UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 2015-____

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

WILLIAM P THRASHER

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

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

OPERATION OF DJI Inspire 1, Phantom 2 & 3 and 3D Robotics (3DR) SOLO

UNMANNED AIRCRAFT SYSTEMS.

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on 

WILLIAM P THRASHER 

31859 N. Finley Point Rd 

Polson, Montana 59860 

(406) 887-2266

jaxgrammy777@gmail.com
TABLE OF CONTENTS

Page 

GLOSSARY OF 

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

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

INTRODUCTION AND INTERESTS OF 

PETITIONER............................................................................................................4 

BACKGROUND.......................................................................................................4 

BASIS FOR 

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

NAME AND ADDRESS OF 

PETITIONER...........................................................................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WILLIAM P THRASHER

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

THE EXTENT OF RELIEF WILLIAM P THRASHER SEEKS AND THE REASON 

WILLIAM P THRASHER SEEKS THE RELIEF..............................................11 

THE REASONS WHY GRANTING WILLIAM P THRASHER REQUEST WOULD 

BE IN THE PUBLIC INTEREST.................................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY..................................................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.............32

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT WILLIAMPTHRASHER REQUEST.....................................................32

CONCLUSION.......................................................................................................33

Attachments explanation.........................................................................34
GLOSSARY OF ABBREVIATIONS

3DR 3D Robotics 

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations 

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

Section 333 FAA Mod and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer 

SOP Standard Operating Procedures 

UAV Unmanned Aircraft Vehicle 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing

SUMMARY

WILLIAM P THRASHER 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 WILLIAM P THRASHER to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and 

photography of construction sites, real estate, and landscape over certain areas of 

the United States. 
INTRODUCTION AND INTERESTS OF THE PETITIONER

WILLIAM P THRASHER provides his clients with expertise and knowledge in 

advanced technologies and solutions to increase efficiency, productivity and 

effectiveness. WILLIAM P THRASHER currently holds a private pilot’s license

certificate number 1878535 with over 100 hours of flight time. The objective of 

WILLIAM P THRASHER and his aerial operations is to provide high quality 

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

targeting:

• Real-estate marketing

• Construction sites before and after

• Appraisals

• Aerial acquisitions for inspections of public and private 

structures.

• Building Inspection operations

BACKGROUND

Unmanned Aircraft Systems: 

DJI Inspire 1, Phantom 2 & 3 

3D Robotics SOLO

WILLIAM P THRASHER seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI Inspire 1, Phantom 2 & 3 and 3D 

Robotics SOLO are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) 

with a Ground Control Station (GCS) utilizing electronic tablet or smart phone 

systems. 

The DJI Inspire 1 has a maximum gross weight of approximately 7 pounds, with a 

length of 17 inches and a width of 18 inches and a height of 10 inches and a 

maximum speed of approximately 30 knots.

DJI Phantom 2 has a maximum gross weight of approximately 3 pounds, while 

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

maximum speed of approximately 29 knots. 
DJI Phantom 3 has a maximum gross weight of 3 pounds, a length of 17.3 inches, 

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

approximately 30 knots.

The 3D Robotics SOLO has a maximum gross weight of 3.5 pounds, a length of 

18 inches, width of 13 inches, height of 10 inches, and a maximum speed of 

approximately 50 knots. 

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO are equipped with four main 

rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS will be operated by 

WILLIAM P THRASHER and 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.

BASIS FOR PETITION

Petitioner, WILLIAM P THRASHER , pursuant to the provisions of the Federal 

Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform 

Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft 

Systems, hereby petitions the Administrator to commercially operate the DJI 

Inspire 1 and DJI Phantom 2 & 3, UASs in the National Airspace System (NAS), 

and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

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

91.417(a) & (b). 

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

with the unmanned aircraft and its operation, WILLIAM P THRASHER operation 

DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs 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, WILLIAM P THRASHER requests relief from Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set 

forth requirements for maintenance that only apply to aircraft with an airworthiness 

certificate. 

WILLIAM P THRASHER submits that the requested relief is proper since an 

equivalent level of safety will be ensured. WILLIAM P THRASHER will use 

experienced personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UASs using the methods, techniques, and 
practices prescribed in the operating documents (i.e., Monthly Maintenance Log, 

and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manuals). 

Furthermore, WILLIAM P THRASHER will document and maintain all maintenance 

records for The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs. 

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

privileges and limitations: Pilot in command, is requested by WILLIAM P 

THRASHER to the extent necessary to allow a Pilot in Command (PIC) with 

significant experience in the field of UAV’s holding FAA ground school 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs in a manner 

consistent with this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 

WILLIAM P THRASHER seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs 

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

Subpart H. As such, WILLIAM P THRASHER submits that he will ensure The DJI 

Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs are in an airworthy condition, prior 

to every flight, by determining that the UASs are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UASs Instruction Manual), and that the aircraft are in a condition for 

safe flight. 

WILLIAM P THRASHER also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1, DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UAS will not have a typical barometric altimeter 

onboard. However, altitude information of The DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UASs will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from 

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

combined with WILLIAM P THASHER operation of The DJI Inspire 1, Phantom 2 & 

3 and 3DR SOLO UASs within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Additionally, WILLIAM P THRASHER seeks an exemption from the requirements 

of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions.

WILLIAM P THRASHER submits that safety will not be affected by operation of 

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs during daylight hours in 

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

enough battery power to fly for a total duration of approximately 15 minutes to the 
first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 5 minutes. 

In accordance with 14 C.F.R. § 11.81, WILLIAM P THRASHER 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:

William P Thrasher

31859 N. Finley Point Rd

Polson, Montana 59860

jaxgrammy777@gmail.com

(406)887-2266

B. The Specific Sections of 14 C.F.R. From Which WILLIAM P THRASHER

Seeks Exemption. 

1. WILLIAM P THRASHER Seeks Exemption from The Requirements 

Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in 

command, subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) of an aircraft that is carrying passengers or property for 

compensation or hire; nor may that person, for compensation or hire, act 

as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft 

in connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

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

2. WILLIAM P THRASHER 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. WILLIAM P THRASHER Seeks Exemption From The 

Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the 

following, in part: 

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

or flight level of that aircraft, as the case may be, by reference to an 

altimeter that is set, when operating--

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

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

route and within 100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or 

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

elevation of the departure airport or an appropriate altimeter 

setting available before departure. 

4. WILLIAM P THRASHER Seeks Exemption From The 

Requirements Of Section 91.151(b).

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

subsection

(b), states the following: 

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

unless (considering wind and forecast weather conditions) there is

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

normal cruising speed, to fly after that for at least 20 minutes. 
5. WILLIAM P THRASHER 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. WILLIAM P THRASHER Seeks Exemption From The 

Requirements Of Section 91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, or alteration, subsection (a)(1), states the 

following: 

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

maintenance, preventive maintenance, rebuilding, or alteration unless--

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

under § 43.7 of this chapter[.] 

7. WILLIAM P THRASHER Seeks Exemption From The 

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

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

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

operate an aircraft unless, within the preceding 12 calendar months, it 

has had --

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

and has been approved for return to service by a person authorized 

by § 43.7 of this chapter; or 

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

accordance with part 21 of this chapter. 

8. WILLIAM P THRASHER Seeks Exemption From The 

Requirements Of Sections 91.417(a) And 91.417(b). 
Section 91.417, entitled Maintenance records, subsections (a) and (b), state 

the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, 

each registered owner or operator shall keep the following records for 

the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and 

alteration and records of the 100-hour, annual, progressive, and 

other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and 

appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the 

Administrator) of the work performed; and 

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

(iii) The signature and certificate number of the person approving 

the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each 

propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, 

engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the 

aircraft which are required to be overhauled on a specified time 

basis. 

(iv) The current inspection status of the aircraft, including the 

time since the last inspection required by the inspection program 

under which the aircraft and its appliances are maintained. 

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

and safety directives including, for each, the method of 

compliance, the AD or safety directive number and revision date. 

If the AD or safety directive involves recurring action, the time 

and date when the next action is required. 
(vi) Copies of the forms prescribed by § 43.9(d) of this chapter 

for each major alteration to the airframe and currently installed 

engines, rotors, propellers, and appliances. 

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

periods prescribed: 

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

retained until the work is repeated or superseded by other work or for 

1 year after the work is performed. 

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

retained and transferred with the aircraft at the time the aircraft is 

sold. 

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

§ 43.11 of this chapter shall be retained until the defects are repaired 

and the aircraft is approved for return to service. 

C. The Extent Of Relief WILLIAM P THRASHER Seeks And The Reason 

WILLIAM P THRASHER Seeks The Relief. 

1. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason 

WILLIAM P THRASHER Seeks Relief From Section 61.113(a) And 

(b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and 

limitations: Pilot in command, is requested to the extent necessary to allow a PIC 

holding a private pilot or higher level certificate, as well as a current and valid 

airman medical certificate, and who has met certain flight-hour and currency 

requirements, to conduct the proposed UAS flight operations for compensation or 

hire. 

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in 

connection with any business or employment if: (1) The flight is only incidental to 

that business or employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. 

As set forth more fully below, WILLIAM P THRASHER submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate DJI 

Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s unless that PIC has met certain 

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

operate either the DJI Inspire 1, DJI Phantom 2 , DJI Phantom 3 3DR SOLO
UAS’s 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, WILLIAM P THRASHER submits that all flights of DJI Inspire 1, Phantom 

2 & 3 and 3DR SOLO UASs, conducted by the PIC pursuant to the grant of this 

Petition: (1) will be incidental to WILLIAM P THRASHER business; and (2) will not 

carry passengers or property for compensation or hire. 

2. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason 

WILLIAM P THRASHER Seeks Relief From Section 91.7(a). 

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

extent required to allow WILLIAM P THRASHER to determine that the DJI Inspire 

1, Phantom 2 & 3 and 3DR SOLO UASs are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., 

the WILLIAM P THRASHER Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manual). 

WILLIAM P THRASHER seeks the requested relief because the DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UASs do not require an airworthiness certificate in 

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

THRASHER will ensure that the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO

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

documents (i.e., Monthly Maintenance Log, and DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UASs Instruction Manual) prior to every flight, and further, determine 

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

limitations below.

3. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason 

WILLIAM P THRASHER Seeks Relief From Section 91.121. 

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

flight operations of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs, which 

utilize a barometric pressure sensor, GPS equipment, and a radio communications 

telemetry data link to downlink altitude information from the UA to the PIC at the 

ground control station (GCS). Since the FAA requires that any altitude information 

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

ground level (AGL), WILLIAM P THRASHER seeks the requested relief because 
the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO 

UASs are equipped with a barometric pressure sensor and GPS equipment, which 

automatically ensures that a ground level pressure setting will be established prior 

to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS. 

4. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason 

WILLIAM P THRASHER Seeks Relief From Section 91.151(b). 

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

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

powered DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 15 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 5 minutes. WILLIAM P 

THRASHER seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UASs will severely constrain the practicality of any 

aerial video or still photo flight operations that WILLIAM P THRASHER proposes 

to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UAS’s operating documents, and WILLIAM P 

THRASHER proposed operating limitations, ensure that WILLIAM P THRASHER

will safely operate the battery powered DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UAS’s during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), with enough battery power to fly for a total duration 

of 15 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 5 minutes.

5. Extent Of Relief WILLIAM P THRASHER Seeks And The Reason 

WILLIAM P THRASHER Seeks Relief From Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, WILLIAM P THRASHER

requests relief from these Sections because the DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UAS’s do not require airworthiness certificates. As set forth more fully 

below, DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs meet the conditions of 

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

WILLLIAM P THRASHER will use trained technicians to perform maintenance, 

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

techniques, and practices prescribed in the UAS operating documents (i.e., the 

WILLIAM P THRASHER Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs Instruction Manual). 

Furthermore, WILLIAM P THRASHER will document and maintain all maintenance 

records for the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs. 

D. The Reasons Why Granting WILLIAM P THRASHER Request Would Be 

In The Public Interest; That Is, How It Would Benefit The Public As A 

Whole. 

Granting the present Petition will further the public interest by allowing WILLIAM P 

THRASHER too 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits 

to the economy. Notably, the benefits of WILLIAM P THRASHER proposed 

operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs will be 

realized without implicating any privacy issues. 

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

DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO , and 3DRsolo UASs

Conducting aerial acquisitions with the DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UASs, instead of manned aircraft, will greatly benefit the public by 

drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery 

power and electric motors, the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO

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

alternative to the cabin class, six cylinder internal combustion engine aircraft that 

are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI Inspire 1, DJI Phantom 2 ,

DJI Phantom 3 UAS, while reducing the carbon footprint of aerial acquisitions, 

also eliminates noise pollution, as the UAS are propelled by battery powered 

electric motors, rather than an internal combustion engine. 

By using the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS to perform aerial 

acquisitions, the substantial risk to life and property in the air and on the ground, 

which is usually associated with traditional manned aircraft flight operations, will be 

substantially reduced or completely eliminated. Aside from the lack of flight crew 

members located onboard the aircraft, the DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UAS’s (weighing approximately 7.7 pounds , 3.5 pounds, 3.9 pounds and 

3.3 pounds respectively, at their maximum gross weights with lengths of 17 inches 

,16 inches and 8 inches respectively, widths of 18 inches , 16 inches and 8 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO , and 3DRsolo UAS will 

Benefit The Economy. 
In addition to being safe and efficient, the DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UASs are also an economical alternative to using manned aircraft to 

conduct similar aerial operations. As such, operation of the DJI Inspire 1, Phantom 

2 & 3 and 3DR SOLO UAS will allow United States based companies, like 

WILLIAM P THRASHER, 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s is one such 

technology that not only allows companies greater operational flexibility compared 

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

a traditional manned aircraft. 

By operating the DJI Inspire, 1, DJI Phantom 2 & 3 and 3DR SOLO UASs, 

companies such as WILLIAM P THRASHER 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax 

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

remain competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

for decades, WILLIAM P THRASHER proposed operation of the DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UASs will not implicate any privacy issues. 

Specifically, the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s will be 

operated only in compliance with operating documents (i.e., the WILLIAM P 

THRASHER Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 

1, DJI Phantom 2 &3 and 3DR SOLO UAS’s (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 WILLIAM P THRASHER

Seeks Exemption. 

1. Reasons Why The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO

UAS’s Meet The Conditions Of The FAA Modernization and Reform 

Act of 2012 (FMRA) Section 333. 

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

with the unmanned aircraft and its operation, WILLIAM P THRASHER operation of 

the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s meet the conditions of 

FMRA Section 333, and will not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness 

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

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

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

(a) In General.--Notwithstanding any other requirement of this subtitle, 

and not later than 180 days after the date of enactment of this Act, the 

Secretary of Transportation shall determine if certain unmanned aircraft 

systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this 

Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the 

determination under subsection (a), the Secretary shall determine, at a 

minimum--

(1) which types of unmanned aircraft systems, if any, as a result 

of their size, weight, speed, operational capability, proximity to 

airports and populated areas, and operation within visual line of 

sight do not create a hazard to users of the national airspace 

system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or 

airworthiness certification under section 44704 of title 49, United 
States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under 

this section that certain unmanned aircraft systems may operate safely 

in the national airspace system, the Secretary shall establish 

requirements for the safe operation of such aircraft systems in the 

national airspace system. 

In seeking this exemption, WILLIAM P THRASHER submits that the DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UAS’s can operate safely in the NAS pursuant to 

FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Inspire 

1, DJI Phantom 2 &3 and 3DR SOLO UASs; (b) the pilot certification requirement; 

and (c) the specific operating limitations. 

a. The Specifications Of The DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UAS’s Demonstrate Its Safe Characteristics.

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s do not create a hazard to 

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

considering its size, weight, speed, and operational capability. 

i. Technical Specifications of DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UAS’s.

The technical specifications of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO

UAS’s are set forth by the DJI Inspire 1, DJI Phantom 2 & 3 User Manuals, 

attached hereto as links. 

ii. The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s 

Autonomous Flight And Navigation Modes Enable The UASs 

To Remain Within A Defined Operational Area. 

The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s may be operated in both 

manual and fully autonomous flight modes. A complete description of the flight and 
navigational modes of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s

provided in the User Manuals, attached hereto as links. 

iii. The DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s

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 Inspire 1, Phantom 2 & 3 and 3DR SOLO 

UAS’s will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, 

the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s 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 Inspire 1 are set forth 

on pages 13 through 15, DJI Phantom 2 UAS pages 20 through 21 and for the 

DJI Phantom 3 at pages 13 through 14 of the DJI Inspire 1, DJI Phantom 2 and 

DJI Phantom 3 User Manuals, attached hereto as links. 

iv. DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s GCS 

Operation.

A complete description of the operation and specifications of the DJI Inspire 1 are 

located on pages 45-51 and 57 respectively. DJI Phantom 2 located on pages 10-

21 and 57 respectively. DJI Phantom 3 located on pages 40-46 and 53 

respectively. 3D Robotics SOL page 62. DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UAS’s User Manuals are attached hereto as links and attachments.

b. Flight Operations of DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UAS’s are Limited to The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer. 

WILLIAM P THRASHER will be the only person to act as a pilot in command (PIC) 

of DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s. Additionally, a safety 

observer will assist him during flight time. 

c. Flights of DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s 

will Be Conducted Pursuant To Specific Operating Limitations. 
In seeking this exemption, WILLIAM P THRASHER proposes to commercially 

operate DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s for the special 

purpose of conducting aerial video and photography over certain areas of United 

States, pursuant to the following specific operating limitations:

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

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UAS’s. 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 45 knots.

4. The UA must be operated at an altitude of no more than 400 feet 

above ground level (AGL), as indicated by the procedures specified in 

the operating documents unless a special request is made and approved 

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

5. The UAs must be operated within visual line of sight (VLOS) of the PIC 

at all times. This requires the PIC to be able to use human vision unaided 

by any device other than corrective lenses, as specified on the PIC’s 

FAA-issued airman medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) 

is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be 

used to satisfy the VLOS requirement as long as the PIC always 

maintains VLOS capability. The SO and PIC must be able to 
communicate verbally at all times. Electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before 

the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC must ensure that the SO can perform the functions 

prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC 

with seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or 

other instruments. 

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

accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the 

conditions and limitations contained in the grant of exemption and the 

procedures outlined in the operating documents, the conditions and 

limitations contained in the grant of exemption take precedence and must 

be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise 

its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the 

Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment to the grant 

of exemption. If the operator determines that any update or revision 

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

the operator must petition for amendment to its grant of exemption. The 

FAA’s UAS Integration Office (AFS-80) may be contacted if questions 

arise regarding updates or revisions to the operating documents. 

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

in a condition for safe flight. If the inspection reveals a condition that 

affects the safe operation of the UAS, the aircraft is prohibited from 

operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. The Ground Control 

Station must be included in the preflight inspection. All maintenance and 

alterations must be properly documented in the aircraft records.
11. Any UAS that has undergone maintenance or alterations that affect 

the UAS operation or flight characteristics, e.g. replacement of a flight 

critical component, must undergo a functional test flight. The PIC who 

conducts the functional test flight must make an entry in the aircraft 

records. 

12. The pre-flight inspection must account for all potential discrepancies, 

e.g. inoperable components, items, or equipment, not already covered in 

the relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s 

aircraft/component, maintenance, over haul, replacement, inspection, 

and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and 

record keeping requirements, in accordance with the operating 

documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft 

records, including total time in service, description of work 

accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

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

the corrective action taken against discrepancies discovered between 

inspections. 

17. The PIC must possess at least a private pilot certificate and at least 

a current 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 UAV 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 UAV 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 UAV 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 UAV

with 25% battery power remaining. 

25. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any 

operations under the grant of exemption. This COA will also require the 

operator to request a Notice to Airman (NOTAM) not more than 72 

hours in advance, but not less than 48 hours prior to the operation. All 

operations shall be conducted in accordance with airspace requirements 

in the ATO issued COA including class of airspace, altitude level and 

potential transponder requirements. 

26. All aircraft operated in accordance with the exemption must be 

identified by serial number, registered in accordance with 14 C.F.R. part 

47, and have identification (N- Number) markings in accordance with 14 

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

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

operation and control of the UAV 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 UAV must remain clear and yield the right of way to all manned 

aviation operations and activities at all times. 

30. The UAV 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 UAV and/or debris in the event 

of an accident. The operator must ensure that nonparticipating 

persons remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 

feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures 

where the owner/controller of such vessels, vehicles or structures 

has granted permission and the PIC has made a safety 

assessment of the risk of operating closer to those objects and 

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

c. Operations nearer to the PIC, SO, operator trainees or essential 

persons do not present an undue hazard to those persons per § 

91.119(a). 

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

property with permission from the land owner/controller or authorized 
representative. Permission from land owner/controller or authorized 

representative will be obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the 

lateral or vertical boundaries of the operational area as defined by the 

applicable COA must be reported to the FAA's UAS Integration Office 

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

Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 

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

WILLIAM P THRASHER 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s unless that PIC 

has demonstrated, by meeting minimum flight-hour and currency requirements, 

that the PIC is able to safely operate the DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UAS’s in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering WILLIAM P THRASHER 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 Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s, WILLIAM P THRASHER

submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for 

WILLIAM P THRASHER 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). 
WILLIAM P THRASHER will not allow any PIC to operate the DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UAS’s unless the PIC has demonstrated, by 

meeting minimum flight-hour requirements or the DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UAS’s training and currency requirements, that the PIC is able to 

safely operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s 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 WILLIAM P THRASHER proposed operations. 

The Administrator has held that prior documented flight experience that was 

obtained in compliance with applicable regulations would ensure safe operations, 

stating as follows: 

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

operations for the purpose of motion picture filming (or similar operations), 

the PIC must have accumulated and logged, in a manner consistent with 14 

CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at 

least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to 

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

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

same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and 

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

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

addition to the hour requirements, the PIC must accomplish 3 takeoffs and 

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

that at a minimum, the flight-hour requirements in Exemption No. 11062 are 

appropriate to practice and build proficiency in the skills necessary to safely 

conduct the petitioner’s proposed operations. The FAA also finds that prior 

documented flight experience that was obtained in compliance with 

applicable regulations would satisfy this requirement. Training, proficiency, 
and experience-building flights can also be conducted under the grant of 

exemption to accomplish the required flight time. During training, 

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

the UAS with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No.11138 at page 15. 

Accordingly, WILLIAM P THRASHER will ensure safe operations by not allowing 

any PIC to operate DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s unless 

that PIC has demonstrated, by meeting minimum flight-hour and currency 

requirements, that the PIC is able to safely operate the DJI Inspire 1, Phantom 2 & 

3 and 3DR SOLO UAS’s in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

3. Reasons Why an Exemption From The Requirements Of Section 

91.7(a) Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained 

because prior to every flight, WILLIAM P THRASHER will ensure that DJI Inspire 

1, Phantom 2 & 3 and 3DR SOLO UAS’s is in an airworthy condition based upon 

the UAS’s compliance with its operating documents and as stated in the conditions 

and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to 

UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

4. Reasons Why An Exemption From The Requirements Of Section 

91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Inspire 1, Phantom 2 & 3 and 3DR 
SOLO UAS’s will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for 

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

with WILLIAM P THRASHER operation of the DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UAS’s within visual line of sight, at or below 400 feet AGL, will ensure 

a level of safety equivalent to Section 91.121. The altitude information will be 

generated by GPS equipment installed onboard the aircraft. Prior to each flight, a 

zero altitude initiation point is automatically established by the UASs at ground 

level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

5. Reasons Why An Exemption From The Requirements Of Section 

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the

DJI Inspire 1, DJI Phantom 2 and DJI Phantom 3 UASs; (2) the limitations on the 

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

Accordingly, WILLIAM P THRASHER will ensure that it will safely operate the 

battery powered DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s during 

daylight hours in VFR conditions, with enough battery power to fly for a total 

duration of 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1, 

DJI Phantom 2 & 3 and 3D Robotics SOLO UAS’s; the limitations on the proposed 

flight operations; and the location of the proposed operations, will ensure an 

equivalent level of safety established by 14 C.F.R. Section 91.151(b). 

Furthermore, safety will be ensured as the DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UAS’s provide audible and visual warnings to the PIC at the GCS when the 

UAs experiences low battery voltage, the first warning occurring at approximately 

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

power. At the critically low battery level, The DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO UASs will descend and land automatically. 
Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics 

and operating limitations of the UAS are considered. Relief has been granted for 

manned aircraft to operate at less than the minimums prescribed in Section 

91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has 

previously granted relief from Section 91.151 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 

11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

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

Would Not Adversely Affect Safety. 

In seeking this exemption, WILLIAM P THRASHER submits that the equivalent 

level of safety with regard to the regulatory maintenance and alteration 

requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & 

(a)(2), and 91.417(a) & (b) will be met because WILLIAM P THRASHER will use 

trained technicians to perform maintenance, alterations, or preventive 

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

prescribed in the operating documents (i.e., the WILLIAM P THRASHER Aerial 

Operations Manual, Monthly Maintenance Log, DJI Inspire 1, Phantom 2 & 3 and 

3DR SOLO Instruction Manual). Furthermore, WILLIAM P THRASHER will 

document and maintain all maintenance records for the DJI Inspire 1, Phantom 2 

& 3 and 3DR SOLO UASs. 

Since the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s will be inspected as 

prescribed by the operating documents, WILLIAM P THRASHER will maintain the 

equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the DJI Inspire 1 DJI Phantom 2 & 3 User Manuals are 

attached hereto as links; a copy of the DJI Inspire 1, Phantom 2 & 3 and 3DR 

SOLO UAS’s Maintenance LOG is attached hereto as Appendix A. 

Likewise, the exemption sought will not adversely affect safety because WILLIAM 

P THRASHER will use trained technicians to perform maintenance, alterations or 

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

prescribed by the operating documents. 

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

established by Sections 91.407, 91.417(a) and 91.417(b), because all 
maintenance of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s will be 

performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

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

safety is not adversely affected when the technical characteristics and operating 

limitations of the UAS are considered. 

In consideration of WILLIAM P THRASHER proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Inspire 1, Phantom 2 & 

3 and 3DR SOLO UAS’s, WILLIAM P THRASHER submits that safety will not be 

adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 

91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has 

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

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

11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 

11156, 11157, 11158, 11159, 11160, 11161). 

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

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

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, WILLIAM P 

THRASHER requests that the FAA prescribe special conditions for the intended 

operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs, which 

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

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

14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 

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

operation of the UAs for the limited purpose of conducting aerial video and 

photography over certain areas of the United States for compensation or hire. 

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

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

national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must 

be established for the safe operation of the UAS in the NAS. 

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

§ 21.16, for operation of the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO UASs, 

since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate 

or appropriate safety standards, due to the novel or unusual design features of the 

aircraft. Section 21.16, entitled Special Conditions, states the following: 
If the FAA finds that the airworthiness regulations of this subchapter do not 

contain adequate or appropriate safety standards for an aircraft, aircraft 

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

aircraft, aircraft engine or propeller, he prescribes special conditions and 

amendments thereto for the product. The special conditions are issued in 

accordance with Part 11 of this chapter and contain such safety standards 

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

establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16.

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

may prescribe special conditions for Leading Edge’s intended operation of the DJI 

Inspire 1, Phantom 2 & 3 and 3DR SOLO UAS’s, which contain such safety 

standards that the Administrator finds necessary to establish a level of safety 

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

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

91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summary That Can Be Published in The Federal 

Register, stating: The Rules from Which WILLIAM P THRASHER Seeks 

Exemption: 

WILLIAM P THRASHER seeks exemption from the requirements of 14 

C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

A Brief Description Of The Nature Of The Exemption WILLIAM P 

THRASHER Seeks: 

This exemption will permit WILLIAM P THRASHER to commercially operate 

an Unmanned Aircraft System (UAS) for the purpose of conducting aerial 

video and photography over certain areas of the United States.
• Any Additional Information, Views, Or Arguments 

Available To Support WILLIAM P THRASHER Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 

2012 

(FMRA) Section 333, which directs the Secretary of Transportation to determine if 

certain UAS may operate safely in the NAS. As such, WILLIAM P THRASHER

request for exemption may be granted pursuant to the authority of FMRA Section 

333 and 14 C.F.R. Part 11, as set forth above. 

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

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

national security; and further, provides the authority for such UAS to operate 

without airworthiness certification. 

As discussed in detail above, WILLIAM P THRASHER will operate the DJI Inspire 

1, Phantom 2 & 3 and 3DR SOLO UAS’s safely in the NAS, without creating a 

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

security. 

CONCLUSION

As set forth herein, WILLIAM P THRASHER 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 Inspire 1, Phantom 2 & 3 and 

3DR SOLO UAS’s commercially, without an airworthiness certificate, for the 

limited purpose of conducting aerial video and photography over certain areas of 

the United States. By granting this Petition, the FAA Administrator will be fulfilling 

the Congressional mandate of the FAA Modernization and Reform Act of 2012, 

while also advancing the interests of the public, by allowing WILLIAM P 

THRASHER to safely, efficiently, and economically operate the DJI Inspire 1, 

Phantom 2 & 3 and 3DR SOLO UAS’s commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, WILLIAM THRASHER

respectfully requests that the Administrator grant this Petition for an exemption 

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

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

permit Leading Edge to operate the DJI Inspire 1, Phantom 2 & 3 and 3DR SOLO 
UAS’s commercially for the purpose of conducting aerial video and photography 

over certain areas of the United States.

November 11, 2015

Attachments to this submission:

1. PETITION FOR EXEMPTION

2. william.p.thrasher.ppl.1878535

3. Phantom 2 quick start

4. 3DR SOLO quick start

5. 3D Robotics SOLO Manual

6. Maintenance log spreadsheet

WILLIAM P THRASHER only utilizes safe and reliable UASs. DJI are industry 

leaders 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 & 3D Robotics software provides real-time altitude and 

location information to the PIC via the linked monitor (smart phone/tablet devices)

Very respectfully,

William P Thrasher 
maximum upload to this site would not support some of my attachments:

I've added links instead:

1. DJI Inspire 1 Manual

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.2_en.pdf

2. DJI Phantom 2 Manual

http://download.djiinnovations.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.00_en.

pdf

3. DJI Phantom 3 Manual

http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manu

al_v1.0_en.pdf

3. 3D Robotics SOLO Manual

https://3drobotics.com/kb/solo-user-manual/