To	whom	it	may	concern,

In	order	to	provide	safe	aerial	videography	and	photography	for public	

business	interests,	I,	Torin	Johnson,	am	submitting	an	Exemption	Request

to	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the Federal	Aviation	

Regulations	form:	

14	C.F.R.	part	21

14	C.F.R.	45.23(b)

14	C.F.R.	61.113(a)	and	(b)

14	C.F.R.	91.7(a)

14	C.F.R.	91.9(b)(2)

14	C.F.R.91.119(c)

14	C.F.R.	91.121

14	C.F.R. 91.151(a)(1)

14	C.F.R.	91.203(a)	and	(b)

14	C.F.R.	91.405(a)

14	C.F.R.	91.407(a)(1)

14	C.F.R.	91.409(a)(1)	and	(2)

14	C.F.R.	91.417(a)	and	(b)

I	am	requesting	these	exemptions	so	that	I	may	safely	operate	my	

registered DJI	Phantom	3	Standard UAS	commercially	along	the	guidelines	

of	the	accompanying	operator’s manual,	FAA	guidelines for	UAS	flight,	and	

safety	guidelines	set	by	the AMA.

Proposed	UAS	and	Operations:

The	DJI	Phantom	3	Standard weighs	less	than	three	pounds,	will	always	be	

flown under	400	feet	limited	via	software	by	its	GPS,	is	electrically powered	

by	a	lithium	ion	battery,	carries	no	fuel	or	crew,	and	will	be transported	in	

storage	to	and	from	all	flight	areas.	The	proposed	exemptions	would	allow	

me	to	operate	the	DJI Phantom	3	Standard UAS	for	commercial	purposes	of	

aerial	videography	and photography	as	a	service	to	public	and	business	

interests,	including:	real-estate photography	and	videography,	wedding	and	

private	individual	photography	and videography,	public	and	commercial	

photography	and	videography,	and	agricultural photography	and	
videography.	Being	a	current	student	in	Digital	Film	and	Video	Production

at	New	England	Institute	of	Art	in	Brookline	MA,	I	would	also	use	this	UAS	

to	produce	projects	for	my	classes,	the	products	of	which may	be	published	

in	local	area	businesses	and	on	their	respective	websites.

Commercial	operation	of	a	UAS	which	are	equipped	with	camera(s)	and	

sensors,	would	provide	professional	services	in	the	following	areas:	

1.	Aerial	photography	or	video	for	public	or	private	use	including	real	

estate,	architecture,	land	surveying,	engineering	and	other	related	

professional	activities.	

2.	Aerial	video	or photography	for	public	or	private	use	including	television,	

public	events,	cinematography	and	newsgathering.	

3.	Aerial	inspection/photography	of	residential/commercial	structures	

under	contract	with	the	owners	or	local	government	authority.	

4.	Aerial	inspection/photography	of	residential/commercial	utility	

infrastructure	including	but	not	limited	to	electrical	power	lines,	wind	

turbines	and	cell	towers.	

5.	Aerial	video/photography	or	providing	live	video	feed	to	assist	with	

search	and	rescue	operations	in	cases	of	an	emergency	or	natural	disaster	

only	when	the	local	authorities	or	government	has	requested	it.	

6.	Training	to	persons	individually	or	belonging	to	both	private	or	public	

organizations	to	increase	awareness	and	improve	safety	for	current	and	

future	UAS	operations.

Specific	section(s)	of	14	CFR	which	I	seek	relief	and	the	reason(s)	I	seek	

relief:

14	C.F.R.	Part	21:	Airworthiness	Certificates

Given	the	size	and	limited	operating	area	associated	with	the UAS	to	be	

utilized,	an	exemption	from	Part	21	meets	the	requirements	of	an	

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

14	C.F.R.	45.23(b):	Display	of	marks:	general

The DJI	Phantom	3	Standard does	not	have	a cabin,	cockpit,	pilot	station,	

fuselage,	boom,	or	tail	on	which	to	mark	large	words,	numbers,	or	phrases,	
I	request exemption	from	the	above	regulation.	However I	will	affix	a small	

decal	to	the	outside	body of	the	UAS	indicating	my	UAS	registration	

number issued	by	the FAA,	name,	and	address.

14	CFR.	61.113(a)	&	(b):	Private	pilot	privileges	and	limitations:	Pilot	in	

command

Under	§	61.113	(a)	and	(b),	certified	private	pilots	are	limited	to	

noncommercial	operations.	However,	I	am	able	to	achieve	an	equivalent	

level	of safety	through	current FAA	regulations	of	UAS	operation	and	AMA	

safety	guidelines	without	such	a	certification	because	of	the	above	

mentioned	safety features	of	the	DJI	Phantom	3.	Additional	manned	airship	

experience	of	a	commercially	certified	pilot would	not	correlate	to	the	

airmanship	skills	necessary	for	operations of	a	UAS. Bearing	any	pilot	

certification	or	license	will	not	ensure	remote piloting	skills	of	a	UAS;	given	

the	DJI	Phantom’s	safety features,	limited	range	and	speed	of	the	UAS, the	

risks	of	operating	this	UAS	are less	than	the	risk	levels	in	commercial	

activities	with	traditional	aircraft.

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

Currently	there	is	no	certificate	applicable	to	this	UAS, and	therefore it	will	

be	up	to	myself,	Torin	Johnson,	to	determine	the	airworthiness	of	the	DJI	

Phantom	3	Standard	in	accordance with	its operating	manual.	Pre	and	post	

flight	inspections	of the	propellers,	motors,	frame,	landing	stands, camera	

and	gimbal	unit,	connected	tablet devices,	a	compass	calibration	and	

properly	ensured	GPS	locks indicated	by	the	DJI Phantom’s	display	of	“Safe	

to	Fly”	message	will	be	performed	before	and	after	every flight,	accurate	

records	are	automatically	saved	within	the	DJI	pilot	application	and	can	be	

accessed	at	any	time.	These	records	will	be	dated	and	will	include	the	total	

flight	time	of each	flight.

14	C.F.R.	91.9	(b)(2).'	Civil	aircraft	flight	manual,	marking,	and	placard	

requirements

Since	no	pilots	or	passengers	on	board	this	aircraft,	and	given	its	size,	this	

regulation is	inapplicable.	An	equivalent	level	of	safety will	be	achieved	by	
maintaining	a	safety/flight	manual	with	the	operator. In	addition	to the	

official	safety/flight	manual	provided	by	DJI	upon	purchase	of	the	Phantom	

3 Standard, following	the	AMA	guidelines	for	safe	flight	operations	and	the	

FAA	regulations	for UAS	operations	will	ensure	a	high	level	of	safety.

14	C.F.R.	91.119(c):	Minimum	safe	altitudes

I,	Torin	Johnson, will	ensure	that	the	UAS	does	not	operate	any	higher	than	

400	feet	at	ground	level	by	setting	the	maximum	altitude	at	400	feet	in	DJI’s	

pilot	application	and ensuring	this	is	set	before	each	flight	as	part	of	the	

pre-flight	inspection.	I	will	not	fly over	congested	areas	or	directly	above	

unprotected	people	or	moving	vehicles.	All	operations	will	be	planned

before	hand	for	proper	flight	safety	and	proper	height	analysis	as	to	avoid

collisions.	The	GPS	and	barometric	sensors	equipped	on	the	DJI Phantom	3	

will	ensure accurate	altitude	readings,	the	output	of	which	will	be	fed	to	my	

tablet	device	in	real	time as	I	operate	the	DJI	Phantom	3	Standard.

14	C.F.R.	91.121:	Altimeter	settings

The	DJI	Phantom	3 Standard utilizes	the	latest	GPS technologies	as	well	as	a	

barometric	sensor	with	live	data	feed	directly	to	the	tablet linked to	the	

transmitter.	An equivalent	level	of	safety	and	accurate	altimeter	readings	

will	be	achieved	by	using	this.

14	C.F.R.	91.151(a)(1):	Fuel	Requirements for flight	in	VFR	conditions

Lithium	ion	batteries	that	are	made	by	DJI	specifically	for	this	particular	UAS	

power	the	DJI	Phantom	3.	They	provide	no	more than	25 minutes	of	flight	

time.	Due to	the	limitations	of	the	batteries,	it	is	currently impossible	to	

comply	with	part	91.151.

14	C.F.R.	91.203(a)	and	(b):	Civil	aircraft:	Certifications	required

Currently,	there	are	no	procedures	for	providing	airworthiness	certificates	

for	the	mentioned	UAS.	I,	Torin	Johnson,	however	will fly	safely	while	

having	the manuals	of	the	DJI	Phantom	3	and	abiding	by	FAA	regulations	for	

UAS	operation	and AMA	safety	guidelines.
14	C.F.R.	91.405	(a):	Maintenance	Required

14	C.F.R.	91.407	(a)(1):	Operation	after,	maintenance,	preventive	

maintenance,	rebuilding,	or	alteration.

14	C.F.R. 91.409(a)(1) and	(2):	Inspections	

&	

I4	C.F.R.	91.417(a)	and	(b):	Maintenance	records

Maintenance	and	inspections	may	be	required	and	should	be	granted	since	

they	apply	to aircraft	with	an	airworthiness	certificate.	However	I,	Torin	

Johnson,	will	perform	both preflight	and	post	flight	inspections	of	the	UAS	

before	and	after	each	flight.	I,	Torin	Johnson,	will	also	follow	manufacturer	

recommendations and	keep	a	written	record	of	any	maintenance	done	to	

the UAS.

Public	Interest	and	Public	Safety:

Aerial	photography	and	videography	allows	for	a	more	safe,	cost	effective,

and	environmentally	friendly	method	to	capturing	imagery	than manned	

aircrafts and	helicopters.	Manned	aircrafts are	expensive	to	operate	and

maintain,	create	a	high	level	of	noise,	require	high	level	of	experience,	and	

are	much	more	hazardous	due	to	size	and combustible	fuel, especially	if	

flown	at	low	heights.	

I,	Torin	Johnson,	in	addition	to	using	my	UAS	for	commercial	uses,	will	also	

offer	my services	free	of	charge	upon	request	and	with	proper	coordination	

to	any	official search	and	rescue	or	emergency	services	organization.	Use	of	

a	UAS	as	opposed	to	manned	aircrafts for	aerial	videography	or	

photography	reduces carbon	emissions	and	traffic	congestion	by vehicles	

looking	to	View	properties	such	as	real-estate	or	farm land,	and	increase

visibility	to	local	attractions;	bolstering	local	commerce	and	even	tourism.

Given	that	there	is	no	fuel	and	no	crew	on	this	UAS,	and	that	it	weighs	

under	three pounds,	as	well	as	having	a	low	maximum	speed	(less	than	

25mph),	safe operation	of	this	craft	does	not	pose	any	immediate	danger	to	

the	environment,	wildlife, infrastructure	or	people.	DJI	has	a	“No	Fly	Zone”	

for	major	cities	and	points	of interest	that	have	registered	as	a	“do	not	fly	

zone.”	Operation	of	the	Phantom	3	Standard	cannot happen	in	these	

locations,	as	any	flight	capabilities	becomes	blocked	by	the	UAS	itself	if
within	range	and	the	operator	is	notified of	the	restricted	zone.	Given	its	

GPS	and	ground	sensing	capabilities, a	failsafe	“Return	To	Home”	mode	will	

safely	return	the	craft	to	the	operator	at	the	push of	a button	when	the	

craft	is	operating outside	of	its	transmitter’s	range.	This	ensures	that	the	

craft	will	not	remain	airborne	in unsafe conditions	and	pose	any	public	

danger. The	UAS	will	also	“Return	To	Home”	if	battery	life	depletes	to	a	

significantly	low	level.

Summary

I, Torin	Johnson,	am	seeking	exemption	from	the	following	rules:	

14	C.F.R.	Part	21

14	C.F.R.	45.23(b)

14	C.F.R.	61.113(a)	and	(b)

14	C.F.R.	91.7(a)

14	C.F.R.	91.9(b)(2)

14	C.F.R.91.119(c)

14	C.F.R.	91.121

14	C.F.R. 91.151(a)(1)

14	C.F.R.	91.203(a)	and	(b)

14	C.F.R.	91.405(a)

14	C.F.R.	91.407(a)(1)

14	C.F.R.	91.409(a)(1)	and	(2)

14	C.F.R.	91.417(a)	and	(b)

With	the	exemptions	of	the	mentioned	rules	I,	Torin	Johnson,	will	be

seeking	to make	my	UAS	photography	and	videography	services	available	to	

public	and commercial	interests.	Alternatively,	public	and	commercial	

interests	had	previously	sought the	use	of	manned	aircraft	to	achieve	what	

I	can	offer	in	a	safer,	more	cost-efficient	manner	by	flying	at	safe	heights	

and strictly	following	the	recommendations	from	DJI	and	safety	procedures	

put	in	place	by	the	AMA.	

These	include	but	are	not	limited	to:

1.	The	UAS	will	weigh	less	than	55	lbs.	

2.	Flights	will	be	operated	within	line	of	sight	of	operator.	
3.	Maximum	total	flight	time	for	each	operational	flight	will	be	25 minutes.	

4.	Flights	will	be	terminated	at	15%	battery	power	reserve.	

4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	

5.	UAS	operator	will	be	trained	and	certified	in	the	proper	safety	and	

operations	of	the	UAS.	

6.	The	UAS	will	only	operate	within	a	controlled	area	as	defined	in	the	

Procedures.	

7.	The	operator	will	post	advisor	notice	around	the	controlled	area.	

8.	The	operator	will	have	been	trained	in	operation	of	UAS	generally	and	

received	up-to-date	information	on	the	UAS	to	be	operated	as	required.	

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

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

Perimeter	and	land.	

10.	The	UAS	will	have	the	capability	to	abort	a	flight	in	case	of	unpredicted	

obstacles	or	emergencies.	

Thank	you	for	your	time	and	effort	in	processing	this	request	and	look	

forward	to cooperating	with	the	FAA	in	its	continued	commitment	for	the

safe	operation	of	UAS.

Sincerely,

Torin	Johnson

3	Church	St

Andover,	MA 01810

TMJohnson1291@gmail.com

978-319-2031