UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

FLORIDA DRONE WORX, 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 a) DJI PHANTOM 

3, and c) 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 18, 2015

Florida Drone Worx, Inc.

Stefan Muehlbauer, Owner

2316 Pine Ridge Rd, #383

Naples, FL 34109

(239) 248-0460

stefan@floridadroneworx.com
Table of Contents

GLOSSARY OF ABBREVIATIONS 3

SUMMARY 4

INTRODUCTION AND INTERESTS OF THE PETITIONER 4

BACKGROUND 4

BASIS FOR PETITION 5

NAME AND ADDRESS OF THE PETITIONER 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH FLORIDA DRONE WORX 

INC. SEEKS EXEMPTION

6

THE EXTENT OF RELIEF FLORIDA DRONE WORX, INC. SEEKS AND THE 

REASON FLORIDA DRONE WORX, INC. SEEKS THE RELIEF

9

THE REASONS WHY GRANTING FLORIDA DRONE WORX, INC’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST

12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY

14

CONCLUSION 24
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 Airmen

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedure

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
SUMMARY 

Florida Drone Worx, 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)(l ), 91.409(a)(l) & ( a)(2), and 91.417( a) & (b), to operate an 

Unmanned Aircraft System pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 

(FMRA). This exemption will permit Florida Drone Worx, Inc. to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial video and photography for real estate 

photography, wedding videography, special events, film sets and landscape over certain areas of the 

United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Florida Drone Worx, Inc. is a subsidiary of Arma Communications Inc. a leading provider of online 

marketing agency. It is the mission of Florida Drone Worx, Inc. to provide our clients with expertise and 

knowledge in all aspects of picture, video & audio production, as well as provide them with advanced 

technologies & solutions that will increase efficiency, productivity and effectiveness. Florida Drone 

Worx, Inc. also provides clients with the highest quality digital content for use in their commercial, 

personal, and non-profit multimedia projects. Florida Drone Worx, Inc. and its parent company Arma 

Communications Inc has several years of professional experience in photography and videography and 

has become recognized as an expert in this field.

Florida Drone Worx, Inc. has 3 years of recreational/hobby experience in all aspects of aerial video and 

photography. The objective of Florida Drone Worx, Inc.'s aerial video and photography operations is to 

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

targeting:

• Real Estate Videography and Photography 

• Wedding Videography and Photography 

• Land survey & appraisals 

• Equipment Inspections 

• Roof Inspections 

• Construction sites before & after 

• Precision Agriculture 

• Creation of commercial messages for Television and Online Media

• Search and Rescue Operations 

• Motion Picture Filming 

• Drone Educational Classes 

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

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3, and DJI Inspire 1 UASs Florida Drone Worx, Inc. seeks an 

exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 3 has a 

maximum gross weight of approximately 2 pounds 13 ounces, while having a length of 16 inches by 16 
inches, height of 8 inches, and a maximum speed of approximately 31 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 Phantom 3, and DJI Inspire 1 UAs 

are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3, and DJI Inspire 1 UAs that will be operated by Florida Drone Worx, 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.P.R. Part 45, Identification and Registration 

Marking.

BASIS FOR PETITION 

Petitioner, Florida Drone Worx, 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 3, and DJI Inspire 1 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, Florida Drone Worx, Inc. operation of DJI Phantom 3, and DJI Inspire 1 UASs 

meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.P.R. Part 21, Subpart H.

Accordingly, Florida Drone Worx, Inc. requests relief from Sections 91.405(a), 91.407(a)(l), 91.409(a)(l) & 

(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to 

aircraft with an airworthiness certificate.

Florida Drone Worx, Inc. submits that the requested relief is proper since an equivalent level of safety 

will be ensured. Florida Drone Worx, 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 3, 

and DJI Inspire 1 Instruction Manual). Furthermore, Florida Drone Worx, Inc. will document and 

maintain all maintenance records for the DJI Phantom 3, and DJI Inspire 1 UASs.

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

limitations: Pilot in command, is requested by Florida Drone Worx, 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 3, and DJI Inspire 1 UASs in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Florida Drone Worx, Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because 

the DJI Phantom 3, and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 

14 C.P.R. Part 21, Subpart H. As such, Florida Drone Worx, Inc. submits that they will ensure that the DJI 
Phantom 3, and DJI Inspire 1 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 3, and DJI Inspire 1 Instruction Manual), and that the aircraft are in a condition for safe flight.

Florida Drone Word, Inc. also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Phantom 3, and DJI Inspire 1 UAs will not have a typical barometric 

altimeter onboard. However, altitude information of the DJI Phantom 3, and DJI Inspire 1 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 Florida Drone Worx, Inc.'s operation of the DJI Phantom 3, and DJI Inspire 1 

UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.

Additionally, Florida Drone Worx, Inc. seeks an exemption from the requirements of Section 91.151 (b), 

entitled Fuel requirements for flight in VFR conditions. Florida Drone Worx, Inc. submits that safety will 

not be affected by operation of the DJI Phantom 3, and DJI Inspire 1 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, Florida Drone Worx, 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: 

Stefan Muehlbauer c/o Florida Drone Worx, Inc. 

2316 Pine Ridge Rd #383

Naples, FL 34109

Tel: (239) 248-0460 

Email: stefan@floridadroneworx.com

B. The Specific Sections Of 14 C.F.R. From Which Florida Drone Worx, 

Inc. Seeks Exemption.

1. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Section Part 21, 

Subpart H

14 C.F.R Part 21, Subpart H, establishes the procedural requirements for the issuance of 

airworthiness certificates as required by 14 C.F.R. §91.203(a)(l)

2. Florida Drone Worx, 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 

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

3. Florida Drone Worx, 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.

4. Florida Drone Worx, 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)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) the case of an aircraft not equipped with a radio, the elevation of the departure 

airport or an appropriate altimeter setting available before departure.

5. Florida Drone Worx, 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.

6. Florida Drone Worx, 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-

(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[.]

7. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Section 91.407(a)(l)
Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, subsection (a)(l), 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§ 4 3. 7 of 

this chapter[.]

8. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Sections 91.409(a)(l) 

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.

9. Florida Drone Worx, 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 

(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. 9 10 

(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.

A. The Extent Of Relief Florida Drone Worx, Inc. Seeks And The 

Reason Florida Drone Worx, Inc. Seeks The Relief.

9. Florida Drone Worx, Inc. Seeks Exemption From The Requirements Of Section Part 21, 

Subpart H

Given the size and limited operating area associated with the UAS to be utilized by Florida 

Drone Worx, Inc., an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 of the Reform Act. 

The Federal Aviation Act (49 U.S. C.§ 44701(§)) and Section 333 of the Reform Act both 

authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, 

upon consideration of the size, weight, speed, operational capability, and proximity to airports 

and populated areas of the particular UAS. 

In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will 

be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions of the proposed UAS operations.
10. Extent Of Relief Florida Drone Worx, Inc. Seeks And The Reason Florida Drone Worx, 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, Florida Drone Worx, Inc. submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3, UAS or 

DJI Inspire 1 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 3, or DJI Inspire 1 

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.

Further, Florida Drone Worx, Inc. submits that all flights of the DJI Phantom 3, and DJI Inspire 

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

Florida Drone Worx, Inc.' business and (2) will not carry passengers or property for 

compensation or hire.

11. Extent Of Relief Florida Drone Worx, Inc. Seeks And The Reason Florida Drone Worx, 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 Florida Drone Worx, Inc. to determine that the DJI Phantom 3, and DJI 

Inspire 1 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., the Florida Drone Worx, Inc. Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 Instruction Manual).

Florida Drone Worx, Inc. seeks the requested relief because the DJI Phantom 3, and DJI Inspire 

1 UASs do not require an airworthiness certificate in accordance with 14 C.P.R. Part 21, 

Subpart H. Therefore, Florida Drone Worx, Inc. will ensure that the DJI Phantom 3, and DJI 

Inspire 1 UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 Instruction 

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

flight, as stated in the conditions and limitations below.
12. Extent Of Relief Florida Drone Worx, Inc. Seeks And The Reason Florida Drone Worx, 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 3, and DJI Inspire 1 UASs, which utilize a barometric pressure 

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

information from the UA to the PIC at the ground control station (GCS). Since the FAA requires 

that any altitude information concerning UAS operations be reported to air traffic control 

(ATC) in feet above ground level (AGL), Florida Drone Worx, Inc. seeks the requested relief 

because the DJI Phantom 3, and DJI Inspire 1 UA's altimeter may be set on the ground to zero 

feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

DJI Phantom 3, and DJI Inspire 1 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.

13. Extent Of Relief Florida Drone Worx, Inc. Seeks And The Reason Florida Drone Worx, 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 3, and 

DJI Inspire 1 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. Florida Drone 

Worx, Inc. seeks the requested relief because without an exemption from Section 91.151 (b), 

the flight time duration of the battery powered DJI Phantom 3, and DJI Inspire 1 UAs will 

severely constrain the practicality of any aerial video or still photo flight operations that 

Florida Drone Worx, Inc. proposes to conduct pursuant to this Petition. 

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

Inspire 1 UASs, the DJI Phantom 3, and DJI Inspire 1 operating documents, and Florida Drone 

Worx, Inc.'s proposed operating limitations, ensure that Florida Drone Worx, Inc. will safely 

operate the battery powered DJI Phantom 3, and DJI Inspire 1 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.

14. Extent Of Relief Florida Drone Worx, Inc. Seeks And The Reason Florida Drone Worx, 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) only apply to 

aircraft with an airworthiness certificate, Florida Drone Worx, Inc. requests relief from these 

Sections because the DJI Phantom 3, and DJI Inspire 1 UASs do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 3, and DJI Inspire 1 UASs meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Florida Drone Worx, 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 Florida Drone Worx, Inc. Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, and DJI Inspire 1 

Instruction Manual). Furthermore, Florida Drone Worx, Inc. will document and maintain all 

maintenance records for the DJI Phantom 3, and DJI Inspire 1 UASs.

C. The Reasons Why Granting Florida Drone Worx, Inc. 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 Florida Drone Worx, Inc. to 

safely, efficiently, and economically perform aerial video and photography of, real estate, wedding films, 

special events, precision agriculture, land survey & appraisal, construction sites, equipment & roof 

inspections, film sets and landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 3, and DJI Inspire I UASs will decrease congestion of the NAS, 

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

Worx, Inc.'s proposed operation of the DJI Phantom 3, and DJI Inspire 1 UASs will be realized without 

implicating any privacy Issues.

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

The DJI Phantom 3, and DJI Inspire 1 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, or DJI Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce 

noise and air pollution, as well as increase the safety of life and property in the air and on the ground. 

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

airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3, and DJI Inspire 1 

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, and DJI Inspire 1 

UASs.

Conducting aerial acquisitions with the DJI Phantom 3, and DJI Inspire 1 U AS's, 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, and DJI Inspire 1 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 3, and DJI Inspire 1 UAs, while reducing the 

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

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

By using the DJI Phantom 3, and DJI Inspire 1 U AS's 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, and DJI Inspire 1 UAs (weighing 

approximately 2 pounds 11 ounces, 2 pounds 13 ounces, and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches, 16 inches, and 17.3 inches respectively, widths of 16 

inches, 16 inches, and 17.7 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 

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 3, and DJI Inspire 1 

UASs Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3, and DJI Inspire 1 UASs are also an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI 

Phantom 3, and DJI Inspire 1 UASs will allow United States based companies, like Florida Drone Worx, 

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 3, and DJI Inspire 1 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 3, and DJI Inspire· 1 UASs, companies such as Florida Drone Worx, 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 3, and DJI Inspire 1 UASs, 

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

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

both in the United States and abroad.
4. There Are No Privacy Issues.

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

Drone Worx, Inc.'s proposed operation of the DJI Phantom 3, and DJI Inspire 1 UASs will not implicate 

any privacy issues. Specifically, the DJI Phantom 3, and DJI Inspire 1 UASs will be operated only in 

compliance with operating documents (i.e., the Florida Drone Worx, Inc. Aerial Operations Manual, 

Monthly Maintenance Log, and DJI DJI Phantom 3, and DJI Inspire 1 Instruction Manual) which requires 

property owner involvement as well as local law enforcement notification, and in accordance with the 

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F .R. § 91.119.

D. 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 Florida Drone 

Worx, Inc. Seeks Exemption.

1. Reasons Why The DJI Phantom 3, and DJI Inspire 1 UAs Meet The Conditions Of The FAA 

Modernization and Reform Act of2012 (FMRA) Section 333.

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

aircraft and its operation, Florida Drone Worx, Inc.'s operation of the DJI Phantom 3, and DJI Inspire 1 

UAS's 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 ofthe 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, Florida Drone Worx, Inc. submits that the DJI Phantom 3, and DJI Inspire 1 

UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Phantom 3, and DJI Inspire 1 UASs; (b) the pilot certification requirement; and 

(c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3, and DJI Inspire 1 UASs Demonstrate Its Safe 

Characteristics. 

The DJI Phantom 3, and DJI Inspire 1 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.

i. Technical Specifications Of The DJI Phantom 3, and DJI Inspire 1 UASs.

The technical specifications of the DJI Phantom 3, and DJI Inspire 1 UASs are set forth by the DJI 

Phantom 3, and DJI Inspire 1 Specifications and Data Sheet, attached hereto as Exhibit A and B.

ii. The DJI Phantom 3, and DJI Inspire 1 UASs Autonomous Flight And Navigation Modes Enable The 

UASs To Remain Within A Defined Operational Area.

The DJI Phantom 3, and DJI Inspire 1 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 3, and DJI 

Inspire 1 UASs are provided at pages 23-29 of the, DJI Phantom 3; and pages 12-18 and 45-52 of the DJI 

Inspire 1 User Manuals, attached hereto as Exhibit C and D.

iii. The DJI Phantom 3, and DJI Inspire 1 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 3, and DJI Inspire 1 UAs will remain stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3, and DJI Inspire 1 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 for the DJI Phantom 3 UAS are set forth at 

page 12 of the DJI Phantom 3 User Manual; and for the DJI Inspire 1 at pages 13 through 15 of the DJI 

Inspire 1 User Manual, attached hereto as Exhibit C and D.

iv. The DJI Phantom 3, and DJI Inspire 1 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 3, and DJI Inspire 1 GCS 

and flight control software is provided at pages 11 through 46 of the DJI Phantom 3 User Manual;; and 

pages 24 through 34 of the DJI Inspire 1 User Manual. DJI Phantom 3 and DJI Inspire 1 User Manuals are 

attached hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 3, and DJI Inspire 1 UASs Are Limited To The Line Of Sight Of A 

Certificated Pilot in Command With A Safety Observer.
Florida Drone Worx, 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 3, and DJI Inspire 1 UASs. 

Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3, and DJI Inspire 1 UASs Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, Florida Drone Worx, Inc. proposes to commercially operate DJI Phantom 3, 

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 3, and DJI Inspire 1 Unmanned Aircraft Systems. 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 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 VAS 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. 

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 thirdclass 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.P.R.§ 61.51(b). Flights for the purposes of training the 

operator's PICs are permitted under the terms ofthe exemption. However, training operations may only 

be conducted during dedicated training sessions. During training, proficiency, and experience-building 

flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must 

operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F .R. § 91. 119. 

19 

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 NOT AM 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 20 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 (NOT AM) 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.P.R. part 47, and have identification (N- Number) markings in 

accordance with 14 C.P.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 

UA must comply with the Federal Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

28. The documents required fewer than 14 C.P.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.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Would Not 

Adversely Affect Safety.

Florida Drone Worx, 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 3, 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 3, or DJI Inspire 1 UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Considering Florida Drone Worx, 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. 11 062); and the airmanship skills necessary to safely 

operate the DJI Phantom 3, or DJI Inspire 1 UAS, Florida Drone Worx, Inc. submits that the additional 

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

airmanship skills necessary for Florida Drone Worx, 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). 

Florida Drone Worx, Inc. will not allow any PIC to operate the DJI Phantom 3, or DJI Inspire 1 UAS unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3, or DJI 

Inspire 1 UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 

3, or DJI Inspire 1 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.P.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 Florida Drone 

Worx, Inc.' 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 

total25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 

takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight-hour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner's proposed operations. The FAA also 

finds that prior documented flight experience that was obtained in compliance with applicable 

regulations would satisfy this requirement. Training, proficiency, and experience-building flights can also 

be conducted under the grant of exemption to accomplish the required flight time. During training, 

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

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

Exemption No. 11138 at page 15. 

Accordingly, Florida Drone Worx, Inc. will ensure safe operations by not allowing any PIC to operate the 

Dll Phantom 3, or Dll Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate the DJI Phantom 3, or DJI Inspire 1 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, Florida Drone Worx, Inc. will ensure that the DJI Phantom 3, or DJI Inspire 1 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, and DJI Inspire 1 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 flight path and altitude. This altitude information, combined with Florida Drone Worx, 

Inc.' operation of the DJI Phantom 3, and DJI Inspire 1 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 91.15l(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, and DJI Inspire 1 UASs; (2) 

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

Accordingly, Florida Drone Worx, Inc. will ensure that it will safely operate the battery powered DJI 

Phantom 3, 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 3, 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 14 C.P.R. Section 91.151(b). Furthermore, safety 

will be ensured as the DJI Phantom 3, and DJI Inspire 1 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 3 and DJI Inspire 1 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)(l), 91.409(a)(l) 

& (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, Florida Drone Worx, 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)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) will be met because Florida Drone Worx, 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 Florida 

Drone Worx, Inc. Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3, and DJI 

Inspire 1 Instruction Manual). Furthermore, Florida Drone Worx, Inc. will document and maintain all 

maintenance records for the DJI Phantom 3, and DJI Inspire 1 UASs. 

Since the DJI Phantom 3, and DJI Inspire 1 UASs will be inspected as prescribed by the operating 

documents, Florida Drone Worx, 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 3, and DJI Inspire 1 User Manuals 

are attached hereto as Exhibit C, and D; a copy of the DJI Phantom 3, and DJI Inspire 1 UAS Maintenance 

LOG is attached hereto as Exhibit E. 

Likewise, the exemption sought will not adversely affect safety because Florida Drone Worx, 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 3, and DJI Inspire 1 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)(l), 

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 U AS are considered. 

In consideration of Florid Drone Worx, Inc.'s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Phantom 3, and DJI Inspire 1 UAS's, Florida Drone Worx, Inc. submits 

that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(l) 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 ofthe FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F .R. § 

21.16 entitled Special Conditions, Florida Drone Worx, Inc. requests that the FAA prescribe special 

conditions for the intended operation of the DJI Phantom 3, and DJI Inspire 1 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. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation 

of the DJI Phantom 3, and DJI Inspire 1 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.P.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.P.R.§ 21.16, the FAA 

may prescribe special conditions for Florida Drone Worx's intended operation of the DJI Phantom 3, and 

DJI Inspire 1 UASs, which contain such safety standards that the Administrator finds necessary to 

establish a level of safety equivalent to that established by 14 C.P.R. Part 21, Subpart H, and 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 

91.417(a) & (b).

E. A Summary That Can Be Published In The Federal Register, Stating: The Rules From Which Florida 

Drone Worx, Inc. Seeks Exemption:

Florida Drone Worx, 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 Florida Drone Worx, Inc. Seeks: 

This exemption will permit Florida Drone Worx, 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. 

Any Additional Information, Views, Or Arguments Available To Support Florida Drone Worx, Inc.'s 

Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of2012 (FMRA) Section 333, 

which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. 

As such, Florida Drone Worx, Inc.'s request for exemption may be granted pursuant to the authority of 

FMRA Section 333 and 14 C.P.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, Florida Drone Worx, Inc. will operate 

the DJI Phantom 3, and DJI Inspire 1 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, Florida Drone Worx, Inc. seeks an exemption pursuant to 14 C.P.R. § 11.61 and

section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which will permit safe operation 

of the DJI Phantom 3, and DJI Inspire 1 UAS's commercially, Without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of United States, By 

granting this petition the FAA administrator will be fulfilling the congressional mandate of the FAA 

Modernization and reform 27 act of2012, while also advancing the interests of the public, by allowing 

Florida Drone Worx, Inc. to safely efficiently and economically operate the DJI Phantom 3,and DJI Inspire 

1 UASs commercially whithin the NAS. 

Wherefore, in accordance with the Federal Aviation Regulations and the FAA Modernization and reform 

act of2012, Section 333 Florida Drone Worx, Inc. respectfully requests that the administrator grant this 

petition for an example from the requirements of 14 C.P.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 Florida Drone 

Worx, Inc. to operate the DJI Phantom 3, and DJI Inspire 1 UASs commercially for the purpose of 

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

November 18, 2015 

Respectfully Submitted

Florida Drone Worx, Inc. 

Stefan Muehlbauer, Owner

2316 Pine Ridge Rd #383

Naples, FL 34109

Telephone: (239) 248 - 0460

Appendices 

A. DJI Phantom 3 Specifications Data Sheet

B. DJI Inspire 1 Specifications Data Sheet

C. DJI Phantom 3 Manufacturer's User Manual 

D. DJI Inspire 1 Manufacturer's User Manual 

E. Monthly Maintenance Log 
Appendix – A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

Florida Drone Worx, 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)

1.2 DJI Phantom 3 

1.2.1 Aircraft 

1.2.1.1 Supported Battery- DJI 4480mAH LiPo Battery 

1.2.1.2 Weight (Battery & Propellers Included)- 2lbs 13.15oz (1280g) 

1.2.1.3 Hover Accuracy (Ready to Fly)- Vertical: +/- 0.1 m (when Vision Positioning is active) 

or+/- 0.5 m; Horizontal: 1.5m 

1.2.1.4 Max Yaw Angular Velocity- 200°/s 

1.2.1.5 Max Tilt Angle - 35° 

1.2.1.6 Max Ascent Speed- 5m/s 

1.2.1. 7 Max Descent Speed- 3m/s 

1.2.1. 8 Max Flight Speed- 15m/s (NOT RECOMMENDED) 

1.2.2 Gimbal 

1.2.2.1 Control Accuracy- ±0.03° 

1.2.2.2 Controllable Range- Pitch: -90° + 30° 

1.2.2.3 Maximum Angular Speed- Pitch: 90°/s 1.2.3 Camera 

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

1.2.3.2 Sensor Size- 1/2.3" 

1.2.3.3 Effective Pixels- 12.4M 

1.2.3 .4 Resolution- 4000x3000 1.2.3.5 UltraHD Video Recording- 4096x2160p 24/25, 

3840x2160p 24/25/30 

1.2.3.6 Recording Field ofView- 94°@20mm 

1.2.4 Transmitter 

1.2.4.1 Operating Frequency- 2.400GHz- 2.483GHz 

1.2.4.2 Communication Distance (unobstructed)- FCC Compliance: 2000m 

1.2.4.3 Receiver Sensitivity (2%PER)- -101dBm 

1.2.4.4 Transmitter Power- FCC Compliance: 20dbm 

1.2.4.5 Working Voltage- 1.2 A @7.4 V
Appendix – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

Florida Drone Worx, 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 

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- 22rn/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 V4" x 17 314" x 12" 

2.2.2 Gimbal 

2.2.2.1 Model- ZENMUSE X3 

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

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 

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 112.3" 

2.2.3.9 HD Video Recording- UHD(4K): 32 4096x2160p24/25, 3840x2160p24/25/30; FHD: 

1920xl080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

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

2.2.4 Transmitter 

2.2.4.1 Name-Cl 

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 (-lOOC to 400C) 

2.2.4.6 Battery- 600mAh LiPo 2S

APPENDIX- C 

DJI PHANTOM 3 Manufacturer's User Manual 

User manual can be found at: 

http://www.dji.com/product/phantom-3/download 

APPENDIX-D 

DJI Inspire 1 Manufacturer's User Manual 

User manual can be found at: 

http://www.dji.com/product/inspire-1/download
Appendix – E

Monthly Maintenance Log

Monthly Maintenance Log

UAS: Month: Year:

Maintenance Performed 

by:

Date Issue 

Discovered

Date Issue 

Addressed

Issue Description & 

Maintenance 

Conducted Print Name Signature

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration Dampening

Other: