UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

CONOR LUKAS CROUCH

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 DJI Phantom 3 

UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on December 26, 2015

CONOR LUKAS CROUCH

715 MOSS CREEK DR.

CAYCE, SC 29033

CONORCROUCH@AOL.COM
TABLE OF CONTENTS 

Page 

GLOSSARY OF 

ABBREVIATIONS............................................................

.......................3 

SUMMARY..................................................................

........................................................4 

INTRODUCTION AND INTERESTS OF 

PETITIONER....................................................4 

BACKGROUND...............................................................

.....................................................4 

BASIS FOR 

PETITION.................................................................

........................................5 

NAME AND ADDRESS OF 

PETITIONER.............................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CONOR LUKAS CROUCH

SEEKS 

EXEMPTION................................................................

.8 

THE EXTENT OF RELIEF CONOR LUKAS CROUCH SEEKS AND THE 

REASON CONOR LUKAS CROUCH SEEKS THE RELIEF...................11 

THE REASONS WHY GRANTING CONOR LUKAS CROUCH’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST 

.........................................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT 

SAFETY...................................................................

.......19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......30
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT CONOR LUKAS CROUCH’S REQUEST.........32

CONCLUSION...............................................................

................................................32

APPENDICES...................33
GLOSSARY OF ABBREVIATIONS 

AGL Above Ground Level 

AOI Area of Interest 

ATC Air Traffic Control 

ATO Air Traffic Organization 

AV Aerial Vehicle 

CFR Code of Federal Regulations 

COA Certificate of Authorization 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System 

LOL Loss of Link 

NAS National Airspace System 

NOTAM Notice to Airman 

PIC Pilot In Command 

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

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 
SUMMARY 

CONOR LUKAS CROUCH 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 CONOR LUKAS CROUCH 

to operate an 

Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and 

photography of real estate, landmarks, for movies or television, for 

historical reference, search and rescue, surveying, architecture, roof 

and pipeline inspection, live events, construction sites, natural 

resource management, insurance companies, training on operation of UAS, 

golf courses and virtual tours.

INTRODUCTION AND INTERESTS OF THE PETITIONER 

CONOR LUKAS CROUCH provides his clients with photography and videography 

of 

properties for the purpose of advertising. CONOR LUKAS CROUCH has many 

hours flying experience. He has over 3 years of video production and 

photography experience. The objective of CONOR LUKAS CROUCH and his 

aerial operations is to provide high 

quality imaging for a variety of commercial, public, and residential 

uses, specifically targeting: 

• Real Estate

• Farming 

• Search and Rescue

• Surveying

• Architecture

• Movies 

• Television

• Roof and Pipeline Inspection

• Live Events

• Construction

• Natural Resource Management

• Insurance Companies

• Golf Courses

• Training on Operation of UAS

• Virtual Tours

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3 UASs 

CONOR LUKAS CROUCH 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 6 pounds 7.5 

ounces, a length of 17.3 

inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed 

of approximately 42 

knots. The DJI Phantom 3 UAS is equipped with four main rotors; driven by 

Lithium Polymer 

battery powered electric motors. 

BASIS FOR PETITION 

Petitioner, CONOR LUKAS CROUCH, 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 a DJI Phantom 3 UASs 

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, CONOR LUKAS 

CROUCH operation of the DJI 

Phantom 3 UAS meets the conditions of FMRA Section 333 and therefore, 

will not require an 

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

H. 

Accordingly, CONOR LUKAS CROUCH 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. 

CONOR LUKAS CROUCH submits that the requested relief is proper since an 

equivalent level of safety will be ensured. CONOR LUKAS CROUCH will use 

experienced 

personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., 

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

Furthermore, CONOR LUKAS CROUCH will document and maintain all 

maintenance records for the DJI Phantom 

3 UAS. 

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

Private pilot privileges and 

limitations: Pilot in command, is requested by CONOR LUKAS CROUCH to the 

extent necessary to allow a Pilot in Command (PIC) holding a private 

pilot or higher level certificate, as well as an airman medical 

certificate, and who has demonstrated, by meeting minimum flight- hour 

and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 3 UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and 
maintaining appropriate distances from people, vessels, vehicles and 

structures. 

CONOR LUKAS CROUCH seeks relief from Section 91.7(a), entitled Civil 

aircraft 

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

airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, CONOR LUKAS CROUCH
submits that he will ensure that the DJI Phantom 3 UAS is in airworthy 

condition, prior to every 

flight, by determining that the UAS are in compliance with the operating 

documents (i.e., Monthly 

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

aircraft are in a condition 

for safe flight. 

CONOR LUKAS CROUCH also seeks an exemption from the requirements of 

Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 3 UAS will not 

have a typical barometric altimeter onboard. However, altitude 

information of the DJI Phantom 3 UAS will be provided to 

the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry datalink, which downlinks from the UA to the GCS 

for active monitoring of the flight path. This altitude information, 

combined with CONOR LUKAS CROUCH’S operation of the DJI 

Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety 

Equivalent to Section 91.121. 

Additionally, CONOR LUKAS CROUCH seeks an exemption from the requirements 

of 

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

conditions. CONOR LUKAS CROUCH

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

3 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 14.5 

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, CONOR LUKAS CROUCH 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: 

CONOR LUKAS CROUCH

715 MOSS CREEK DR.

CAYCE, SC 29033

CONORCROUCH@AOL.COM
B. The Specific Sections Of 14 C.F.R. From Which CONOR LUKAS CROUCH Seeks 

Exemption. 

1. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot 

in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in 

command (PIC) 

of an aircraft that is carrying passengers or property for compensation 

or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an 

aircraft in 

connection with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation 

or hire. 

2. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 

91.7(a). 

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

states the following: 

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

condition. 

3. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the 

following, in part: 

(a) Each person operating an aircraft shall maintain the cruising 

altitude or flight level of that aircraft, as the case may be, by 

reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route 

and within 

100 nautical miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or 
(iii) In the case of an aircraft not equipped with a radio, the elevation 

of the departure airport or an appropriate altimeter setting available 

before departure. 

4. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 

91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, 

subsection

(b), states the following: 

(b) No person may begin a flight in a rotorcraft under VFR conditions 

unless 

(considering wind and forecast weather conditions) there is enough fuel 

to fly to the 

first point of intended landing and, assuming normal cruising speed, to 

fly after that for 

at least 20 minutes. 

5. CONOR LUKAS CROUCH Seeks Exemption From The Requirement 

Of Section 91.405(a). 

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

following: Each 

owner or operator of an aircraft—

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

part and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as prescribed 

in part 43 of this chapter. 

6. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive 

maintenance, rebuilding, 

or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized 

under § 43.7 

of this chapter[.] 

7. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the 

following: 
(a) Except as provided in paragraph (c) of this section, no person may 

operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and 

has been 

approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in 

accordance with 

part 21 of this chapter. 

8. CONOR LUKAS CROUCH Seeks Exemption From The Requirements Of Sections 

91.417(a) And 91.417(b). 

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

state the following: 

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

each 

registered owner or operator shall keep the following records for the 

periods specified 

in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration 

and 

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

approved 

inspections, as appropriate, for each aircraft (including the airframe) 

and each 

engine, propeller, rotor, and appliance of an aircraft. The records must 

include--

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

of the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

propeller, and 

each rotor. 

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

propeller, 

rotor, and appliance. 

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

which 

are required to be overhauled on a specified time basis. 

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

since the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained. 

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

safety 

directives including, for each, the method of compliance, the AD or 

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

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

required. 

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

major 

alteration to the airframe and currently installed engines, rotors, 

propellers, 

and appliances. 

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

periods prescribed: 

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

retained until the work is repeated or superseded by other work or for 1 

year after the work is performed. 

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

retained and 

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

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

43.11 of 

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

aircraft is approved for return to service. 

C. The Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason 

CONOR LUKAS CROUCH Seeks The Relief. 

1. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason 

CONOR LUKAS CROUCH 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 flighthour 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, CONOR LUKAS CROUCH submits that an 

equivalent level of safety will be maintained because no PIC will be 

allowed to operate the DJI Phantom 3 

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

requirements, demonstrating that the PIC is able to safely operate either 

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, CONOR LUKAS CROUCH submits that all flights of the DJI Phantom 3 

UASs, 

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

incidental to CONOR LUKAS 

CROUCH’s business; and (2) will not carry passengers or property for 

compensation 

or hire. 

2. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason 

CONOR LUKAS CROUCH 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 CONOR LUKAS CROUCH to determine that the DJI 

Phantom 3 UASs are in airworthy condition prior to every flight by 

ensuring that the UAS is in 

compliance with the operating documents (i.e., the CONOR LUKAS CROUCH

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

Instruction Manual). 

CONOR LUKAS CROUCH seeks the requested relief because the DJI 

Phantom 3 UAS do not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, 

Subpart H. Therefore, CONOR LUKAS CROUCH will ensure that the DJI Phantom 

3 

UAS are in airworthy condition based upon its compliance with the 

operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 3 Instruction Manual) prior to 

every flight, and 

further, determine that the aircraft are in condition for safe flight, as 

stated in the conditions and 

limitations below. 

3. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason 

CONOR LUKAS CROUCH 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 UAS, which utilize a 

barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from 

the UA to the PIC at the ground control station (GCS). Since the FAA 

requires that any altitude information concerning 

UAS operations be reported to air traffic control (ATC) in feet above 

ground level (AGL), 

CONOR LUKAS CROUCH seeks the requested relief because the DJI Phantom 3 

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 

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. 

4. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason 

CONOR LUKAS CROUCH 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 UAS during day light hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 14.5 

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

cruising speed, 

to fly after that for at least 4.5 minutes. CONOR LUKAS CROUCH seeks the 

requested 

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

time duration of the battery 

powered DJI Phantom 3 UAs will severely constrain the practicality of any 

aerial video or still photo flight operations that CONOR LUKAS CROUCH

proposes to conduct pursuant to 

this Petition. 

Significantly, as set forth below, the technical specifications of the 

DJI Phantom 3 UASs, the DJI 

DJI Phantom 3 operating documents, and CONOR LUKAS CROUCH’s proposed 

operating limitations, ensure that CONOR LUKAS CROUCH will safely operate 

the battery powered DJI Phantom 3 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 

14.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after 

that for at least 4.5 minutes. 

5. Extent Of Relief CONOR LUKAS CROUCH Seeks And The Reason 

CONOR LUKAS CROUCH 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, CONOR LUKAS CROUCH requests 

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

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

Phantom 3 UAS meets the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly, CONOR LUKAS 

CROUCH will use trained technicians to perform maintenance, alterations, 

or preventive maintenance on the UAS’s using the methods, techniques, and 

practices prescribed in the UAS operating documents(i.e., the CONOR LUKAS 

CROUCH Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 

3 Instruction Manual). Furthermore, CONOR LUKAS CROUCH will document and 

maintain all maintenance records for the and DJI Phantom 3 UAS. 
D. The Reasons Why Granting CONOR LUKAS CROUCH 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 CONOR LUKAS CROUCH to safely, efficiently, and economically 

perform aerial video and photography of real estate, landmarks, for 

movies or television, for historical reference, search and rescue, 

surveying, architecture, roof and pipeline inspection, live events, 

construction sites, natural resource management, insurance companies, 

training on operation of UAS, and golf courses over certain areas of the 

United States. 

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

the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of 

CONOR LUKAS CROUCH’s proposed operation of the DJI Phantom 3 UAS will be 

realized without implicating 

any privacy issues. 

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

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

efficient, and economical alternative to the manned aircraft 

traditionally utilized to obtain aerial imagery. By reducing the amount 

of manned aircraft needed to perform aerial acquisitions, an exemption 

allowing the use of 

the DJI Phantom 3 UAS would reduce the amount of manned aircraft in the 

NAS, reduce noise and 

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

air and on the ground. 

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

NAS, congestion around 

airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom 3 UAS do not require an airport to takeoff or land. Likewise, 

a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air 

traffic control during the ground, takeoff, departure, arrival, and 

landing phases of flight operations. 

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

Phantom 3 

UAS. 

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing 

the levels of air and noise pollution generated 

during traditional aerial video and still photography flight operations. 

By using battery power and 

electric motors, DJI Phantom 3 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. 

By using the DJI Phantom 3 UASs 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 UAS 

(weighing 

approximately 6 pounds 7.5 ounces, at their maximum gross weights with 

length of 17.3 inches respectively, widths of 16 inches and 17.7 inches 

respectively, and with no fuel on board), has less physical potential for 

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

compared 

to the manned aircraft that typically conduct similar operations 

(weighing approximately 6,000 

pounds with a wingspan of approximately 42 feet, a length of 34 feet, and 

a fuel capacity of 180 

gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 3 

UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 UAS is also an 

economical alternative to 

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

operation of the DJI Phantom 3 

UAS will allow United States based companies, like CONOR LUKAS CROUCH, 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 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 UAS, companies such as CONOR LUKAS CROUCH

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 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. 

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 CONOR LUKAS CROUCH Seeks 

Exemption. 

1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333. 
In consideration of the size, weight, speed, and limited operating area 

associated with the unmanned aircraft and its operation, CONOR LUKAS 

CROUCH’s DJI Phantom 3 UAS meet the conditions of FMRA Section 333, and 

will not require an airworthiness certificate in 

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

Section 333 provides authority for a 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, CONOR LUKAS CROUCH submits that the DJI 

Phantom 3 

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

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

the pilot certification requirement; and (c) the specific operating 

limitations. 
a. The Specifications Of The DJI Phantom 3 UAS Demonstrate Its Safe

Characteristics. 

The DJI Phantom 3 UASs 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 UAS. 

The technical specifications of the DJI Phantom 3 UAS is set forth by the 

DJI Phantom 3 User 

Manual, attached hereto as Appendix A. 

ii. The DJI Phantom 3 UAS Autonomous Flight And Navigation Modes Enable 

The UAS To Remain Within A Defined Operational Area. 

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

autonomous flight modes. A complete description of the flight and 

navigational modes of the DJI Phantom 3 UAS is provided at pages 12-16 

and 45-50 of the DJI Phantom 3 User Manuals, attached hereto as Appendix 

B. 

iii. The DJI Phantom 3 UAS Are Designed For Automatic Return To 

Home Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation. 

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

stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Phantom 3 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 of the DJI Phantom 3 at 

pages 13 through 15 of 

the DJI Phantom 3 User Manuals, attached hereto as Appendix B. 

iv. The DJI Phantom 3 GCS And Its Operation. 

A complete description of the operation and specifications of the DJI 

Phantom 3 GCS and flight control software is provided at pages 40 through 

47 of the DJI Phantom 3 User Manual. DJI 

Phantom 3 User Manuals are attached hereto as Appendix A. 

b. Flight Operations Of DJI Phantom 3 UAS Is Limited To The Line Of Sight 

Of A Certificated Pilot in Command With A Safety Observer. 

CONOR LUKAS CROUCH will be the only person to act as a pilot in command 

(PIC) of 

the DJI Phantom 3 UAS. Additionally, a safety observer will assist in 

flights. 

c. Flights Of The DJI Phantom 3 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, CONOR LUKAS CROUCH proposes to commercially 

operate the DJI Phantom 3 UASs for the special purpose of conducting 

aerial video and photography over 

certain areas of United States, pursuant to the following specific 

operating limitations: 
1. Operations authorized by this grant of exemption will be limited to 

the following 

aircraft described in the operating documents, rotorcraft UASs weighing 

less than 55 

pounds maximum gross weight: DJI Phantom 3 Unmanned Aircraft Systems. 

Proposed 

operations of any other aircraft will require a new petition or a 

petition to amend this 

grant. 

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

operations for the purpose of aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UAS 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. The use of first person view (FPV) by the PIC or safety observer (SO) 

is not permitted. 

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

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

capability. The SO and 

PIC must be able to communicate verbally at all times. Electronic 

messaging or texting 

is not permitted during flight operations. The PIC must be designated 

before the flight and cannot transfer his or her designation for the 

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

functions prescribed in the operating documents. 

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

seeing and 

avoiding other air traffic and other ground based obstacles/obstructions 

and is not permitted to operate the camera or other instruments. 
9. The operating documents and the grant of exemption must be accessible 

during UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and limitations 

contained in the grant of exemption and the procedures outlined in the 

operating documents, the conditions and limitations contained in the 

grant of exemption take precedence and must be followed. Otherwise, 

the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It 

is the operator’s responsibility 

to track such revisions and present updated and revised documents to the 

Administrator 

upon request. The operator must also present updated and revised 

documents if it petitions for extension or amendment to the grant of 

exemption. If the operator 

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

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

amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operating 

documents. 

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

is in a condition 

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

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

until the necessary maintenance has been performed and the UAS is found 

to be in a condition for safe flight. The Ground 

Control Station must be included in the preflight inspection. All 

maintenance and 

alterations must be properly documented in the aircraft records. 

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

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

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

conducts the functional test flight must make an entry in the aircraft 

records. 

12. The pre-flight inspection must account for all potential 

discrepancies, e.g. 

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

relevant

sections of the operating documents. 

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

maintenance, overhaul, replacement, inspection, and life limit 

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

keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, 

alterations, and status of replacement/overhaul component parts must be 

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

description of work accomplished, and 

the signature of the authorized person returning the UAS to service. 

15. Each UAS operated under this exemption must comply with all 

manufacturer 

Safety Bulletins. 

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

the corrective action taken against discrepancies discovered between 

inspections. 

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

least a current thirdclass medical certificate. 

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

the operator’s qualification criteria and demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be 

operated under the exemption, 

including evasive and emergency maneuvers and maintaining appropriate 

distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 

C.F.R. § 61.51(b). Flights for the purposes of 

training the operator’s PICs are permitted under the terms of the 

exemption. However, 

training operations may only be conducted during dedicated training 

sessions. During 

training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the 

PIC must operate the UA with 

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

91.119. 

19. UAS operations may not be conducted during night, as defined in 14 

C.F.R. § 1.1. 

All operations must be conducted under visual meteorological conditions 

(VMC). If 

flight at night is required, a special request will be made at the FAA 

office closest to 

proposed area of operations. Flights under special visual flight rules 

(SVFR) are not authorized. 

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

reference point as denoted on a current FAA-published aeronautical chart 

unless a letter of agreement 
with that airport’s management is obtained, and the operation is 

conducted in 

accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the 

Administrator upon 

request. 

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

2,000 feet horizontally from a cloud or when visibility is less than 3 

statute miles from the PIC. 

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

return to a predetermined location within the planned operating area and land or be 

recovered in 

accordance with the operating documents. 

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

or emergencies in accordance with the operating documents. 

24. The PIC is prohibited from beginning a flight unless (considering 

wind and forecasted weather conditions) there is enough power to fly at 

normal cruising speed to the intended landing point and land the UAS with 

25% battery power remaining. 

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

Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under 

the grant of 

exemption. This COA will also require the operator to request a Notice to 

Airman 

(NOTAM) not more than 72 hours in advance, but not less than 48 hours 

prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of 

airspace, altitude level and potential transponder requirements. 

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

identified by serial number, registered in accordance with 14 C.F.R. part 

47, and have identification (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. 

Markings must be as large as practicable. 
27. Before conducting operations, the radio frequency spectrum used for 

operation and 

control of the UA must comply with the Federal Communications Commission 

(FCC) 

or other appropriate government oversight agency requirements.

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

available to 

the PIC at the Ground Control Station of the UAS any time the UAS is 

operating. 

These documents must be made available to the Administrator or any law 

enforcement official upon request. 

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

aviation 

operations and activities at all times. 

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

vehicle. 

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

nonparticipating 

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

persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect 

nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator 

must ensure that nonparticipating persons remain under such protection. 

If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must 

cease immediately and/or; 

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

the owner/

controller of such vessels, vehicles or structures has granted permission 

and the PIC has made a safety assessment of the risk of operating closer 

to those objects and determined that it does not present an undue hazard, 

and; 

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

persons do 

not present an undue hazard to those persons per § 91.119(a). 
32. All operations shall be conducted over private or controlled-access 

property with 

permission from the land owner/controller or authorized representative. 

Permission 

from land owner/controller or authorized representative will be obtained 

for each flight to be conducted. 

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

lateral or vertical boundaries of the operational area as defined by the 

applicable COA must be reported 

to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents 

must be reported to the National Transportation Safety Board (NTSB) per 

instructions contained on the NTSB Web site: www.ntsb.gov. 

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

And

(b) Would Not Adversely Affect Safety. 

CONOR LUKAS CROUCH 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 UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 3 

UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Considering CONOR LUKAS CROUCH’s proposed area of operations, and the 

operating 

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

aeronautical knowledge requirements to those of commercial pilot 

requirements (See Exemption No. 11062); and the airmanship skills

necessary to safely operate the DJI Phantom 3 UAS, CONOR LUKAS CROUCH

submits that the additional manned airmanship experience of a 

commercially certificated pilot would not correlate to the airmanship 

skills necessary for CONOR LUKAS CROUCH’s 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). 

CONOR LUKAS CROUCH will not allow any PIC to operate the DJI Phantom 3 

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

requirements or the DJI 

Phantom 3 UAS training and currency requirements, that the PIC is able to 

safely operate the DJI 

Phantom 3 UAS in a manner consistent with this exemption, including 

evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 
Specifically, the PIC must have accumulated and logged, in a manner 

consistent with 14 C.F.R. § 

61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

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

and model of UAS to be used for operations under 

the exemption). In addition to the hour requirements, the PIC must 

accomplish 3 takeoffs and 

landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight 

experience that was obtained in compliance with applicable regulations 

will ensure an equivalent level of safety during 

CONOR LUKAS CROUCH’s proposed operations. The Administrator has held that 

prior 

documented flight experience that was obtained in compliance with 

applicable regulations would 

ensure safe operations, stating as follows: 

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

operations for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated 

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

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

as a UAS pilot with a multi-rotor UAS. 

Prior to operations under Exemption No. 11062, the PIC must also have 

accumulated and 

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

model of UAS to be used for operations under the exemption. For 

clarification, the FAA considers these minimum hour requirements to be 

inclusive rather than additive; i.e. 5 hours make and 

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

hours may be included in the total 25 hours of UAS rotorcraft time. In 

addition to the hour requirements, 

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

(for currency 

purposes). The FAA finds that at a minimum, the flight-hour requirements 

in Exemption 

No. 11062 are appropriate to practice and build proficiency in the skills 

necessary to safely 

conduct the petitioner’s proposed operations. The FAA also finds that 

prior documented 

flight experience that was obtained in compliance with applicable 

regulations would satisfy 

this requirement. Training, proficiency, and experience-building flights 

can also be conducted under the grant of exemption to accomplish the 

required flight time. During 

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

required to operate the UAS with appropriate distances in accordance with 

14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 
Accordingly, CONOR LUKAS CROUCH will ensure safe operations by not 

allowing any 

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

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

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

the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be 

maintained because prior to 

every flight, CONOR LUKAS CROUCH will ensure that the DJI Phantom 3 UAS 

is in an 

airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated 

in the conditions and limitations herein. 

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

specific to UAS, in 

circumstances similar, in all material respects, to those presented 

herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

11136, 11138, 11150, 

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

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

Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be 

maintained because the altitude information of the DJI Phantom 3 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 CONOR LUKAS CROUCH’s operation of the DJI 

Phantom 3 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 UASs 

at ground level. 

The FAA has previously granted relief from Section 91.121 specific to 

UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

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

Would Not Adversely Affect Safety. 

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

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

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

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

Accordingly, CONOR LUKAS CROUCH will ensure that it will safely operate 

the battery 

powered DJI Phantom 3 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 UAS; the limitations on the proposed flight operations; and the 

location of the proposed operations, will 

ensure an equivalent level of safety established by 14 C.F.R. Section 

91.151(b). Furthermore, 

safety will be ensured as the DJI Phantom 3 UAS provide audible and 

visual warnings to the PIC at the GCS when the UAS 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 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, CONOR LUKAS CROUCH 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 CONOR LUKAS CROUCH 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 Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

Instruction Manual). 

Furthermore, CONOR LUKAS CROUCH will document and maintain all 

maintenance 

records for the DJI Phantom 3 UAS. 

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

operating documents, 

CONOR LUKAS CROUCH will maintain the equivalent level of safety 

established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI 

Phantom 3 User Manuals are attached hereto as Appendix A; a copy of the 

DJI Phantom 3 UAS Maintenance LOG is attached 

Here to as Appendix B. 

Likewise, the exemption sought will not adversely affect safety because 

CONOR LUKAS CROUCH will use trained technicians to perform maintenance, 

alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the operating 

documents. 

Furthermore, the exemption sought would maintain an equivalent level of 

safety established by 

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

DJI Phantom 3 UAS will 

be performed by trained technicians. Maintenance will be documented and 

maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)

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

not adversely affected when 

the technical characteristics and operating limitations of the UAS are 

considered. 

In consideration of CONOR LUKAS CROUCH’s proposed operating limitations, 

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

UAS, CONOR LUKAS CROUCH 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, CONOR LUKAS CROUCH

requests that the FAA prescribe special conditions for the intended 

operation of the DJI Phantom 3 UAS, which 

contain such safety standards that the Administrator finds necessary to 

establish a level of safety 

equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 

C.F.R §§ 61.113(a) & (b), 

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

(a)(2), and 91.417(a) & (b). 

Such special conditions will permit safe operation of the UAS for the 

limited purpose of 

conducting aerial video and photography over certain areas of the United 

States for compensation 

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

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

otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without 

airworthiness certification in 

accordance with any requirements that must be established for the safe 

operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 

14 C.F.R. 

§ 21.16, for operation of the DJI Phantom 3 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 CONOR LUKAS CROUCH’s intended 

operation of the DJI 

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

finds necessary to 

establish a level of safety equivalent to that established by 14 C.F.R. 

Part 21, Subpart H, and 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b). 

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

The Rules From Which CONOR LUKAS CROUCH Seeks Exemption: 

CONOR LUKAS CROUCH 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 CONOR LUKAS CROUCH

Seeks: 

This exemption will permit CONOR LUKAS CROUCH to commercially operate 

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

video and 

photography over certain areas of the United States. 

• Any Additional Information, Views, Or Arguments Available To 

Support CONOR LUKAS CROUCH’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, CONOR 

LUKAS CROUCH 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, CONOR LUKAS CROUCH will operate the DJI 

Phantom 3 

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, CONOR LUKAS CROUCH 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 UAS 

commercially, without an airworthiness certificate, for the limited 

purpose of conducting aerial video and photography. 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 CONOR LUKAS CROUCH to safely, efficiently, and economically 

operate the DJI Phantom 3 UAS commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization 

and Reform Act of 2012, Section 333, CONOR LUKAS CROUCH respectfully 

requests that the Administrator grant this Petition for an exemption from 

the requirements of 14 C.F.R 

Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b), and permit CONOR LUKAS CROUCH to operate the 

DJI 

Phantom 3 UAS commercially for the purpose of conducting aerial video and 

photography. Dated:

June 12, 2015 

Respectfully submitted, 

CONOR LUKAS CROUCH

715 MOSS CREEK DR.

CAYCE, SC 29033

CONORCROUCH@AOL.COM
Appendices: 

A – DJI Phantom 3 Specifications Data Sheet 

APPENDIX – A 

DJI Phantom 3 TECHNICAL SPECIFICATIONS 

CONOR LUKAS CROUCH only utilizes safe and reliable UAS. DJI is an 

industry leader 

in small UAS production. DJI UASs are loaded with ground breaking 

software enabling the user to 

set parameters which will not allow flight into controlled airspace. 

Parameters can also be set to 

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

as limit flight to a predetermined and set distance. In addition, DJI 

software provides real-time altitude and location 

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

devices) 

2.2.1 Aircraft 

2.2.1.1 Model – Phantom 3 

2.2.1.2 Weight (Battery Included) – 1280 grams 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: +/- 10cm; Horizontal:

+/-1m 

2.2.1.4 Max Angular Velocity –Yaw: 200°/s 

2.2.1.5 Max Tilt Angle - 35° 

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 3m/s 

2.2.1.8 Max Speed – 16m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 6000m 

2.2.1.10 Max Flight Time – Approximately 23 minutes 

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 
2.2.1.14 Operating Temperature Range – 14°F to 104°F (-10°C to 40°C) 

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

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X3 

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

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

2.2.2.4 Angular Vibration Range - ±0.03° 

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -90° to +30°; Pan: ±320° 

2.2.2.7 Mechanical Range – Pitch: -125° to 45°; Pan: ±330° 

2.2.2.8 Max Controllable Speed – Pitch: 120°/s; Pan: 180°/s 

2.2.3 Camera 

2.2.3.1 Name – Sony EXMOR 

2.2.3.2 Model – 12.4M Pixel 

2.2.3.3 Total Pixels – 12.4M 

2.2.3.4 Effective Pixels – 12.76M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 94° 

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 

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

3840x2160p24/25/30;

FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 

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

2.2.4 Transmitter 

2.2.4.1 Name – C1 

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

2.2.4.3 Communicating Distance (unobstructed) – 2000m 

2.2.4.4 Output Power – 9W 

2.2.4.5 Operating Temperature Range - 14°F to 104°F (-10°C to 40°C) 

2.2.4.6 Battery – 600mAh LiPo 2S