DRONE IT’s

PETITION

FOR

EXEMPTION

Reinaldo Fuentes

19377 NE 10th AVE #510

Miami, FL 33179

Ph: 7862615714 / E-mail: RPSflorida@gmail.com
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Reinaldo Fuentes

DRONE IT,

19377 NE 10th AVE #510

Miami, FL 33179

Ph: 7862615714 / E-mail: RPSflorida@gmail.com

DRONE IT seeks exemption from the requirements 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. This 

exemption will permit DRONE IT, to operate Unmanned Aircraft Systems, small (UASs) for the 

commercial purpose of conducting aerial video and photography of construction sites, real estate, events, 

and search and rescue. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

DRONE IT provides its clients with expertise and knowledge in advanced technologies and 

solutions to increase efficiency, productivity and effectiveness. Reinaldo Fuentes, founder of DRONE 

IT, has over 2 years recreational / hobby experience in all aspects of aerial video and photography, and 

over 50 hours of flight time on various sizes Unmanned Aerial Vehicles (UAV). The objective of 

DRONE IT, Aerial Video and Photography is to provide high quality imaging for a variety of 

commercial, public, residential and governmental uses, specifically targeting: 

• Construction sites (before and after)

• Events (public and private)

• Real-estate marketing

• Aerial inspections 

• Search and rescue operations 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision.
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DRONE IT seeks an exemption to operate UASs for compensation or hire

within the NAS. The DJI Phantom 2 Vision quadcopter is a vertical takeoff and landing (VTOL) 

Unmanned Aerial Vehicle (UAV) with a Ground Control Station (GCS) utilizing electronic device.

The DJI Phantom 2 Vision has a maximum gross weight of approximately 6 pounds, while having a 

length of 14 inches width of 14 inches, height of 5 inches, and a maximum speed of approximately 

15m/s (not recommended).

The DJI Phantom 2 Vision quadcopter UAVs is equipped with four main rotors; driven by a 

5200mAh Lithium Polymer battery powered electric motors.

The DJI Phantom 2 Vision quadcopter that will be operated by DRONE IT, 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

DRONE IT, pursuant to the provisions of the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned 

Aircraft Systems, hereby petitions the Administrator for permission to commercially operate The DJI 

Phantom 2 Vision quadcopter 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 System and its operation, DRONE IT’s DJI Phantom 2 Vision quadcopter 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, DRONE IT, 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. 
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DRONE IT submits that the requested relief is proper since an equivalent level of safety will be 

ensured. DRONE IT 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 Instruction Manuals). Furthermore, DRONE 

IT will document and keep all maintenance records for The DJI Phantom 2 Vision quadcopter UAV. 

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

limitations: Pilot in command, is requested by DRONE IT to theextent necessary to allow a Pilot in 

Command (PIC) holding a student pilot, 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 Phantom 2 Vision quadcopter UAV in a 

manner consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

DRONE IT seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, because the DJI 

Phantom 2 Vision quadcopter UAV does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, DRONE IT submits that it will ensure that the DJI Phantom 2 

Vision quadcopter is in an airworthy condition, prior to every flight, by determining hat the UAV is in 

compliance with the operating documents.

DRONE IT also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom 2 Vision quadcopter UAV will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Phantom 2 Vision quadcopter UAV will be provided 

to the PIC via Global Positioning System (GPS) equipment, and radio communications telemetry data 

link, which downlinks from the UAV to the GCS for active monitoring of the flight path. This altitude 

information, combined with DRONE IT’s operation of the DJI Phantom 2 Vision quadcopter UAV

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

Additionally, DRONE IT seeks an exemption from the requirements of Section 91.151(b), entitled 

Fuel Requirements for Flight in VFR conditions. DRONE IT submits that safety will not be affected by 

operation of the DJI Phantom 2 Vision quadcopter UAV during daylight hours in visual meteorological 

conditions (VMC) under Visual Flight Rules (VFR), with enough battery power to fly for a total 
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duration of approximately 25 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, DRONE IT provides the following information in support of 

its petition for exemption: 

A. Name and address of the petitioner:

DRONE IT

Reinaldo Fuentes, owner/founder

19377 NE 10th Ave. #510, Miami FL. 33179

Ph: 786.261.5714

E-mail: rpsflorida@gmail.com

B. The specific Sections of 14 C.F.R. from which DRONE IT seeks exemption:

1. DRONE IT 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. DRONE IT 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.
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3. DRONE IT 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. DRONE IT 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. DRONE IT 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.
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6. DRONE IT 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. DRONE IT 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. DRONE IT seeks exemption from the requirements of Sections 91.417(a) and 91.417(b):

Section 91.417, entitled Maintenance Records, subsections (a) and (b), states 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 
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(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 DRONE IT seeks and the reason DRONE IT seeks the relief:

1. Extent of relief DRONE IT seeks and the reason DRONE IT seeks relief from Section 

61.113(a) and (b):
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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 UAVs 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, DRONE IT submits that an equivalent level of safety will be 

maintained because no PIC will be allowed to operate The DJI Phantom 2 Vision quadcopter 

UAV unless that PIC has met certain flight-hour and currency requirements, demonstrating that 

the PIC is able to safely operate either The DJI Phantom 2 Vision quadcopter UAV 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, DRONE IT submits that all flights of The DJI Phantom 2 Vision quadcopter UAV, 

conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to DRONE IT,

business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent of relief DRONE IT seeks and the reason DRONE IT 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 DRONE IT to determine the DJI Phantom 2 Vision quadcopter is in airworthy 

condition prior to every flight by ensuring that the UAVs is in compliance with the operating 

documents (i.e., the DRONE IT, Aerial Operations Manual, Flight log, Monthly Maintenance 

Log, and Instruction Manuals). 
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DRONE IT seeks the requested relief because The DJI Phantom 2 Vision quadcopter UAV does

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

Therefore, DRONE IT will ensure that DJI Phantom Vision UAV is in airworthy condition based 

upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and 

Instruction Manuals) prior to every flight, and further, determine that the aircraft is in condition 

for safe flight, as stated in the conditions and limitations below. 

3. Extent of relief DRONE IT seeks and the reason DRONE IT seeks relief from Section 

91.121:

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

operations of the DJI Phantom 2 Vision quadcopter UAV, which utilizes a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry datalink 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 UAVs operations be reported to air traffic control 

(ATC) in feet above ground level (AGL), DRONE IT seeks the requested relief because the DJI 

Phantom 2 Vision quadcopter UAV 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 

Phantom 2 Vision quadcopter UAV is 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 UAV on the heads-up 

display of the GCS. 

4. Extent of relief DRONE IT seeks and the reason DRONE IT 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 the DJI Phantom 2 Vision 

quadcopter UAV during daylight hours in visual meteorological conditions (VMC), under visual 
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flight rules (VFR), for a total duration of 25 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 5 minutes. DRONE IT seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time duration 

of the battery powered the DJI Phantom 2 Vision quadcopter UAV will severely constrain the 

practicality of any aerial video or still photo flight operations that DRONE IT proposes to 

conduct pursuant to this Petition. 

The DJI Phantom 2 Vision quadcopter UAV operating documents, and DRONE IT’s proposed 

operating limitations, ensure that DRONE IT will safely operate the battery powered DJI 

Phantom 2 Vision quadcopter UAV during daylight hours in visual meteorological conditions 

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

25 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 DRONE IT seeks and the reason DRONE IT 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, DRONE IT requests relief from these Sections because 

the DJI Phantom 2 Vision quadcopter UAV does not require airworthiness certificates. As set 

forth more fully below, the DJI Phantom 2 Vision quadcopter UAV meets the conditions of 

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

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

the UASs using the methods, techniques, and practices prescribed in the UASs operating 

documents (i.e., the DRONE IT, Aerial Operations Manual, Monthly Maintenance Log, and 

Instruction Manuals). Furthermore, DRONE IT will document and keep all maintenance records 

for the DJI Phantom 2 Vision quadcopter UAV.
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D. The reasons why granting DRONE IT 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 DRONE IT to safely, 

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

events and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 Vision quadcopter UAV will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits of DRONE IT’s

proposed operation of the DJI Phantom 2 Vision quadcopter UAVs will be realized without implicating 

any privacy issues. 

1. The public will benefit from decreased congestion of the NAS:

The DJI Phantom 2 Vision quadcopter UAV is 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 The DJI Phantom 2 Vision quadcopter UAV 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 Phantom 2 

Vision quadcopter UAV 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 Phantom 2 Vision 

quadcopter UAV:

Conducting aerial acquisitions with the DJI Phantom 2 Vision quadcopter UAV, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise 
13

pollution generated during traditional aerial video and still photography flight operations. By 

using battery power and electric motors, the DJI Phantom 2 Vision quadcopter UAV produces 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 Phantom 2 Vision quadcopter UAV, while reducing the carbon footprint of aerial 

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

electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 2 Vision quadcopter UAV 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 

Phantom 2 Vision quadcopter UAV (weighing approximately 6 pounds, at their maximum gross 

weights with lengths of 14 inches widths of 14 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 Phantom 2 Vision 

quadcopter UAV will benefit the economy:

In addition to being safe and efficient, the DJI Phantom 2 Vision quadcopter UAV is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI Phantom 2 Vision quadcopter UAV will allow United States based 

companies, like DRONE IT, 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 Phantom 2 Vision quadcopter UAV 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. 
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By operating the DJI Phantom 2 Vision quadcopter UAV, companies such as DRONE IT, 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 Phantom 2 Vision 

quadcopter UAV, 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, 

DRONE IT’s proposed operation of the DJI Phantom 2 Vision quadcopter UAV will not 

implicate any privacy issues. Specifically, the DJI Phantom 2 Vision quadcopter UAV will be 

operated only in compliance with operating documents (i.e., the DRONE IT, Aerial Operations 

Manual, Monthly Maintenance Log, and 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 

DRONE IT seeks exemption:

1. Reasons why the DJI Phantom 2 Vision quadcopter UAV meets 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, DRONE IT’s operation of the DJI Phantom 2 Vision 

quadcopter UAV 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 UAVs to operate without airworthiness certification and sets 

forth requirements for considering whether a UAVs will create a hazard to users of the NAS or 
15

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, DRONE IT submits that the DJI Phantom 2 Vision quadcopter UAV

can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the 

characteristics of the DJI Phantom 2 Vision quadcopter UAV; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

a. The specifications of the DJI Phantom 2 Vision quadcopter UAV

demonstrate its safe characteristics:

The DJI Phantom 2 Vision quadcopter UAV 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. 
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i. Technical specifications:

The technical specification of the DJI Phantom 2 Vision quadcopter UAV is set 

forth by the Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 2 Vision quadcopter UAV Autonomous Flight And 

Navigation Modes Enable The UAVs To Remain Within A Defined 

Operational Area. 

The DJI Phantom 2 Vision quadcopter may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and navigational 

modes of the DJI Phantom 2 Vision quadcopter is provided at pages of the DJI 

Phantom 2 Vision User Manual, attached hereto as Exhibit B. 

iii. The DJI Phantom 2 Vision quadcopter UAV 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 Phantom 2 Vision quadcopter UAV will 

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 2 Vision quadcopter UAV do not reacquire control link data from the 

GCS, the UAVs will assume that the Control Link is lost and the UAV 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 Phantom 2 Vision 

quadcopter UAV are set forth on pages of the DJI Phantom 2 Vision User 

Manual, attached hereto as Exhibit B. 
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iv. The DJI Phantom 2 Vision quadcopter UAV GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 2 

Vision quadcopter UAV GCS and flight control software is provided at pages of 

the User Manual. User Manuals are attached hereto as Exhibits B. 

b. Flight operations of DJI Phantom 2 Vision quadcopter UAV. UAS are 

limited to the line of sight of a Certificated Pilot in Command with a Safety 

Observer:

DRONE IT will only utilize certificated pilots who possess a current and valid airman 

medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2 Vision 

quadcopter UAV. Additionally, a safety observer will assist all pilots during flight time. 

c. Flights of DJI Phantom 2 Vision quadcopter UAV will be conducted pursuant to 

specific operating limitations:

In seeking this exemption, DRONE IT proposes to commercially operate DJI Phantom 2 

Vision quadcopter UAV 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 Phantom 2 Vision

quadcopter UAV 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 UAVs may not be flown at an indicated airspeed exceeding 100 knots. 
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4. The UAVs 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 UAVs 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 

UAV 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 
19

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 UAVs 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 UAV 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 UAVs that has undergone maintenance or alterations that affect the 

UAVs 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 UASs 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 
20

work accomplished, and the signature of the authorized person returning the 

UAVs to service. 

15. Each UAVs 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 student pilot, private pilot certificate, or 

greater 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 

UAVs in a manner consistent with how the UAVs 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 UAVs with appropriate 

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

19. UAVs 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 UAVs may not operate within 5 nautical miles of a airport reference point 

as denoted on a current FAA-published aeronautical chart unless a letter of 
21

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 UAVs may not be operated less than 400 feet below or less than 1,000 

feet horizontally from a cloud or when visibility is less than 2 statute miles from 

the PIC. 

22. If the UAVs 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 UAVs 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. 
22

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

operation and control of the UAVs 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 UAV any time the UAV 

is operating. These documents must be made available to the Administrator or any 

law enforcement official upon request. 

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

operations and activities at all times. 

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

vehicle. 

31. Flight operations must be conducted at least 400 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 400 feet of the UAVs, 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; 
23

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:

DRONE IT 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 Phantom 2 Vision

quadcopter UAV unless that PIC has demonstrated, by meeting minimum flight-hour and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision

quadcopter UAV in a manner consistent with the exemption, including evasive and emergency 

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

Considering DRONE IT,' 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 Phantom 2 Vision quadcopter UAV, DRONE IT, submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for DRONE IT,' specific proposed flight operations.
24

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

DRONE IT, will not allow any PIC to operate the DJI Phantom 2 Vision quadcopter UAV unless 

that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 2 

Vision quadcopter UAV training and currency requirements, that the PIC is able to safely 

operate the DJI Phantom 2 Vision quadcopter UAV 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 UAVs rotorcraft pilot (with a minimum of 5 hours of those 

hours as a UAVs 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 DRONE IT,' 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 UAVs rotorcraft pilot 

including at least 10 hours logged as a UAVs pilot with a multi-rotor UAVs. Prior to operations 

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 

hours as a UAVs pilot operating the same make and model of UAVs 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 UAVs 

rotorcraft time.
25

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

with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15.

Accordingly, DRONE IT, will ensure safe operations by not allowing any PIC to operate UAS 

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

that the PIC is able to safely operate the 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, DRONE IT, will ensure that the DJI Phantom 2 Vision quadcopter UAV is in an 

airworthy condition based upon the UAV’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 UAVs, 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). 
26

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 Phantom 2 Vision quadcopter UAV will be provided to the PIC 

via GPS equipment and a radio communications telemetry data link, which downlinks from the 

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

combined with DRONE IT,' operation of the DJI Phantom 2 Vision quadcopter UAV 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 

UAVs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAV 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 ach flight, a zero altitude 

initiation point is; (2) the limitations on the proposed flight operations; and (3) the location of the 

proposed flight operations. Accordingly, DRONE IT, will ensure that it will safely operate the 

battery powered the during daylight hours in VFR conditions, with enough battery power to fly 

for a total duration of 25 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 Phantom 2 Vision 

quadcopter; 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, UASs provide audible and visual warnings to the PIC at the GCS when the UASs 
27

experiences low battery voltage, the first warning occurring at approximately 25% remaining 

battery power, and at approximately 10% remaining battery power 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, DRONE IT, 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 DRONE IT, 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 DRONE IT, Aerial Operations Manual, Monthly Maintenance Log, DJI Phantom 2 Vision

Instruction Manual). Furthermore, DRONE IT, will document and maintain all maintenance 

records for the DJI Phantom 2 Vision UAS. 

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, DRONE IT, requests that the FAA prescribe 

special conditions for the intended operation of the DJI Phantom 2 Vision 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). 
28

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 Phantom 2 Vision 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 Leading Edge’s intended operation of the DJI Phantom 2 Vision

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). 

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which Deland Drones Seeks Exemption: 
29

Deland Drones 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 DRONE IT seeks: 

This exemption will permit DRONE IT, to commercially operate an Unmanned Aircraft System, small 

(UASs) for the purpose of conducting aerial video and photography over certain areas of the United 

States. 

G. Any Additional information, views or arguments available to support DRONE IT’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, DRONE IT,' 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, DRONE IT, will operate the DJI Phantom 2 Vision UAS 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, DRONE IT seeks an exemption pursuant to 14 C.F.R. §11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI 

Phantom 2 Vision 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 DRONE IT, to 
30

safely, efficiently, and economically operate the DJI Phantom 2 Vision UAS commercially within the 

NAS. 

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

Reform Act of 2012, Section 333, DRONE IT, 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 Phantom 2 Vision UAS commercially for the purpose of conducting aerial video 

and photography over certain areas of the United States. 

Dated: March 29th, 2015

Respectfully submitted by

Reinaldo Fuentes, Owner DRONE IT,

19377 NE 10th AVE #510

Miami, FL 33179

Ph: 786.261.5714 / E-mail: RPSflorida@gmail.com

Appendices: 

A - DJI Phantom 2 Vision Specifications Data Sheet 

B - DJI Phantom 2 vision Owner Manual

The DJI Phantom 2 Vision Maintenance guidelines ensure an equivalent level of safety to the 

maintenance requirements. In addition, any component failure detectable by the system will be reported 

to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Nonfatal 

Condition Response. 
31

Appendix A 

The Phantom 2 Vision ushers in a new era of aerial Photography, the sharp, powerful DJI-designed 

camera, making professional imaging tools easily accessible to everyone. 

Vision+ 

Battery 

5200mAh LiPo 

Phantom 2 Vision 1160g (with battery & Weight propellers) 

Hover Accuracy (Ready Vertical:0.8m to Fly) Horizontal:2.5m 

Max Yaw Angular 200°/s Velocity 

Max Tilt Angle 35° 

Max Ascent / Descent Ascent: 6m/s Speed Descent: 3m/s 

Max Flight Speed 15m/s(Not Recommended) 

Diagonal Length 350mm 

Tilting Range of Gimbal Pitch : 0°-60°

1. Ready to fly 

2. Precision flight and stable hovering 

3. Radar positioning & return home 

4. Onscreen real-time flight parameters 

5. High performance camera 

6. Camera tilt control 

7. Film straight down 

8. Supports Adobe DNG RAW 

9. Adobe lens profile support 

10. Camera parameter settings 

11. Album synchronization 
32

TRANSMITTER 

1. Operating Frequency: 5.728 GHz – 5.85 GHz 

2. Communication Distance (open area): CE: 300m; FCC: 500m

3. Receiver Sensitivity (1%PER): -93dBm

4. Transmitter Power: CE: 25mw; FCC: 125mw 

5. Working Voltage: 80 mA@6V 

6. Battery: 4 AA Batteries 

CAMERA 

1. Resolution: 14 Megapixel

2. FOV: 120°/ 110° / 85° 

3. Sensor size: 1/2.3" 

4. HD Recording: 1080p30 /1080p60 

RANGE EXTENDER 

1. Operation Frequency: 2412-2462MHz

2. Communication Distance (Open Area) 300m

3. Transmitter Power: <=17dbm

4. Power Consumption: 1.5W

The Phantom 2 Vision Range Extender is a wireless communication device that operates within the 2.4 

GHz frequency band. It is used to extending the effective range of communication between a 

Smartphone and the Phantom 2 Vision. In an open, unobstructed area, the transmission distance can 

reach up to 300 meters. This can be reduced by trees, buildings and other sources of the same frequency. 

Before every flight, it is suggested that you ensure the Range Extender is functioning properly; 

otherwise communication issues between the mobile device and the Phantom 2 Vision may occur. 

DJI VISION APP 

System Requirement of Mobile Device: 

1. IOS recommended: iPhone4s, iPhone 5, iphone5s, iPhone6, iPhone6 Plus, IPod Touch5 ( available 

but not recommended: iPad3, iPad4, iPod mini) 

2. Android recommended: Samsung Galaxy S3, S4, Note 2, Note 3 or phones of similar configuration

Phantom 2 Vision Before Flight 
33

Once pre-flight preparation is complete, it is recommended to carry out the tasks in the Phantom Pilot 

Training Guide to prepare for more complex flight maneuvers and learn to fly safely. Ensure that all 

flights are carried out in a suitable location. 

Flight Environment Requirements 

1. Do not use the aircraft in severe weather conditions. These include wind speed exceeding category 4, 

snow, rain and smog. 

2. Fly in open fields as high buildings or steel structures may affect the accuracy of the onboard 

compass. 

3. Keep the Phantom away from obstacles, crowds, high voltage power lines, trees or bodies of water 

when in flight. 

4. Reduce the chance of electromagnetic interference by not flying in areas with high levels of 

electromagnetism, including base stations or radio transmission towers. 

5. The Phantom cannot operate within the polar areas. 

6. Do not fly the aircraft within no-fly zones specified by local laws and regulations. 

Preflight Checklist 

1. Remote Controller, smart battery, Range Extender and smartphone are fully charged. 

2. Propellers are mounted correctly. 

3. Damping absorbers are in good condition, not broken or worn. 

4. Anti-drop kits have been mounted correctly. 

5. Camera lens cap has been removed. 

6. Micro-SD card has been inserted if necessary. 

7. Motors can start and are functioning as normal. 

8. DJI VISION App can connect to the camera. 

DJI Vision App Usage 

The DJI VISION App controls the Phantom 2 Vision camera including capture, recording, settings and 

pitch angle. It also displays essential flight information including flight parameters and battery. 

Calibrating the Compass 
34

IMPORTANT: Make sure to calibrate the compass in every new flight location. The compass is very 

sensitive to electromagnetic interference, which can cause abnormal compass data leading to poor flight 

performance or even flight failure. Regular calibration is required for optimum performance. 

Calibration Procedures 

Choose an open space to carry out the following procedures. Watch the Phantom 2 Vision quick start 

video for more details. 

Hints and Tips: 

If compass calibration is needed before flight, a prompt will appear on the DJI VISON App’s camera 

page. It will disappear after successful calibration. 

When to Recalibrate 

1. When compass data is abnormal, the rear LED flight indicator will blink red and yellow. 

2. Flying in different location to last flight. 

3. Mechanical structure of the Phantom has changed, i.e. changed mounting position of the compass. 

4. Severe drifting occurs in flight, i.e. Phantom does not fly in straight lines. 

Starting Motors 

A Combination Stick Command (CSC) is used to start the motors instead of simply pushing the stick up. 

Push both sticks to their bottom corners to start the motors. Once the motors have spun up, release both 

sticks simultaneously. 

Stopping Motors 

There are two methods to stop the motors. 

Method 1: When the Phantom has landed, push the throttle down, then conduct CSC. Motors will stop 

immediately. Release both sticks once motors stop. 

Method 2: When the aircraft has landed, push the throttle down and hold. Motors will stop after 3 

seconds. 

Warning: Do not execute CSC during normal flight. This will stop the motors and cause the aircraft to 

drop without control. 

References: Conduct the CSC as neatly as you can. Release the sticks once motors start/stop. Take off / 
35

Landing Procedures 

1. Place the Phantom 2 Vision on open flat ground with battery indicators facing towards you. 

2. Power on the Remote Controller and Range Extender, then the Smart Flight Battery. 

3. Launch the DJI VISION App and start bind it with your smartphone then enter the camera preview 

page. 

4. Wait until the Rear LED Flight Indicator blinks green. This means it has initialized and is Ready to 

Fly. If it flashes yellow, it is in Ready to Fly (non-GPS) mode and will require more careful flight. 

Execute the CSC command to start motors. 

5. Push the throttle up slowly to take off. Refer to Remote Controller Operation for more details. 

6. Shoot photos and videos using the DJI VISION App. Refer to DJI VISION App Usage for more 

details. 

7. To land, hover over a level surface and gently pull down on the throttle gently to descend. 

8. After landing, execute the CSC command or hold the throttle at its lowest position for 3 seconds or 

more until the motors stop. 

9. Turn off the smart battery, Range Extender and Remote Controller. 

Important: 

1. When the Rear LED Flight Indicator blinks yellow rapidly during flight, the aircraft has entered 

Failsafe mode.

2. A low battery level warning is indicated by the Rear LED Flight Indicator blinking red slowly or 

rapidly during flight. 

3. View tutorials about flight for more flight information: www.dji.com/phantom2vision/training. 

Video Suggestions and Tips 

1. Work through the checklist before each flight. 

2. Aim to shoot when flying in Ready to Fly only. 

3. Always fly in good weather, such as sunny or windless days. 

4. Change camera settings to suit you. These include FOV, photo format and exposure compensation. 

5. Take flight tests to establish flight routes and scenes. 

6. Push the sticks gently to make aircraft movements stable and smooth. 
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Failsafe Function 

The Phantom will enter Failsafe mode when its connection to the Remote Controller is lost. The Flight 

Control System will automatically control the aircraft to return to home and land to prevent injury or 

damage. 

Hints and Tips:

Home Point: When the Phantom enters ’Ready to Fly’ from the ‘Ready to Fly status (non-GPS)’, the 

GPS coordinates will be recorded and set as the home point. 

1. When Remote Controller signal is lost, the aircraft will return to the recorded home point 

coordinates and land. 

2. Home point coordinates are used to calculate the horizontal distance of the aircraft (shown as 

“Distance” on the GUI of the DJI VISION App). 

3. After successfully recording the home point, rear LED flight indicators blink fast green. 

When will Failsafe Activate? 

1. The Remote Controller is powered off. 

2. The Phantom has flown out of effective communication range. 

3. The signal between the Remote Controller and the Phantom has been blocked. 

4. There is interference causing a signal problem with the Remote Controller. 

Failsafe Procedure 

Initiating the Failsafe mode from different flying statuses will results in different landing processes. 

Ready to Fly (non-GPS) ---- Automatic landing 

The Flight Control System will keep the aircraft level during descent and landing. It may be drift during 

the descent and landing process. 

Ready to Fly ---- Automatic go home and land 

The Flight Control System will automatically control the aircraft to fly back to the home point and land. 

The below demonstrates the complete Ready to Fly Failsafe landing process. 

Important: 

1. To ensure the aircraft successful return to home after Failsafe activation, aim to only fly in Ready to 

Fly mode. 
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2.The Phantom will automatically descend during the Failsafe process if there are less than 6 GPS 

satellites detected for more than 20 seconds. 

3.The aircraft cannot avoid obstacles during Failsafe. 

Hints and Tips: Quickly flipping the S2 switch of the Remote Controller from top to bottom 5 times or 

more will reset the current aircraft position as a new home point. Rear LED flight indicators will blink 

green rapidly when successful. 

Failsafe on the DJI VISION App 

The DJI VISION App will provide information during Failsafe 

Regaining Control During Failsafe Procedures 

Low Battery Level Warning Function 

The low battery level warning alerts users when the battery is close to depletion during flight. When it 

appears, users should promptly fly back and land to avoid accidental damage. The Phantom 2 Vision has 

two levels of low battery level warning. The default battery level warning thresholds are 30% (low 

battery level warning) and 15% (critical low battery level warning) respectively. 

Flight Limits 

All unmanned aerial vehicle (UAV) operators should abide by all regulations from such organizations as 

the ICAO (International Civil Aviation Organization) and their own national airspace regulations. For 

safety reasons, the flight limits function is enabled by default to help users use this product safely and 

legally. The flight limits function includes height, distance limits and No Fly Zones. 

In Ready to Fly mode, height, distance limits and No Fly Zones work together to manage flight. In 

Ready to Fly (non-GPS) status, only height limits work and flights cannot go higher than 120m. 

References: Default parameters in Assistant Software are compliant within the definitions of class G 

ruled by ICAO. (Refer to Airspace Classification to get more details). As each country has its own rules, 

make sure to configure these parameters to comply with these rules before flying. 

Max Height & Radius Limits 

Max Height & Radius limits flying height and distance. Configuration can be done in the Phantom 2 

Vision Assistant. Once complete, your Phantom will fly in a restricted cylinder.

Preparing the Remote Controller 

The Phantom 2 Vision Remote Controller is a wireless communication device using the 5.8GHz 

frequency band. Remote Controller and Phantom are paired before delivery. The Remote Controller is 
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set to Mode 2 by default. This can be adjusted in the PHANTOM RC Assistant Software. See Using the 

PHANTOM RC 

Definitions:

Compliance Version: The Phantom 2 Vision Remote Controller is compliant with CE and FCC (see the 

FCC ID) regulations.

Operating Mode: Mode 1 and Mode 2 refer to different channel mappings. Mode 1: The right stick 

controls throttle. Mode 2: The left stick controls throttle. 

Hints and Tips:

The Range Extender and Phone Holder are already mounted on the Remote Controller. Twist the Phone 

Holder to face outwards and fix it in position for mobile device installation. 

Warning: Large smartphones and tablets are not recommended for the Phone Holder as they do not fit. 

The Remote Controller 

Before every flight, it is suggested that you ensure the Range Extender is functioning properly; 

otherwise communication issues between the mobile device and the Phantom 2 Vision may occur. 

Safe operating procedures:

Getting ready for take off

- Turn on the remote controller.

- Be sure that both switches (S1 & S2) are in their top position.

- Turn on the range extender.

- Turn on the intelligent flight battery pressing once, release then press and hold.

- Connect your smart device to the Phantom’s WiFi signal.

- Start the vision application.

- Calibrate the Phantom’s compass by:

- Flipping the S1 switch located on the top right on the remote controller between its top and bottom 

positions at least 5 times, ending with the S1 switch in the top position; or tap “compass calibration” 
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in the DJI vision app. When the LED flight indicator lights display solid yellow, DJI Phantom 2 

Vision is ready for calibration.

- Pick up the Phantom and rotate it 360* horizontally with the front facing away from you. When the 

LED flight indicator changes to solid green the horizontal calibration was a success.

- Continue the calibration process by holding the Phantom vertically with the front facing downward 

and rotating it 360* again. When the LED flight indicator lights blink green the full calibration was a 

success.

- If the LED flight indicators blink red and yellow, the calibration was not successful and you should 

try the calibration process again.

Takeoff

- Set Phantom on a flat surface with the camera pointing away from pilot.

- Ensure home point has been achieved by checking the vision app for at least 6 GPS satellites. The 

LED flight indicators will flash green quickly when a home point is recorded.

- Start the Phantom by pushing both sticks on the radio to their bottom corners, towards one another (4 

o’clock with the left stick and 7 o’clock with the right stick). This will start the motors.

- Slowly push left throttle stick up to increase power to the motors until the Phantom lifts off the 

ground. Always push the sticks softly.

- Allow the Phantom to hover at 10-15 feet to check for proper stability and get your bearings.

- Gently adjust the sticks to ensure Phantom responds accordingly.

- Frame the shot via the FPV view on mobile device.

- Push the shutter button in the vision app to take images or video.

Landing

- Select a safe landing area and hover over it.

- Descend by gently reducing the throttle taking the left stick down.

- Once safely landed push the throttle down and hold until motors stop completely.

- Download videos and photos to your mobile device through the vision app.

- Turn off the intelligent flight battery, range extender and remote controller.

Post-flight debrief

- After each flight, and before your next flight, always inspect the Phantom for any damage.
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Other comments:

- No personal modifications are recommended to the Phantom

- Do the compass calibration and always ensure the home point has been recorded before flying.

- Stay focused while flying; alternate your eyes between the Phantom and on the smart device.

- Be aware of the flight parameters. Monitor battery telemetry closely.

- You can get a max of 25 minutes of flight time with the intelligent flight battery, depending on 

location, environmental conditions and flight maneuvers.

- The remote controller has a typical range of about 2,600 feet while the video feed has a range of 

about 2,300 feet. However, we do not recommend flying beyond “Line of Sight” (LOS).

- The default height limit is 400 feet and we recommend never exceeding this height.

- The Phantom can fly a max of 33mph, however we do not recommend flying at this speed. Always 

be careful, as the Phantom can pick up additional speed when flying down wind.

- Including battery and camera the Phantom weighs 2.7lbs

- The Phantom can climb at a speed of 20feet/second and descend at a speed of 6feet/second.