Monday, November 30, 2015

Attn:

U. S. Department of Transportation Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave, SE Washington, DC 20590

RE: Austin Brown dba. GLOBAL AIR MEDIA, LLC

REQUEST AN EXEMPTION FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE 

OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING 

COMMERCIAL OPERATION OF DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF The FAA Modernization and Reform Act of 2012 (Public 

Law 112-95) 

Austin Brown

CEO, Global Air Media, LLC

33 S. Highland Ave., Baltimore, MD 21224

410-504-2369

info@globalairmedia.com
GLOSSARYOFABBREVIATIONS

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) 

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
SUMMARY

Austin Brown dba. GLOBAL AIR MEDIA, LLC hereafter referred to as The GLOBAL AIR 

MEDIA, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b), to operate an Unmanned Aircraft System (DJI Phantom 3 Pro) pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit The 

GLOBAL AIR MEDIA, LLC to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography of construction sites, residential

and commercial real estate, civil landscapes and events over certain areas of the United States.

INTRODUCTIONANDINTERESTSOFTHEPETITIONER

The staff at GLOBAL AIR MEDIA, LLC has over 10 years of experience in providing private, 

commercial, and government clients with expertise and knowledge in project management, 

multimedia marketing, general contracting and training using advanced technologies and

solutions. GLOBAL AIR MEDIA’s experienced staff has worked on hundreds of various 

projects over the past 10 years in all types of industries with a perfect client and employee safety 

record. GLOBAL AIR MEDIA, LLC will offer professional and innovative aerial photography, 

mapping, surveying, and inspection services by use of Unmanned Aerial Systems (UAS). As we 

intend to serve a wide range of clients from governmental, commercial, public, and residential, 

our mission is to improve safety and efficiency for each client while providing the highest quality 

end product. Areas we will be specifically targeting include:

• Construction

• Aerial Mapping and Surveys

• Real-estate marketing

• Economic development

• Photography and Film

• Agriculture

• Private and governmental training

The staff has safely flown the DJI Phantom Pro 3 electric quadcopters recreationally for 

approximately 2 years without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Pro, UAS

The GLOBAL AIR MEDIA, LLC seeks an exemption to operate DJI Phantom 3 Pro system for 

compensation or hire within the NAS. The DJI Phantom 3 Pro is vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic 

tablet or smart phone systems. The DJI Phantom 3 Pro has a maximum gross w eight o f

approximately 2.8 lb. while having a diagonal dimension of 23.2”, a maximum speed of 

approximately 16.4’fps and a maximum flying height of 400'. The DJI Phantom 3Pro is equipped 

with four main rotors; driven by Lithium Polymer battery powered electric motors.
The DJI Phantom 3 Pro that will be operated by The GLOBAL AIR MEDIA, LLC 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.

BASISFORPETITION

Petitioner, The GLOBAL AIR MEDIA, LLC 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 Pro, UAS 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, The GLOBAL AIR MEDIA, LLC operation of DJI

Phantom 3Pro 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, The GLOBAL AIR MEDIA, LLC 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.

The GLOBAL AIR MEDIA, LLC submits that the requested relief is proper since an

equivalent level of safety will be ensured. The GLOBAL AIR MEDIA, LLC will use

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

Furthermore, The GLOBAL AIR MEDIA, LLC will document and maintain all maintenance 

records for the DJI Phantom 3 Pro UAS.

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

and limitations: Pilot in command, is requested by The GLOBAL AIR MEDIA, LLC 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 Pro UAS in a manner consistent with this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

The GLOBAL AIR MEDIA, LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Pro UAS do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, The GLOBAL AIR MEDIA, LLC 

submits that they will ensure that the DJI Phantom 3 Pro UAS is in an airworthy condition, prior

to every flight, by determining that the UAS are in compliance with the operating documents
(i.e., Monthly Maintenance Log, and DJI Phantom 3 Pro Instruction Manual), and that the

aircraft are in a condition for safe flight. The GLOBAL AIR MEDIA, LLC also seeks an 

exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI

Phantom 3 Pro UAS will not have a typical barometric altimeter onboard. However, altitude

information of the DJI Phantom 3 Pro 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 The GLOBAL AIR MEDIA‘s cooperation of the DJI Phantom 3 Pro UAS within visual

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

91.121.

Additionally, The GLOBAL AIR MEDIA, LLC seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. The GLOBAL AIR 

MEDIA, LLC submits that safety will not be affected by operation of the DJI Phantom 3 Pro 

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 23 minutes. 

Battery power indicators are also able to show exactly how much battery power is left, as

well as how much time is needed to return safely back to point of takeoff.

In accordance with 14 C.F.R. § 11.81, The GLOBAL AIR MEDIA, LLC 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: 

Austin Brown

CEO, Global Air Media, LLC

33 S. Highland Ave., Baltimore, MD 21224

410-504-2369

info@globalairmedia.com

B. The Specific Sections of 14 C.F.R. From Which The GLOBAL AIR MEDIA, LLC 

Seeks Exemption.

1. The GLOBAL AIR MEDIA, LLC 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.

2. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Section

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: 

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

3. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Section

91.121.

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

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

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

operating--

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

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

within 100 nautical miles of the aircraft;

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

this section, the current reported altimeter setting of an appropriate available 

station; or

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

departure airport or an appropriate altimeter setting available before 

departure.

4. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Section

91.151(b).

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

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

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

for at least 20 minutes.

5. The GLOBAL AIR MEDIA, LLC 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[.]

6. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter [.]

7. The GLOBAL AIR MEDIA, LLC Seeks Exemption from the Requirements of Sections

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

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

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

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

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

approved for return to service by a person authorized by § 43.7 of this chapter; or

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

with part 21 of this chapter.
8. The GLOBAL AIR MEDIA, LLC 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.

(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 the GLOBAL AIR MEDIA, LLC Seeks and the Reason the

GLOBAL AIR MEDIA, LLC Seeks the Relief.

1. Extent Of Relief The GLOBAL AIR MEDIA, LLC Seeks And The Reason The

GLOBAL AIR MEDIA, LLC 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, The GLOBAL AIR MEDIA, LLC submits that an equivalent level

of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Pro 

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 Pro 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, The GLOBAL AIR MEDIA, LLC submits that all flights of the DJI Phantom 3 Pro 

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

GLOBAL AIR MEDIA’s business; and (2) will not carry passengers or property for

compensation or hire.
2. GLOBAL AIR MEDIA, LLC Seeks Relief From Section 1.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent 

required to allow The GLOBAL AIR MEDIA, LLC to determine that the DJI Phantom 3 Pro 

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

with the operating documents (i.e., the GLOBAL AIR MEDIA, LLC Aerial Operations Manual, 

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

The GLOBAL AIR MEDIA, LLC seeks the requested relief because the DJI Phantom 3 Pro UAS

do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Therefore, The GLOBAL AIR MEDIA, LLC will ensure that the DJI Phantom 3 Pro UAS 

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

Monthly Maintenance Log, and DJI Phantom 3 Pro) prior to every flight, and further, determine

that the aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. Extent Of Relief The GLOBAL AIR MEDIA, LLC Seeks And The Reason The GLOBAL 

AIR MEDIA, LLC 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 Pro UAS , which utilize a barometric pressure sensor, GPS 

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

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

altitude information concerning UAS operations be reported to air traffic control (ATC) in feet 

above ground level (AGL), The GLOBAL AIR MEDIA, LLC seeks the requested relief because 

the DJI Phantom 3 Pro UAS 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 Pro UAS are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS.

4. Extent Of Relief The GLOBAL AIR MEDIA, LLC Seeks And The Reason The GLOBAL 

AIR MEDIA, LLC 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 Pro UAS 

during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 23 minutes.
The GLOBAL AIR MEDIA, LLC seeks the requested relief because without an exemption

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

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

that The GLOBAL AIR MEDIA, LLC proposes to conduct pursuant to this Petition.

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

DJI Phantom 3 Pro operating documents, and The GLOBAL AIR MEDIA, LLC proposed

operating limitations, ensure that The GLOBAL AIR MEDIA, LLC will safely operate the

battery powered DJI Phantom 3 Pro 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 23 minutes.

5. Extent Of Relief The GLOBAL AIR MEDIA, LLC Seeks And The Reason The GLOBAL 

AIR MEDIA, LLC 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, The GLOBAL AIR MEDIA, LLC requests relief

from these Sections because the DJI Phantom 3 Pro UAS do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 3 Pro UAS meet the conditions of

FMRA Section 333 for operation without an airworthiness certificate. Accordingly, The

GLOBAL AIR MEDIA, LLC will use 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 GLOBAL AIR MEDIA, LLC Aerial Operations Manual,

Monthly Maintenance Log, and DJI Phantom 3 Pro Instruction Manual). Furthermore, The

GLOBAL AIR MEDIA, LLC will document and maintain all maintenance records for the DJI 

Phantom 3 Pro UAS.

D. The Reasons Why Granting the GLOBAL AIR MEDIA, LLC 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 The GLOBAL AIR 

MEDIA, LLC to safely, efficiently, and economically perform aerial video and photography of

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

Additionally, use of the DJI Phantom 3 Pro UAS will decrease congestion of the NAS, reduce 

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

GLOBAL AIR MEDIA, LLC proposed operation of the DJI Phantom 3 Pro UAS will be

realized without implicating any privacy issues.

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

The DJI Phantom 3 Pro 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 Pro 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

Pro 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 Pro 

UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Pro UAS, instead of manned aircraft,

will greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerial video and still photography flight operations. By using

battery power and electric motors, the DJI Phantom 3 Pro 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 Pro 

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 Pro 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 Pro UAS (weighing 

approximately 2.8 pounds at their maximum gross weight with diagonal dimension of 23.2 

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 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 Pro 

UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 Pro UAS are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As such,

operation of the DJI Phantom 3 Pro UAS will allow United States based companies, like The

GLOBAL AIR MEDIA, LLC 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 Pro 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 Pro UAS, companies such as The GLOBAL AIR MEDIA, LLC

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 Pro 

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.

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

The GLOBAL AIR MEDIA’s proposed operation of the DJI Phantom 3 Pro UAS will not

implicate any privacy issues. Specifically, the DJI Phantom 3 Pro UAS will be operated only in 

compliance with operating documents (i.e., the GLOBAL AIR MEDIA, LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Pro 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 The GLOBAL AIR MEDIA, LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Pro 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, The GLOBAL AIR MEDIA’s operation of the DJI Phantom 

3 Pro 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.

(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, The GLOBAL AIR MEDIA, LLC submits that the DJI Phantom 3 Pro 

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

characteristics of the DJI Phantom 3 Pro UAS; (b) the pilot certification requirement; and (c) the 

specific operating limitations.

a. The Specifications Of The DJI Phantom 3 Pro UAS Demonstrate Its Safe 

Characteristics.

The DJI Phantom 3 Pro UAS does not create a hazard to users of the NAS or the public, or

otherwise pose a threat to national security considering its size, weight, speed, and operational 

capability.

i. Technical Specifications of the DJI Phantom 3 UAS.

The technical specifications of the DJI Phantom 3 Pro UAS are set forth by the DJI Phantom 3

User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 3 Pro UAS Global Positioning Modes Enable the UAS to remain 

within a defined operational area.
The DJI Phantom 3 Pro UAS may be operated in both manual and global positioning flight

modes. A complete description of the flight and navigational modes of the DJI Phantom 3 Pro 

UAS is provided at pages 11 of the DJI Phantom 3 User Manual attached hereto as Appendix A.

iii. The DJI Phantom 3 Pro UAS 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 Pro UAS will remain stationary, in flight, for

3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Pro UAS does not reacquire control

link data from the GCS, the UAS will assume that the Control Link is lost and the will return to

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

shutdown. A complete description of the Failsafe Functions of the DJI Phantom 3 Pro UAS 

are set forth at pages 12 through 14 of the DJI Phantom 3 Pro User Manual, attached hereto as 

Appendix A.

iv. The DJI Phantom 3 GCS and Its Operation.

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

control software is provided at pages 23 through 29 of the DJI Phantom 3 User Manual. DJI 

Phantom 3 User Manual is attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 3 Pro UAS Is Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer.

The GLOBAL AIR MEDIA, LLC video production staff will be the only persons to act as a pilot

in command (PIC) of the DJI Phantom 3 UAS. Additionally, a safety observer will assist him at

all times during flight time.

c. Flights Of DJI Phantom 3 Pro UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, The GLOBAL AIR MEDIA, LLC proposes to commercially operate

DJI Phantom 3 Pro 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 Pro 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 400 feet above ground level (AGL), as

indicated by the procedures specified in the operating documents unless a special request is made

and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. 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 t o 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.

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

Bulletins.

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

against discrepancies discovered between inspections.

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

medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s

qualification criteria and demonstrates the ability to safely operate the UAS in a manner

consistent with how the UAS will be operated under the exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and 

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

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

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

training sessions. During training, proficiency, and 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. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

operations must be conducted under visual meteorological conditions (VMC). If flight at night is

required, a special request will be made at the FAA office closest to proposed area of operations.

Flights under special visual flight rules (SVFR) are not authorized.

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

current FAA-published aeronautical chart unless a letter of agreement with that airport’s

management is obtained, and the operation is conducted in accordance with a NOTAM as required

by the operator’s COA. The letter of agreement with the airport management must be made

available to the Administrator upon request.

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

from a cloud or when visibility is less than 3 statute miles from the PIC.
22. If the UA loses communications or loses its GPS signal, it must return to a 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.

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

conditions) there is enough power to fly at normal cruising speed to the intended landing point 

and land the UA with 25% battery power remaining.

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

Authorization (COA) prior to conducting any operations under the grant of exemption. This COA 

will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in

advance, but not less than 48 hours prior to the operation. All operations shall be conducted in 

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

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, 

registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in

accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable.

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

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

appropriate government oversight agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC

at the Ground Control Station of the UAS any time the UAS is operating. These documents 

must be made available to the Administrator or any law enforcement official upon 

request.

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

activities at all times.

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

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

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

structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The operator 

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are within 

500 feet of the UA, flight operations must cease immediately and/or;
b. The aircraft is operated near vessels, vehicles or structures where the 

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

the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not 

present an undue hazard to those persons per § 91.119(a).

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

from the land owner/controller or authorized representative. Permission from land

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

33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of

the operational area as defined by the applicable COA must be reported to the FAA's UAS

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov.

2. Reasons Why an Exemption from the Requirements of Section 61.113(a) and (b) Would 

Not Adversely Affect Safety.

The GLOBAL AIR MEDIA, LLC 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 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 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures.

Considering The GLOBAL AIR MEDIA, LLC proposed area of operations, and the operating 

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

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

airmanship skills necessary to safely operate the DJI Phantom 3 Pro UAS, The GLOBAL AIR 

MEDIA, LLC submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship skills necessary for The

GLOBAL AIR MEDIA, LLC 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).

The GLOBAL AIR MEDIA, LLC will not allow any PIC to operate the DJI Phantom 3 Pro UAS 

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

Phantom 3 Pro UAS training and currency requirements, that the PIC is able to safely operate the 
DJI Phantom 3 UAS in a manner consistent with this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and 

structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. §

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations under 

the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes).

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

obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during The GLOBAL AIR MEDIA, LLC proposed operations. The Administrator has held that 

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

would ensure safe operations, stating as follows:

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

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

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

UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor 

UAS. Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make 

and model of UAS to be used for operations under the exemption. For clarification, the 

FAA considers these minimum hour requirements to be inclusive rather than additive; i.e.

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

10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the 

hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

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

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

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

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

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

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

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

flights the PIC is required to operate the UA with appropriate distances in accordance 

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, The GLOBAL AIR MEDIA, LLC will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 3 Pro 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 Pro 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, The GLOBAL AIR MEDIA, LLC will ensure that the DJI Phantom 3 Pro 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 Pro 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 The GLOBAL AIR MEDIA, LLC operation of the DJI Phantom 3 Pro 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

UAS 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 Pro UAS;

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

operations. Accordingly, The GLOBAL AIR MEDIA, LLC will ensure that it will safely operate

the battery powered DJI Phantom 3 Pro UAS during daylight hours in VFR conditions, with

enough battery power to fly for a total duration of 23 minutes.
Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 Pro 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 Pro UAS provide audible and visual warnings to the

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

approximately 33% remaining battery power, and again at approximately 10% remaining battery

power. At the critically low battery level, the DJI Phantom 3 Pro 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, The GLOBAL AIR MEDIA, LLC 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 

The GLOBAL AIR MEDIA, LLC 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 GLOBAL AIR MEDIA, LLC Aerial Operations 

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

The GLOBAL AIR MEDIA, LLC will document and maintain all maintenance records for the

DJI Phantom 3 Pro UAS.

Since the DJI Phantom 3 Pro UAS will be inspected as prescribed by the operating documents,

The GLOBAL AIR MEDIA, LLC 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 Pro User

Manuals are attached hereto as Appendix A and B; a copy of the DJI Phantom 3 Pro UAS 

Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will not adversely affect safety because The GLOBAL AIR 

MEDIA, LLC 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 Pro 
UAS will be performed by trained technicians. Maintenance will be documented and maintained 

utilizing the monthly maintenance log. Significantly, previous exemptions granted

b y 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 The GLOBAL AIR MEDIA, LLC proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3 Pro UAS, The GLOBAL 

AIR MEDIA, LLC submits that safety will not be adversely affected by granting exemption from 

14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The

FAA has previously granted relief specific to UAS in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065,

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160,

11161).

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

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

and 14 C.F.R. § 21.16 entitled Special Conditions, The GLOBAL AIR MEDIA, LLC requests 

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

UAS, which contain such safety standards that the Administrator finds necessary to establish a

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

61.113(a)

& (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)

& (b). Such special conditions will permit safe operation of the UAS for the limited purpose of 

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

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

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

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

certification in accordance with any requirements that must be established for the safe operation 

of the UAS in the NAS.

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

§ 21.16, for operation of the DJI Phantom 3 Pro UAS, since the airworthiness regulations

of 14 C.F.R. Part 21 does not contain adequate or appropriate safety standards, due to the

novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states

the following:

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

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

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

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations.
See 14 C.F.R. § 21.16.

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

prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 3Pro

UAS, which contain such safety standards that the Administrator finds necessary to establish a

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

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The

Rules from Which the GLOBAL AIR MEDIA, LLC Seeks Exemption:

The GLOBAL AIR MEDIA, LLC 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 The GLOBAL AIR MEDIA, 

LLC Seeks:

This exemption will permit The GLOBAL AIR MEDIA, LLC 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

The GLOBAL AIR MEDIA, LLC 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, The GLOBAL AIR MEDIA, LLC request for

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

11, as set forth above.

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

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

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, The GLOBAL AIR MEDIA, LLC will operate the DJI Phantom

3 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, The GLOBAL AIR MEDIA, LLC 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 Pro 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 The GLOBAL AIR MEDIA, LLC 

to safely, efficiently, and economically operate the DJI Phantom 3 Pro UAS commercially within 

the NAS.
27

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

Modernization and Reform Act of 2012, Section 333, The GLOBAL AIR MEDIA, LLC 

respectfully requests that the Administrator grant this Petition for an exemption from the

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading 

Edge to operate the DJI Phantom 3 Pro UAS commercially for the purpose of

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

Dated: 

Monday, November 30, 2015

Respectfully

submitted,

Austin Brown

CEO, Global Air Media

33 S. Highland Ave., Baltimore, MD 21224

410-504-2369

info@globalairmedia.com

Appendices

A – Link to DJI Phantom 3 Pro Manual: Click on link below

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.2

_en.pdf