UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Travis Neuber

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

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

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

OPERATION OF DJI PHANTOM 3 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on May 30, 2015 
TABLE OF CONTENTS 

Page 

GLOSSARY OF 

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

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

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

BACKGROUND................................................................................................................5 

BASIS FOR 

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

NAME AND ADDRESS OF PETITIONER..........................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH TRAVIS NEUBER

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

THE EXTENT OF RELIEF TRAVIS NEUBER SEEKS AND THE REASON TRAVIS NEUBER

 SEEKS THE RELIEF.............................................11 

THE REASONS WHY GRANTING TRAVIS NEUBER'S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .../...................................................14 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY........................................................................17 

CONCLUSION.................................................................................................................32
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

Section 333 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
SUMMARY

Travis Neuber seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) 

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

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the 

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

Travis Neuber to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography for film sets, real estate photography, 

special events, wedding videography, and landscape over certain areas of the United 

States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is Travis Neuber, and I am a producer with expertise and knowledge 

in all aspects of video and audio production. Travis Neuber also provides clients with 

the highest quality digital content for use in their commercial, personal, and non-profit 

multimedia projects. Travis Neuber has over 7 years of professional experience in 

photography and videography and is recognized as an expert in this field. Travis Neuber

has 2 years of recreational/hobby experience in all aspects of aerial video and 

photography. The objective of Travis Neuber's aerial video and photography operations 

is to provide high quality imaging for a variety of commercial, public, and residential 

uses, specifically targeting: 

• Motion Picture Filming 

• Real Estate Photography 
• Land survey & appraisals 

• Equipment Inspections 

• Wedding Videography and Photography 

• Creation of commercial messages for Television. 

• Coverage of Sporting events.

• Increase public knowledge of UAS and promote safe UAS operations. 
BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 UASs 

Travis Neuber seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Phantom 3 are vertical takeoff and landing

 (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) 

utilizing electronic tablet or smart phone systems. The DJI Phantom 3 has a 

maximum gross weight of approximately 3 pounds 11 ounces, while having a length of 

16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 

29 knots. 

The DJI Phantom 3 UAS are equipped with four main rotors; driven by Lithium Polymer

battery powered electric motors.

The DJI Phantom 3 UAs that will be operated by Travis Neuber,

will be registered in accordance with 49 U.S.C. 44103, Registration of 

Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance 

with 14 C.F.R. Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, Travis Neuber, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Phantom 3 UAS

in the National Airspace System (NAS), and for an exemption from the 

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

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

In consideration of the speed, weight, size, and limited operating area associated 
with the unmanned aircraft and its operation, Travis Neuber operation of DJI Phantom 

3 UAS meets the conditions of FMRA Section 333 and therefore, will not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

 

Accordingly, Travis Neuber 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. 

Travis Neuber submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Travis Neuber will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS 

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

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). Furthermore,

Travis Neuber will document and maintain all maintenancerecords for the DJI Phantom 3

UAS. 

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

pilot privileges and limitations: Pilot in command, is requested by Travis Neuber to 

the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher 

level certificate, as well as an airman medical certificate, and who has demonstrated, by 

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

operate the DJI Phantom 3 UASs in a manner consistent with this exemption,

including evasive and emergency maneuvers and maintaining appropriate distances from

people, vessels, vehicles and structures. 

Travis Neuber seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,

Travis Neuber submits that he will ensure that the DJI Phantom 3 UAS are in an

airworthy condition, prior to every flight, by determining 
that the UASs are in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 3 Instruction Manual),and that the aircraft

are in a condition for safe flight. 

Travis Neuber also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 UA will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 3

UA will be provided to the PIC via Global Positioning System (GPS) equipment and

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

for active monitoring of the flight path. This ltitude information, combined with Travis

Neuber's operation of the DJI Phantom 3 UAS within visual line of sight, at or below

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

Additionally, Travis Neuber seeks an exemption from the requirements of 

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

Neuber submits that safety will not be affected by operation of the DJI Phantom 3

UA during daylight hours in visual meteorological conditions (VMC) under visual

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

approximately 13.5 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Travis Neuber provides the following 

information in support of its petition for exemption: 

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: 

Travis Neuber

N4151 Long Road

Chilton, WI 53014

920-588-0561

Email: travis.neuber@hotmail.com
B. The Specific Sections Of 14 C.F.R. From Which Travis Neuber Seeks 

Exemption. 

1. Travis Neuber 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. Travis Neuber Seeks Exemption From The Requirements Of Section 

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

3. Travis Neuber 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. Travis Neuber 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. Travis Neuber Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the 

following: Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and 

shall between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Travis Neuber 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. Travis Neuber 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. Travis Neuber Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

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

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section: 
(1) Records of the maintenance, preventive maintenance, and alteration and 

records of the 100-hour, annual, progressive, and other required or 

approved inspections, as appropriate, for each aircraft (including the 

airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include-- 

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

the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

and each rotor. 

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

propeller, rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 

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

the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained. 

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

safety directives including, for each, the method of compliance, the 

AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next 

action is required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

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

prescribed: 

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

until the work is repeated or superseded by other work or for 1 year after 

the work is performed. 

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

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 

of this chapter shall be retained until the defects are repaired and the 

aircraft is approved for return to service. 

C. The Extent Of Relief Travis Neuber Seeks And The Reason Travis Neuber

Seeks The Relief. 

1. Extent Of Relief Travis Neuber Seeks And The Reason Travis Neuber

Seeks Relief From Section 61.113(a) And (b). 

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

limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding 
a private pilot or higher level certificate, as well as a current and valid airman medical 

certificate, and who has met certain flight-hour and currency requirements, to conduct the 

proposed UAS flight operations for compensation or hire. 

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

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

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

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

compensation or hire. 

As set forth more fully below, Travis Neuber submits that an equivalent level 

of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3

UAS unless that PIC has met certain flight-hour and currency requirments,

demonstrating that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner

consistent with the operations specifications as described in this exemption, including

evasive and emergency maneuvers, as well as maintaining appropriate distances from

people, vessels, vehicles and structures.

Further, Travis Neuber submits that all flights of the DJI Phantom 3 UAS

cconducted by the PIC pursuant to the grant of this Petition: (1) will be incudental to

Travis Neuber's business; and (2) will not carry passengers or property for compensation

or hire. 

2. Extent Of Relief Travis Neuber Seeks And The Reason Travis Neuber

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 Travis Neuber to determine that the DJI Phantom 3 UAS

are in airworthy condition prior to every flight by ensuring that the UAS is in compliance

with the operating documents (i.e., the Travis Neuber Aerial Operations Manual,

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual). 
Travis Neuber seeks the requested relief because the DJI Phantom 3 UAS does

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

 Therefore, Travis Neuber will ensure that the DJI Phantom 3 UAS are in airworthy

condition based upon its compliance with the operating documents (i.e., Monthly

Maintenance Log, and DJI Phantom 3 Instruction Manual) prior to every flight. 

3. Extent Of Relief Travis Neuber Seeks And The Reason Travis Neuber

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 3UAS, which utilize a barometric pressure

sensor, GPS equipment, and a radio communications telemetry data link to

downlink altitude information from the UA to the PIC at the ground control station

(GCS). Since the FAA requires that any altitude information concerning UAS 

operations be reported to air traffic control (ATC) in feet above ground level (AGL), 

Travis Neuber seeks the requested relief because the DJI Phantom 3 UA's

altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. 

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

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Phantom 3 UA are equipped with a barometric pressure

sensor and GPS equipment, which automatically ensures that a ground level

pressure setting will be established prior to each flight, and provides the PIC with altitude

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

4. Extent Of Relief Travis Neuber Seeks And The Reason Travis Neuber
Seeks Relief From Section 91.151(b). 

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

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

Phantom 3 UA during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), for a total duration of 13.5 minutes to the first point

of intended landing and, assuming normal cruising speed, to fly after that 

for at least 4.5 minutes. Travis Neuber seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of the battery powered DJI 

Phantom 3 UA will severely constrain the practicality of any aerial video or still photo

flight operations that Travis Neuber proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 3

UAS operating documents, and Travis Neuber's proposed operating limitations, ensure that

Travis Neuber will safely operate the battery powered DJI Phantom 3 UA during

daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR),

with enough battery power to fly for a total duration of 15 minutes to the first point of

intended landing and, assuming normal cruising speed, to fly after that for at least 5 minutes. 

5. Extent Of Relief Travis Neuber Seeks And The Reason Travis Neuber

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, Travis Neuber requests relief 

from these Sections because the DJI Phantom 3 UAS do not require airworthiness

certificates. As set forth more fully below, the DJI Phantom 3 UAS meet the conditions of

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

Travis Neuber will use trained technicians to perform maintenance, alterations, or
preventive maintenance on the UAS using the methods, techniques, and practices

prescribed in the UAS operating documents i.e., the Travis Neuber Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual).

Furthermore, Travis Neuber will document and maintain all maintenance

records for the DJI Phantom 3 UAS.

D. The Reasons Why Granting Travis Neuber's 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 Travis

Neuber to safely, efficiently, and economically perform aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 3 UAS will decrease congestion 

of the NAS, reduce pollution, and provide significant benefits to the econmy.

Notably, the benefits of Travis Neuber proposed operation of the DJI 

Phantom 3 UAS will be realized without implicating any privacy issues.

 

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

The DJI Phantom 3 are battery powered and serve as a safe,

efficient, and economical alternative to the manned aircraft traditionally utilized 

to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform 

aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 UAS

would reduce the amount of manned aircraft in the NAS, reduce noise and 

air pollution, as well as increase the safety of life and property in the air and on the 

ground. 

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

congestion around airports caused by arriving and departing aircraft will be reduced. The 
DJI Phantom 3 UA 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 3 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 UAS,

 instead of manned aircraft, will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated during traditional aerial video and still 

photography flight operations. By using battery power and electric motors, the DJI 

Phantom 3 UAS produce no air pollution, and is the most viable environmentally

cconscious 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 3 UA, while reducing the carbon footprint of aerial acquisitions, also

 eliminates noise pollution, as the UAs are propelled by battery powered 

electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 3 UAS to perform aerial acquisitions, the substantial

 risk to life and property in the air and on the ground, which is usually associated

 with traditional manned aircraft flight operations, will be substantially reduced

 or completely eliminated. Aside from the lack of flight crew members located 

onboard the aircraft, the DJI Phantom 3 UA (weighing 

approximately 2 pounds 11 ounces at their maximum gross weights with lengths

 of 16 inches and widths of 16 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 3 UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 UAS are

also an economical alternative to using manned aircraft to conduct similar aerial

operations. As such, operation of the DJI Phantom 3 UAS will allow United States

based companies, like Travis Neuber, 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  UAS is one such technology WKDWQRWRQO\DOORZV

companies greater operational flexibility compared to manned DLUFUDIWEXW

provides such flexibility without the high operational cost of a traditionalPDQQHG

Dircraft. 

By operating the DJI Phantom  UAS, companies VXFKDV7UDYLV1HXEHUFDQ

remain competitive and profitable, and therefore, provide JUHDWHUMREVWDELOLW\WRHPSOR\HHV

DQGcontractors, which will ultimately contribute to JURZWKRIWKH86HFRQRP\

 Improved financial performance of U.S. companies, WKURXJKFRPPHUFLDOXVHRI

 the DJI Phantom  UAS, provides DVWDEOHZRUNIRUFHWKDWLQFUHDVHVFRQVXPHUVSHQGLQJ

 improves local, state, and federal WD[UHYHQXHVDQGDOORZVFRPSDQLHVWRLQYHVWLQ

 research and development in order to UHPDLQFRPSHWLWLYHERWKLQWKH8QLWHG6WDWHV

 and abroad. 

4. There Are No Privacy Issues. 

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

decades, Travis Neuber's proposed operation of the DJI Phantom 8$6
will not implicate any privacy issues. Specifically, the DJI Phantom 

UAS will be operated only in compliance with operating GRFXPHQWVLHWKH7UDYLV

1HXEHUAerial Operations Manual, Monthly Maintenance /RJDQG'-,

Phantom Instruction Manual) which requires SURSHUW\RZQHULQYROYHPHQWDVZHOO

Ds local law enforcement notification, and in DFFRUGDQFHZLWKWKH)HGHUDO$YLDWLRQ

Regulations, including the minimum altitude UHTXLUHPHQWVRI&)5

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 Travis Neuber Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 UAs Meet The Conditions of the

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

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

with the unmanned aircraft and its operation, Travis Neuber's operation of the DJI 

Phantom  UAS meet the conditions of FMRA Section 333, DQGZLOOQRWUHTXLUHDQ

 airworthiness certificate in accordance with 14 C.F.R. Part 21, 6XESDUW+

Section 333 provides authority for a UAS to operate without airworthiness 

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

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

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

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

later than 180 days after the date of enactment of this Act, the Secretary of 

Transportation shall determine if certain unmanned aircraft systems may 

operate safely in the national airspace system before completion of the plan 

and rulemaking required by section 332 of this Act or the guidance required 

by section 334 of this Act. 

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

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

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

size, weight, speed, operational capability, proximity to airports and 

populated areas, and operation within visual line of sight do not create 
a hazard to users of the national airspace system or the public or pose 

a threat to national security; and 

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

airworthiness certification under section 44704 of title 49, United 

States Code, is required for the operation of unmanned aircraft 

systems identified under paragraph (1). 

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

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the 

safe operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Travis Neuber submits that the DJI Phantom 3

UAS can operate safely in the NAS pursuant to FMRA Section 333, as

demonstrated by: (a) the characteristics of the DJI Phantom 3 UAS; (b) the pilot 

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

a. The Specifications Of The DJI Phantom 3 UAS

 Demonstrate Its Safe Characteristics.

The DJI Phantom 3 UASs do not create a hazard to 

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

its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 8$6

The technical specifications of the DJI Phantom 8$6DUHVHWIRUWKE\WKH

UASs are set forth by the DJI Phantom  Specifications and 'DWD6KHHWDV

Exhibit A and B. 

ii. The DJI Phantom  UASs Autonomous )OLJKWDQG1DYLJDWLRQ

Modes Enable The UASs To Remain Within A Defined

Operational Area. 

The DJI Phantom 3 UAS3 may be operated in both manual and fully autonomous

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

 Phantom 3 UAS is provided at pages 25-35 of the DJI Phantom 3.
1 User Manuals, attached hereto as Exhibit C and D. 

iii. The DJI Phantom 3 UAS Are Designed 

For Automatic Return To Home Point Or Hover In The Event Of 

Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 3 UA will remain stationary,

in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 UA does not 

 reacquire control link data from the GCS, the UA will assume that the Control Link

is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS

and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 3

UAS are set forth at pages 27 through 29 of the DJI Phantom 3 User Manuals, attached

hereto as Exhibit C.

iv. The DJI Phantom 3 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Phantom 3

GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 3

User Manual. DJI Phantom 3 User Manuals are attached hereto as Exhibit C.

b. Flight Operations Of DJI Phantom 3 UAS Are Limited To The

Line Of Sight Of A Certificated Pilot in Command.

Travis Neuber 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 3

 UAS. 

c. Flights Of DJI Phantom 3 UAS Will Be 

Conducted Pursuant To Specific Operating Limitations. 
In seeking this exemption, Travis Neuber proposes to commercially operate 

DJI Phantom 3 UAS for the special purpose of conducting aerial video and photography

over certain areas of United States, pursuant to the following specific operating limitations:

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

following aircraft described in the operating documents, rotorcraft UASs 

weighing less than 55 pounds maximum gross weight: DJI Phantom 

and Unmanned Aircraft Systems. Proposed operations of any RWKHUD

ircraft will require a new petition or a petition to amend this grant. 

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

for the purpose of aerial video and photography. 

3. The UAs may not be flown at an indicated airspeed exceeding 2 knots. 

4. The UA must be operated at an altitude of no more than 500 feet above ground 

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

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

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

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate. 

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

permitted. 

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The SO and PIC must be able to communicate verbally at all times. 

Electronic messaging or texting is not permitted during flight operations. The 

PIC must be designated before the flight and cannot transfer his or her 

designation for the duration of the flight. The PIC must ensure that the SO can 

perform the functions prescribed in the operating documents. 

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

and avoiding other air traffic and other ground based obstacles/obstructions 

and is not permitted to operate the camera or other instruments. 

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

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the 

grant of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

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

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

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

and present updated and revised documents to the Administrator upon request. 
The operator must also present updated and revised documents if it petitions 

for extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, then the operator must petition for amendment to 

its grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operating 

documents. 

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

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

safe operation of the UAS, the aircraft is prohibited from operating until the 

necessary maintenance has been performed and the UAS is found to be in a 

condition for safe flight. The Ground Control Station must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical 

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

functional test flight must make an entry in the aircraft records. 

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

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

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

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, 

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

returning the UAS to service. 

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

Safety Bulletins. 

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

corrective action taken against discrepancies discovered between inspections. 

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

third- class medical certificate. 

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

operator’s qualification criteria and demonstrates the ability to safely operate 

the UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

§ 61.51(b). Flights for the purposes of training the operator’s PICs are 

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

only be conducted during dedicated training sessions. During training, 

proficiency, and experience-building flights, all persons not essential for flight 
operations are considered nonparticipants, and the PIC must operate the UA 

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

91.119. 

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

1.1. All operations must be conducted under visual meteorological conditions 

(VMC). If flight at night is required, a special request will be made at the 

FAA office closest to proposed area of operations. Flights under special visual 

flight rules (SVFR) are not authorized. 

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

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

agreement with that airport’s management is obtained, and the operation is 

conducted in accordance with a NOTAM as required by the operator’s COA. 

The letter of agreement with the airport management must be made available 

to the Administrator upon request. 

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

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

the PIC. 

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

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 UA with 25% battery power 

remaining. 

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

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

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

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

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

be conducted in accordance with airspace requirements in the ATO issued 

COA including class of airspace, altitude level and potential transponder 

requirements. 

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

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, 

Subpart C. Markings must be as large as practicable. 

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

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

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

available to the PIC at the Ground Control Station of the UAS any time the 
UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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

operations and activities at all times. 

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

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

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

persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating persons from the UA and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where 

nonparticipating persons leave such protection and are within 500 feet 

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

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

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

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

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

do not present an undue hazard to those persons per § 91.119(a). 

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

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

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

 

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

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to 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. 

 

7UDYLV1HXEHU 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  UAS unless that PIC has demonstrated, byPHHWLQJPLQLPXPIOLJKWKRXU

and currency requirements, that the PIC is able to safely RSHUDWHWKH'-,3KDQWRP

 UAS in a manner consistent with the H[HPSWLRQLQFOXGLQJHYDVLYHDQGHPHUJHQF\
 maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures. 

Considering 7UDYLV1HXEHU
V proposed area of operations, and the operating 

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and 

the airmanship skills necessary to safely operate the DJI Phantom 3

UAS, 7UDYLV1HXEHU submits that the additional manned airmanship 

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

skills necessary for 7UDYLV1HXEHU
V specific proposed flight operations. 

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

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

7UDYLV1HXEHU will not allow any PIC to operate the DJI Phantom 3

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

requirements or the DJI Phantom 3 UAS training and currency requirements,

 that the PIC is able to safely operate the DJI Phantom 3 UAS in a manner

 consistent with this exemption, including evasive and emergency maneuvers and

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

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

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 
experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during 7UDYLV1HXEHU
V proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

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

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours 

of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

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

exemption. For clarification, the FAA considers these minimum hour 

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

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

included in the total 25 hours of UAS rotorcraft time. In addition to the hour 

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

90 days (for currency purposes). The FAA finds that at a minimum, the flighthour requirements in Exemption No. 11062 are appropriate to practice and build 

proficiency in the skills necessary to safely conduct the petitioner’s proposed 

operations. The FAA also finds that prior documented flight experience that was 

obtained in compliance with applicable regulations would satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted 

under the grant of exemption to accomplish the required flight time. During 

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

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

Exemption No. 11138 at page 15. 

Accordingly, 7UDYLV1HXEHU will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 3 UAS unless that PIC has demonstrated, by

 meeting minimum flight-hour and currency requirements, that the PIC is able to

 safely operate the DJI Phantom 3 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, 7UDYLV1HXEHUwill ensure that the DJI Phantom 3

UAS is in an airworthy condition based upon the UAS’s compliance with its operating
 documents and as stated in the conditions and limitations herein.

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

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety. 

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

because the altitude information of the DJI Phantom 3 UA will be provided to the PIC

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

from the UA to the GCS for active monitoring of the flight path and altitude. This

 altitude information, combined with 7UDYLV1HXEHU
V operation of the DJI

 Phantom 3 UA within visual line of sight, at or below 500 feet AGL, will ensure a level 

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

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

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

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

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) 

Would Not Adversely Affect Safety. 

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

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

Phantom 3 UAS; (2) the limitations on the proposed flight operations; and

 (3) the location of the proposed flight operations. Accordingly, 7UDYLV
1HXEHU will ensure that it will safely operate the battery powered DJI Phantom 3

UA during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

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

3 UAS; the limitations on the proposed flight operations; and the location of the

 proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3

 UAS provide audible and visual warnings to the PIC at the GCS when the UA

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

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

At the critically low battery level, the DJI Phantom 3 UAS will descend and

land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 

91.151 establish that safety is not adversely affected when the technical characteristics 

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

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted 

relief from Section 91.151 specific to UAS, in circumstances similar, in all material 

respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 

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

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

6. Reasons Why An Exemption From The Requirements Of Sections 

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

Not Adversely Affect Safety. 

In seeking this exemption, 7UDYLV1HXEHU 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 7UDYLV1HXEHU 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 7UDYLV1HXEHU Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Instruction

 Manual). Furthermore, 7UDYLV1HXEHU will document and maintain all 

maintenance records for the DJI Phantom 3 UAS. 

Since the DJI Phantom 3 UAS will be inspected as prescribed by the operating 

documents, 7UDYLV1HXEHU will maintain the equivalent level of safety established by Sections

 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy 

of the DJI Phantom 3 User Manuals are attached hereto as 

Exhibit C.

Likewise, the exemption sought will not adversely affect safety because 7UDYLV

1HXEHU will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

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

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Phantom 3 UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

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

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

the UAS are considered. 

In consideration of 7UDYLV1HXEHU
V proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3

UAS, 7UDYLV1HXEHU submits that safety will not be adversely affected by 
granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted relief specific to 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

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

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

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, 7UDYLV1HXEHU

requests that the FAA prescribe special conditions for the intended operation of the DJI 

Phantom 3 UAS, which contain such safety standards that the Administrator finds

 necessary to establish a level of safety equivalent to that established by 14

 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

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

special conditions will permit safe operation of the UAs for the limited purpose of 

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

compensation or hire. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

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

without airworthiness certification in accordance with any requirements that must be 

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

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R. 

§ 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, since the 

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate 

safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not 

contain adequate or appropriate safety standards for an aircraft, aircraft engine, or 
propeller because of a novel or unusual design feature of the aircraft, aircraft 

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions are issued in accordance with Part 11 of this 

chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.F.R. § 21.16.

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

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

Phantom 2 Vision+ and DJI Inspire 1 UASs, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established 

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

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

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

Rules From Which Travis Neuber Seeks Exemption: 

Travis Neuber 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 Travis Neuber

Seeks: 

This exemption will permit Travis Neuber to commercially operate an 

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

photography over certain areas of the United States. 

 

• Any Additional Information, Views, Or Arguments Available To Support Travis

Neuber'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, Travis Neuber's request for 

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. 

Part 11, as set forth above. 

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

will create a hazard to users of the NAS or the public, or otherwise pose a threat to 
national security; and further, provides the authority for such UAS to operate without 

airworthiness certification. 

As discussed in detail above, Travis Neuber will operate the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs 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, Travis Neuber 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+ and DJI Inspire 1 UASs 

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 Travis Neuber to safely, efficiently, and economically operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, Travis Neuber 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+ and DJI Inspire 1 UASs commercially for the purpose of conducting 

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

Dated: March 28, 2015

 Respectfully submitted, 

 Travis Neuber

 

 _________________________ 

 Travis Neuber

Travis Neuber

N4151 Long Road

Chilton, WI 53014

920-588-0561 

Appendices:

A – DJI Phantom 2 Vision+ Specifications Data Sheet 

B – DJI Inspire 1 Specifications Data Sheet 
APPENDIX – A 

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS 

Travis Neuber only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user 

to set parameters which will not allow flight into controlled airspace. Parameters can also 

be set to limit flight to no higher than a predetermined and set altitude as well as limit 

flight to a predetermined and set distance. In addition, DJI software provides real-time 

altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices) 

1.1 DJI Phantom 2 Vision+ 

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 - 200/s

1.1.1.5 Max Tilt Angel - 35

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 - ±0.03

1.1.2.3 Controllable Range – Pitch: -90 - 0

1.1.2.4 Maximum Angular Speed – Pitch: 90/s

1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 32F - 104F (0C - 40C)

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 - 110/85

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 

APPENDIX – B

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

Travis Neuber only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user 

to set parameters which will not allow flight into controlled airspace. Parameters can also 

be set to limit flight to no higher than a predetermined and set altitude as well as limit 

flight to a predetermined and set distance. In addition, DJI software provides real-time 

altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices) 

2.2	DJI	Inspire	1	

2.2.1	Aircraft	
2.2.1.1	Model	–	T600

2.2.1.2	Weight	(Battery	Included)	–	6lbs	7.5291oz	(2935g)	

2.2.1.3	Hovering	Accuracy	(GPS	Mode)	–	Vertical:	0.5m;	Horizontal:	2.5m	

2.2.1.4	Max	Angular	Velocity	–	Pitch:	3000/s;	Yaw:	1500/s	

2.2.1.5	Max	Tilt	Angle	-	350

2.2.1.6	Max	Ascent	Speed	–	5m/s

2.2.1.7	Max	Descent	Speed	–	4m/s

2.2.1.8	Max	Speed	–	22m/s	(ATTI	mode,	no	wind	–	NOT	RECOMMENDED)	

2.2.1.9	Max	Flight	Altitude	–	4500m

2.2.1.10	Max	Wind	Resistance	–	10m/s

2.2.1.11	Max	Flight	Time	–	Approximately	18	minutes	

2.2.1.12	Motor	Model	–	DJI	3510	

2.2.1.13	Propeller	Model	–	DJI	1345	

2.2.1.14	Operating	Temperature	Range	–	140F	to	1040F	(-100C	to	400C)	

2.2.1.15	Dimensions	–	17	1⁄4”	x	17	3⁄4”	x	12”

2.2.2	Gimbal	

2.2.2.1	Model	–	ZENMUSE	X3	

2.2.2.2	Output	Power	(with	camera)	–	Static:	9W;	In	Motion:	11W	

2.2.2.3	Operating	Current	–	Static:	750mA;	In	Motion:	900mA	

2.2.2.4	Angular	Vibration	Range	-	±0.030	

2.2.2.5	Mounting	–	Detachable	

2.2.2.6	Controllable	Range	–	Pitch:	-900	to	+300;	Pan:	±3200	

2.2.2.7	Mechanical	Range	–	Pitch:	-1250	to	450;	Pan:	±3300	

2.2.2.8	Max	Controllable	Speed	–	Pitch:	1200/s;	Pan:	1800/s	

2.2.3	Camera	

2.2.3.1	Name	–	X3	

2.2.3.2	Model	–	FC350

2.2.3.3	Total	Pixels	–	12.76M

2.2.3.4	Effective	Pixels	–	12.4M

2.2.3.5	Image	Max	Size	–	4000x3000

2.2.3.6	ISO	Range	–	100-3200

2.2.3.7	Field	of	View	-	940

2.2.3.8	CMOS	–	Sony	EXMOR	1/2.3”	

2.2.3.9	HD	Video	Recording	–	UHD(4K):	4096x2160p24/25,	

3840x2160p24/25/30;	FHD:	1920x1080p24/25/30/48/50/60;	HD:	

1280x720p24/25/30/48/50/60

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

2.2.4	Transmitter	

2.2.4.1	Name	–	C1

2.2.4.2	Operating	Frequency	–	5.728-5.850GHz;	2.400-2.483GHz	

2.2.4.3	Communicating	Distance	(unobstructed)	–	2000m

2.2.4.4	Output	Power	–	9W

2.2.4.5	Operating	Temperature	Range	-	140F	to	1040F	(-100C	to	400C)	

2.2.4.6	Battery	–	600mAh	LiPo	2S