UNITED STATES OF AMERICA DEPARTMENT OF 

TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC Regulatory Docket No. ___________________ 

Docket Operations, M-30

U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE

Room W12-140, West Building Ground Floor Washington, DC 

20590-0001 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

David Arnold AirbornePics

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)(l), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) 

CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 2 

AND DJI INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION 

AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

Submitted on January 28, 2016 

AirbornePics c/o David Arnold Owner 

4 La Sinfonia, Rancho Santa Margarita, California 92688 

949.525.1997

TABLE OF CONTENTS 

GLOSSARY OF 

ABBREVIATIONS ....................................................................... 3 

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

INTRODUCTION AND INTERESTS OF 

PETITIONER............................................................. 4 
BACKGROUND ..............................................................................5 

BASIS FOR 

PETITION........................................................................................ 5 

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

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

David Arnold and AirbornePics SEEKS EXEMPTION ............. 8 

C. THE EXTENT OF RELIEF AND THE REASON DAVID ARNOLD 

AND AIRBORNEPICS SEEKS THE RELIEF 

............................................................................... 11 

D. THE REASONS WHY GRANTING DAVID ARNOLD AND 

AIRBORNEPICS REQUEST WOULD BE IN THE

PUBLIC INTEREST ....................................................................... 13 

E. THE REASONS WHY GRANTING THE EXEMPTION

WOULD NOT ADVERSELY AFFECT SAFETY........................... 15 

THE REASONS WHY GRANTING AN EXEMPTION

FROM THE REQUIREMENTS OF 61.113(A) AND (B)

WOULD NOT ADVERSELY AFFECT 

SAFETY..................................................................... 22 

CONCLUSION ............................................................................... 23 

EXHIBITS 

Page 2 of 26 
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization Aerial Vehicle

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 

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of2012 (FMRA)

SO Safety Observer

SOP Standard Operating Procedure

DJI UAV manufacturer

ESC Electronic speed control

FPV First Person View

Li-Po Lithium Polymer battery 

VTOL Vertical Takeoff and Landing 

RCV Radio Controlled Vehicle 

sUAS Small Unmanned Aircraft System -under 55 pounds Gross Weight 

UAS Unmanned Aircraft System

Page 3 of 26 
SUMMARY 

DAVID ARNOLD AND AIRBORNEPICS seeks exemption from the 

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

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

to operate an Unmanned Aircraft System pursuant to Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA). This exemption 

will permit DAVID ARNOLD AND AIRBORNEPICS to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial video and photography for marketing, film sets, real 

estate photography, commercials, special events, wedding 

cinematography, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is DAVID ARNOLD, and I am the Manager and Owner of 

AIRBORNEPICS I also hold a Private pilot certificate, along with a 3rd 

Class Medical Certificate. 

DAVID ARNOLD is also a drone builder and operator (pilot) with 

expertise and knowledge in aspects of building, programing and 

operating multiple types of UAS'S along with camera set up and 

operation. DAVID ARNOLD is also an experienced professional 

photographer who provides clients with the highest quality digital 

content for use in their commercial, personal, and non-profit multimedia 

projects. DAVID ARNOLD is a member of the Academy of Model 

Aeronautics (“AMA”) and has 20 years of Radio Controlled aircraft 

experience including helicopters. The objective of DAVID ARNOLD 

AND AIRBORNEPICS, aerial video and photography operations is to 

provide high quality imaging for a variety of commercial, public, and 
residential uses, along with testing of repaired drones for clients in a safe 

testing location away from all obstacles and people at all times. 

Page 4 of 26 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire1

DAVID ARNOLD AND AIRBORNEPICS seeks an exemption to 

operate DJI systems for compensation or hire within the NAS. The DJI 

Phantom 3 and DJI Inspire1 are vertical takeoff and landing (VTOL) 

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

electronic tablet or smart phone systems. The DJI Phantom3 has a 

maximum gross weight of approximately 2 pounds 7 ounces, while 

having a length of 16 inches width of 16 inches, height of 8 inches, and a 

maximum speed of approximately 29 knots. The DJI Inspire 1 has a 

maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, 

width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. The DJI Phantom 3 and DJI Inspire l UA’s are 

equipped with four main rotors; driven by electric motors powered by a 

Lithium Polymer battery. 

The DJI Phantom 3 and DJI Inspire 1 sUAS’s that will be operated by 

DAVID ARNOLD AND AIRBORNEPICS 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 Markings. 

BASIS FOR PETITION 

Petitioner,DAVID ARNOLD AND AIRBORNEPICS, pursuant to the 

provisions of the Federal Aviation Regulations (14C.F.R. § 11.61) and 

the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, 
Special Rules for Certain Unmanned Aircraft Systems, hereby petitions 

the Administrator to commercially operate the DJI Phantom 2 and the 

DJI Inspire 1 sUAS 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), 91.119, 91.121, 91.l51(b), 91.405(a), 91.407(a)(I), 91.409(a)(l) 

& (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, DAVID 

ARNOLD AND AIRBORNEPICS operation of DJI Phantom 3 and DJI 

Inspire 1 sUAS’s 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, DAVID ARNOLD AND AIRBORNEPICS requests relief 

from Sections 91.405(a), 91.407(a)(I), 91.409(a)(I) & (a)(2), and 91.417 

(a) & (b), as these sections set forth requirements for maintenance that 

only apply to aircraft with an airworthiness certificate. 

DAVID ARNOLD AND AIRBORNEPICS submits that the requested 

relief is proper since an equivalent level of safety will be ensured. 

DAVID ARNOLD AND AIRBORNEPICS will use experienced 

personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the sUAS 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, DAVID ARNOLD AND AIRBORNEPICS will 

document and maintain all maintenance records for the DJI Phantom 3 

and DJI Inspire 1 sUAS. 

Page 5 of 26 

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

Private pilot privileges and limitations: Pilot in command, is requested 

by DAVID ARNOLD AND AIRBORNEPICS 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 sUAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

DAVID ARNOLD AND AIRBORNEPICS seeks relief from Section 

91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 2 

and DJI Inspire 1 sUAS do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, DAVID 

ARNOLD AND AIRBORNEPICS submits that he will ensure that the 

DJI Phantom 3 and DJI Inspire l sUAS are in an airworthy condition, 

prior to every flight, by determining that the sUAS 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. 

 DAVID ARNOLD AND AIRBORNEPICS 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 2 

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 UAS to the GCS for 

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

with operation of the DJI Phantom 3 and DJI Inspire 1 sUAS within 

visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. 

Additionally, DAVID ARNOLD AND AIRBORNEPICS seeks an 

exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. DAVID ARNOLD AND 

AIRBORNEPICS submits that safety will not be affected by operation 

of the DJI Phantom 3 and DJI Inspire 1 sUAS’s during daylight hours in 

visual meteorological conditions under visual flight rules (VFR), with 

enough battery power to fly to point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. 
Page 6 of 26 

In accordance with 14 C.F.R. § 11.81, DAVID ARNOLD AND 

AIRBORNEPICS 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: 

DAVID ARNOLD AND AIRBORNEPICS

4 La Sinfonia, Rancho Santa Margarita, CA 92688 

rsmarnold@yahoo.com

949.525.1997 

Page 7 of 26 

B. The Specific Sections Of 14 C.F.R. from Which AERIAL 

IMAGES AND VIDEO LLC Seeks Exemption. 

1. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption 

From The Requirements Of Section 61.1l3(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- 

 i. The flight is only incidental to that business or 

employment; and 

 ii. The aircraft does not carry passengers or property 

for compensation or hire. 

2. DAVID ARNOLD AND AIRBORNEPICS 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. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption 

From The Requirements Of Section 91.121. 

a. 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-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)

(l)(i) of this section, the current reported altimeter setting of an 
appropriate available station; 

(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. DAVID ARNOLD AND AIRBORNEPICS 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. 

Page 8 of 26 

5. DAVID ARNOLD AND AIRBORNEPICS 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. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption From 

The Requirements Of Section 91.407(a) 

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration; 
a. Subsection (a)(1), states the following: 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. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption From 

The Requirements Of Sections 91.409(a)(1) And 91.409(a)(2). 

a. Section 91.409, entitled Inspections, subsection (a), states the 

following: 

i. 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. DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption From 

The Requirements Of Sections 91.417(a) And 91.417(b). 

a. Section 91.417, entitled Maintenance records, subsections (a) and (b), 

state the following: 

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

the work performed; and 

Page 9 of 26 

(b) The date of completion of the work performed; and 

(c) The signature, and certificate number of the person approving the 

aircraft for return to service. 

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 I 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. 

Page 10 of 26 

C. The Extent Of Relief DAVID ARNOLD AND AIRBORNEPICS 

Seeks And The Reason DAVID ARNOLD AND AIRBORNEPICS 

Seeks The Relief. 

1. Relief From Section 61.113(a) And (b): 

a. 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, DAVID ARNOLD AND AIRBORNEPICS submits that an 

equivalent level of safety will be maintained because no PIC will be 

allowed to operate the DJI Phantom 2 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 2 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, DAVID 

ARNOLD AND AIRBORNEPICS submits that all flights of the DJI 

Phantom 3 and DJI Inspire 1 sUAS, conducted by the PIC pursuant to 

the grant of this Petition: (1) will be incidental to DAVID ARNOLD 

AND AIRBORNEPICS business; and (2) will not carry passengers or 

property for compensation or hire. 

Page 11 of 26 

 b. Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is 

requested to the extent required to allow DAVID ARNOLD AND 

AIRBORNEPICS to determine that the DJI Phantom 3 and DJI 

Inspire 1 sUAS are in airworthy condition prior to every flight by 

ensuring that the UAS is in compliance with the operating 

documents (i.e., DAVID ARNOLD AND AIRBORNEPICS Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 

3 and DJI Inspire 1 Instruction Manual). DAVID ARNOLD AND 

AIRBORNEPICS seeks the requested relief because the DJI 

Phantom 3 and DJI Inspire 1 sUAS do not require an airworthiness 

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

Therefore, DAVID ARNOLD AND AIRBORNEPICS will ensure 

that the DJI Phantom 3 and DJI Inspire 1 sUAS 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 User Manuals; prior to every flight, and further, 

determine that the aircraft are in condition for safe flight, as stated 

in the conditions and limitations below.Relief from Section 91.121, 

entitled Altimeter settings, may be required to allow flight 

operations of the DJI Phantom 3 and DJI Inspire 1 sUAS, 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), DAVID ARNOLD AND 

AIRBORNEPICS seeks the requested relief because the DJI 

Phantom 3 and DJI Inspire 1 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 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. 

 c. Relief from Section 91.151(b) entitled Fuel requirements for flight 

in VFR conditions, is requested to the extent required to allow 

flights of the battery powered DJI Phantom 2 and DJI Inspire 1 

sUAS during daylight hours in visual meteorological conditions 

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

approximately15.5 minutes to the first point of intended landing 

and, assuming normal cruising speed, to fly after that for at least 

4.5 minutes. DAVID ARNOLD AND AIRBORNEPICS 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 

DAVID ARNOLD AND AIRBORNEPICS proposes to conduct 

pursuant to this Petition. Significantly, as set forth below, the 

technical specifications of the DJI Phantom 3 and DJI Inspire 1 

sUAS, the DJI Phantom 3 and DJI Inspire 1 operating documents, 

and the operating limitations proposed by DAVID ARNOLD AND 

AIRBORNEPICS, ensure that DAVID ARNOLD AND 

AIRBORNEPICS will safely operate the battery powered DJI 

Phantom 3 and DJI Inspire 1 sUAS 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. 

Page 12 of 26

d. 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, DAVID 

ARNOLD AND AIRBORNEPICS requests relief from these Sections 

because the DJI Phantom 3 and DJI Inspire 1 sUAS do not require 

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

Phantom 2 and DJI Inspire 1 sUAS meet the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. 

Accordingly, DAVID ARNOLD AND AIRBORNEPICS will use trained 

technicians to perform maintenance, alterations, or preventive 

maintenance on the sUAS using the methods, techniques, and practices 

prescribed in the UAS operating documents (i.e., DAVID ARNOLD 

AND AIRBORNEPICS Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction 

Manual). Furthermore, DAVID ARNOLD AND AIRBORNEPICS will 

document and maintain all maintenance records for the DJI Phantom 3 

and DJI Inspire 1 sUAS. 

D.

Would Be In The Public Interest: That Is, How It Would Benefit The 

Public As A Whole. 

The Reasons Why Granting DAVID ARNOLD AND 

AIRBORNEPICS Request 

Granting the present Petition will further the public interest by allowing 

DAVID ARNOLD AND AIRBORNEPICS safely, efficiently, and 

economically perform aerial video and photography of construction 

sites, real estate, and landscape over certain areas of the United States. 
Additionally, use of the DJI Phantom 3 and DJI Inspire 1 sUAS will 

decrease congestion of the NAS, reduce pollution, crashes and accidents 

caused by pilot error and provide significant benefits to the economy. 

Notably, the benefits of DAVID ARNOLD AND AIRBORNEPICS 

proposed operation of the DJI Phantom 3 and DJI Inspire 1 sUAS will 

be realized without conflicting with or violation of 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 sUAS. 

Page 13 of 26 
Conducting aerial media acquisitions with the DJI Phantom 3 and DJI 

Inspire 1 sUAS, 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 sUAS 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 which burn 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 

eliminate 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 sUAS 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 14 ounces and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches and 17.3 inches 

respectively, widths of 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 sUAS Will Benefit The 

Economy. 

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

Inspire 1 sUAS 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 sUAS will allow United 

States based companies 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 sUAS utilizes 

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 sUAS, 

companies such as DAVID ARNOLD AND AIRBORNEPICS 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 sUAS, 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. 

Page 14 of 26 

Page 15 of 26 

Similar to the manned aerial media acquisition flight operations that 

have been conducted for decades, DAVID ARNOLD AND 

AIRBORNEPICS proposed operation of the DJI Phantom 3 and DJI 

Inspire 1 sUAS would not implicate any privacy issues. Specifically, the 

DJI Phantom 3 and DJI Inspire 1 sUAS will be operated only in 

compliance with operating documents (i.e., DAVID ARNOLD AND 

AIRBORNEPICS Aerial Operations Manual, Monthly Maintenance 

Log, and 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. 

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 

DAVID ARNOLD AND AIRBORNEPICS Seeks Exemption. 

 1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 sUAV Meet 

The Conditions Of The FAA Modernization and Reform Act of 

2012 (FMRA) Section 333: 

 2. In consideration of the size, weight, speed, and limited operating 

area associated with the unmanned aircraft and its operation, 

DAVID ARNOLD AND AIRBORNEPICS operation of the DJI 

Phantom 3 and DJI Inspire 1 sUAS 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 rule making 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 minimumi. 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 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 (J). 

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. 

Page 16 of 26 

In seeking this exemption, DAVID ARNOLD AND AIRBORNEPICS 

submits that the DJI Phantom 3 and DJI Inspire 1 sUAS 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 sUAS, (b) 

the pilot certification requirement and (c) the specific operating 

limitations. 

i. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 

sUAS Demonstrate Its Safe Characteristics. 

The DJI Phantom 3 and DJI Inspire 1 sUAS 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. 
ii. Technical Specifications Of The DJI Phantom 2 and DJI 

Inspire 1 sUAS. 

The DJI Phantom 3 and DJI Inspire 1 Specifications and Data 

Sheet, attached hereto as Exhibits A and B, set the technical 

specifications of the DJI Phantom 3 and DJI Inspire 1 sUAS forth. 

iii. The DJI Phantom 3 and DJI Inspire 1 sUAS Autonomous 

Flight And Navigation Modes Enable The sUAS To Remain 

Within A Defined Operational Area. 

The DJI Phantom 3 and DJI Inspire 1 sUAS 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 sUAS is provided at pages 25-35 of 

the DJI Phantom 3 and pages 12-16 and 45-50 of the DJI Inspire I 

User Manuals, attached hereto as Exhibit C and D. 

iv. The DJI Phantom 3 and DJI Inspire 1 sUAS Are Designed For 

Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 2 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 of the DJI Phantom 2 UAS are set forth at pages 

27 and 28 and for the DJI Inspire 1 at pages 13 through 15 of the 

DJI Phantom 2 along with complete DJI Inspire 1 User Manuals, 

attached hereto as Exhibit C and D. 
v. The DJI Phantom 3 and DJI Inspire 1 Ground Control Station 

(“GCS”) And It's 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 32 through 44 of the DJI Phantom 3 User 

Manual and pages 23 through 33 of the DJI Inspire 1 User Manual. 

DJI Phantom 2 and DJI Inspire 1 User Manuals are attached hereto 

as Exhibits C and D. 

Page 17 of 26 

Page 18 of 26 

vi. Flight Operations Of DJI Phantom 3 and DJl Inspire 1 sUAS Are 

Limited To The Line Of Sight Of A Certificated Pilot in Command 

With A Safety Observer. 

vii. AERIAL IMAGES AND VIDEO LLC 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 

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

time. 

viii. Flights Of DJI Phantom 3 and DJI Inspire 1 sUAS Will Be 

Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, AERIAL IMAGES AND VIDEO LLC 

proposes to commercially operate DJI Phantom 3 and DJI Inspire 1 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 sUAS 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 UAS 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. 

Page 19 of 26 

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

accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the 

conditions and limitations contained in the grant of exemption and 

the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption take 

precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the 

operator's responsibility to track such revisions and present 

updated and revised documents to the Administrator upon request. 

The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If 

the operator determines that any update or revision would affect 

the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. 

The FAA's UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating 

documents. 

 10. Prior to each flight the PIC must inspect the UAS to ensure that it 

is in a condition f or 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 sUAS 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. 

Page 20 of 26 

 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 UAS may not operate within 5 nautical miles of an airport 

reference point as denoted on a current FAA-published 

aeronautical chart unless a letter of agreement with that airport's 

management is obtained, and the operation is conducted in 

accordance with a NOTAM as required by the operator's COA. The 

letter of agreement with the airport management must be made 

available to the Administrator upon request. 

 21. The UAS may not be operated less than 500 feet below or less than 

2,000 feet horizontally from a cloud or when visibility is less than 

3 statute miles from the PIC. 

 22. If the 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 
Page 21 of 26 

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 UAS must remain clear and yield the right of way to all 

manned aviation operations and activities at all times. 

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

or vehicle. 

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

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

unless: 

 a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the 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) 

Page 22 of 26 

within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Website: www.ntsb.gov. 

Reasons Why An Exemption From The Requirements Of Section 

61.113(a) And (b) Would Not Adversely Affect Safety. 

DAVID ARNOLD AND AIRBORNEPICS submits that the equivalent 

level of safety established by Section 61.113(a) and (b) will be 

maintained because no PIC will be allowed to operate the DJI Phantom 

2 and DJI Inspire 1 sUAS unless that PIC has demonstrated, by meeting 

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

safely operate the DJI Phantom 2 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 DAVID ARNOLD AND 

AIRBORNEPICS 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 or DJI Inspire 1 UAS, 

DAVID ARNOLD AND AIRBORNEPICS submits that the additional 

manned airmanship experience of a commercially certificated pilot 

would not correlate to the airmanship skills necessary for DAVID 

ARNOLD AND AIRBORNEPICS 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). DAVID ARNOLD AND 

AIRBORNEPICS 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.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 DAVID ARNOLD AND AIRBORNEPICS 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 sUAS 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 requirement, the PIC must accomplish takeoffs and landings in the 

preceding 90 days (for currency purposes). The FAA finds that at a 

minimum, the flight hour requirement 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 night 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.

Page 23 of 26

Exemption No. 11138 at page 15. Accordingly, DAVID ARNOLD AND 

AIRBORNEPICS will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 3 or DJI Inspire 1 U AS unless the 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.

CONCLUSION

DAVID ARNOLD AND AIRBORNEPICS 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 operations of the 

DJI Phantom 3 and DJI Inspire 1 UAS commercially, without an 

airworthiness certificate, for 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 
Page 24 of 26
EXHIBIT A

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

DAVID ARNOLD AND AIRBORNEPICS only utilizes safe and reliable 

sUAS. DJI is an industry leader in small UAS production. DJI sUAS are 

complete with leading edge and proven software enabling the user to set 

parameters which will not allow flight into controlled airspace. Parameters 

can also he 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) 

DJI Phantom 3

1.1 Aircraft

1.1.1 Supported Battery -DJI 4480mAh 4S LiPo Battery

1.1.2 Weight (Battery & Propellers Included) -2 lbs 11.81 oz (1,242g) 

1.1.3 Hover Accuracy (Ready to Fly) -Vertical: .8m; Horizontal: 2.5m 

1.1.4 Max Yaw Angular Velocity 200°/s

1.1.5 Max Tilt Angel 35°

1.1.6 Max Ascent / Descent Speed: Ascent 6m/s Descent 2m/s

1.1.7 Max Flight Speed-15m/s (NOT RECOMMENDED)

1.2 Gimbal

1.2.1 Working Current -Static: 750mA; Dynamic: 900mA

1.2.2 Control Accuracy -±O.03°

1.2.3 Controllable Range -Pitch: 90° to 0°

1.2.4 Maximum Angular Speed Pitch: 90°/s

1.3 Camera

1.3. 1 Operating Temperature Range 32°F - 104°F (O°C to 40°C) 1.3.2 

Sensor Size 1⁄2.3"

1.3.3 Effective Pixels: 14 Megapixels

1.3.4 Resolution 4384x3288px

1.3.5 HD Video Recording: 1080p 30 & nop

1.3.6 Recording Field of View: 110°/85° 

Page 25 of 26 
EXHIBIT B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

DAVID ARNOLD AND AIRBORNEPICS only utilizes safe and reliable 

sUAS. DJI is an industry leader in small UAS production. DJI sUAS are 

complete with leading edge and proven 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) 

DJI Inspire 1 

1.1 Aircraft

1.1.1 Model -T600

1.1.2 Weight (Battery Included) -6 lbs 7.52910z (2,935g)

1.1.3 Hovering Accuracy (GPS Mode) -Vertical: 0.5m; Horizontal: 2.5m 

1.1.4 Max Angular Velocity: Pitch: 300°/s; Yaw: 150°/s

1.1.5 Max Tilt Angle: 35°

1.1.6 Max Ascent Speed: 5m/s

1.1.7 Max Descent Speed: 4m/s

1.1.8 Max Speed: 22m/s (ATTI mode, no wind-NOT RECOMMENDED) 

1.1.9 Max Flight Altitude 4,500m MSL

1.1.10 Max Wind Resistance: 10m/s

1.1.11 Max Flight Time -Approximately 18 minutes

1.1.12 Motor Model: DJI 3510

1.1.13 Propeller Model: DJI 1345

1.1.14 Operating Temperature Range: 14°F to 104°F (-10°C to 40°C) 1.1.15 

Dimensions 438x451x201 mm 17.25” x 17.76" x 7.9"

1.2 Gimbal

1.2.1 Model: ZENMUSE X3

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

1.2.3 Operating Current -Static: 750mA; In Motion: 900mA

1.2.4 Angular Vibration Range -±0.03 °

1.2.5 Mounting -Detachable

1.2.6 Controllable Range: Pitch: -90°to +30°; Pan: ±320°
1.2.7 Mechanical Range: Pitch: -125°to +45°; Pan: ±330°

1.2.8 Max Controllable Speed: Pitch: 120°/s; Pan: 180°/s

1.3 Transmitter

1.3.1 Name-CI

1.3.2 Operating Frequency 5.728 to 5.850 GHz; 2.400-2.483GHz

1.3.3 Communicating Distance (unobstructed): 3.1 miles

1.3.4 Output Power -9W

1.3.5 Operating Temperature Range -14°F to 104°F (-10°C to 40°C)

1.3.6 Battery 4,500mAh 2S or optional 5,700mAh LiPo 2S 

Page 26 of 26