UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

FRANCIS M. CAMPOS DOING BUSINESS AS “AERIALSHOTZ”, A SOLE 

PROPRIETORSHIP, FOR AN EXEMPTION SEEKING RELIEF FROM THE 

REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 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 A DJI PHANTOM 3 

PROFESSIONAL UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on September 3, 2015

Francis M. Campos

AerialShotz

33 Drakewood Lane

Novato CA 94947

Tel: (415) 892-1573
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TABLE OF CONTENTS

Page 

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

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

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

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

BASIS FOR PETITION........................................................................................................6

NAME AND ADDRESS OF PETITIONER............................................................8

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

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

THE EXTENT OF RELIEF AERIALSHOTZ SEEKS AND THE REASON 

AERIALSHOTZ SEEKS THE RELIEF................................................................11

THE REASONS WHY GRANTING AERIALSHOTZ REQUEST WOULD 

BE IN THE PUBLIC INTEREST ........................................................................14

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY........................................................................17

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER....29

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT AERIALSHOTZ REQUEST................................29

CONCLUSION..................................................................................................................30

APPENDICES...................................................................................................................32
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

Francis M. Campos, dba and hereinafter referred to as AerialShotz seeks exemption 

from the requirements of 14 C.F.R §§ 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 AerialShotz 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

Francis M. Campos holds a FAA Commercial Helicopter and Fixed Wing License (Cert 

No. 1586591) with an Instrument Rating and has over 1500 hours flying time as a Private 

Pilot, a U.S. Army Combat Helicopter Pilot, Aircraft Commander and Flight Instructor. 

He also has a current California Driver’s License (S0466578). Francis M. Campos also has

over 10 years recreational/hobby experience in all aspects of remote control aerial video 

and photography. Total RC logged time is currently 51 hours and 39 minutes. He has 

experience as a multimedia and interactive video producer and has owned and operated a 

small computer integration company. He has also worked as a licensed real estate agent in 

California.

The objective of Francis M. Campos’ company AerialShotz’ aerial video and photography 

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

residential uses, targeting:
5

Real Estate Photography and Videography, Real Estate Marketing

Aerial photography/videography of houses - residential and commercial buildings

Aerial inspections of public and private structures during and after construction

Insurance Inspections of Home and Property

Search and Rescue operations (volunteer)

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS.

AerialShotz seeks an exemption to operate a DJI Phantom 3 Professional UAS for 

compensation or hire within the NAS. The DJI Phantom 3 Professional is a vertical takeoff 

and landing (VTOL) Unmanned Aircraft System (UAS) with a Ground Control Station 

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

has a maximum gross weight of 2 pounds 13.1 ounces, a length of 16.2 inches, width of 

16.6 inches, height of 10.5 inches, and a maximum speed of approximately 31.1 knots. The 

DJI Phantom 3 Professional UAS is equipped with four main rotors; Driven by Lithium 

Polymer battery powered electric motors. The DJI Phantom 3 Professional UAS that will 

be operated by AerialShotz 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, AerialShotz, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Phantom 3 Professional UAS 

in the National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R. 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, AerialShotz’ operation of DJI Phantom 3 

Professional UAS meets the conditions of FMRA Section 333 and therefore, will not 

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

Accordingly, AerialShotz 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. 

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

safety will be ensured. AerialShotz will use experienced and/or authorized DJI repair 

center personnel or technicians to perform maintenance, alterations, or preventive 

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

operating documents (i.e., AerialShotz Monthly Maintenance Log, and DJI Phantom 3 

Professional Instruction Manual). Furthermore, AerialShotz will document and maintain 

all maintenance records for the DJI Phantom 3 Professional UAS. 
7

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

because the DJI Phantom 3 Professional UAS does not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. As such, AerialShotz submits that they

will ensure that the DJI Phantom 3 Professional UAS is in an airworthy condition, prior to 

every flight, by determining that the UAS is in compliance with the operating documents 

(i.e., AerialShotz Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction 

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

AerialShotz also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 

Professional UAS will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the UAS

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

with AerialShotz operation of DJI Phantom 3 Professional UAS within visual line of sight, 

at or below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, AerialShotz seeks an exemption from the requirements of Section 

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

that safety will not be affected by operation of the DJI Phantom 3 Professional 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. 
8

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

Francis M. Campos

AerialShotz

33 Drakewood Lane

Novato CA 94947

Tel: (415) 892-1573

Email: fmikec@gmail.com

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

1. AerialShotz 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. 

2. AerialShotz 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 
9

(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. 

3. AerialShotz 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. 

4. AerialShotz Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 

5. AerialShotz 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 [.] 

6. AerialShotz 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 --
10

(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. 

7. AerialShotz 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 

(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. 
11

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

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

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

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

required. 

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

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

propellers, and appliances. 

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

prescribed: 

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

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

work is performed. 

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

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

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

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

approved for return to service. 

C. The Extent Of Relief AerialShotz Seeks And The Reason AerialShotz Seeks The 

Relief. 

1. Extent Of Relief AerialShotz Seeks And The Reason AerialShotz 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 AerialShotz to determine that the DJI Phantom 3 Professional 

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

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

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

AerialShotz seeks the requested relief because the DJI Phantom 3 Professional 

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

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

in airworthy condition based upon its compliance with the operating documents (i.e., 
12

AerialShotz Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction 

Manual) prior to every flight, and further, determine that the aircraft is in condition for safe 

flight, as stated in the conditions and limitations below.

2. Extent Of Relief AerialShotz Seeks And The Reason AerialShotz Seeks 

Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI Phantom 3 Professional UAS, which utilize a barometric 

pressure sensor, GPS equipment, and a radio communications telemetry data link to 

downlink altitude information from the UAS 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), AerialShotz

seeks the requested relief because the DJI Phantom 3 Professional UA’s altimeter may be 

set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight. 

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

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Phantom 3 Professional 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 UAS on the heads-up display of the GCS. 

3. Extent Of Relief AerialShotz Seeks And The Reason AerialShotz Seeks 

Relief From Section 91.151(b). 
13

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR 

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Phantom 3 Professional 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. AerialShotz seeks the requested relief because without an exemption from 

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

Professional UAs will severely constrain the practicality of any aerial video or still photo 

flight operations that AerialShotz proposes to conduct pursuant to this Petition. 

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

Professional UAS, the DJI Phantom 3 Professional operating documents, and AerialShotz

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

powered DJI Phantom 3 Professional 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.

4. Extent Of Relief AerialShotz Seeks And The Reason AerialShotz 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, AerialShotz requests relief from 

these Sections because the DJI Phantom 3 Professional UAS does not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 3 Professional 

UAS meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, AerialShotz will use experienced and/or authorized DJI repair 
14

center personnel or trained technicians to perform maintenance, alterations, or preventive 

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

UAS operating documents (i.e., the Aerial Operations Manual, AerialShotz Monthly

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

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

Professional UAS. 

D. The Reasons Why Granting AerialShotz 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 

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

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

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

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

benefits of AerialShotz proposed operation of the DJI Phantom 3 Professional UAS will be 

realized without implicating any privacy issues. 

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

The DJI Phantom 3 Professional 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 3 Professional 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 
15

DJI Phantom 3 Professional 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.

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

Phantom 3 Professional UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 Professional 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 3 Professional 

UAS produce no air pollution, and is the most viable environmentally conscious alternative 

to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The DJI Phantom 3 Professional UA, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by 

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

By using the DJI Phantom 3 Professional UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually

associated with traditional manned aircraft flight operations, will be substantially reduced 

or completely eliminated. Aside from the lack of flight crew members located onboard the 

aircraft, the DJI Phantom 3 Professional UAS (weighing approximately 2 pounds 13.1 

ounces respectively, at its maximum gross weight with a length of 16.2 inches and width of 

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

life and property on the ground, and in the air, compared to the manned aircraft that 
16

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 DJI Phantom 3 

Professional UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 Professional UAS are 

also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 Professional UAS will allow United 

States based companies, like AerialShotz, to remain competitive and contribute to growth 

of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation 

fuels, U.S. owned and operated companies must adopt new and alternative technology in 

order to remain competitive. Operating the battery powered DJI Phantom 3 Professional 

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

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

cost of a traditional manned aircraft. 

By operating the DJI Phantom 3 Professional UAS, companies such as AerialShotz, 

can remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial use of 

the DJI Phantom 3 Professional UAS, provides a stable workforce that increases consumer 

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

in research and development in order to remain competitive both in the United States and 

abroad. 

4. There Are No Privacy Issues. 
17

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

decades, AerialShotz proposed operation of the DJI Phantom 3 Professional UAS will not 

implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be 

operated only in compliance with operating documents (i.e., the Aerial Operations Manual, 

AerialShotz Monthly Maintenance Log, and DJI Phantom 3 Professional 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 AerialShotz Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 Professional 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, AerialShotz operation of the DJI Phantom 3 

Professional UAS meet the conditions of FMRA Section 333, and will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

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

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

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

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

later than 180 days after the date of enactment of this Act, the 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. 
18

(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, AerialShotz submits that the DJI Phantom 3 

Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS; (b) the 

pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate 

Its Safe Characteristics.

The DJI Phantom 3 Professional UAS do not create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 Professional UAS. 

The technical specifications of the DJI Phantom 3 Professional UAS are set forth in 

Appendix A

ii. The DJI Phantom 3 Professional UAS Autonomous Flight And 

Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area. 
19

The DJI Phantom 3 Professional UAS may be operated in both manual and fully

autonomous flight modes. A complete description of the flight and navigational modes of 

the DJI Phantom 3 Professional UAS is provided in the Manufacturer’s User Manual*

*See Note in Appendices Page 32

iii. The DJI Phantom 3 Professional UAS is Designed For Automatic Return 

To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 3 Professional UAS will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 

Professional UAS does 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 shut down. 

A complete description of the Failsafe Functions of the DJI Phantom 3 Professional UAS 

is provided in the Manufacturer’s User Manual*

*See Note in Appendices Page 32 

iv. The DJI Phantom 3 Professional GCS And Its Operation.

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

Professional GCS and flight control software is provided in the Manufacturer’s User 

Manual *

*See Note in Appendices Page 32 

b. Flight Operations Of DJI Phantom 3 Professional UAS Are Limited To 

The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 
20

Francis M. Campos will act as pilot in command (PIC) of the DJI Phantom 3 Professional 

UAS. Additionally, a safety observer will assist during flight time.

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

To Specific Operating Limitations. 

In seeking this exemption, AerialShotz proposes to commercially operate the DJI 

Phantom 3 Professional UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific 

operating limitations:

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

aircraft described in the operating documents, rotorcraft UAS weighing less than 

55 pounds maximum gross weight: DJI Phantom 3 Professional Unmanned 

Aircraft System. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant. 

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

for the purpose of aerial video and photography. 

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

4. The UAS 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. 
21

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. 

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. 
22

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

Safety Bulletins. 

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

corrective action taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a Sport Pilot Certificate and at least a valid stateissued driver’s license. 

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 experience-building flights, all persons not essential for flight 

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

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 UAS 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 UAS loses communications or loses its GPS signal, it must return to a 

pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 
23

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 UAS 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. 

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

and control of the UAS 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 UAS 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 UAS 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 
24

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. 

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, AerialShotz will ensure that the DJI Phantom 3 Professional 

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 3 Professional UAS will be provided 

to the PIC via GPS equipment and a radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. 
25

This altitude information, combined with AerialShotz operation of the DJI Phantom 3 

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

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

will safely operate the battery powered DJI Phantom 3 Professional 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 3 

Professional UAS; the limitations on the proposed flight operations; and the location of 

the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3 Professional 

UAS provide audible and visual warnings to the PIC at the GCS when the UAS
26

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 3 Professional UAS will descend and land 

automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical 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, AerialShotz 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 AerialShotz will use trained technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the AerialShotz Aerial Operations Manual, 

AerialShotz Monthly Maintenance Log, and DJI Phantom 3 Professional Instruction 

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

for the DJI Phantom 3 Professional UAS. 
27

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the 

operating documents, AerialShotz will maintain the equivalent level of safety established 

by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 

Professional User Manual; a copy of the DJI Phantom 3 Professional UAS Maintenance 

LOG is attached hereto as Exhibit B. 

Likewise, the exemption sought will not adversely affect safety because 

AerialShotz will use trained technicians or an authorized DJI Repair Station to perform 

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

techniques, and practices prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Phantom 3 Professional UAS will be performed by trained technicians. Maintenance 

will be documented and maintained utilizing the AerialShotz 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. 

In consideration of AerialShotz proposed operating limitations, the operating 

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

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, 
28

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, AerialShotz requests that the 

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

Professional 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 §§ , 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe 

operation of the UAS for the limited purpose of conducting aerial video and photography

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

forth the requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. 

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

§ 21.16, for operation of the DJI Phantom 3 Professional UAS, 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 
29

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 AerialShotz’ intended operation of the DJI Phantom 3 

Professional UAS, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R Sections , 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 AerialShotz Seeks Exemption: 

AerialShotz seeks exemption from the requirements of 14 C.F.R Sections 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 AerialShotz Seeks: 

This exemption will permit AerialShotz 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 

AerialShotz 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, AerialShotz 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. 
30

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, AerialShotz will operate the DJI Phantom 3 

Professional UAS safely in the NAS, without creating a hazard to users of the NAS, or the 

public, or otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, AerialShotz seeks an exemption pursuant to 14 C.F.R. § 11.61 

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will 

permit safe operation of the DJI Phantom 3 Professional UAS commercially, without an 

airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing 

AerialShotz to safely, efficiently, and economically operate the DJI Phantom 3 

Professional UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, AerialShotz respectfully requests 

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

C.F.R Sections 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 AerialShotz to operate the DJI Phantom 3 Professional 
31

UAS commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

Dated: September 2, 2015

Respectfully submitted,

Francis M. Campos

______________________________

Francis M. Campos

AerialShotz

33 Drakewood Lane

Novato CA 94947

Tel: (415) 892-1573
32

Appendices:

A – DJI Phantom 3 Professional Technical Specifications

B –AerialShotz Monthly Maintenance Log

C – DJI Phantom 3 Professional User Manual*

*NOTE: Unable to attach – file too large. This document can be accessed at:

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4_

en.pdf

or 

http://bit.ly/1K82LJu
33

APPENDIX – A

DJI Phantom 3 Professional Specifications

Aircraft Weight (Battery & Propellers Included): 1280 g

Max. Ascent Speed 5 m/s

Max. Descent Speed 3 m/s

Max. Speed 16 m/s (ATTI mode, no wind)

Max. Flight Altitude 6000 m

Max. Flight Time Approximately 23 minutes

Operating Temperature: 0°C to 40°C

GPS Mode: GPS/GLONASS

Gimbal:

Controllable Range Pitch: - 90° to + 30°

Vision Positioning:

Velocity Range < 8 m/s (2 m above ground)

Altitude Range 30 cm-300 cm

Operating Range 30 cm-300 cm

Operating Environment Brightly lit (lux > 15) patterned surfaces

Camera:

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

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

ISO Range 100-3200(video) 100-1600(photo)

Electronic Shutter Speed 8s -1/8000s

Image Max. Size 4000 x 3000

Still Photography Modes:

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Supported SD Card Types:

Micro SD Max. capacity: 64 GB. Class 10 or UHS-1 rating required
34

Video Recording Modes:

UHD : 4096x2160p 24/25, 3840x2160p24/25/30

FHD:1920x1080p 24/25/30/48/50/60

HD:1280x720p 24/25/30/48/50/60

Max. Bitrate Of Video Storage 60 Mbps

Supported File Formats:

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Operating Temperature Range:°C to 40°C

Remote Controller:

Operating Frequency 2.400 GHz-2.483 GHz

Transmitting Distance 2000 m (Outdoor And Unobstructed)

Video Output Port: USB

Operating Temperature Range; 0°C- 40°C

Battery 6000 mAh LiPo 2S

Mobile Device Holder Tablets and smartphones

Transmitter Power(EIRP) FCC: 20 dbm; CE:16 dbm

Working Voltage 1.2 A @7.4 V

Charger:

Voltage 17.4 V

Rated Power 100 W

Intelligent Flight Battery: ( PH3-4480 mAh-15.2 V )

Capacity 4480 mAh

Voltage 15.2 V

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Operating Temperature -10°C- 40°C

Max. Charging Power 100 W
35

APPENDIX – B

AerialShotz Monthly Maintenance Log

UAS #_____ Date Issue Maintenance Initials

Performed

Firmware

Check

Frame

Engines

Propellers

Camera

Gimbal

Landing

Gear

Vibration

Other: