UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

LightSpeed Paperless Products, Inc,

dba SCOTT PHOTO WORKS.

Federal Employer ID #: 20-2925866

DUNS #: 605702609

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 PROFESSIONAL

UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on

July 21, 2015

Lightspeed Paperless Products, INC, 

dba SCOTT PHOTO WORKS

Scott Schaeffler, President 

217 Beachview Dr

Fort Walton Beach, FL 32547

850-803-0885

scott@scottphotoworks.com
 2

TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS .....................................................................................3

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

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

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

BASIS FOR PETITION ............................................................................................................5

A. NAME AND ADDRESS OF PETITIONER....................................................................6

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH, SCOTT PHOTO WORKS

SEEKS EXEMPTION ...............................................................................................7

C. THE EXTENT OF RELIEF SCOTT PHOTO WORKS SEEKS AND THE REASON

SCOTT PHOTO WORKS SEEKS THE RELIEF ............................................................10

D. THE REASONS WHY GRANTING SCOTT PHOTO WORKS’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ...........................................................................................13

E. THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY....................................................................................................................15

F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..............25

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT SCOTT PHOTO WORKS' REQUEST..................................................................25

CONCLUSION........................................................................................................................26
 3

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)

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
 4

SUMMARY

Lightspeed Paperless Products, INC, dba Scott Photo Works (hereafter SCOTT 

PHOTO WORKS), 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 SCOTT 

PHOTO WORKS to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of real estate properties, aerial 

surveying, and other special events, over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Scott Schaeffler and I am the owner and president of Lightspeed 

Paperless Products, INC, dba SCOTT PHOTO WORKS. I am also a commercial pilot (both 

airplane and rotorcraft). My company provides photography services to the real estate 

market in the Florida Panhandle, in addition to aerial photography services for a local 

aviation company. We also provide similar services to various special events in the same 

area. The objective of SCOTT PHOTO WORKS’ aerial video and photography operations 

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

specifically targeting:

• Real Estate Videography and Photography

• Special Event Videography and Photography

• Land survey & appraisals

• Construction sites before & after
 5

BACKGROUND

Unmanned Aircraft System: DJI Phantom 3 Professional UAS

SCOTT PHOTO WORKS seeks an exemption to operate DJI systems for compensation 

or hire within the NAS. The DJI Phantom 3 Professional 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 Professional has a maximum 

gross weight of approximately 2 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. It 

is equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors.

The DJI Phantom 3 Professional that will be operated by SCOTT PHOTO WORKS 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, SCOTT PHOTO WORKS, 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 Professional 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, SCOTT PHOTO WORKS operation of DJI Phantom

3 Professional 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, SCOTT PHOTO WORKS 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.

SCOTT PHOTO WORKS submits that the requested relief is proper since an 

equivalent level of safety will be ensured. SCOTT PHOTO WORKS 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 Professional Instruction Manual). 

Furthermore, SCOTT PHOTO WORKS will document and maintain all maintenance records 

for the DJI Phantom 3 Professional UAS.
 6

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

privileges and limitations: Pilot in command, is requested by SCOTT PHOTO WORKS to 

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

certificate, as well as an airman medical certificate or valid U.S. drivers license, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

SCOTT PHOTO WORKS seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 Professional UAS does not require an 

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

such, SCOTT PHOTO WORKS submits that they will ensure that the DJI Phantom 3 

Professional UAS is in an airworthy condition, prior to every flight, by determining that the 

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

Phantom 3 Professional Instruction Manual), and that the aircraft is in a condition for safe 

flight.

SCOTT PHOTO WORKS also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS

will not have a typical barometric altimeter onboard. However, altitude information of the 

DJI Phantom 3 Professional UAS 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 SCOTT PHOTO WORKS’s operation of the DJI Phantom 3 Professional UAS within 

visual line of sight, at or below 500 feet AGL,

will ensure a level of safety equivalent to Section 91.121.

Additionally, SCOTT PHOTO WORKS seeks an exemption from the requirements of 

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

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

Professional UAS 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, SCOTT PHOTO WORKS 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: 

Scott Schaeffler

Scott Photo Works

217 Beachview Dr

Fort Walton Beach, FL 32547

Tel: (850) 803-0885

Email: scott@scottphotoworks.com
 7

B. The Specific Sections Of 14 C.F.R. From Which SCOTT PHOTO WORKS seeks

Exemption.

1. SCOTT PHOTO WORKS Seeks Exemption From The Requirements Of 

Section Part 21, Subpart H

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1)

2. SCOTT PHOTO WORKS 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.

3. SCOTT PHOTO WORKS 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.

4. SCOTT PHOTO WORKS 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.
 8

5. SCOTT PHOTO WORKS 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.

6. SCOTT PHOTO WORKS 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[.]

7. SCOTT PHOTO WORKS 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[.]

8. SCOTT PHOTO WORKS 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.

9. SCOTT PHOTO WORKS 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:
 9

(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.
 10

C. The Extent Of Relief SCOTT PHOTO WORKS Seeks And The Reason SCOTT 

PHOTO WORKS Seeks The Relief.

1. SCOTT PHOTO WORKS Seeks Exemption From The Requirements Of 

Section Part 21, Subpart H

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

SCOTT PHOTO WORKS, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act.

The Federal Aviation Act (49 U.S.C.§ 44701(f)) and Section 333 of the Reform Act 

both authorize the FAA to exempt aircraft from the requirement for an airworthiness 

certificate, upon consideration of the size, weight, speed, operational capability, and 

proximity to airports and populated areas of the particular UAS.

In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least as safe, or safer, than a conventional rotorcraft operating with 

an airworthiness certificate without the restrictions and conditions of the proposed 

UAS operations.

2. Extent Of Relief SCOTT PHOTO WORKS Seeks And The Reason 

SCOTT PHOTO WORKS 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, SCOTT PHOTO WORKS submits that an equivalent 

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

Phantom 3 Professional UAS unless that PIC has met certain flight-hour and 

currency requirements, 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, SCOTT PHOTO WORKS submits that all flights of the DJI Phantom 3 

Professional UAS, conducted by the PIC pursuant to the grant of this Petition: (1) 

will be incidental to SCOTT PHOTO WORKS' business; and (2) will not carry 

passengers or property for compensation or hire.
 11

3. Extent Of Relief SCOTT PHOTO WORKS Seeks And The Reason 

SCOTT PHOTO WORKS 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 SCOTT PHOTO WORKS to determine that the DJI Phantom 3 

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

UAS is in compliance with the operating documents (i.e., the SCOTT PHOTO 

WORKS Aerial

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

Instruction Manual).

SCOTT PHOTO WORKS seeks the requested relief because the DJI Phantom 3 

Professional UAS does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, SCOTT PHOTO WORKS will ensure that the 

DJI Phantom 3 Professional UAS is in airworthy condition based upon its compliance 

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 

Professional 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.

4. Extent Of Relief SCOTT PHOTO WORKS Seeks And The Reason 

SCOTT PHOTO WORKS 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 Professional UAS, which utilize a barometric 

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

downlink altitude information from the UAS 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), 

SCOTT PHOTO WORKS seeks the requested relief because the DJI Phantom 3 

Professional UAS’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 Professional UAS 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.

5. Extent Of Relief SCOTT PHOTO WORKS Seeks And The Reason SCOTT 

PHOTO WORKS 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 Professional UAS 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 
 12

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

minutes. SCOTT PHOTO WORKS seeks the requested relief because without an 

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

Phantom 3 Professional UAS will severely constrain the practicality of any aerial 

video or still photo flight operations that SCOTT PHOTO WORKS proposes to 

conduct pursuant to this Petition.

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

Professional UAS, the DJI Phantom 3 Professional operating documents, and SCOTT 

PHOTO WORKS' proposed operating limitations, ensure that SCOTT PHOTO WORKS 

will safely operate the battery powered DJI Phantom 3 Professional UAS during 

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

(VFR), 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.

6. Extent Of Relief SCOTT PHOTO WORKS Seeks And The Reason 

SCOTT PHOTO WORKS 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, SCOTT PHOTO WORKS requests 

relief from these Sections because the DJI Phantom 3 Professional UAS does not 

require airworthiness certificates. As set forth more fully below, the DJI Phantom 3 

Professional UAS meets the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, SCOTT PHOTO WORKS 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 SCOTT PHOTO WORKS Aerial Operations Manual, Monthly 

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

SCOTT PHOTO WORKS will document and maintain all maintenance records for the 

DJI Phantom 3 Professional UAS.
 13

D. The Reasons Why Granting SCOTT PHOTO WORKS' 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 SCOTT PHOTO 

WORKS to safely, efficiently, and economically perform aerial video and photography of, real 

estate, special events, agriculture, land survey & appraisal, and construction sites over certain 

areas of the United States.

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

NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of SCOTT PHOTO WORKS’s proposed operation of the DJI Phantom 3 Professional UAS

will be realized without implicating any privacy issues.

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

The DJI Phantom 3 Professional UAS 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 amount of manned aircraft needed to perform aerial 

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

Professional UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Professional 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 Professional

UAS produces no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The DJI Phantom 3 Professional UAS, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as 

the UAS is propelled by battery powered electric motors, rather than an internal 

combustion engine.

By using the DJI Phantom 3 Professional 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 
 14

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

onboard the aircraft, the DJI Phantom 3 Professional UAS (weighing approximately 2 

pounds 13 ounces including battery with a length & width of 16 inches), has less 

physical

potential for collateral damage to life and property on the ground, and in the air, 

compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 

34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2

Vision+ and DJI Inspire 1 UAS Will Benefit The Economy.

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

UAS is also an economical alternative to using manned aircraft to conduct similar

aerial operations. As such, operation of the DJI Phantom 3 Professional

UAS will allow United States based companies, like SCOTT PHOTO WORKS, 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 3 Professional 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 Professional UAS, companies such as SCOTT 

PHOTO WORKS, can remain competitive and profitable, and therefore, provide 

greater job stability to employees and contractors, which will ultimately contribute to 

growth of the U.S. economy. Improved financial performance of U.S. companies, 

through commercial use of the DJI Phantom 3 Professional 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, SCOTT PHOTO WORKS’ proposed operation of the DJI Phantom 3 

Professional UAS will not implicate any privacy issues. Specifically, the DJI 

Phantom 3 Professional UAS will be operated only in compliance with operating

documents (i.e., the SCOTT PHOTO WORKS Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 Professional 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.
 15

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 SCOTT PHOTO WORKS Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional UAS 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, SCOTT PHOTO WORKS’ operation of the 

DJI Phantom 3 Professional 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, SCOTT PHOTO WORKS submits that the DJI Phantom 3 

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

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional

UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.
 16

a. The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate 

Its Safe Characteristics.

The DJI Phantom 3 Professional UAS does not create a hazard to users of

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

considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 3 Professional

UAS. The technical specifications of the DJI Phantom 3 Professional

UAS are set forth by the DJI Phantom 3 Professional Specifications 

Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight 

And Navigation Modes Enable The UAS To Remain Within A 

Defined Operational Area.

The DJI Phantom 3 Professional UAS 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 Professional UAS are 

provided at pages 11 and 26 of the DJI Phantom 3 Professional User

Manual, attached hereto as Exhibit B.

iii. The DJI Phantom 3 Professional UAS Is 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 Professional UAS

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

seconds, the DJI Phantom 3 Professional UAS does not reacquire 

control link data from the GCS, the UAS 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 for the DJI 

Phantom 3 Professional UAS are set forth on page 14 of the DJI Phantom 

3 Professional User Manual attached hereto as Exhibit B.

iv. The DJI Phantom 3 Professional GCS And Its Operation.

A complete description of the operation and specifications of the DJI 

Phantom 3 Professional GCS and flight control software is provided at 

pages 22 through 29 of the DJI Phantom 3 Professional User Manual 

attached hereto as Exhibits B.

b. Flight Operations Of DJI Phantom 3 Professional UAS Is Limited To 

The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer.

SCOTT PHOTO WORKS 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 Professional UAS. Additionally, a safety observer will assist 

all pilots during flight time.
 17

c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted

Pursuant To Specific Operating Limitations.

In seeking this exemption, SCOTT PHOTO WORKS proposes to 

commercially operate DJI Phantom 3 Professional 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 UAS

weighing less than 55 pounds maximum gross weight: DJI Phantom 3 

Professional Unmanned Aircraft System. Proposed operations of any other 

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

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

operations for the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 31 knots.

4. The UA must be operated at an altitude of no more than 400 feet above 

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

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

altitudes reported to ATC must be in feet AGL.

5. The 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. 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.

7. 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.

8. 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 
 18

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.

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

condition for safe flight. 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. 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. The PIC will make an 

entry in the aircraft record of the corrective action taken against discrepancies 

discovered between inspections.

10. 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 functional test flight 

must be conducted in such

a manner so as to not pose an undue hazard to persons and property.

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

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

12. Each UAS operated under this exemption must comply with all manufacturer 

Safety

Bulletins.

13. The PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, 

the District of Columbia, Puerto Rico, a territory, a possession, or the 

Federal government. The PIC must also meet the flight review requirements 

specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or 

her pilot certificate.

14. 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 
 19

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.

15. 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.

16. The UAS may not operate within 5 nautical miles of an airport reference 

point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or 

for airports not

denoted with an ARP, the center of the airport symbol as denoted on the current

FAA-published aeronautical chart, unless a letter of agreement with that 

airport’s

management is obtained or otherwise permitted by a COA issued to the 

exemption

holder. The letter of agreement with the airport management must be made 

available

to the Administrator or any law enforcement official upon request. The 

17. 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.

18. 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.

19. The PIC must abort the flight in the event of unpredicted obstacles or 

emergencies.

20. 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.

21. 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. All operations shall be conducted in 

accordance with the ATO-issued COA.

22. 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 
 20

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

Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of 

the UAS and any documents required under 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.

24. The UA must remain clear and yield the right of way to all 

manned aviation operations and activities at all times.

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

vehicle.

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

nonparticipating persons, vessels, vehicles, and structures unless (The PIC, 

VO, operator trainees or essential persons are not considered nonparticipating 

persons):

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

for operating closer to those objects 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).

27. 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.

28. 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.
 21

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And

(b) Would Not Adversely Affect Safety.

SCOTT PHOTO WORKS 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 3 Professional 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 Professional UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering SCOTT PHOTO WORKS’s proposed area of operations, and the 

operating limitations set forth-above; the parallel nature of FAA-certified 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 Professional UAS, SCOTT PHOTO WORKS submits that the additional 

manned airmanship experience of a commercially certificated pilot would not correlate 

to the airmanship skills necessary for SCOTT PHOTO WORKS’ 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).

SCOTT PHOTO WORKS will not allow any PIC to operate the DJI Phantom 3 

Professional UAS unless that PIC has demonstrated that the PIC is able to safely 

operate the DJI Phantom 3 Professional 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 the PIC must have accumulated and logged, in a manner 

consistent with 14 CFR 61.51(b), a minimum of 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 (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).

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, SCOTT PHOTO WORKS will ensure that 

the DJI Phantom 3 Professional UAS is in an airworthy condition based upon the 

UAS'
 22

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 Professional UAS 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 SCOTT PHOTO WORKS’ 

operation of the DJI Phantom 3 Professional UAS within visual line of sight, at or 

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. The 

altitude information will be generated by GPS equipment installed onboard the 

aircraft. Prior to each flight, a zero altitude initiation point is automatically established 

by the UAS 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 Professional UAS; (2) the limitations on the 

proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, SCOTT PHOTO WORKS will ensure that it will safely operate the 

battery powered DJI Phantom 3 Professional UAS 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 Professional 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 Professional UAS provides audible and visual warnings to the PIC 

at the GCS when the UAS experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately
 23

10% remaining battery power. At the critically low battery level, the DJI Phantom 3 

Professional 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, SCOTT PHOTO WORKS 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 SCOTT PHOTO WORKS will use trained 

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

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

documents (i.e., the SCOTT PHOTO WORKS Aerial Operations Manual, Monthly 

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

SCOTT PHOTO WORKS will document and maintain all maintenance records for 

the DJI Phantom 3 Professional UAS.

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

the operating documents, SCOTT PHOTO WORKS 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 Professional User Manual is attached hereto as Exhibit B; a copy of 

the DJI Phantom 3 Professional UAS Maintenance LOG is attached hereto as Exhibit 

C.

Likewise, the exemption sought will not adversely affect safety because 

SCOTT PHOTO WORKS 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 Professional 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
 24

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 SCOTT PHOTO WORKS’ proposed operating limitations, 

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

UAS, SCOTT PHOTO WORKS 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, SCOTT PHOTO 

WORKS requests that the FAA prescribe special conditions for the intended operation 

of the DJI Phantom 3 Professional 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 3 Professional UAS, since the 

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

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

21.16, entitled Special Conditions, states the following:

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

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or 

propeller, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the FAA 

finds necessary to establish a level of safety equivalent to that established in the 

regulations. See 14 C.F.R. § 21.16.

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

may prescribe special conditions for SCOTT PHOTO WORKS' intended operation of 

the DJI Phantom 3 Professional UAS, which contain such safety standards that the
 25

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

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

91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

F. A Summary That Can Be Published In The Federal Register: 

The Rules From Which SCOTT PHOTO WORKS Seeks Exemption:

SCOTT PHOTO WORKS 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 SCOTT 

PHOTO WORKS Seeks:

This exemption will permit SCOTT PHOTO WORKS to commercially operate an 

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

photography over certain areas of the United States.

G. Any Additional Information, Views, Or Arguments Available To Support SCOTT 

PHOTO WORKS’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, SCOTT PHOTO WORKS’ 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, SCOTT PHOTO WORKS will operate the DJI 

Phantom 3 Professional UAS safely in the NAS, without creating a hazard to users of the 

NAS, or the public, or otherwise pose a threat to national security.
Conclusion 

As set forth herein, SCOTT PHOTO WORKS seeks an exemption pursuant to 14 C.F.R. 

8 1 1.6 1 and Section 333 of the FAA Modernization and Reform Act of 20 12 (FMRA), 

which will permit safe operation of the DJI Phantom 3 ProfessionalUAS commercially, 

without an airworthiness certificate, for the limited purpose of conducting aerial video and 

photography over certain areas of the United States. By this Petition, the FAA 

Administrator will be hlfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 201 2, while also advancing the interests of the public, by allowing SCOTT 

PHOTO WORKS to safely, efficiently, and economically operate the DJI Phantom 3 

Professional UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, SCOTT PHOTO WORKS respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements of 

14 C.F.R Sections 61.1 13(a) & (b), 91.7(a), 91.121,91.151(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (a)(2), and 91.41 7(a) & (b), and permit SCOTT PHOTO WORKS to operate 

the DJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial 

video and photography over certain areas of the United States. 

Dated: July 2 1,20 15 

Respec,tfully submitted, 

S'cott Schaeffler, President 

Lightspeed Paperless Products, Inc, dba SCOTT PHOTO WORKS 

2 17 Beachview Dr 

Fort Walton Beach, FL 32547 

Tel: 850-803-0885 

Email: scott@scottphotoworks.com 

Appendices: 

A -- DJI Phantom 3 Professional Specifications 

B -- DJI Phantom 3 Professional User Manual 

C -- DJI Phantom 3 Professional Maintenance Log 
 27

APPENDIX – A

DJI PHANTOM 3 PROFESSIONAL TECHNICAL SPECIFICATIONS

SCOTT PHOTO WORKS only utilizes safe and reliable UAS. DJI is an industry leader in small 

UAS production. DJI UAS 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)

Aircraft

Weight (Including Battery And Propellers) 1280 g

Diagonal Size (Including Propellers) 590 mm

Max Ascent Speed 5 m/s

Max Descent Speed 3 m/s

Hover Accuracy

Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level 6000 m

Operating Temperature 0°C to 40°C

GPS Mode GPS/GLONASS

Gimbal

Controllable Range Pitch -90° to +30°

Stabilization 3-axis (pitch, roll, yaw)

Remote Controller

Operating Frequency 2.400 GHz-2.483 GHz

Max Distance 2000m (outdoors and unobstructed)

Video Output Port USB

Operating Temperature 0°C- 40°C

Battery 6000 mAh LiPo 2S

Receiver Sensitivity (1%PER) -101 dBm ±2 dBm

Transmitter Power (EIRP)

FCC: 20 dBm

CE: 16 dBm

Working Voltage 1.2 A @7.4 V

Battery Charger

Voltage 17.4 V

Rated Power 100 W

Phantom 3 Advanced

Intelligent Flight Battery

Capacity 4480 mAh

Voltage 15.2 V
 28

Battery Type LiPo 4S

Energy 68 Wh

Net Weight 365 g

Max Flight Time Approximately 23 minutes

Operating Temperature -10°C to 40°C

Max Charging Power 100 W
 29

APPENDIX – B

DJI PHANTOM 3 PROFESSIONAL

Manufacturer’s User Manual

User manual can be found at:

http://www.dji.com/product/phantom-3/download
 30

APPENDIX - C

MONTHLY MAINTENANCE LOG

month: year: _________

UAS:

Date Issue

Discovered

Date Issue

Addressed

Issue Description &

Maintenance conducted

Maintenance Performed By: 

(Print & Sign)

Software

Updates

Airframe

Engines

Propellers

Camera

Gimbal

Landing Gear

Vibration

Dampening

Other: