 
41 

DJI Matrice 100 TECHNICAL SPECIFICATIONS 

Cellcom Inc. only utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

production. DJI UASs are loaded with ground breaking software enabling the user to set 

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

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

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

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

2.2 DJI Matrice 100 

2.2.1 Aircraft 

2.2.1.1 Model – DJI E-Series 620D 

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 4500m 

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 40 minutes

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345s 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

2.2.1.15 Dimensions – 25.6” x 25.6” 

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X5 

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.030

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 
42 

2.2.3.1 Name – X5 

2.2.3.2 Model – Zenmuse X5 

2.2.3.3 Total Pixels – 16MP 

2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 

1280x720p24/25/30/48/50/60 

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

2.2.4 Transmitter 

2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 

2.2.4.6 Battery – 600mAh LiPo 2S 

APPENDIX – D 
43 

DJI Phantom 2 Vision+ Manufacturer’s User Manual 

http://download.dji-innovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.2_en.pdf 

APPENDIX – E 

DJI Inspire 1 Manufacturer’s User Manual 

http://192.168.1.1:8181/http:/download.dji-innovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf 

APPENDIX – F 

DJI Matrice 100 Manufacturer’s User Manual 

http://192.168.1.1:8181/http:/download.dji-innovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pdf 
44 

APPENDIX – G 

Maintenance Log 

 

Date issue 

discovered

Date issue 

resolved 

Issue Description/Mainenance 

Conducted 

 Repair/ Maintance 

performed By 

Airframe 

Motor 

Propellers 

Flight Control Update 

Gimbal 

Misc 
45