March 11, 2016

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue

Room W12-140

West Building Ground Floor

Washington, DC 20590-0001

RE: Petition for Exemption under Section 333 FAA Modernization and Reform 

Act of 2012, Public 112-95 February 14, 2012, Section 333

Dear Sir or Madam:

Attached you will find my request for an exemption from the listed Federal

Aviation Regulations to allow for commercial operations of a small Unmanned 

Aircraft System (UAS) for aerial videography and photography for public and 

private use including, but not limited to, marketing of residential and commercial 

real estate.

I thank you for your time and consideration of this request. Should you have any 

questions or concerns please do not hesitate to contact me.

Introduction

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the 

Reform Act) and 14 C.F.R. Part 11, Kenneth Duquaine (DBA Aerial Photography 

Services), hereby applies for an exemption from the listed Federal Aviation 

Regulations (FARs) to allow commercial operation of his small Unmanned 

Aircraft Systems (UAS) for aerial imaging of residential and commercial real 

estate for advertising purposes so long as such operations are conducted within 

and under the conditions outlined herein or as may be established by the FAA as 

required by Section 333.

As detailed in this document, the requested exemption would permit the 

operation of UAS under controlled conditions in airspace that is 1) limited, 2) 

predetermined, 3) controlled as to access, and 4) would provide safety 

enhancements to the already best practices safety protocols followed by the 

applicant. Approval of this exemption would thereby enhance safety and fulfill 

the Secretary of Transportation's (the FAA Administrator's) responsibilities to

"...establish requirements for the safe operation of such aircraft systems in the 

national airspace system" section 333(c) of the Reform Act.

This exemption request is specifically for the use of a DJI Phantom 2 Vision+, 

which is on the FAA list of approved UAS under Section 333 as of February 18, 

2016.

Regulations from which the exemption is requested: 

14 C.F.R. Part 21
14 C.F.R. 45.23(a & b)

14 C.F.R. 61.113 (a & b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109 (a)

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a) and (b). 

Exemption Applicant Contact Information

Kenneth R. Duquaine

4397 Top O Pines Drive

Holly, MI 48442

(248) 634-2122

(248) 634-2123

(248) 342-0790 (mobile)

kduquaine@hotmail.com

windshoppe@comcast.net

Intended SUAS Use

The petitioner, Kenneth Duquaine, plans to use UAS in order to capture aerial 

video and photographs for the purpose of enhancing real estate listings. By 

allowing the requested exemption, FAA will provide the petitioner with a method

for capturing aerial photos and video that are more economically accessible to 

the communities he intends to serve, more environmentally friendly, and safer 

because of the UAS’s light weight, lack of combustible fluids, and not having to 

carry human occupants. The petitioner believes such advantages to be in the 

public’s best interests. All deployment of UAS for the purposes stated will be 

with the permission of property owners.

Extent of Relief Sought and Reasons for Seeking Relief

Kenneth Duquaine submits this petition in accordance with Reform Act, 112 P.L. 

95 §§ 331-334, seeking relief from any currently applicable federal aviation 

regulations FARs pertaining to operation of UAS which prevent the petitioner

from commencing commercial photographic flight operations within the U.S. 

national airspace. The Reform Act in § 332 provides for such integration of civil 

UAS into our national airspace system as it is in the public’s interest to do so. 
The petitioner’s small and lightweight UAS, not exceeding 7 lbs, meets the 

definition of “small unmanned aircraft” as set forth in § 331. 

The petitioner requests exemption to use his UAS to capture videography and 

photography for real estate listings. The petitioner understands that the FAA is 

committed to safely integrating UAS into national airspace and believes that his 

many hours of experience safely operating UAS since the advent of the 

technology qualifies him as a candidate for exemption. Additionally, the 

petitioner requests the following facts be taken into consideration:

a. The size and weight of his UAS is under 7 lbs 

b. His UAS will be operated commercially at low speeds always less than 20 

knots 

c. His UAS is outfitted with the most up to date safety and fail-safe features 

d. The petitioner is a very experienced UAS operator 

e. The petitioner will strictly adhere to all of the “Conditions and Limitations” 

applied to recent grants for similar petitions, as well as any introduced in the 

future.

The petitioner requests exemption from the following specific regulations: 

14 C.F.R Part 21 Certification Procedures for Product and Parts, 

Airworthiness Certificates 

The FAA is authorized to exempt UAS from the requirement for an airworthiness 

certificate upon consideration of the size, speed, weight, operational capability, 

proximity to airports and populated areas, and whether operation within visual 

line of sight creates a hazard to users of the national airspace system or the 

public. Because the petitioner plans to operate a DJI Phantom 2 Vision +, 

weighing no more than 7 lbs under extremely controlled circumstances as set 

forth herein and intends to keep speeds at less than 20 knots, he requests an 

exemption from the above. 

14 C.F.R. 45.23 (b) Display of Marks: General and 45.29 Size of Marks 

(a) Each operator of an aircraft must display on that aircraft marks 

consisting of the Roman capital letter "N" (denoting United States 

registration) followed by the registration number of the aircraft. Each 

suffix letter used in the marks displayed must also be a Roman 

capital letter. 

(b) When marks include only the Roman capital letter “N” and the 

registration number is displayed on limited, restricted or light-sport 

category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to 

the cabin, cockpit, or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words “limited,” “restricted,” “lightsport,” “experimental,” or “provisional,” as applicable.
The size of the UAS the petitioner plans to use is not large enough to 

accommodate the required size of the registration numbers. The petitioner

requests relief from the above requirement on the grounds that it is not applicable 

at this time. The petitioner’s UAS is currently registered with the FAA and its 

applicable registration numbers are displayed on the UAF as required under the 

existing FAA guidelines.

14 C.F.R. 61.113 (a) & (b) Private Pilot Privileges and Limitations: Pilot in 

Command 

(a) Except as provided in paragraphs (b) through (h) of this section, no 

person who holds a private pilot certificate may act as pilot in command of 

an aircraft that is carrying passengers or property for compensation or 

hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in command 

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. 

The petitioner’s UAS will not carry a pilot or passengers. Traditional operations 

in the past required a person or persons to elevate in a potentially combustible 

vehicle in order to carry out the same operations the petitioner plans to 

accomplish by way of UAS. Because the petitioner will operate in a controlled 

environment, at low altitudes and speeds, with no persons on board, using a light 

weight vehicles, the risks are substantially less than in the past. The petitioner

also requests exemption regarding the limitations of compensation for hire since 

he will be charging clients for videography and photography in the real estate 

market. 

14 C.F.R. 91.7 Civil Aircraft Worthiness 

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

condition. 

(b) The pilot in command of a civil aircraft is responsible for determining 

whether that aircraft is in condition for safe flight. The pilot in command 

shall discontinue the flight when unairworthy mechanical, electrical, or 

structural conditions occur.

In the event that an exemption is granted, there will be no airworthiness 

certificate issued for the petitioner’s UAS. Without an airworthiness certificate, no 

FAA regulatory standard will exist for determining airworthiness. As outlined 

above and in attached exhibits, the petitioner is committed to incorporating strict 

safety and operational procedures in order to create an adequate level of safety 

that should exceed current standards. 
C.F.R.91.9(b)(2) Civil Aircraft Flight Manual, marking and placard 

requirements 

(b) No person may operate a U.S.-registered civil aircraft—

(1)For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of 

this chapter unless there is available in the aircraft a current, approved 

Airplane or Rotorcraft Flight Manual or the manual provided for in § 

121.141(b); and 

(2)For which an Airplane or Rotorcraft Flight Manual is not required by § 

21.5 of this chapter, unless there is available in the aircraft a current 

approved Airplane or Rotorcraft Flight Manual, approved manual material, 

markings, and placards, or any combination thereof. 

(c) No person may operate a U.S.-registered civil aircraft unless that aircraft 

is identified in accordance with part 45 of this chapter. 

Since the UAS the petitioner plans to use is not large enough to carry

documentation and does not have on board pilots, it does not have the ability to 

carry such documents. The petitioner can recreate the same standard of safety 

by having the required manuals on hand during each flight. 

C.F.R. 91.103 Pre-Flight Action 

Each pilot in command shall, before beginning a flight, become familiar 

with all available information concerning that flight. This information must 

include—

(a)For a flight under IFR or a flight not in the vicinity of an airport, weather 

reports and forecasts, fuel requirements, alternatives available if the 

planned flight cannot be completed, and any known traffic delays of which 

the pilot in command has been advised by ATC; 

(b) For any flight, runway lengths at airports of intended use, and the 

following takeoff and landing distance information: 

(1)For civil aircraft for which an approved Airplane or Rotorcraft Flight 

Manual containing takeoff and landing distance data is required, the takeoff 

and landing distance data contained therein; 

and 

(2)For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and runway

slope, aircraft gross weight, and wind and temperature. 

There is no pre-flight manual to refer to in regards to the UAS the petitioner plans

to use. The petitioner will apply all pre-flight recommendations from the Manuals 

provided from the manufacturer along with his own safety measures as outlined 

herein. The petitioner is committed to incorporating all of the safety measures 

illustrated throughout this petition as well as evolving practices as needed to 

ensure a high level of safety. 

C.F.R. 91.109(a) Flight Instruction; Simulated Instrument flight and certain 
flight tests 

(a) No person may operate a civil aircraft (except a manned free balloon) 

that is being used for flight instruction unless that aircraft has fully

functioning dual controls. However, instrument flight instruction may be 

given in an airplane that is equipped with a single, functioning throwover 

control wheel that controls the elevator and ailerons, in place of fixed, dual 

controls, when—

(1)The instructor has determined that the flight can be conducted safely; 

and 

(2)The person manipulating the controls has at least a private pilot 

certificate with appropriate category and class ratings. 

Because the UAS is radio controlled and operated, it does not have fully 

functional dual controls. It is, however, outfitted with very effective safety features 

that assist the craft in returning to a safe landing zone that is designated before 

flight if the Pilot in Command (PIC) is no longer able to operate the UAS. The 

petitioner does not consider this regulation applicable and requests exemption. 

C.F.R. 91.119 Minimum Safe Altitudes 

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

aircraft below the following altitudes: 

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

landing without undue 

hazard to persons or property on the surface. 

(b)over congested areas. Over any congested area of a city, town, or 

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

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

the aircraft. 

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

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

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

vessel, vehicle, or structure. Page 8 of 19 
d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the 

operation is conducted without hazard to persons or property on the 

surface—

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

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

helicopter complies with any routes or altitudes specifically prescribed for 

helicopters by the FAA; and 

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

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

The petitioner asserts that the above is not applicable and believes it is in the 

interest of safety to maintain strict rules for maximum altitudes. The petitioner will 

not be operating his UAS commercially above 200 feet. His UAS does not 

contain flammable or combustible fluids and, therefore, offers a safer 

circumstance compared to current standards. The petitioner’s UAS is also small 

and lightweight and is designed to automatically return to safe landing zones in 

the event of an emergency. Risks are minimized through operating in extremely 

controlled circumstances as outlined in this petition. 

C.F.R. 91.121 Altimeter Settings 

Requires each person to reference an altimeter 

The UAS the petitioner plans to use utilizes GPS for altitude readings. Safety can 

be achieved by referencing the GPS data before and during each flight. The 

petitioner believes that an exemption for this regulation is necessary on the basis 

that an adequate level of safety and adherence to the purpose of the regulation 

can be achieved through the GPS readings. 

C.F.R. 91.151(a) Fuel requirements for flight in VFR conditions. 

(a) No person may begin a flight in an airplane 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—

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

The petitioner requests an exemption to the above regulation on the basis that 

the UAS he plans to use does not carry fuel and will only be used during daylight 

hours. Operations will only be conducted under clear and favorable conditions. 

The petitioner’s UAS is also outfitted with automatic return home features when 

the battery life reaches a certain level of depletion. 

C.F.R. 91.203 (a) &(b) Civil aircraft: Certifications required.
(a) Except as provided in § 91.715, no person may operate a civil aircraft 

unless it has within it the following: 

(1) An appropriate and current airworthiness certificate. Each U.S. 

airworthiness certificate used to comply with this subparagraph (except a 

special flight permit, a copy of the applicable operations specifications 

issued under § 21.197 c of this chapter, appropriate sections of the air 

carrier manual required by parts 121 and 135 of this chapter containing that 

portion of the operations specifications issued under § 21.197 c or an 

authorization under § 91.611 ) must have on it the registration number 

assigned to the aircraft under part 47 of this chapter . However, the 

airworthiness certificate need not have on it an assigned special 

identification number before 10 days after that number is first affixed to the 

aircraft. A revised airworthiness certificate having on it an assigned special 

identification number, that has been affixed to an aircraft, may only be 

obtained upon application to an FAA Flight Standards district office. 

(2) An effective U.S. registration certificate issued to its owner or, for 

operation within the United States, the second copy of the Aircraft 

registration Application as provided for in § 47.31 c or a registration 

certification issued under the laws of a foreign country. 

(b) No person may operate a civil aircraft unless the airworthiness 

certificate required by paragraph 

(a) of this section or a special flight authorization issued under § 91.715 is 

displayed at the cabin or cockpit entrance so that it is legible to 

passengers or crew. 

The petitioner’s UAS is not capable of carrying certification and registration 

documents and therefore he believes this is inapplicable. There is no onboard 

pilot and such documents would need to be produced by the ground operator. 

The petitioner will ensure that all documentation required by the FAA are on hand 

at ground level during all flight operations. 

C.F.R. 91.405 (a) Maintenance Required 

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

The petitioner seeks exemption from the above on the basis that in the event of a 

grant, there will be no applicable airworthiness certificate. Though in the interest 

of assuring a high level of safety, the petitioner is committed to obtaining any 

repairs or replacements immediately from the manufacturer.

C.F.R. 91.407 (a) (1) Operation after Maintenance, Preventative 

Maintenance, Rebuilding, or 

(a) No person may operate any aircraft that has undergone maintenance, 
preventive maintenance, (1) It has been approved for return to service by a 

person authorized under § 43.7 of this chapter 

The petitioner points out that at this time there are no persons authorized to 

certify the model of UAS he intends to use for commercial purposes. Although, 

as stated above, he will seek the assistance of the best qualified service 

technicians and help from the manufacturer. 

C.F.R. 91.409(a)(2) Inspections 

(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—

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

accordance with part 21 of this chapter. 

In the event of an exemption being granted, the petitioner believes that this is 

inapplicable and therefore requests relief.

. 

14 C.F.R. 91.417(a) Maintenance Records 

(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. 

(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. 

The petitioner requests relief from the above on the basis that at this time, those 

regulations are inapplicable to the small and relatively simple UAS he plans to 

use. Because of the size of the small UAS he plans to use modifications are 

limited. The only possible modifications the petitioner contemplates would be for 

safety purposes in the form of prop guards designed by the manufacturer. In 

addition, the petitioner plans to utilize the most detailed records possible relative 

to the operations of the UAS.

How your request would benefit the public as a whole

Up to the present time the services the petitioner intends to offer have been 

performed by commercial aircraft and at considerable cost. The petitioner 

believes that the substitution of small UAS in place of traditional aircraft to 

accomplish the same services provides a host a safety benefits. The UAS are 

considerably safer because of their size, weight, and power source. They are 

operated at low altitudes under extremely controlled circumstances and do not 

require onboard pilots. The petitioner believes that this strongly supports the 

position that the risks to person or property are dramatically lower with UAS. It is 

undoubtedly in the public’s interest to reduce the occurrences of catastrophic or 

fatal crashes by way of integrating newer and safer technologies to accomplish 

the same goals. From an environmental standpoint the use of UAS will eliminate 

the emissions created by conventional aircraft in the course of providing the 

same services.

Through the use of UAS, the petitioner will be able offer economically accessible 

alternatives to homeowners and realtors that previously were completely out of 

reach except for a limited group. 

Reasons why the exemption would not adversely affect safety, or how the 
exemption would provide a level of safety at least equal to the existing rule

As stated and supported throughout this petition, the petitioner, is fully capable 

of integrating UAS in a manner that will not adversely affect safety. The petitioner 

has also pointed out that integrating UAS for the purpose of obtaining real estate 

photos and videography not only meets but exceeds the current level of safety 

offered through traditional manned aircraft.

Summary

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication 

in the Federal Register: 

Kenneth R. Duquaine seeks an exemption from the following: 

14 C.F.R. Part 21

14 C.F.R. 45.23(a & b)

14 C.F.R. 61.113 (a & b)

14 C.F.R. 91.7 (a)

14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.103

14 C.F.R. 91.109 (a)

14 C.F.R. 91.119

14 C.F.R. 91.121

14 C.F.R. 91.151 (a)

14 C.F.R. 91.203 (a) & (b)

14 C.F.R. 91.405 (a)

14 C.F.R. 91.407(a)(1); 

14 C.F.R. 91.409(a)(2); 

14 C.F.R. 91.417(a) and (b). 

The exemption requested by the petitioner, Kenneth R. Duquaine, would allow 

commercial operations of UAS under strictly controlled conditions for the purpose 

of real estate photography, videography, and marketing. The pilot in command is 

an experienced UAS operator and will be accompanied by a visual observer. The 

petitioner plans to use the DJI Phantom 2 Vision +.which is outfitted with 

numerous safety features and is commonly used. This small, lightweight, UAS 

poses minimal risks to property and people. The UAS’s physical characteristics 

and fail safe features combined with the petitioner’s commitment to safe 

operating procedures and policies meets or exceeds the level of safety 

commonly accepted with traditional manned aircraft.

The petitioner does not seek to exercise the privileges of an exemption outside of 

the United States.

ADDENDA

Phantom 2 Vision Plus Specifications, Operational considerations
DJI Phantom 2 Vision +

Quadcopter: Hover Accuracy

Vertical: 2.6' / 0.8m 

Horizontal: 8.2' / 2.5m

Quadcopter: Max Yaw Angular Velocity

200 deg. /s

Quadcopter: Max Tilt Angle

35 deg.

Quadcopter: Maximum Ascent/Descent Speed

Ascent: 19.7 fps / 6 m/s 

Descent: 6.6 fps / 2 m/s

Quadcopter: Maximum Flight Velocity

49.2 fps / 15 m/s (not recommended)

Quadcopter: Flight Time

Up to 25 minutes per battery

Quadcopter: Takeoff Weight

= 2.9 lb / 1.3 kg

Quadcopter: Operating Temperature

14 to 122 deg. F / -10 to 50 deg. C

Quadcopter: Power Requirements

DJI Phantom 2 Smart Battery

Flight Control: Connectivity

1x Micro-USB for user with Assistant Software

Flight Control: System Requirements

Assistant Software: Windows or OS X

Motors: Model

CCW: Phantom 2 2312 Motor (Part 10) 

CW: Phantom 2 2312 Motor (Part 11)

Motors: Recommended Takeoff Weight

10.6oz / 300.50g per axis

Motors: Maximum Tension

1.8lbs / 0.82kg per axis

Motors: Stator Size

0.9 x 0.5" / 22.86 x 12.70mm

Motors: Motor Velocity Constant

KV: 960 rpm/V

Motors: Working Temperature

23 to 104 deg. F / -5 to 40 deg. C

Transmitter: Operating Frequency

2.4 GHz ISM

Transmitter: Communication Distance

Open Area: 3280.8' / 1000 m

Transmitter: Receiver Sensitivity

At 1% PER: -97 dBm

Transmitter: Working Current/Voltage

120 mA at 3.7 VDC
Transmitter: Power Requirements

Built-In Lithium-Polymer Battery: 3.7 V, 2000 mAh

Propellers: Attachment

Self-tightening

Propellers: Maximum Thrust

1.5lbs / 0.68kg (with 2212 motor KV 920 at 12 V)

Battery: Type

3S lithium-polymer

Battery: Capacity

5200 mAh, 11.1 VDC

Battery: Charging Environment Range

32 to 104 deg. F / 0 to 40 deg. C

Battery: Discharging Environment Range

-4 to 122 deg. F / -20 to 50 deg. C

H4-3D Gimbal: Angular Vibration Range

Pitch/Roll: +/-0.02 deg. 

Yaw: +/-0.03 deg.

H4-3D Gimbal: Maximum Rotation Speed

Tilt Axis: +/-130 deg. /s

H4-3D Gimbal: Controlled Rotation Range

Tilt Axis Control: -130 deg. to +45 deg.

H4-3D Gimbal: Working Current

Electrical & Mechanical:

Static Current: 400 mA (at 12 V) 

Dynamic Current: 600 mA (at 12 V)

H4-3D Gimbal: Power Requirement

Electrical & Mechanical: 3S to 6S (12 V to 26 V)

H4-3D Gimbal: Camera Compatibility

GoPro HERO4 Black only

H4-3D Gimbal: Flight Control Systems

Supported:

A2 

WooKong-M 

NAZA-M 

NAZA-M V2

H4-3D Gimbal: Operating Temperature

50 to 122 deg. F / 10 to 50 deg. C

Dimensions

Diagonal: 13.8" / 350.52mm 

H4-3D Gimbal: 4.1 x 3.6 x 3.1" / 104.14 x 91.44 x 78.74mm

Propellers (Dia. x Pitch): 9.4 x 5" / 238.76 x 127.00mm

Weight

Motors: 1.9oz / 53.86g 

General: 2.2lbs / 1.00kg 

Gimbal: 5.9oz / 167.26g 

GCU: 0.8oz / 22.68g
Before and after every flight, the multi‐rotor's operational condition will be 

inspected for damage and deterioration, paying attention to the props for 

damage, cracks or wear and the UAS’s fuselage for damage. If damage, cracks 

or unusual wear is detected operations will be suspended until proper repairs 

have been made using the manufactures approved replacement parts and/or 

repair facilities.

There is no intention of modifying aircraft beyond factory specifications. The UAS 

will be in compliance with the FAA airworthiness regulations.

Safety

Propeller guards: Propeller guards such as the DJI manufacture’s guards will 

always be in use during commercial flights.

Spotter: To ensure safety, a second person acting as a spotter will be on site to 

review and observe any potential hazards before and during the flight.

Population of Intended Area

To ensure safety, all non‐essential personnel will be removed from the area. 

There will be no flight over densely populated areas like stadiums, schools, 

malls, casinos, and the like during operating hours.

Airports

According FAA rules and to ensure pilot(s) safety, there will no flight in or around 

airports unless explicit permission is granted according to current FAA 

regulations.

Weather

To ensure safety of spotter, property owners, pets, and wildlife, flights will be 

conducted in optimal weather conditions. Flights will not be conducted in winds 

above 20 mph.

Return‐to‐Home Feature

In the event the DJI Phantom 2 Vision + loses signal or runs critically low on 

battery the UAS has a GPS controlled return to home feature. The "home" is set 

upon flight startup.

Flying in Confined Areas

There is a high probability of flying in confined spaces, around residential

properties. The PIC and spotter will be in constant communication by two way 

radio, cell phone, or other approved FAA communications device when 

geographically separated during flight to ensure awareness of obstacles, hazards 

and UAS location.

Line of Site

The UAS will always be within the unaided line of site of the pilot and spotter. 

Height
Fights will not exceed 200 AGL at any time while operated commercially.

Potential Hazards

The following are potential hazards that may, or may not be, present during flight 

operations. The PIC and spotter will make every attempt to be aware of:

 Other UASs

 Homes, commercial buildings, out buildings, low and high voltage power lines

 Trees, shrubs, and hedges

 Automobiles and other mechanical vehicles

 Wildlife

 Rivers, lakes, ponds, and other bodies of water

 The unforeseen presence of people or animals

Privacy Concerns

During flight operations privacy concerns are of high priority. With each 

commercial flight permission will be obtained in advance from the property owner 

or an authorized agent.

During each flight operation, the petitioner will make every effort to avoid filming 

neighboring properties.

Pilot Qualifications

The current PIC, Kenneth Duquaine, has had considerable experience flying 

UAS recreationally and has been flying the DJI Phantom 2 Vision + since its 

introduction.

Any future PIC employed by the petitioner will

* Be familiar with current FAA regulations regarding UAS commercial

usage.

* have sufficient eye sight (with or without corrective lenses and

without the aid of binoculars) to see and operate the UAS at the distances 

necessary for the purpose of the flight.

*be in good health.

New Pilots in training will 

* Be fully trained and experienced in the operation of the Phantom 2 Vision +

* shadow and act as the Pilot in Command Spotter for 1 month or for a minimum 

of 10 hours prior to first flight as PIC.

* demonstrate a workable knowledge of the UAS and proficiency in operational

control at all times.

* watch online training videos to further enhance their skills.

Each pilot will follow set flight plans and schedules and be aware of all current 

FAA regulations.

This concludes my petition. Thank you for your consideration.

Kenneth R. Duquaine