UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _____ _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

LAWRENCE BRIDGES 

SOUTHERN AIR SERVICES 

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. 91.15Hb). 91.405(a). 91.407(a)(l), 

91.409(a)(l) & (a)(2). AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1 UNMANNED 

AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on May 22, 2015 

Lawrence Bridges. Owner 

Black Forest Gun Wurk. LLC 

DBA: SAS Defense 

DBA: Southern Air Services 

1 01 Demorest Square 

Demorest GA 30535 

706-778-1440 

Hereafter referred to as "SAS". 
TABLE OF CONTENTS 

Page 

GLOSSARY OF 

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

SUl\1Mr\RY ......................................................................................................................... 4 

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

Bi-\CI(C1RC)lJND ................................................................................................................ 5 

BASIS FOR 

PETITION ........................................................................................................................... S 

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

TllE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SAS SEEKS 

EXEMPTI()N .......................................................................................................... 8 

THE EXTENT OF RELIEF SAS SEEKS AND THE REASON SAS SEEKS 

TI-lE RELIEF .................................................................................. .11 

THE REASONS WHY GRANTING SAS REQUEST WOULD BE IN THE 

PUBLIC INTEREST ................................................................................. 14 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT 

SAFETY ................................................................................................................ 17 

CC)NCLtJSION ................................................................................................................. 32 
AGL 

AOI 

ATC 

ATO 

AV 

CFR 

COA 

FAA 

fAR 

GCS 

GPS 

LOL 

NAS 

NOT AM 

PJC 

Section 333 

so 

SOP 

UA 

UAS 

VFR 

VLOS 

VMC 

VTOL 

GLOSSARY OF ABBREVIATIONS 

Above Ground Level 

Area oflnterest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code ofFederal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of2012 (FMRA) 

Safety Observer 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 
SUMMARY 

SAS seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.12L 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) 

& (b). to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA 

Modernization and Reform Act of2012 (FMRA). This exemption will permit SAS to 

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

PI-IOTOGRAMMETRY, AERIAL PHOTOGRAPHY, MAPPING and SURVEYING 

over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is Lawrence Bridges, I am the owner of SAS. I hold an ATP MultiEngine Land. certificate #2737408, date of issue 07 MAR 2008, with five (5) PIC Type 

Ratings. I have served as a Part 121 Air Carrier PIC with over 8000 hours and was a Part 

135 Air Taxi Chief Pilot. Since there are no current UA V regulations on the books just 

yet, I am seeking exemptions pursuant to Section 333 of the FAA Modernization and 

Reform Act of2012. 

The objective is to add services to my existing company in order to offer 

PHOTOGRAMMETRY, AERIAL PHOTOGRAPHY, MAPPING and SURVEYING 

over certain areas of the United States for commercial purposes. 
BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs 

SAS seeks an exemption to operate DJI systems for compensation or hire within 

the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1 are vertical takeoff and landing 

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

electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ 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. 

The OJ I Inspire 1 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 2 Vision+ and DJI Inspire 1 UAs are equipped 

with four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs that will be operated by SAS 

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

I 4 C.F.R Part 4 7, Aircrqfi Registration, and marked in accordance with 14 C.F.R. Part 45, 

identification and Registration Marking. 

BASIS FOR PETITION 

Petitioner, SAS, pursuant to the provisions of the Federal Aviation Regulations 

(14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of2012 (FMRA), 

Section 333, S!xcial Rulesfin· Certain Unmanned Aircraft Systems, hereby petitions the 

Administrator to commercially operate the DJI Phantom 2 Vision+, DJI Inspire 1 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)(l), 

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

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

with the unmanned aircraft and its operation, SAS operation ofDJI Phantom 2 Vision+ 

and D.lllnspire 1 UASs meets the conditions ofFMRA Section 333 and therefore, will 

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

Accordingly, SAS requests relieffrom Sections 91.405(a), 91.407(a)(1), 

91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate. 

SAS submits that the requested relief is proper since fi-n equivalent level of safety 

will be ensured. SAS will use experienced personnel or technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

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

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). 

Furthermore, SAS will document and maintain all maintenance records for the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs. 

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

pilot priPileges and limitations: Pilot in command, is requested by SAS 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 2 Vision+ and DJI Inspire 1 UASs in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

SAS seeks relief from Section 91. 7( a), entitled Civil aircraft airworthiness, 

because the D.II Phantom 2 Vision+ and DJI Inspire 1 UASs do not require an 

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

submits that he will ensure that the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs are in 

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

Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and that the aircraft are in a 

condition for safe t1ight. '-

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

Altimeter Se!lings, as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will not have a 

typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 

2 Vision+ and DJI Inspire 1 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 SAS's operation ofthe DJI Phantom 2 Vision+ and DJI 

Inspire I UASs within visual line of sight, at or below 400 feet AGL, will ensure a level 

of safety equivalent to Section 91.121. 

Additionally, SAS seeks an exemption from the requirements of Section 

91.151 (b), entitled Fuel requirements for flight in VFR conditions. SAS submits that 

safety will not be affected by operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 

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, SAS 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: 

Lawrence Bridges 

Southern Air Services 

I 0 I Demorest Smmre 

Demorest GA 30535 

706-778-1440 

captbridges@aol.com 
B. The Specific Sections of 14 C.F.R. From Which SAS Seeks Exemption. 

1. SAS 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 Drivate 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. SAS 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. SAS 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 oDerating 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--

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

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

within 100 nautical miles of the aircraft; 

(ii) Ifthere 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 aimort or an appropriate altimeter setting available 

before departure. 
4. SAS 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 oerson mav bezin a flizht in a rotorcraft under VFR conditions unless 

(considerinz vvind and forecast weather conditions) there is enouzh fuel to flv 

to the first ooint ofintended landinz and, assuming normal cruising speed, to 

jly C(/fer thatfor at least 20 minutes. 

5. SAS 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. SAS 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 mav operate anv aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless--

( I ) It has been approved for return to service by a person authorized under § 

43.7 ofthis chapter[.] 

7. SAS 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 mav operate an 

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

( 1) An annual insoection in accordance with oart 43 of this chaoter and has 

been aooroved for return to service by a person authorized by§ 43.7 of 

this chapter; or 

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

with part 21 of this chapter. 

8. SAS 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 1 00-hour. annuaL orogressive, and other required or 

aporoved insoections, as aporopriate, 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 safetydirective 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 (3 43.9(d) of this chapter for each 

maior 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 

unti 1 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 (3 43.11 

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

aircraft is approved for return to service. 

C. The Extent of Relief SAS Seeks and the Reason SAS Seeks the Relief. 

I. Extent of Relief SAS Seeks and the Reason SAS 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 f1ight-hour and currency requirements, to conduct the 

proposed UAS t1ight 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, SAS submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ 

UAS or DJllnspire 1 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 

2 Vision+ or DJI Inspire 1 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, SAS submits that all flights ofthe DJI Phantom 2 Vision+ and DJI 

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

incidental to SAS 's business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent of Relief SAS Seeks and the Reason SAS Seeks Relief from Section 

9l.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to 

the extent required to allow SAS to determine that the DJI Phantom 2 Vision+ and DJI 

Inspire I UASs are in airworthy condition prior to every flight by ensuring that the UAS 

is in compliance with the operating documents (i.e., the SAS Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction 

Manual). 

SAS seeks the requested relief because the DJI Phantom 2 Vision+ and DJI 
Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 2 I. Subpart H. Therefore, SAS will ensure that the DJI Phantom 2 Vision+ and DJI 

Inspire I UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 

I Instruction Manual) prior to every flight, and further, determine that the aircraft are in 

condition for safe f1ight, as stated in the conditions and limitations below. 

3. Extent of Relief SAS Seeks and the Reason SAS Seeks Relief from Section 

91.121. 

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

f1ight operations of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, 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), SAS 

seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 1 UA's 

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

pressure or field altitude, before each f1ight. 

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

9 I. I 2 I is sought to the extent necessary to comply with the applicable conditions and 

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

be maintained since the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are equipped with 

a barometric pressure sensor and GPS equipment, which automatically ensures that a 

ground level pressure setting will be established prior to each flight, and provides the PIC 

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

4. Extent of Relief SAS Seeks and the Reason SAS 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 t1ights of the battery powered DJI 

Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours in visual meteorological 

conditions (VMC), under visual f1ight rules (VFR), for a total duration of 13.5 minutes to 

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

for at least 4.5 minutes. SAS seeks the requested relief because without an exemption 

from Section 91.151 (b), the flight time duration of the battery powered DJI Phantom 2 

Vision+ and DJI Inspire 1 UAs will severely constrain the practicality of any aerial video 

or still photo flight operations that SAS proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating 

documents, and SAS proposed operating limitations, ensure that SAS will safely operate 

the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs during daylight hours 

in visual meteorological conditions (VMC), under visual f1ight rules (VFR), with enough 

battery power to f1y 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. 

5. Extent of Relief SAS Seeks and the Reason SAS Seeks Relief from Sections 

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

Since Sections 9l.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

only apply to aircraft with an airworthiness certificate, SAS requests relief from these 

Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require 

airworthiness certificates. As set fmih more fully below, the DJI Phantom 2 Vision+ and 

DJI Inspire 1 UASs meet the conditions ofFMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, SAS will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the SAS 
Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and 

D.l I Inspire 1 Instruction Manual). Furthermore, SAS will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. 

D. The Reasons Whv Grantin2: SAS Reuuest 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 SAS 

safely, efficiently, and economically perform PHOTOGRAMMETRY, AERIAL 

Pl-IOTOCiRAPHY, MAPPING and SURVEYING over certain areas of the United States. 

Additionally, use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will 

decrease congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of SAS's proposed operation of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs will be realized without implicating any privacy issues. 

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

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are battery powered and serve 

as a safe, ef1icient, and economical alternative to the mmmed aircraft traditionally utilized 

Lo obtain aerial imagery. By reducing the amount ofmmmed aircraft needed to perform 

aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI 

Inspire I UAS would reduce the amount ofmmmed 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 

OJ I Phantom 2 Vision+ and DJI Inspire 1 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 Safetv And Efficiency Of The DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1 

U ASs, 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 2 Vision+ and DJI Inspire 1 UASs produce no air pollution, and is the most 

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

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

while burning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI 

Phantom 2 Vision+ and DJI Inspire 1 UAs, while reducing the carbon footprint of aerial 

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

electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 2 Vision+ and DJI Inspire 1 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 2 Vision+ and DJI Inspire 1 UAs (weighing 

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 

16 inches and 1 7. 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. Performin!! Aerial Video and Photo!!raohv Ooerations With The DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Inspire 

I UASs are also an economical alternative to using manned aircraft to conduct similar 

aerial operations. As such, operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs will allow United States based companies, like SAS, to remain competitive and 

contribute to growth ofthe U.S. economy. Specifically, with the rising cost of aviation 

fuel and the Environmental Protection Agency ("EPA") regulatory actions phasing out 

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

alternative technology in order to remain competitive. Operating the battery powered DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs 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 mmmed aircraft. 

By operating the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, companies such 

as SAS, 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 performm1ce of U.S. companies, through commercial 

use of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, provides a stable workforce 

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

allovv·s companies to invest in research and development in order to remain competitive 

both in the United States and abroad. 

4. The1·e Are No Privacy Issues. 

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

decades, SAS 's proposed operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ and 
DJI Inspire 1 UASs will be operated only in compliance with operating documents (i.e., 

the SAS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 

Vision+ and DJI Inspire 1 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. 

E. The Reasons Whv Grantine: The Exemotion Would Not Adverselv Affect Safety, 

Or How The Exemotion Would Provide A Level Of Safetv At Least Equal To 

That P1·ovided By The Rule From Which SAS Seeks Exemption. 

1. Reasons Whv The DJI Phantom 2 Vision+ and DJI Insoire 1 UAs Meet 

The Conditions Of The FAA Modernization and Reform Act of2012 

(FMRA) Section 333. 

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

\Vith the unmanned aircraft and its operation, SAS's operation of the DJI Phantom 2 

Vision+ and OJ I Inspire 1 UASs meet the conditions ofFMRA 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: 

(o) in General. --Notwithstandinf! anv other reauirement of this subtitle. and not 

later than 180 davs after the date of enactment of this Act. the Secretarv of 

Tranmortation shall determine if certain unmanned aircraft svstems mav 

ooerate safelv in the national airsvace svstem before comvletion of the olan 

and rulemakinz reauired by section 332 of this Act or the guidance required 

by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Svstems. --In makinf! the determination 

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

(!) which tvves of unmanned aircraft svstems. if anv. as a result of their 

size. weidtt. sveed. overational cavabilitv. vroximitv to aimorts and 

vovulated areas. and overation within visual line of sif!ht 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 reouired for the overation of unmanned aircrqft 

systems identified under paragraph (1). 

(c) Reouirements for Safe Overation.--Jfthe Secretarv determines under this 

section that certain unmanned aircraft svstems mav overate safelv in the 

national airsvace svstem. the Secretarv shall establish reouirements for the 

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

In seeking this exemption, SAS submits that the DJI Phantom 2 Vision+ and DJI 

Inspire I UASs can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ and DJI Inspire 1 

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

a. The Snecifications Of The DJI Phantom 2 Vision+ and DJI Inspire 1 

U ASs Demonstrate Its Safe Characteristics. 

The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not create a hazard to 

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

its size, weight, speed, and operational capability. 

i. Technical Snecifications Of The DJI Phantom 2 Vision+ and DJI 

Inspire 1 UASs. 

The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 Specifications and 

Data Sheet, attached hereto as Exhibit A and B. 

ii. The DJI Phantom 2 Vision+ and DJI Insnire 1 UASs Autonomous 

Fli2:ht And Navi2:ation Modes Enable The UASs To Remain Within 

A Defined Operational Area. 

The DJI Phantom 2 Vision+ and DJI Inspire 1 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 2 Vision+ and DJI Inspire 1 UASs is provided at 

pages 25-35 of the DJI Phantom 2 Vision+ and pages 12-16 and 45-50 of the DJI Inspire 

I User Manuals, attached hereto as Exhibit C and D. 

iii. The DJI Phantom 2 Vision+ and DJI Insnire 1 UASs Are Desi2:ned 

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

Loss Of The Control Link Or Navigation. 
When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs 

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

Phantom 2 Vision+ and DJI Inspire 1 UAs do 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 2 Vision+ 

U AS are set forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 

of the DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals, attached hereto as Exhibit 

C and D. 

iv. The DJI Phantom 2 Vision+ and DJI Inspire 1 GCS and Its 

Operation. 

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

Vision+ and DJI Inspire 1 GCS and flight control software is provided at pages 32 

through 43 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 of the 

DJI Inspire 1 User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are 

attached hereto as Exhibits C and D. 

b. Fli~ht Ooerations Of DJI Phantom 2 Vision+ and DJI Insoire 1 UASs 

Are Limited To The Line Of Sight Of A Certificated Pilot in Command 

With A Safety Observer. 

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

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

DJI Inspire 1 UASs. Additionally, a safety observer will assist all pilots during flight time. 

c. Fli~hts of DJI Phantom 2 Vision+ and DJI Insoire 1 UASs Will Be 

Conducted Pursuant To Specific Operating Limitations. 

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

Vision+ and DJI Inspire 1 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 2 Vision+ 

and DJI Insnire 1 Unmanned Aircraft Systems. Proposed operations of any 

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

2. t!AS onerations undet: this_ exemntion will be limited to conducting operations 

for the purpose of aenal vrdeo and photography. 

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

4. The UA must be ODerated 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 rec.lUest is made and approved by ATC. All altitudes 

reported to A TC must be in feet AGL. 

5. The U As must be ODerated within visual line of sight (VLOS) of the PIC at all 

times. This rec.lUires 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 

caoability. 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. 

~- The SO must not nerform 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 ooerating documents and the grant of exemption must be accessible during 

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

discreDancy exists between the conditions and limitations contained in the 

grant of exemntion and the txocedures 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 ODerating 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 onerator must also present updated and revised documents if it petitions 

for extension or amendment to the grant of exen11Jtion. If the operator 

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

FAA granted the exemDtion. then the oDerator must netition for amendment to 

its grant of exemntion. 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 f1ight. If the inspection reveals a condition that affects the 
safe cmeration of the UAS, the aircraft is orohibited 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 

oreflight insnection. 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 

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

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

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

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

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

relevant sections ofthe operating documents. 

13. The onerator must follow the UAS manufacturer's aircraft/component 

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

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

recmirements, in accordance with the operating documents. Maintenance, 

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

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

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

returning the UAS to service. 

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

Safety Bulletins. 

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

corrective action taken against discrepancies discovered between inspections. 

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

third- class medical certificate. 

18. The onerator may not nennit any PIC to operate unless the PIC meets the 

ooerator'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 

aonrooriate 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 oftraining the operator's PICs are 

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

only be conducted during dedicated training sessions. During training, 

oroficiency, and experience-building flights, all persons not essential for fliQ;ht 

ooerations 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 cmerations 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 ooerate within 5 nautical miles of an airoort reference ooint 

as denoted on a current F AA-oublished aeronautical chart unless a letter of 

agreement with that airoort's management is obtained, and the ooeration is 

conducted in accordance with a NOT AM as required by the ooerator'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 ooerated 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 

nre- determined location within the olanned ooerating area and land or be 

recovered in accordance with the operating documents. 

23. The PIC must abort the flight in the event ofunoredicted obstacles or 

emergencies in accordance with the operating documents. 

24. The PIC is orohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough oower to fly at normal cruising 

soeec~ t? the intended landing point and land the UA with 25% battery power 

remammg. 

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

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

onerations under the grant of exemotion. This COA will also require the 

onerator to request a Notice to Airman (NOT AM) not more than 72 hours in 

advance, but not less than 48 hours orior to the ooeration. All ooerations shall 

be conducted in accordance with airsoace requirements in the A TO issued 

COA including class of airspace, altitude level and potential transponder 

requirements. 

26. All aircraft onerated in accordance with the exemotion must be identified by 

serial number, registered in accordance with 14 C.F .R. oart 4 7, and have 

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

Subpart C. Markings must be as large as practicable. 

27. Before conducting ooerations, the radio frequency soectrum used for 

oneration and control of the UA must co molY 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 ooerating. 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 onerations must be conducted at least 500 feet from all nonoarticipating 

persons (persons other than the PIC, SO, operator trainees or essential 
persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are oresent that sufficiently protect 

nonnarticinating nersons fi-om 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 

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

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

an undue hazard, and; 

c. Onerations 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 onerations shall be conducted over private or controlled-access property 

with Dermission from the land owner/controller or authorized reDresentative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

33. Anv incident accident or flight operation that transgresses the lateral or 

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

must be reDorted to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be renorted to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: 

WWlN.ntsb.rrov. 

2. Reasons Whv an Exemotion from the Reouirements of Section 61.113(a) 

and (b) Would Not Adversely Affect Safety. 

SAS submits that the equivalent level of safety established by Section 61.113(a) 

and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs unless that PIC has demonstrated, by meeting minimum 

l1ight-hour and currency requirements, that the PIC is able to safely operate the DJI 

Phantom 2 Vision+ or DJI Inspire 1 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Considering SAS '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. 11 062); and the airmanship 

ski lis necessary to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS, SAS 
submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for SAS's specific proposed 

f1ight operations. 

The FAA has previously granted relieffrom 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). 

SAS will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 

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

or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS training and currency requirements, 

that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 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 U AS 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 SAS'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 Exemotion No. 11062, the FAA required that orior to conducting ooerations for 

the ouroose of motion oicture filming (or similar ooerations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.5l(b ), 25 hours 

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

oilot with a multi-rotor UAS. Prior to ooerations under Exemotion No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 
onerating the same make and model ofUAS to be used for operations under the 

exemntion. For clarification, the FAA considers these minimum hour 

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

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

included in the total25 hours ofUAS rotorcraft time. In addition to the hour 

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

90 davs (for currency purnoses). The FAA finds that at a minimum, the flighthour reouirements in Exemntion No. 11062 are appropriate to practice and build 

nroficiencv in the skills necessary to safely conduct the petitioner's proposed 

onerations. The FAA also finds that prior documented f1ight experience that was 

obtained in comnliance with applicable regulations would satisfy this requirement. 

Training, nroficiency, and experience-building f1ights can also be conducted 

under the grant of exemption to accomplish the required f1ight time. During 

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

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

Exemption No. 11138 at page 15. 

Accordingly, SAS will ensure safe operations by not allowing any PIC to operate 

the 0.11 Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has demonstrated, by 

meeting minimum f1ight-hour and currency requirements, that the PIC is able to safely 

operate the DJI Phantom 2 Vision+ or DJI Inspire 1 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 Whv an Exenmtion 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 f1ight, SAS will ensure that the DJI Phantom 2 Vision+ or DJI 

Inspire 1 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, 

I 1 1 1 2, 1 I 1 3 6, 1 1 13 8, 1 115 0, 1 1 15 3, 1115 6, 1115 7, 1115 8, 1115 9, 11160, 11161). 

4. Reasons Whv an Exemotion from the Requirements of Section 91.121 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained 
because the altitude information of the DJI Phantom 2 Vision+ and DJI Inspire 1 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 SAS's operation of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 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 Whv an Exemotion from the Requirements of Section 91.15l(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 2 Vision+ and DJI Inspire 1 UASs; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, SAS will 

ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ and DJI 

Inspire I 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 ofthe DJI Phantom 

2 Vision+ and DJllnspire 1 UASs; 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 2 Vision+ and DJI Inspire 1 UASs 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 Vision+ and 

DJ I Inspire 1 UASs \vill 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 

rei ief 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 Whv An Exemotion From The Reauirements Of Sections 

9l.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, SAS 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)(l) & (a)(2), and 91.417(a) & (b) will be met because 

SAS 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 SAS Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, SAS 

will document and maintain all maintenance records for the DJI Phantom 2 Vision+ and 

DJ I Inspire 1 U ASs. 

Since the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be inspected as 

prescribed by the operating documents, SAS will maintain the equivalent level of safety 
established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy ofthe DJI 

Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibit C and 

D; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Maintenance LOG will 

be an android based digital app that will be downloaded on a monthly basis to a hard 

paper copy. 

Likewise, the exemption sought will not adversely affect safety because SAS 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 

D.J I Phantom 2 Vision+ and DJI Inspire 1 UASs 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)(l) & (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 ofSAS's proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Inspire 1 

UASs. SAS submits that safety will not be adversely affected by granting exemption 

from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) 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 P AA Modernization and Reform Act of 

2012 (FMRA) and 14 C.P.R. § 21.16 entitled Special Conditions, SAS requests that the 

FAA prescribe special conditions for the intended operation of the DJI Phantom 2 

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

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

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

91.151 (b), 91.405(a), 91.407(a)(l ), 91.409(a)(l) & (a)(2), and 91.417(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. PMRA Section 333 sets forth the requirements for considering 

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

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

without airworthiness certification in accordance with any requirements that must be 

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

Likewise, the Administrator may prescribe special conditions pursuant to 14 

C.F.R. 

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

airworthiness regulations of 14 C.P.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 adecmate or annronriate safety standards for an aircraft aircraft engine, or 

orcmeller because of a novel or unusual design feature of the aircraft aircraft 

engine or oroneller. he orescribes soecial conditions and amendments thereto for 

the nroduct. The snecial conditions are issued in accordance with Part 11 of this 

chanter and contain such safety standards for the aircraft aircraft engine or 

nroneller as the P AA finds necessary to establish a level of safety equivalent to 

that established in the regulations. 

See 14 C.P.R.§ 21.16. 
Theref()re, in accordance with FMRA Section333 and 14 C.F.R. § 21.16, the 

FAA may prescribe special conditions for SAS's intended operation ofthe DJI Phantom 

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

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

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

91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

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

Rules From Which SAS Seeks Exemption: 

S'AS seeks exemotion kom the reauirements o(] 4 C.F.R Sections 61.1 JJ(a)&(b), 

9 !. 7(a). 9 !. J 21. 91.15 J (b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 

9 J .4 !7 (a) & (b). 

A Brief Description of the Nature of the Exemption SAS Seeks: 

This exemvtion ~will vermit SAS to commerciallv overate an Unmanned Aircraft 

Svstem (UAS) for the vurvose of conducting aerial video and photography over 

certain areas o/the United States. 

• Anv Additional Information, Views, or Arguments Available to Support 

SAS'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, SAS's request for exemption may 

be granted pursuant to the authority ofFMRA 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 

\viii 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, SAS will operate the DJI Phantom 2 Vision+ and 

DJl Inspire 1 UASs safely in the NAS, without creating a hazard to users of the NAS, or 

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

As set forth herein, SAS seeks an exemption pursuant to 14 C.F.R. § 11.61 and 

Section 333 of the FAA Modernization and Reform Act of2012 (FMRA), which will 

permit safe operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 

commercially, without an airworthiness certificate, for the limited purpose of conducting 

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

Petition, the FAA Administrator will be fultllling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, 

by allowing SAS to safely, efficiently, and economically operate the DJI Phantom 2 

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

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of2012, Section 333, SAS 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, 91.15l(b), 91.405(a), 91.407(a)(l), 

91.409(a)(J) & (a)(2), and 91.417(a) & (b), and permit SAS to operate the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs commercially for the purpose of conducting aerial video 

and photography over certain areas of the United States. 

Dated: May 22,2015 

Respectfully submitted, 

Lawrence Bridges 

Lawr~ri~ Lawrence Bridges 

Black Forest GunWurks, LLC 

DBA: SAS Defense 

DBA: Southern Air Services 

101 Demorest Square 

Demorest GA 30535 

706-778-1440 
Appendices: 

A- OJ! Phantom 2 Vision+ Soecifications Data Sheet 

B - OJ l Insoire 1 Soecifications Data Sheet 

C --OJ! Phantom 2 Vision+ User Manual 

0 - OJ 1 Inspire 1 User Manual 

APPENDIX-A 

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS 

SAS onlv utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

oroduction. OJI UASs are loaded with ground breaking software enabling the user to set 

oarameters which will not allow flight into controlled airsoace. Parameters can also be set 

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

oredetermined and set distance. In addition, DJI software movides real-time altitude and 

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

1.1 DJI Phantom 2 Vision+ 

I . I . I Aircraft 

I .1.1. I Suooorted Battery- DJI 5200mAH LiPo Battery 

1. I. 1.2 Weight (Battery & Prooellers Included)- 2lbs 11.810oz (1242g) 

1.1.1.3 Hover Accuracy (Readv to Flv)- Vertical: .8m; Horizontal: 2.5m 

1.1.1.4 Max Yaw Angular Velocity- 200 0/s 

I .1.1.5 Max Tilt Angel- 35 0 

I .1.1.6 Max Ascent Soeed- 6m/s 

I. I. I .7 Max Descent Sneed- 2m/s 

I. I .1.8 Max Flight Speed- 15m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

1.1.2.1 Working Current- Static: 750mA; Dynamic: 900mA 

1.1.2.2 Control Accuracy- ±0.03 0 

1.1.2.3 Controllable Range- Pitch: -900 - 00 

1.1.2.4 Maximum Angular Speed- Pitch: 900/s 

1.1.3 Camera 

I. 1.3.1 Ooerating Temoerature Range- 320F- 1040F (OOC- 400C) 

I .1.3.2 Sensor Size- 1/2.3" 

I. I .3.3 Effective Pixels- 14M 

I. I .3.4 Resolution- 4384x3288 

4. 1.3.5 HD Video Recording- 1080o30 & 720p 

4. I .3 .6 Recording Field of View- 110 0/85 0 

I. I .4 Transmitter 

1.1.4.1 Ooerating Frequency- 5.728GHz- 5.85GHz 

I. I .4.2 Communication Distance (unobstructed)- FCC Compliance: 800m 

1.1.4.3 Receiver Sensitivity (1 %PER) - -93dBm 
1.1.4.4 Transmitter Power- FCC Compliance: 1OOm W 

1.1.4.5 Working Voltage- 120mA@3.7V 

1.1 .5 Range Extender 

1.1.5.1 Onerating Frequency- 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed)- 500-700m 

1.1.5.3 Transmitter Power- 20dBm 

1.1.5.4 Power Consumption- 2W 

APPENDIX-B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

SAS onlv utilizes safe and reliable UASs. DJI is an industry leader in small UAS 

nroduction. DJI UASs are loaded with ground breaking software enabling the user to set 

narameters which will not allow flight into controlled airspace. Parameters can also be set 

to limit llir.d1t to no higher than a nredetermined and set altitude as well as limit flight to a 

])redetermined and set distance. In addition, DJI software nrovides real-time altitude and 

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

2.2 DJI Inspire 1 

2.2.1 Aircraft 

2.2.1.1 Model- T600 

2.2.1.2 Weight (Batterv Included)- 61bs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracv (GPS Mode)- Vertical: 0.5m: Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity- Pitch: 300°/s; Yaw: 150°/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 -4m/s 

2.2.1.8 Max Speed- 22m/s (A TTl mode, no wind- NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude- 4500m 

2.2.1.10 Max Wind Resistance- 10m/s 

2.2.1.11 Max Flight Time- Approximately 18 minutes 

2.2.1.12 Motor Model- DJI 3510 

2.2.1.13 Propeller Model- DJI1345 

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

2.2.1.15 Dimensions -17 W' x 17 %" x 12" 

2.2.2 Gimbal 

2.2.2.1 Model- ZEN MUSE 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- X3 

2.2.3.2 Model- FC350 

2.2.3.3 Total Pixels -12.76M 
2.2.3 Camera 

2.2.3.1 Name -X3 

2.2.3.2 Model- FC350 

2.2.3.3 Total Pixels -12.76M 

2.2.3.4 Effective Pixels -12.4M 

2.2.3.5 Image Max Size- 4000x3000 

2.2.3.6 ISO Range -100-3200 

2.2.3. 7 Field of View- 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