UNITED STATES OF 

AMERICA

 DEPARTEMNT OF 

TRANSPORTATION 

 FEDERAL AVIATION 

ADMINISTRATION 

 

WASHINGTON, DC 

 

 Regulatory Docket 

No.________________ 

 IN THE MATTER OF THE 

PETITION FOR EXEMPTION OF: 

 

Addison M. Dickinson 

 FOR AN EXEMPTION SEEKING RELIEF 

FROM THE REQUIREMENTS OF 

 TITLE 14 OF THE CODE OF 

FEDERAL REGULATIONS 

 SECTIONS 14 CFR PART 21, 

45.23(b),61.113 (a)&(b), 91.7 (a), 91.9 (b)(2) 

 91.103, 91.109, 91.119, 91.121, 91.151 (a), 91.203 (a)&(b), 

91.405 (a), 401 (a)(1), 409 (a)(2), 

 And 417 (a)&(b) CONCERNING 

COMMERCIAL OPERATION OF THE 

 DJI PHANTOM 2 VISION+, DJI 

PHANTOM 3, AND DJI INSPIRE 1 

 UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF 

 THE FAA MODERNIZATION AND REFORM 

ACT OF 2012 (PUBLIC LAW 112-95) 
Submitted on July 22, 2015

Addison M. Dickinson

11288 Persimmons Blvd

Royal Palm Beach, FL 33411

561 542-2665

addisondickinson@gmail.com 
July 22, 2015 
U. S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Section 333 of the FAA Reform Act and Part 11 of the 

Federal 

Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR 61.113 (a) 

& (b); 

91.7 (a);91.9 (b) (2);91.103(b); 91.109;91.119; 91.121; 91.151(a);91.203(a) & 

(b);91.405 

(a); 91.407(a) (1); 91.409 (a) (2);91.417 (a) & (b). 

Dear Sir or Madam: 

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

Reform

Act) and 14 C.F.R. Part 11, Addison M. Dickinson, operator of Small Unmanned 

Aircraft 

Systems (“sUASs”) equipped to offer on-demand commercial UAS operations for 

a host 

of industries and applications. These include: 

• Public Safety Support Operations 

• Solar field voltaic module inspection 

• Utility-power generation system inspections and patrolling

• Pipeline inspection and patrolling, 

• Filmmaking, cinematography, and videography 

• Precision agriculture

• Wildlife and forestry monitoring 

• Aerial surveying 

• Construction site inspection and monitoring 

* infrastructure inspection and monitoring 

* scientific research

* search and rescue

• Real-estate marketing 

• Motion Picture Filming

* infrastructure inspection and monitoring 
* scientific research

* search and rescue

• Real-estate marketing 

• Motion Picture Filming

Addison M. Dickinson hereby applies for an exemption from the listed Federal 

Aviation Regulations (“FARs”) to allow commercial operation of its sUASs, 

so long as such operations are conducted within and under the conditions 

outlined herein or as may be established by the FAA as required by Section 333. 

As described more fully below, the requested exemption would permit the 

operation of 

small, unmanned and relatively inexpensive sUAS under controlled conditions in 

airspace that is 1) limited 2) predetermined 3) controlled as to access and 4) would 

provide safety enhancements to the already safe operations using conventional 

aircraft. 

Approval of this exemption would thereby enhance safety and fulfill the Secretary

of 

Transportation’s (the FAA Administrator’s) responsibilities to “...establish 

requirements 

for the safe operation of such aircraft systems in the national airspace system.” 

Section 

333(c) of the Reform Act. 
The name and address of the petitioner is: 
Addison M. Dickinson

11288 Persimmons Blvd

Royal Palm Beach, FL 33411

561 542-2665

addisondickinson@gmail.com

Regulations from which the exemption is requested: 

14 CFR Part 21 

14 C.F.R. 45.23(b) 

14 CFR 61.113 (a) & (b) 

14 C.F.R. 91.7 (a) 

14 CFR 91.9 (b) (2) 

14 C.F.R. 91.103 

14 C.F.R. 91.109 

14 C.F. R. 91.119 

14 C.F.R. 91.121 

14 CFR 91.151 (a) 

14 CFR 91.203 (a) & (b) 

14 CFR 91.405 (a) 

14 CFR 407 (a) (1) 

14 CFR 409 (a) (2) 

14 CFR 417 (a) & (b) 

This exemption application is expressly submitted to fulfill Congress’ goal in 

passing 

Section 333(a) through (c) of the Reform Act. This law directs the Secretary of 

Transportation to consider whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before completion of the rulemaking 

required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types of UASs do not create a hazard to 

users 

of the NAS or the public or pose a threat to national security in light of the 

following: 

• The UAS’s size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may 

operate safely in the national airspace system, the Secretary shall establish 
requirements for the safe operation of such aircraft in the national airspace 

system.” Id. 

§333(c) (emphasis added) 

Applicant interprets this provision to place the duty on the Administrator to not 

only 

process applications for exemptions under section 333, but for the Administrator to 

craft 

conditions for the safe operation of the UAS, if it should be determined that the 
conditions set forth herein do not fulfill the statutory requirements for approval. 

The Federal Aviation Act expressly grants the FAA the authority to issue 

exemptions. 

This statutory authority by its terms includes exempting civil aircraft, as the term is 

defined under §40101 of the Act that includes sUASs, from the requirement that all 

civil 

aircraft must have a current airworthiness certificate. 

The Administrator may grant an exemption from a requirement of a regulation 

prescribed 

under subsection (a) or (b) of this section or any sections 44702-44716 of this title 

if the 

Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See 

also 49 

USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

Addison M. Dickinson's UASs are rotorcraft, weighting 55 or fewer lbs. including 

payload. 

They operate, under normal conditions at a speed of no more than 50 knots and 

have the 

capability to hover, and move in the vertical and horizontal plane simultaneously. 

They 

will operate only in line of sight and will operate only within a sterile area. Such 

operations will insure that the sUAS will “not create a hazard to users of the 

national 

airspace system or the public.” Specific operational sUASs are the DJI Phantom 2 

Vision+, 

DJI Phantom 3, and DJI Inspire 1. The DJI Phantom 2 Vision+, DJI Phantom 3, 

and DJI 

Inspire 1 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

Ground

Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI 

Phantom 2 Vision+ and Phantom 3 have a maximum gross weight of 

approximately 2 

pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of 

8 inches, 

and 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 2 
Vision+,

Phantom 3, and the DJI Inspire 1 UAs are equipped with four main rotors; driven 

by 

Lithium Polymer battery powered electric motors. The DJI Phantom 2 Vision+, 

Phantom 3, 

and DJI Inspire 1 UAs that will be operated by HYSight Technologies 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.

Reform Act Section 333 (b). 

Given the small size of the sUASs involved and the restricted sterile environment 

within 

which they will operate, the applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately. Also 

due to 

the size of the UASs and the restricted areas in which the relevant sUASs will 

operate, 

approval of the application presents no national security issue. Given the clear 

direction 

in Section 333 of the Reform Act, the authority contained in the Federal Aviation 

Act, as 

amended; the strong equivalent level of safety surrounding the proposed 

operations, and 

the significant public benefit, including enhanced safety, reduction in 

environmental 

impacts, including reduced emissions associated with allowing UASs, the grant of 

the 

requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested 

exemption without delay. 
AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

The applicant proposes that the exemption requested herein apply to civil aircraft 

that 

have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to 

operations 

under the current regulatory structure because the proposed operations represent a 

safety enhancement to the already safe operations conducted with conventional 

aircraft. 

These limitations and conditions to which Addison M. Dickinson agrees to be 

bound when 

conducting commercial operations under an FAA issued exemption include: 

 

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated within line of sight of a pilot and/or observer.

3. Maximum total flight time for each operational flight will be 45 minutes. 

Flights will be terminated at 25% battery

power reserve should that occur prior to the 45 minute limit.

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not 

more than 200 feet above an elevated

platform from which filming is planned.

5. Minimum crew for each operation will consist of the sUAS Pilot, the Visual 

Observer, and/or the Camer Operator.

6. sUAS pilot may be an FAA licensed airman with at least a private pilot’s 

certificate and 3rd class medical certificate.

7. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other 

than the sUAS Pilot, who possess

the necessary PIC qualifications, is also present (i.e. the Visual Observer), that 

person can also be designated as

the PIC.

8. The UAS will only operate within a confined “Sterile Area” of the flight 

operations area.

9. A briefing will be conducted in regard to the planned sUAS operations prior to 

each day’s activities. It will be

mandatory that all personnel who will be performing duties within the boundaries 

of the safety perimeter be

present for this briefing.

10. The operator will obtain the consent of all persons involved and ensure that 

only consenting persons will be

allowed within 100 feet of the flight operation, and this radius may be reduced to 
30 feet based upon an equivalent

level of safety determination.

11. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on

the particular UAS to be operated.

12. Observer and pilot will at all times are able to communicate by voice and/or 

text.

13. Written and/or oral permission from the relevant property holders will be 

obtained.

14. All required permissions and permits will be obtained from territorial, state, 

county or city jurisdictions,

including local law enforcement, fire, or other appropriate governmental agencies.

15. If the sUAS loses communications or loses its GPS signal, the UAS will have

capability to return to a pre-determined location within the Security Perimeter and 

land.

16. The sUAS will have the capability to abort a flight in case of unpredicted 

obstacles or emergencies.

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 

(a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural 

requirements 

for the issuance of airworthiness certificates as required by FAR §91.203 (a) (1). 

Given 

the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, an exemption from Part 21 Subpart H meets the requirements of an 

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

Federal 

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

authorize the 

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

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

airports 

and populated areas of the particular UAS. In all cases, an analysis of these criteria 

demonstrates that the UAS operated without an airworthiness certificate, in the 

restricted 

environment and under the conditions proposed will be at least as safe, or safer, 

than a 

conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness 

certificate 

without the restrictions and conditions proposed. 

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither 

a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured area as set out in the Manual. Unlike other

civil 

aircraft, operations under this exemption will be tightly controlled and monitored 

by both 

the operator, pursuant to the Manual’s requirements, and under the requirements 

and in 

compliance with local public safety requirements, to provide security for the area 

of 

operation as is now done with conventional filming. The FAA will have advance 

notice of 

all operations. These safety enhancements, which already apply to civil aircraft

operated 
in connection with motion picture and television production, provide a greater 

degree of 

safety to the public and property owners than conventional operations conducted 

with 

airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, 

application 

of these same criteria demonstrates that there is no credible threat to national 

security 

posed by the UAS, due to its size, speed of operation, location of operation, lack of 

explosive materials or flammable liquid fuels, and inability to carry a substantial 

external 

load. The FAA has issued the following exemptions to this regulations Exemptions 

Nos. 11251. 

14 C.F.R. § 45.23 (b). Marking of the Aircraft 

The regulation requires: 

When marks include only the Roman capital letter "N" and the registration number 

is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft 

near each 

entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor 

more 

than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," 

or 

"provisional," as applicable. Even though the UAS will have no airworthiness 

certificate, 

an exemption may be needed as the UAS will have no entrance to the cabin, 

cockpit or 

pilot station on which the word “Experimental” can be placed. Given the size of 

the 

sUAV, two-inch lettering will be impossible. The word “Experimental” will be 

placed on

the fuselage in compliance with §45.29 (f). 

The equivalent level of safety will be provided by having the sUAV marked on its 
fuselage as required by §45.29 (f) where the pilot, observer and others working 

with the 

sUAV will see the identification of the UAS as “Experimental.” The FAA has 

issued the 

following exemptions to this regulation to Exemptions, but not limited to, Nos. 

10700, 8738, 

10167 and 10167A, 11256, 11251. 

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

Command. 

Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. 

Because the 

sUAS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the 

aircraft 

to have a private pilot’s license rather than a commercial pilot’s license to operate 

this 

small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the 

sUAS 

is remotely controlled with no living thing on board. The area of operation is 

controlled 

and restricted, and all flights are planned and coordinated in advance. The level of 

safety 

provided by the requirements included in the Manual exceeds that provided by a 

single 

individual holding a commercial pilot’s certificate operating a conventional 

aircraft. The 

risks associated with the operation of the sUAS are so diminished from the level of 

risk 

associated with commercial operations contemplated by Part 61 when drafted, that 

allowing operations of the sUAS as requested with a private pilot as the PIC 

exceeds the 

present level of safety achieved by 14 C.F.R. §61.113 (a) & (b). 

14 C.F.R. §91.7(a): Civil aircraft airworthiness. 

The regulation requires that no person may operate a civil aircraft unless it is in 

airworthy 

condition. As there will be no airworthiness certificate issued for the aircraft, 
should this 

exemption be granted, no FAA regulatory standard will exist for determining 

airworthiness. Given the size of the aircraft and the requirements contained in the 

Manual for maintenance and use of safety check lists prior to each flight, as set 

forth in 

Sections J, L and Q, an equivalent level of safety will be provided. 

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. 

Section 91.9 (b) (2) provides: 

No person may operate a U.S.-registered civil aircraft ... 

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of 

this 

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

Rotorcraft 

Flight Manual, approved manual material, markings, and placards, or any 

combination 

thereof. The sUAS, given its size and configuration has no ability or place to carry 

such a 

flight manual on the aircraft, not only because there is no pilot on board, but 

because 

there is no room or capacity to carry such an item on the aircraft. 

The equivalent level of safety will be maintained by keeping the flight manual at 

the 

ground control point where the pilot flying the sUAS will have immediate access 

to it. 

The FAA has issued the following exemptions to this regulation, but not limited to: 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 

10602,

32827, 10700, 11251, and 11256. 
14 C.F.R. § 91.103: Preflight action 

This regulation requires each pilot in command to take certain actions before flight 

to 

insure the safety of flight. As FAA approved rotorcraft flight manuals will not be 

provided 

for the aircraft an exemption will be needed. The PIC will take all actions 

including 

reviewing weather, flight battery requirements, landing and takeoff distances and 

aircraft 

performance data before initiation of flight. 

14 C.F.R. §91.109: Flight instruction: 

Section 91.103 provides that no person may operate a civil aircraft (except a 

manned 

free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. sUASs and remotely piloted aircraft, by their design do 

not have fully functional dual controls. Flight control is accomplished through the 

use of a control box that communicates with the aircraft via radio communications. 

The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. 

See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by 

the fact that neither a pilot nor passengers will be carried in the aircraft and by the

size and speed of the aircraft. 

14 C.F.R. §91.119: Minimum safe altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 

91.119 (d) 

allows helicopters to be operated at less than the minimums prescribed, provided 

the 

person operating the helicopter complies with any route or altitudes prescribed for 

helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and 

the 

exemption requests authority to operate at altitudes up to 400 AGL, or not more 

than 

200 above an elevated platform from which filming is planned, an exemption may 

be 

needed to allow such operations. As set forth herein, except for the limited 

conditions 

stated in the Manual, the UAS will never operate at higher than 400 AGL. It will 
however 

be operated in a restricted area with security perimeter, where buildings and people 

will 

not be exposed to operations without their pre-obtained consent. The equivalent 

level of 

safety will be achieved given the size, weight, and speed of the UAS as well as the 

location where it is operated. No flight will be taken without the required 

permission of 

the property owner or local officials. Because of the advance notice to the property 

owner and participants in the aerial activity, all affected individuals will be aware 

of the 

planned flight operations. Compared to flight operations with aircraft or rotorcraft 

weighting far more than the maximum 55lbs. proposed herein and the lack of 

flammable 

fuel, any risk associated with these operations is far less than those presently 

presented 

with conventional aircraft operating at or below 500 AGL other industries. In 

addition, the 

low-altitude operations of the sUAS will ensure separation between these 

small-UAS 

operations and the operations of conventional aircraft that must comply with 

Section 

91.119. 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires each person operating an aircraft to maintain cruising 

altitude by 

reference to an altimeter that is set “...to the elevation of the departure airport or an 
appropriate altimeter setting available before departure.” As the sUAS may not 

have a 

barometric altimeter, but instead a GPS altitude read out, an exemption may be 

needed. 

An equivalent level of safety will be achieved by the operator, pursuant to the 

Manual 

and Safety Check list, confirming the altitude of the launch site shown on the GPS 

altitude indicator before flight. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Section 91.151 (a) prohibits an individual from beginning “a flight in an airplane 

under 

VFR conditions unless (considering wind and forecast weather conditions) there is 

enough fuel to fly to the first point of intended landing, and, assuming normal 

cruising 

speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, 

to fly 

after that for at least 45 minutes.” 

The battery powering the sUAS provides approximately 30-50 minutes of powered 

flight. To 

meet the 30-minute reserve requirement in 14 CFR §91.151, sUAS flights would 

be 

limited to approximately 20 minutes in length. Given the limitations on the UAS’s 

proposed flight area and the location of its proposed operations within a 

predetermined 

area, a longer time frame for flight in daylight or night VFR conditions is 

reasonable. 

Applicant believes that an exemption from 14 CFR §91.151(a) falls within the 

scope of 

prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation 

to 

operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a 

tightly 

controlled area where only people and property owners or official representatives

who 

have signed waivers will be allowed, with less than 30 minutes of reserve fuel, 

does not 

engender the type of risks that Section 91.151(a) was intended to alleviate given 

the size 
and speed of the small UAS. Additionally, limiting sUAS flights to 20 minutes 

would 

greatly reduce the utility for which the exemption will be granted. 

Applicant believes that an equivalent level of safety can be achieved by limiting 

flights to 

45 minutes or 25% of battery power whichever happens first. This restriction

would be 

more than adequate to return the sUAS to its planned landing zone from anywhere 

in its 

limited operating area. Similar exemptions have been granted to other operations, 

including 

Exemptions 2689F, 5745, 10673, 10808, and 11251. 

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and 

Registration 

The regulation provides in pertinent part: 

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it 

has 

within it the following: 

(1) An appropriate and current airworthiness certificate. . . . 

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

required by 

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

is 

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

The UAS fully loaded weighs no more than 55 lbs and is operated without an 

onboard 

pilot. As such, there is no ability or place to carry certification and registration 

documents 

or to display them on the sUAS. 

An equivalent level of safety will be achieved by keeping these documents at the 

ground 

control point where the pilot flying the sUAS will have immediate access to them, 

to the 

extent they are applicable to the sUAS. The FAA has issued numerous exemptions 

to 
this regulation. A representative sample of other exceptions includes Exemption 

Nos. 

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, 10700, 11251, and 11256. 

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance 

Inspections 

These regulations require that an aircraft operator or owner “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...,” and others shall inspect or maintain the 

aircraft in 

compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness 

certificate, these sections will not apply to the applicant. The operator pursuant to 

the 

flight manual and operating handbook will accomplish maintenance. An equivalent 

level 

of safety will be achieved because these small UASs are very limited in size and 

will 

carry a small payload and operate only in restricted areas for limited periods of 

time. If 

mechanical issues arise the UAS can land immediately and will be operating from 

no 

higher than 400 feet AGL. As provided in the Manual, the operator will ensure that 

the 

UAS is in working order prior to initiating flight, perform required maintenance, 

and keep 

a log of any maintenance performed. Moreover, the operator is the person most 

familiar 

with the aircraft and best suited to maintain the aircraft in an airworthy condition to 

provide the equivalent level of safety. 

********* 

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

in the 

Federal Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 
(a); 91.9 

(b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 

91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate 

commercially a small unmanned vehicle (55lbs or less). 

Approval of exemptions allowing commercial operations of sUASs, will enhance 

safety 

by reducing risk. Conventional operations, using jet or piston power aircraft, 

operate at 

extremely low altitudes just feet from the subjects being filmed and in extreme 

proximity 

to people and structures and present the risks associated with vehicles that weigh in 

the 

neighborhood of 4,000lbs, carrying large amounts of jet A or other fuel. Such 

aircraft 

must fly to and from the operational location. In contrast, a sUAS weighing fewer 

than 55 

lbs. and powered by batteries eliminates virtually all of that risk given the reduced 

mass 

and lack of combustible fuel carried on board. The sUAS is carried to the operation 

site 

and not flown. The sUAS will carry no passengers or crew and, therefore, will not 

expose 

them to the risks associated with manned aircraft flights. 
The operation of small UASs, weighting less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the 

grant 

of the exemptions requested herein, including exempting the applicant from the 

requirements of Part 21 and allowing commercial operations. These lightweight 

aircraft 

operate at slow speeds, close to the ground, and in a sterile environment and, as a 

result, are far safer than conventional operations conducted with turbine helicopters 

operating in close proximity to the ground and people. 

Privacy 

All flights will occur over private or controlled access property with the property 

owner’s 

prior consent and knowledge. Filming will be of people who have also consented 

to 

being filmed or otherwise have agreed to be in the area where filming will take 

place. 

The grant of this exemption request will provide improved safety in both day and 

night 

operations. Satisfaction of the criteria provided in Section 333 of the Reform Act 

of 2012-

-size, weight, speed, operating capabilities, proximity to airports and populated 

areas 

and operation within visual line of sight and national security – provide more than 

adequate justification for the grant of the requested exemptions allowing 

commercial 

operation of applicant’s UAS. It is of note that certain public safety operations may 

involve advanced monitoring technology such as Infrared Red, Night Vision, etc.

These specific operations will be governed pursuant to all applicable Local, State, 

and Federal laws regarding search and seizure including court approval of said 

operations via search warrant. 

Conclusion 

As set forth herein, Addison M. Dickinson 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 2 

Vision+, DJI Phantom 3, and DJI Inspire 1 UASs commercially, without an

airworthiness certificate, for the limited purpose of conducting the 
aforementioned on-demand commercial sUAS operations that include: 

• Public Safety Support Operations 

• Solar field voltaic module inspection 

• Utility-power generation system inspections and patrolling, 

• Pipeline inspection and patrolling, 

• Filmmaking, cinematography, and videography, 

• Precision agriculture, 

• Wildlife and forestry monitoring, 

• Aerial surveying, and 

• Construction site inspection and monitoring 

* infrastructure inspection and monitoring 

* scientific research

* search and rescue

• Real-estate marketing 

• Motion Picture Filming
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 Addison M. Dickinson to safely, 

efficiently,
and economically operate sUASs commercially within the NAS. 
WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA

Modernization and Reform Act of 2012, section 333, Addison M. Dickinson 

respectfully

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

requirements 

of 14 C.F.R Sections 45.23(b); Part 21; 61.113(a) & (b), 91.7(a); 91.9(b); 

91.103(b);

91.109; 91.119; 91.121; 91.151(a); 91.203(a); 91.405(a), 91.407(a)(1); 

91.409(a)(1) &

(a)(2), and 91.417(a) & (b), and permit Addison M. Dickinson to operate the DJI 

Phantom

2 Vision+, DJI Phantom 3, and the DJI Inspire 1 commercially in the United 

States. 

Respectfully Submitted, 

Addison M. Dickinson

11288 Persimmons Blvd

Royal Palm Beach, FL 33411

561 542-2665

addisondickinson@gmail.com

Appendices: 

A – DJI Phantom 2 Vision+/Phantom 3 – Specifications Data Sheet 

B – DJI Inspire 1 Specifications Data Sheet 

C – Link to DJI Phantom 2 Vision+ Manufacturer’s User Manual 

D – Link to DJI Inspire 1 Manufacturer’s User Manual 

APPENDIX – A 

DJI PHANTOM 2 VISION+/PHANTOM 3 TECHNICAL SPECIFICATIONS 

Addison M. Dickinson only utilizes safe and reliable sUASs. DJI is an industry 

leader

in small UAS production. DJI UASs are loaded with ground breaking software 

enabling 

the user to set parameters which will not allow flight into controlled airspace. 

Parameters 

can also be set to limit flight to no higher than a predetermined and set altitude as 

well 

as limit flight to a predetermined and set distance. In addition, DJI software 

provides 

real-time altitude and location information to the PIC via the linked monitor (smart 

phone/tablet devices) 

1.1 DJI Phantom 2 Vision+/Phantom 3 

. 

1.1.1 Aircraft 

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m

1.1.1.4 Max Yaw Angular Velocity - 2000/s 

1.1.1.5 Max Tilt Angel - 350 1.1.1.6 Max Ascent Speed – 6m/s 

1.1.1.7 Max Descent Speed – 2m/s 

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

. 

1.1.2 Gimbal 

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 

1.1.2.2 Control Accuracy - ±0.030 

1.1.2.3 Controllable Range – Pitch: -900 - 00 

1.1.2.4 Maximum Angular Speed – Pitch: 900/s 

.1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C)

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M 

1.1.3.4 Resolution – 4384x3288 4.1.3.5 HD Video Recording – 1080p30 & 720p 

4.1.3.6 Recording Field of View - 1100/850 

.1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 1.1.4.3 

Receiver Sensitivity (1%PER) - -93dBm 
1.1.4.4 Transmitter Power – FCC Compliance: 100mW 

1.1.4.5 Working Voltage – 120mA@3.7V 

1.1.5 Range Extender 

1.1.5.1 Operating Frequency – 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm
1.1.5.4 Power Consumption – 2W 

APPENDIX – B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Addison M. Dickinson only utilizes safe and reliable UASs. DJI is an industry 

leader

in small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled 

airspace.

Parameters can also be set to limit flight to no higher than a predetermined and set 

altitude as well as limit flight to a predetermined and set distance. In addition, DJI

software provides real-time altitude and location information to the PIC via the 

linked 

monitor (smart phone/tablet devices) 

AC

2.2 DJI Inspire 1 

. 

2.2.1 Aircraft 

2.2.1.1 Model – T600 

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350 

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 20 minutes 

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 2.2.1.15

Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X3 

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

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.030 

2.2.2.5 Mounting – Detachable 
2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 

2.2.3.1 Name – X3 
2.2.3.2 Model – FC350 

2.2.3.3 Total Pixels – 12.76M 2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940 

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30;

FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 

. 

2.2.4 Transmitter 

2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 

2.2.4.3 Communicating Distance (unobstructed) – 2000m

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 400C) 

2.2.4.6 Battery – 600mAh LiPo 2S 

APPENDIX – C 

DJI Phantom 2 Vision+ Manufacturer’s User Manual 

http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/Phantom_2_

Vision_Plus_User_M anual_v1.8_en.pdf 

APPENDIX – D 

DJI Inspire 1 Manufacturer’s User Manual 

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.0_en.pdf