UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

DAVID HUNT dba IMAGE EFFECTS

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 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 

AND INSPIRE 1 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on June 22, 2015

DAVID HUNT

3516 Sunset Ave Caldwell Idaho 83605

619 806 5126

david@imageeffects.com
SUMMARY

DAVID HUNT seeks exemption from the requirements of 14 C.F.R §§ 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 DAVID HUNT to operate an Unmanned Aircraft 

System (UAS) for the commercial purpose of conducting aerial video and photography of 

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

DAVID HUNT will provide his clients with expertise and knowledge in advanced technologies 

and solutions to increase efficiency, productivity and effectiveness. DAVID HUNT has nearly 

25 hours of recreational/hobby flying experience in aspects of aerial video and photography. The 

objective of DAVID HUNT and his aerial operations is to safely provide high quality imaging 

for a variety of commercial, public, and residential uses, specifically targeting: 

• Agriculture 

• General aerial still photos 

• Wildlife population surveys 

• Real Estate marketing 

• Motion Picture Filming 

• Aerial inspections of public and private structures

• Search and Rescue operations 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 & Inspire 1 UASs 

DAVID HUNT seeks an exemption to operate DJI systems for compensation or hire within the 

NAS. The DJI Phantom 3 is a 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 while having a length of 16 

inches, width of 16 inches, height of 8 inches, and a maximum speed of approximately 30 knots

and the Inspire 1 is approximately 15 pounds 15 x 15 x 20 inches, and a maximum speed of 

approximately 30 knots. Both the DJI Phantom 3 and Inspire 1 UA is equipped with four main 

rotors, driven by Lithium Polymer battery powered electric motors.

Both the UA that will be operated by DAVID HUNT 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, DAVID HUNT, 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 & Inspire 1UA in the National Airspace System 

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 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, DAVID HUNT’s operation of the DJI Phantom 2 & Inspire 

1 UA 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, DAVID HUNT 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. DAVID HUNT submits that the requested 

relief is proper since an equivalent level of safety will be ensured. DAVID HUNT 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 DJI Instruction Manual). Furthermore, 

DAVID HUNT will document and maintain all maintenance records for the DJI Phantom 3 & 

Inspire 1UA. 

Privileges and Limitations: Pilot in Command, is requested by DAVID HUNT to the extent 

necessary to allow a Pilot in Command (PIC) who has demonstrated, by meeting minimum 20 

flight-hour requirements and that the PIC is able to safely operate the said DJI UA in a manner 

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

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

DAVID HUNT seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, because 

the DJI Phantom 3 & Inspire 1 UA does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, DAVID HUNT submits that he will ensure that the 

DJI Phantom 3& Inspire 1 UA is in an airworthy condition, prior to every flight, by determining 

that the UA is in compliance with the operating documents (i.e., Monthly Maintenance Log, and 

DJI Instruction Manual), and that the aircraft is in a condition for safe flight. 

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

Altimeter Settings, as the DJI Phantom 3 UA & Inspire 1will not have a typical barometric 

altimeter onboard. However, altitude information of these said 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 altitude 

information, combined with DAVID HUNT’s operation of the DJI Phantom 3 & Inspire 1 UA 

within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. 
Additionally, DAVID HUNT seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel Requirements for Flight in VFR Conditions. DAVID HUNT submits that safety will 

not be affected by operation of the DJI Phantom 3 & Inspire 1 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 17.5 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, DAVID HUNT provides the following information in 

support of his petition for exemption

Name And Address Of The Petitioner. 

DAVID HUNT

3516 Sunset Ave Caldwell Idaho 83605

619 806 5126

david@imageeffects.com.com
The Specific Sections Of 14 C.F.R. From Which DAVID HUNT Seeks Exemption. 

1. DAVID HUNT 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. 

2. DAVID HUNT 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. 

3. DAVID HUNT 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. 

4. DAVID HUNT 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[.] 

5. DAVID HUNT 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. 

6. DAVID HUNT 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. 

7. DAVID HUNT 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. 

The Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT Seeks The

Relief. 

1. Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT 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 DAVID HUNT to determine that the DJI Phantom 3 & Inspire 1 UA is in 

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

operating documents (i.e., Monthly Maintenance Log and DJI Instruction Manual). 

DAVID HUNT seeks the requested relief because the DJI Phantom 3 & Inspire 1 UA does not 

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

DAVID HUNT will ensure that the DJI Phantom 3 & Inspire 1 UA is in airworthy condition 

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

DJI Instruction Manual) prior to every flight, and further, determine that the aircraft is in 

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

2. Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT 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 UA, which utilizes 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), DAVID HUNT seeks the requested relief because the DJI Phantom 3 
& Inspire 1 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 & Inspire 1 UA 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 UA on the heads-up display of the GCS. 

3. Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT 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 & Inspire 

1 UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 17.5 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 4.5 minutes. DAVID HUNT seeks the 

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

of the battery powered DJI Phantom 3 & Inspire 1 UA will severely constrain the practicality of 

any aerial video or still photo flight operations that DAVID HUNT proposes to conduct pursuant 

to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 & Inspire 1 

UA, the DJI Phantom 3 & Inspire 1 and DAVID HUNT’s proposed operating limitations, ensure 

that DAVID HUNT will safely operate the battery powered DJI Phantom 3 & Inspire 1 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 17.5 minutes to the first point of 

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

4. Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT 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, DAVID HUNT requests relief from these Sections 

because the DJI Phantom 3 & Inspire 1 UA does not require airworthiness certificates. As set 

forth more fully below, the DJI UAS meets the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, DAVID HUNT 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 Monthly 

Maintenance Log, and DJI Instruction Manual). Furthermore, DAVID HUNT will document and 

maintain all maintenance records for the DJI Phantom 3 & Inspire 1 UAS. 

The Reasons Why Granting DAVID HUNT’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 DAVID HUNT 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 & Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and provide 
significant benefits to the economy. Notably, the benefits of DAVID HUNT’s proposed 

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

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

The DJI Phantom 3 & Inspire 1 UA is battery powered and serves as a safe, efficient, and 

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. An 

exemption allowing the use of a DJI UAS would reduce the number of manned aircraft in the 

NAS and 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 UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft 

conducting aerial video and photography missions would result in fewer aircraft that must be 

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of 

flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 & Inspire 1 UAS, instead of manned 

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

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

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

environmentally conscious alternative to the cabin class, six cylinder internal combustion engine 

aircraft that are typically utilized for aerial video and photography, while burning approximately 

20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 & Inspire 1 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 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 UA (weighing approximately 3 & 15 pounds 

and with a length of 16 & 20 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 UAS Will Benefit 

The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 & Inspire 1 UA is also an economical 

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

the DJI Phantom 3 & Inspire 1 UAS will allow United States based companies, like DAVID 

HUNT dba Image Effects, to remain competitive and contribute to growth of the U.S. economy. 

Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 

(EPA) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies 

must adopt new and alternative technology in order to remain competitive. Operating the battery 

powered DJI UAS is one such technology that not only allows companies greater operational 
flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 3 & Inspire 1 UAS, companies such as DAVID HUNT dba 

Image Effects, can remain competitive and profitable, and therefore, provide greater job stability 

to employees and contractors, which will ultimately contribute to growth of the U.S. economy. 

Improved financial performance of U.S. companies, through commercial use of the DJI UAS, 

provides a stable workforce that increases consumer spending; improves local, state, and federal 

tax revenues; and allows companies to invest in research and development in order to remain 

competitive both in the United States and abroad. 

4. There Are No Privacy Issues. 

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

decades, DAVID HUNT’s proposed operation of the DJI UAS will not implicate any privacy 

issues. Specifically, the DJI UAS will be operated only in compliance with operating documents 

(i.e., The Monthly Maintenance Log, and DJI Instruction Manual) 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. 

Seeks And The Reason DAVID HUNT 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 DAVID HUNT to determine that the DJI Phantom 3 & Inspire 1 UA is in 

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

operating documents (i.e., Monthly Maintenance Log and DJI Instruction Manual). 

DAVID HUNT seeks the requested relief because the DJI UA does not require an airworthiness 

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

ensure that the DJI Phantom 3 & Inspire 1 UA is in airworthy condition based upon its 

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

Manual) prior to every flight, and further, determine that the aircraft is in condition for safe 

flight, as stated in the conditions and limitations below. 

1. Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT 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 3 & Inspire 1 UA, which utilizes 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), DAVID HUNT seeks the requested relief because the DJI 

Phantom 3 & Inspire 1 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 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 UA on the heads-up display of the GCS. 

2. Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT 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 UA during daylight 

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

duration of 17.5 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 4.5 minutes. DAVID HUNT seeks the requested relief because 

without an exemption from Section 91.151(b), the flight time duration of the battery powered 

DJI Phantom 3 & Inspire 1 UA will severely constrain the practicality of any aerial video or still 

photo flight operations that DAVID HUNT proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 & Inspire 1 

UA, the DJI Phantom 3, Inspire 1 and DAVID HUNT’s proposed operating limitations, ensure 

that DAVID HUNT will safely operate the battery powered DJI Phantom 3 & Inspire 1 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 17.5 minutes to the first point of 

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

3. Extent Of Relief DAVID HUNT Seeks And The Reason DAVID HUNT 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, DAVID HUNT requests relief from these Sections 

because the DJI Phantom 3 & Inspire 1 UA does not require airworthiness certificates. As set 

forth more fully below, the DJI UAS meets the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, DAVID HUNT 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 Monthly 

Maintenance Log, and DJI Instruction Manual). Furthermore, DAVID HUNT will document and 

maintain all maintenance records for the DJI Phantom 3 & Inspire 1 UAS. 
The Reasons Why Granting DAVID HUNT’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 DAVID HUNT to 

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

real estate, Farms and landscape over certain areas of the United States. Additionally, use of the 

DJI Phantom 3 & Inspire 1 UAS will decrease congestion of the NAS, reduce pollution, and 

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

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

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

The DJI UA is battery powered and serves as a safe, efficient, and economical alternative to the 

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

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

Phantom 3 & Inspire 1 UAS would reduce the number of manned aircraft in the NAS and 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 & 

Inspire 1 UA does 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 & 

Inspire 1 UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 & Inspire 1 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 & Inspire 1 UAS produce no air pollution, and is 

the most viable environmentally conscious alternative to the cabin class, six cylinder internal 

combustion engine aircraft that are typically utilized for aerial video and photography, while 

burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 3 & 

Inspire 1 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 & Inspire 1 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 & Inspire 1 UA (weighing approximately 3 & 15 pounds at its 

maximum gross weight with a length of 16 & 20 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 UAS Will Benefit 

The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 & Inspire 1 UA is also an economical 

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

the DJI UAS will allow United States based companies, like DAVID HUNT dba Image Effects

to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising 

cost of aviation fuel and the Environmental Protection Agency (EPA) regulatory actions phasing 

out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered DJI UAS is one such 

technology that not only allows companies greater operational flexibility compared to manned 

aircraft, but provides such flexibility without the high operational cost of a traditional manned 

aircraft. By operating the DJI UAS, companies such as DAVID HUNT dba Image Effects, can 

remain competitive and profitable, and therefore, provide greater job stability to employees and 

contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial 

performance of U.S. companies, through commercial use of the DJI UAS, provides a stable 

workforce that increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain competitive both in 

the United States and abroad. 

4. There Are No Privacy Issues. 

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

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

Specifically, the DJI Phantom 3 & Inspire 1 UAS will be operated only in compliance with 

operating documents (i.e., The Monthly Maintenance Log, and DJI Instruction Manual) 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. 

Rule From Which DAVID HUNT Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 & Inspire 1 UA 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, DAVID HUNT’s operation of the DJI UAS meets the 

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

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

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

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

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

following, in part: 

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

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

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

system before completion of the plan and rulemaking required by section 332 of this Act or the 

guidance required by section 334 of this Act. 
(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

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

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

speed, operational capability, proximity to airports and 

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

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

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

under section 44704 of title 49, United States Code, is required for the operation of unmanned 

aircraft systems identified under paragraph (1). 

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

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

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

airspace system. 

In seeking this exemption, DAVID HUNT submits that the DJI Phantom 3 & Inspire 1 UAS can 

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

characteristics of the DJI Phantom 3 & Inspire 1 UA; (b) the pilot certification requirement; and 

(c) the specific operating limitations. 

A complete description of the operation and specifications of the DJI Phantom 3 & Inspire 1

GCS and flight control software is provided at DJI WEB SITE

1. 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 & Inspire 1 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 DAVID HUNT’s operation of the DJI Phantom 3 & Inspire 1 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). 
2. 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 & Inspire 1

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

flight operations. Accordingly, DAVID HUNT will ensure that it will safely operate the batterypowered DJI UA during daylight hours in VFR conditions, with enough battery power to fly for 

a total duration of 17.5 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 UAS, the limitations on 

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

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

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

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

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

battery level, the DJI Phantom 3 & Inspire 1 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). 

3. 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, DAVID HUNT 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 DAVID HUNT

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 Monthly Maintenance Log and DJI Instruction Manual). Furthermore, DAVID HUNT

will document and maintain all maintenance records for the DJI UAS. Since the DJI UAS will be 

inspected as prescribed by the operating documents, DAVID HUNT 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 User Manual is attached hereto as Appendix A; a copy of the DJI Phantom 3 & Inspire 1

UAS Maintenance LOG is attached hereto as Appendix B. 

Likewise, the exemption sought will not adversely affect safety because DAVID HUNT 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 & 

Inspire 1 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 DAVID HUNT’s proposed operating limitations, the operating documents, 

and the technical aspects of the DJI Phantom 3 & Inspire 1 UAS, DAVID HUNT 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). 

CONCLUSION 

As set forth herein, DAVID HUNT 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 3 & Inspire 1 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 DAVID HUNT dba Image Effects to safely, 

efficiently, and economically operate the DJI Phantom 3 & Inspire 1 UAS commercially within 

the NAS. 

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

Modernization and Reform Act of 2012, Section 333, DAVID HUNT respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R 

Sections 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 DAVID HUNT to operate the DJI Phantom 3 & Inspire 1 UAS 

commercially for the purpose of conducting aerial video and photography over certain areas of 

the United States. 

Dated: June 22nd, 2015 

Respectfully, 

David Hunt