October 12, 2015

United States Department of Transportation

Federal Aviation Administration

800 Independence Ave, SW

Washington, DC 20591

Re: Exemption from requirements of specific provisions of Section 333 of the 

FAA Modernization and Reform Act of 2012 pursuant to the Federal Aviation 

Regulations

Dear Sir or Madam;

I, Dane Sponberg, of Raftermen Photography (Petitioner), respectfully request an 

exemption from several provisions of Title 14 of the Code of Federal Regulations 

(C.F.R.) to permit the use of a small Unmanned Aerial System (UAS) 

commercially, in airspace regulated by the Federal Aviation Administration 

(FAA). Raftermen Photography provides clients with photographs and videos for 

advertising and public uses, and wishes to operate a small light-weight UAS for the 

commercial purpose of conducting aerial video and photography of events and real 

estate for public and private use.

This request is for exemption from 14 C.F.R §§ 91.7(a), 91.151(a), 91.405(a), 

91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b), 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. The basis for this exemption request is outlined in this petition as 

well as in the supporting DJI Phantom Vision 2+ Owner’s Manual which can be 

found in Appendix A.

Sincerely,

Dane Sponberg

Raftermen Photography

Address

Phone Number

Email
PROPOSED OPERATIONS

I, Dane Sponberg, intend to use the UAS for one purpose – to perform video 

filming and photographing by air for public and private use. Specifically, I will use 

the UAS, which is equipped with cameras and sensors, in order to engage in the 

following commercial activities in various locations in the United States: video 

filming by air and photographing for public and private purposes, including: 

television, cinematography, advertising or promotions. Filming and Photography 

will only be conducted with permission and under contract with registered owners 

or with any local government authority and only when safe to do so.

BACKGROUND/EQUIPMENT

Rafterman Photography seeks an exemption to operate the DJI Phantom Vision 2+ 

system for compensation within airspace regulated by the FAA. The DJI Phantom 

Vision 2+ is a vertical takeoff and landing (VTOL) Unmanned Aircraft with a 

Ground Control Station (GCS) that uses an electronic tablet or smart phone system. 

The DJI Phantom 2+ weighs approximately two (2) pounds eleven (11) ounces and

is about sixteen (16) long and sixteen (16) wide. It is eight (8) inches tall and has a 

maximum speed of approximately twenty-nine (29) knots.

The DJI Phantom Vision 2+ is a lightweight battery operated 4-motor rotorcraft in 

the form of a quadcopter with the following equipment: an on-board flight 

computer with GPS navigation and location ability that receives signals for flight 

controls from a ground-based transmitter/controller; an integrated on-board camera 

capable of capturing imagery in the form of full color, high definition still photos 

and video; an on-board telemetry system that delivers flight data from the on-board 

flight computer to the on-board radio transmitter including altitude AGL, 

horizontal and vertical speed, compass direction of flight and direction back to its 

launch site; and a 600mW, 5.8GHz on-board radio transmitter that transmits live 

video from the on-board camera plus all the flight data from the telemetry system 

described above.

The ground station for this UAS includes a pilot in operational control of the flight 

from beginning to end; a 100mW, 2.4GHz radio transmitter/controller operated by 

the pilot to control the UAS while in flight; a radio receiver receiving live video 

and flight data from the on-board camera and projects it onto a screen for the pilot 

to view during flight; and an observer to provide a second pair of eyes to visually 

track the UAS while in flight.
The DJI Phantom Vision 2+ UAS is capable of controlled flight and these devices 

are offered for general sale around the world and have often been used as Model 

Aircraft in the USA. Furthermore, I, Dane Sponberg, have flown this UAS

recreationally since ___ and have practiced safety protocols and controls to avoid 

and prevent public hazard and manned aircraft disasters. Lastly, my use of the 

UAS will act to further safety regulations, as I record flight data during my 

operations, which can then be shared with the FAA. (Do you do this? If not, just 

delete this sentence.)

RELEVANT STATUTORY AUTHORITY

Petitioner, Rafterman Photography, hereby petitions the Administrator to 

commercially operate the DJI Phantom 2+ in the National Airspace System (NAS), 

and for an exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.151(a), 

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

Congress has directed the FAA "to safely accelerate the integration of civil 

unmanned aircraft systems into the national airspace system."1Pursuant to Section 

333 of the Reform Act, the FAA Administrator is to permit unmanned aircraft 

systems to operate in the NAS where it is safe to do so based on the following 

considerations: the UAS’s size, weight, speed and operational capability; proximity 

to airports and populated areas; and operation of the UAS within the visual line of 

sight of the operator.2 Additionally, the FAA Administrator has general authority 

to grant exemptions from the agency's safety regulations and minimum standards 

when the Administrator decides a requested exemption does not create a hazard to 

users in the NAS, the public, or to national security.

3

If it is determined that the 

unmanned aircraft system 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.4 A petitioner requesting an exemption 

must explain the reasons why the exemption would benefit the public as a whole, 

and would not adversely affect safety (or how it would provide a level of safety at 

least equal to the existing rules).5

 

1

Federal Aviation Administration Modernization and Reform Act of 2012 § 332(a)(1)

2

Id. at § 332(b)(1)

3

Id.

4

Id. at (b)(c)

5

14 C.F.R. §11.81
The proposed operations in this Petition for Exemption qualify for expedited 

approval pursuant to Section 333 of the Reform Act as each of the statutory criteria 

and relevant factors are satisfied.

a. Approval is Warranted Based on the UAS Size, Wight, Speed, and 

Operational Capability

The UAS has a maximum take-off weight of less than 5 pounds, flight speed is less 

than 15 miles per hour, and will not be flown at an altitude above 300 feet AGL. 

All flights will be flown so that they can be safely terminated with a reserve battery 

power more than 20-percent of the battery’s capacity. The UAS does not contain 

any flammable fuel and has a failsafe mode, prop guards, and GPS system.

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

with the DJI Phantom Vision 2+ unmanned aircraft and its operation, Rafterman 

Photography meets the conditions of FMRA Section 333 and therefore, will not 

require an airworthiness certificate in accordance with 14 C.F.R. 21(h).

Furthermore, Rafterman Photography 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 aircrafts with an airworthiness 

certificate. The requested relief is proper since an equal level of safety will be 

guaranteed by Rafterman Photography. Rafterman Photography will use 

experienced technicians to maintain or alter the UAS, as prescribed in the 

operating manual, and will retain all maintenance records.

b. Approval is Warranted Based on Public Interest

The public interest will be served by granting Raftermen Photography a Petition 

for Exemption. Congress’ established national policy favors early integration of 

UASs into the NAS in controlled, safe working environments such as those 

proposed in this Petition. In addition, the public also has an interest in reducing the 

hazards associated with alternate methods of conducting similar operations. The 

use of the DJI Phantom 2+ will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. This UAS is battery powered is a 

safe, efficient, and economical alternative to the manned aircraft traditionally 

utilized to obtain aerial imagery. Allowing the use of this UAS in the NAS will 

reduce noise and air pollution, as well as increase safety in the air and on the 

ground as it has less potential for damage to life and property compared to a 

manned aircraft. The DJI Phantom 2+ does not require an airport to takeoff or land 
so operation of this UAS will decrease congestion in and around airports.

Moreover, by using battery power, the DJI Phantom 2+ produces no air pollution 

and eliminates noise pollution.

Furthermore, there is also an economical benefit to using UASs as opposed to 

manned aircrafts to conduct similar aerial operations. Operation of the DJI 

Phantom 2+ will allow companies, like Raftermen Photography to remain 

competitive and contribute to growth of the United States economy.

SUMMARY FAA MAY PUBLISH IN THE FEDERAL REGISTER

Raftermen Photography seeks exemption from the requirements of 14 C.F.R. 

Sections 91.7(a), 91.151(c), 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and 

(b), so as to commercially operate an Unmanned Aircraft System for the purpose 

of conduction aerial photography and videography over certain areas of the United 

States.

a. 14 C.F.R. 91.7(a): I, Dane Sponberg, will ensure the UAS is airworthy prior 

to each operation based on compliance with the Phantom Vision 2+ 

operating manual. Pursuant to 14 C.F.R. §19.121, Petitioner requests relief 

considering the limited altitude of the UAS and proposed operations.

b. 14 C.F.R. 91.151(c): I, Dane Sponberg, will ensure that each flight will not

commence unless there is enough battery power to fly to the first point of 

intended landing and land the UAS with 30-percent battery remaining. 

Furthermore, each flight will last no longer than twenty (20) minutes.

c. 14 C.F.R. 91.405(a); 91.407 (a)(1); 91.409(a)(2); 91.417(a) and (b): These 

provisions apply only to aircrafts that require an airworthiness certificate. 

Therefore, these regulations do not apply to my DJI Phantom Vision 2+ 

UAS. As a precaution, however, I will inspect my UAS before and after 

each operation according to the owner’s manual.

CONCLUSION

As set forth in this petition, Raftermen Photography seeks an exemption pursuant 

to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act 

of 2012, which will permit safe operation of the DJI Phantom 2+ 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 benefitting the interests of the public, by allowing Raftermen Photography to 

safely, efficiently, and economically operate a UAS commercially within the NAS.

Wherefore, Dane Sponberg, on behalf of Raftermen Photography, respectfully 

requests that this petition for exemption from 14 C.F.R. Sections 91.7(a), 

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

therefore allow Rafterman Photography to operate a DJI Phantom Vision 2+ 

commercially for aerial videography and photography.

Respectfully submitted on this __ day of ____ 2015.

Dane Sponberg

Address

Phone Number

Email
Appendix A

DJI PHANTOM VISION 2+ TECHNICAL SPECIFICATIONS 

1.1 DJI Phantom Vision 2+ 

1.1.1 Aircraft 1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 

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

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

1.1.1.4 Max Yaw Angular Velocity - 2000/s 1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s 

1.1.1.7 Max Descent Speed – 2m/s 

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

1.1.2 Gimbal 

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

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00 33 

1.1.2.4 Maximum Angular Speed – Pitch: 900/s 

1.1.3 Camera 

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

1.1.3.2 Sensor Size – 1/2.3” 1.1.3.3 Effective Pixels – 14M 

1.1.3.4 Resolution – 4384x3288 

4.1.3.5 HD Video Recording – 1080p30 & 720p 

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 

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

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW 

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender 

1.1.5.1 Operating Frequency – 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W