1

March, 4 2016

Attn: U. S. Department of Transportation Docket Operations West Building Ground Floor,

Room w12-140 1200 New Jersey Ave, SE Washington, DC 20590

RE: AERO QUEST L.L.C. REQUEST AN EXEMPTION FROM THE REQUIREMENTS

OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b),

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

CONCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 

2012 (PUBLIC LAW 112-95)

Wesley Parsons

Member

AERO QUEST L.L.C.

636 Baker St.

Costa Mesa, CA 92626

949-302-4631

wparsons.media@gmail.com
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TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS.......................................................3

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

INTRODUCTION AND INTERESTS OF PETITIONER.......................4

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

BASIS FOR PETITION............................................................................5

NAME AND ADDRESS OF PETITIONER............................................6

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

SEEKS EXEMPTION...............................................................................7

THE EXTENT OF RELIEF AEROQUEST SEEKS AND THE REASON

AEROQUEST SEEKS THE RELIEF......................................................10

THE REASONS WHY GRANTING AEROQUEST’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ...........................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO AEROQUEST

WOULD NOT ADVERSELY AFFECT SAFETY.................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT AEROQUEST’S REQUEST...................................25

CONCLUSION........................................................................................................26

APPENDICES.........................................................................................................27
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

AERO QUEST L.L.C. hereafter referred to as AEROQUEST seeks exemption from the 

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft 

System (DJI Phantom 3, DJI Inspire, DJI Matrice) pursuant to Section 333 of the FAA 

Modernization and Reform Act of 2012 (FMRA). This exemption will permit AEROQUEST to 

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

video and photography of residential and commercial real estate, construction sites, civil 

landscapes and events over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

AEROQUEST intends to provide clients (which include private sector businesses and nonprofits, along with local state and federal agencies) with expertise and knowledge in video and 

multimedia marketing, advertising, and training using advanced technologies and solutions. Each 

member of the AEROQUEST team holds at least a Private Pilot Certificate, and has operated 

both full size aircraft and UAS with a perfect safety record. The objective of AEROQUEST and 

our Unmanned Aircraft Systems (DJI Phantom 3, DJI Inspire, DJI Matrice) aerial operations is to 

provide a more affordable, high-quality imagery system for a variety of governmental, 

commercial, public, and residential uses, specifically targeting

• Real Estate

• Aerial Photography/Cinematography

• Land Surveying & Mapping

• Precision Agriculture

• Search & Rescue Aid

• Law Enforcement Operations

• Special event coverage

• Private and governmental training
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BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire, DJI Matrice.

AEROQUEST seeks an exemption to operate DJI UAS for compensation or hire within the 

NAS. All DJI UAS operated by AEROQUEST are vertical takeoff and landing (VTOL)

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

smart phone systems. DJI UAS operated by AEROQUEST have a maximum gross weight of 

approximately 6.4 lb. while having a maximum diagonal dimension of 25.6”, a maximum speed 

of approximately 22 m/s and a maximum flying height of 400'. DJI UAS operated by 

AEROQUEST use GPS for a hovering accuracy of .5 meters vertically, and 2.5 meters 

horizontally. Each is equipped with Lithium Polymer battery powered electric motors.

The DJI UAS operated by AEROQUEST 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, AEROQUEST, 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 DJI UAS in the National Airspace System (NAS), and for an exemption 

from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

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

unmanned aircraft and its operation, AEROQUESTs operation of DJI UAS meets the conditions 

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

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

Accordingly, AEROQUEST 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.

AEROQUEST submits that the requested relief is proper since an equivalent level of safety will 

be ensured. AEROQUEST will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the DJI UAS using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, 

and DJI UAS Instruction Manuals). Furthermore, AEROQUEST will document and maintain all 

maintenance records for the DJI UAS.
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Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges

and limitations: Pilot in command, is requested by AEROQUEST to the extent necessary to 

allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an 

airman medical certificate, and who has demonstrated, by meeting minimum flight- hour and 

currency requirements, that the PIC is able to safely operate the DJI UAS in a manner consistent 

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

distances from people, vessels, vehicles and structures.

AEROQUEST seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

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

Subpart H. As such, AEROQUEST submits that they will ensure that the DJI UAS is in an 

airworthy condition, prior to every flight, by determining that the DJI UAS are in compliance 

with the operating documents (i.e., Monthly Maintenance Log, and DJI UAS Instruction 

Manuals), and that the aircraft are in a condition for safe flight.

AEROQUEST also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI UAS will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI UAS will be provided to the PIC via Global Positioning 

System (GPS) equipment and radio communications telemetry data link, which downlinks from 

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

with AEROQUEST’s operation of the DJI UAS within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, AEROQUEST seeks an exemption from the requirements of

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

submits that safety will not be affected by operation of the DJI UAS during daylight hours in 

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

power to fly for a total duration of approximately 23 minutes. Battery power indicators are also 

able to show exactly how much battery power is left, as well as how much time is needed to 

return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, AEROQUEST 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:

Wesley Parsons

Member

AEROQUEST L.L.C.

636 Baker St.

Costa Mesa, CA 92626

949-302-4631

wparsons.media@gmail.com
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B. The Specific Sections Of 14 C.F.R. From Which AEROQUEST

Seeks Exemption.

1. AEROQUEST 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. AEROQUEST 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. AEROQUEST 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
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(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. AEROQUEST 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. AEROQUEST 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. AEROQUEST 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. AEROQUEST 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.
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8. AEROQUEST 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
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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 AEROQUEST Seeks And The Reason AEROQUEST Seeks The 

Relief.

1. Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST 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, AEROQUEST submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate the DJI UAS unless that PIC has met 

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

operate either the DJI UAS in a manner consistent with the operations specifications as described 

in this exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.

Further, AEROQUEST submits that all flights of the DJI UAS, conducted by the PIC pursuant to 

the grant of this Petition: (1) will be incidental to AEROQUEST’s business; and (2) will not 

carry passengers or property for compensation or hire.
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2. Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST 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 AEROQUEST to determine that the DJI UAS are in airworthy condition prior 

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

AEROQUEST Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Instruction 

Manuals).

AEROQUEST seeks the requested relief because the DJI UAS do not require an airworthiness 

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

ensure that the DJI UAS are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI UAS) 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 AEROQUEST Seeks And The Reason AEROQUEST Seeks Relief 

From Section 91.121.

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

operations of the DJI UAS, which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the 

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

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

(AGL), AEROQUEST seeks the requested relief because the DJI UA’s altimeter may be set on 

the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before 

each flight.

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

to the extent necessary to comply with the applicable conditions and limitations stated below. As

more fully set forth herein, an equivalent level of safety will be maintained since the DJI UAS 

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

that a ground level pressure setting will be established prior to each flight, and provides the PIC 

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

4. Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST 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 UAS during daylight 

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

duration of 23 minutes. AEROQUEST seeks the requested relief because without an exemption 

from Section 91.151(b), the flight time duration of the battery powered DJI UAS will severely 

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

proposes to conduct pursuant to this Petition.
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Significantly, as set forth below, the technical specifications of the DJI UAS, the DJI UAS 

operating documents, and AEROQUEST’s proposed operating limitations, ensure that 

AEROQUEST will safely operate the battery powered DJI UAS during daylight hours in visual 

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

to fly for a total duration of 23 minutes.

5. Extent Of Relief AEROQUEST Seeks And The Reason AEROQUEST 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, AEROQUEST requests relief from these Sections 

because the DJI UAS do not require airworthiness certificates. As set forth more fully below, the 

DJI UAS meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, AEROQUEST will use trained technicians to perform maintenance, 

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

prescribed in the UAS operating documents (i.e., the AEROQUEST Aerial Operations Manual, 

Monthly Maintenance Log, and DJI UAS Instruction Manuals). Furthermore, AEROQUEST will 

document and maintain all maintenance records for the DJI UAS.

D. The Reasons Why Granting AEROQUEST 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 AEROQUEST to safely, 

efficiently, and economically perform aerial video and photography of construction sites, real 

estate, agriculture, events and civil landscape over certain areas of the United States.

Additionally, use of the DJI UAS will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of AEROQUEST’s proposed 

operation of the DJI UAS will be realized without implicating any privacy issues.

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

The DJI UAS are battery powered and serve as a safe, efficient, and economical alternative to the 

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of 

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI 

UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as 

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

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

around airports caused by arriving and departing aircraft will be reduced. The DJI UAS do not 

require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air traffic 

control during the ground, takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI UAS.
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Conducting aerial acquisitions with the DJI UAS, instead of manned aircraft, will greatly benefit 

the public by drastically reducing the levels of air and noise pollution generated during 

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

electric motors, the DJI UAS produce no air pollution, and is the most viable environmentally 

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

typically utilized for aerial video and photography, while burning approximately 20-30 gallons 

per hour of leaded aviation fuel. The DJI 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 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 UAS (weighing approximately 6.4 pounds at 

their maximum gross weight with a maximum diagonal dimension of 25.6 inches, and with no 

fuel on board), has less physical potential for collateral damage to life and property on the 

ground, and in the air, compared to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 

feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 UAS Will

Benefit The Economy.

In addition to being safe and efficient, the DJI UAS are also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the DJI UAS will 

allow United States based companies, like AEROQUEST, 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 UAS is one such technology that not 

only allows companies greater operational flexibility compared to manned aircraft, but provides 

such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI UAS, companies such as AEROQUEST, 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 UAS, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United States and 

abroad.

4. There Are No Privacy Issues.

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

AEROQUEST’s proposed operation of the DJI UAS will not implicate any privacy issues. 

Specifically, the DJI UAS will be operated only in compliance with operating documents (i.e.,
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AEROQUEST Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS Instruction 

Manuals) 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 AEROQUEST Seeks Exemption.

1. Reasons Why The DJI UAS Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333.

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

unmanned aircraft and its operation, AEROQUEST’s operation of the DJI UAS meet the 

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

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

Section 333 provides authority for a UAS to operate without airworthiness certification and sets

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the

following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than

180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine if certain unmanned aircraft systems may operate safely in the national

airspace system before completion of the plan and rulemaking required by section 332 of

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

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

subsection (a), the Secretary shall determine, at a minimum

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

weight, speed, operational capability, proximity to airports and populated areas,

and operation within visual line of sight do not create a hazard to users of the

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

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

certification under section 44704 of title 49, United States Code, is required for

the operation of unmanned aircraft systems identified under paragraph (1).

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

certain unmanned aircraft systems may operate safely in the national airspace system, the

Secretary shall establish requirements for the safe operation of such aircraft systems in

the national airspace system.
15

In seeking this exemption, AEROQUEST submits that the DJI UAS can operate safely in the 

NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI UAS; 

(b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI UAS Demonstrate Its Safe Characteristics.

The DJI UAS does not create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI UAS.

The technical specifications of the DJI UAS are set forth by the DJI User Manuals, attached 

hereto as Appendix A, Appendix B, and Appendix C.

ii. The DJI UAS Global Positioning Modes Enable The UAS To Remain Within A 

Defined Operational Area.

The DJI UAS may be operated in both manual and global positioning flight modes. A complete 

description of the flight and navigational modes of the DJI UAS is provided at pages 11 of the 

DJI Inspire 1 User Manual attached hereto as Appendix A, pages 11 of the DJI Phantom 3 

Professional User Manual attached hereto as Appendix B, and pages 35 of the DJI Matrice 100 

User Manual attached hereto as Appendix C.

iii. The DJI UAS Are Designed For Automatic Return To Home Point Or

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI UAS will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI UAS does not reacquire control link data from the GCS, the 

UAS will assume that the Control Link is lost and the will return to the home position (i.e., 

failsafe mode) via GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI UAS are set forth at pages

12 through 14 of the DJI Inspire 1 User Manual, attached hereto as Appendix A, pages 12 

through 14 of the DJI Phantom 3 Professional User Manual attached hereto as Appendix B, and 

pages 42 through 44 of the DJI Matrice 100 User Manual attached hereto as Appendix C.

iv. The DJI GCS And Its Operation.

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

control software is provided at pages 23 through 29 of the DJI Inspire 1 User Manual, attached 

hereto as Appendix A, pages 23 through 29 of the DJI Phantom 3 Professional User Manual 

attached hereto as Appendix B, and pages 29 through 41 of the DJI Matrice 100 User Manual 

attached hereto as Appendix C.
16

b. Flight Operations Of DJI Inspire 1 UAS Is Limited To The Line Of Sight Of A

Certificated Pilot in Command With A Safety Observer.

AEROQUEST authorized production staff will be the only persons to act as a pilot in command 

(PIC) of the DJI UAS. Additionally, a safety observer will assist him/her at all times during 

flight time.

c. Flights Of DJI Inspire 1 UAS Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, AEROQUEST proposes to commercially operate DJI UAS for the 

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

pursuant to the following specific operating limitations.

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

aircraft described in the operating documents, rotorcraft UAS weighing less than 55

pounds maximum gross weight: DJI Inspire 1, DJI Phantom 3, and DJI Matrice

Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the

purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

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

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

PIC must be able to communicate verbally at all times. Electronic messaging or texting is

not permitted during flight operations. The PIC must be designated before the flight and

cannot transfer his or her designation for the duration of the flight. The PIC must ensure

that the SO can perform the functions prescribed in the operating documents.

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

avoiding other air traffic and other ground based obstacles/obstructions and is not

permitted to operate the camera or other instruments.
17

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,

overhaul, replacement, inspection, and life limit requirements.

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

requirements, in accordance with the operating documents. Maintenance, inspection,

alterations, and status of replacement/overhaul component parts must be noted in the

aircraft records, including total time in service, description of work accomplished, and

the signature of the authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with all 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.
18

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

thirdclass medical certificate.

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

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

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

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

vehicles and structures. PIC qualification flight hours must be logged in a manner

consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s

PICs are permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training, proficiency, and

experience-building flights, all persons not essential for flight operations are considered

nonparticipants, and the PIC must operate the UA with appropriate distance from

nonparticipants in accordance with 14 C.F.R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All

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

night is required, a special request will be made at the FAA office closest to proposed

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

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

denoted on a current FAA-published aeronautical chart unless a letter of agreement with

that airport’s management is obtained, and the operation is conducted in accordance with

a NOTAM as required by the operator’s COA. The letter of agreement with the airport

management must be made available to the Administrator upon request.

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

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a 

predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

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

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

landing point and land the UA with 25% battery power remaining.

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

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
19

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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as

large as practicable.

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

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

other appropriate government oversight agency requirements.

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

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

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

upon request.

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

operations and activities at all times.

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

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

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

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

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

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

arises where nonparticipating persons leave such protection and are within 500

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

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

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

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

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

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

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

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

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

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

conducted.

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

boundaries of the operational area as defined by the applicable COA must be reported to
20

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.

AEROQUEST 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 UAS unless that PIC 

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

able to safely operate the DJI UAS in a manner consistent with the exemption, including evasive 

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

and structures.

Considering AEROQUEST’s proposed area of operations, and the operating limitations set forthabove; 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 UAS, AEROQUEST submits that the additional manned airmanship 

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

necessary for AEROQUEST’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11158, 11159, 11160, 11161).

AEROQUEST will not allow any PIC to operate the DJI UAS unless that PIC has demonstrated, 

by meeting minimum flight-hour requirements or the DJI UAS training and currency 

requirements, that the PIC is able to safely operate the DJI UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.

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

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

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

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

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

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

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

during AEROQUEST’s 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
21

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, AEROQUEST will ensure safe operations by not allowing any PIC to operate the 

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

requirements, that the PIC is able to safely operate the DJI UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not

Adversely Affect Safety.

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

every flight, AEROQUEST will ensure that the DJI UAS is in an airworthy condition based upon 

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

limitations herein.

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not

Adversely Affect Safety.

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

altitude information of the DJI UAS will be provided to the PIC via GPS equipment and a radio 

communications telemetry data link, which downlinks from the UA to the GCS for active
22

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

AEROQUEST’s operation of the DJI UAS within visual line of sight, at or below 500 feet AGL, 

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

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

initiation point is automatically established by the UAS at ground level.

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

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157,

11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R.

Section 91.151(b) as a result of (1) the technical specifications of the DJI UAS; (2) the

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

operations. Accordingly, AEROQUEST will ensure that it will safely operate the battery 

powered DJI UAS during daylight hours in VFR conditions, with enough battery power to fly for 

a total duration of 23 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI UAS; the limitations on 

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

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

ensured as the DJI UAS provide audible and visual warnings to the PIC at the GCS when the 

UAS experiences low battery voltage, the first warning occurring at approximately 33% 

remaining battery power, and again at approximately 10% remaining battery power. At the 

critically low battery level, the DJI UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and operating limitations of the

UAS are considered. Relief has been granted for manned aircraft to operate at less than the

minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650.

Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS, in

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

8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.

In seeking this exemption, AEROQUEST 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 AEROQUEST will 

use trained technicians to perform maintenance, alterations, or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed in the operating documents (i.e.,
23

AEROQUEST Aerial Operations Manual, Monthly Maintenance Log, and DJI UAS User 

Manuals). Furthermore, AEROQUEST will document and maintain all maintenance

records for the DJI Inspire 1 UAS.

Since the DJI UAS will be inspected as prescribed by the operating documents, AEROQUEST 

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 UAS User Manuals are attached hereto as Appendix A, B, C.

Likewise, the exemption sought will not adversely affect safety because AEROQUEST 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 UAS 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 AEROQUEST’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI UAS, AEROQUEST 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, AEROQUEST requests that the FAA 

prescribe special conditions for the intended operation of the DJI UAS, which contain such 

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

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 

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

special conditions will permit safe operation of the UAS for the limited purpose of conducting 

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

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

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

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

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

the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for
24

operation of the DJI UAS, 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 AEROQUEST’s intended operation of the DJI UAS, which 

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

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

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

91.417(a) & (b).

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

From Which AEROQUEST Seeks Exemption:

AEROQUEST 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 AEROQUEST Seeks:

This exemption will permit AEROQUEST 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

AEROQUEST’s 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, AEROQUEST’s 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, AEROQUEST will operate the DJI UAS safely in the NAS, 
25

without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to 

national security.
26

CONCLUSION

As set forth herein, AEROQUEST 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 UAS commercially, without an airworthiness certificate, for the limited 

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

granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the 

FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by 

allowing AEROQUEST to safely, efficiently, and economically operate the DJI UAS 

commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, AEROQUEST 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 AEROQUEST to operate the DJI UAS commercially for 

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

Dated: March 3, 2016

Respectfully submitted,

Wesley Parsons

Member

AERO QUEST L.L.C.

636 Baker St.

Costa Mesa, CA 92626

949-302-4631

wparsons.media@gmail.com
27

Appendices:

Appendix A – Link to DJI Inspire 1 User Manual: Click on link below

http://download.djiinnovations.com/downloads/inspire_1/en/Inspire_1_User_Manual_v1.4_en.p

df

Appendix B – Link to DJI Phantom 3 Professional User Manual: Click on link below

https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.p

df

Appendix C – Link to DJI Matrice 100 User Manual: Click on link below

http://download.djiinnovations.com/downloads/dev/Matrice/en/M100_User_Manual_v1.0_en.pd

f