September 16, 2015

Submission by: Brock Holliday

Flagship Drones

44-179 Elba Court

Palm Desert, California 92260

U.S. Department of Transportation Docket

Management System

1200 New Jersey Ave SE

Washington, DC 20590

RE: Exemption request under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam,

I have 26 years of Part 135 commercial helicopter pilot experience. I am currently flying as a Part 135 

EMS helicopter pilot with the following ratings: commercial helicopter, instrument, and helicopter CFI 

rating with 10,800 helicopter flight hours, a second-class FAA Medical, and a valid California driver's 

license. I am seeking a FAA 333 exemption for my new company. 

Flagship Drones seeks exemption from the requirements of 14 C.F.R. 21, subpart H; 45.23(b), 

61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(a) and (b), 91.109, 91.119, 91.121, 91.151(b), 91.203(a) 

and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (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 Flagship Drones to operate an Unmanned Aircraft System (UAS) within the 

United States for the commercial purpose of conducting:

flare stack inspection

real estate

utility-power generation system inspections and patrolling

pipeline inspection and patrolling

film making, cinematography, video, and photography

closed-set motion picture filming

precision agriculture

wildlife and forestry monitoring

aerial surveying

construction site inspection and monitoring

Public Entity Support Operations

UAS Flight Instruction
Name:

Brock Holliday

Flagship Drones

44-179 Elba Court

Palm Desert, CA 92260

(760)567-2680

I, Brock Holliday, operator of Flagship Drones, will operate a DJI Phantom 3 and a DJI Inspire 1, UAS 

weighing less than 7 lbs at takeoff, and can take photos and videos using the on board camera. See 

attachments below. 

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

The Aircraft are battery powered and serve as a safe, efficient, and economical alternative to the 

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

aircraft needed to perform aerial acquisitions, an exemption allowing the use of petitioner’s UAS's

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 Aircraft do not require 

an airport to takeoff and 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 and Inspire 1

UAS

Currently being in the helicopter commercial industry for 26 years, I understand the hazards 

between commercial aircraft and UAS systems. UAS systems 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 petitioner's UAS 

will produce no air pollution and is the most environmentally conscious alternative to today's airplanes 

and helicopters that are typically utilized for aerial video and photography and carry many gallons of 

fuel on board. Our UAS systems will also eliminate noise pollution and are propelled by battery 

powered electric motors, rather than the traditional turbine or combustion engine. By using UAS 

systems to perform aerial work, the substantial risk to life and property in the air and on the ground, 

will be substantially reduced or completely eliminated. This exemption will be conducted as outlined 

in the proposed rule set in motion on 02/23/2015 in docket FAA-2015-0150.

Operational Limitations: Visual line-of-sight (VLOS) only; the unmanned aircraft must remain 

within VLOS of the operator or visual observer

At all times the small unmanned aircraft must remain close enough to the operator for the operator to 

be capable of seeing the aircraft with vision unaided by any device other than corrective lenses.

Small unmanned aircraft may not operate over any persons not directly involved in the operation.

Daylight-only operations (official sunrise to official sunset, local time)

Must yield right-of-way to other aircraft, manned or unmanned.

May use visual observer (VO) but not required

First-person view camera cannot satisfy “see-and-avoid”requirement, but can be used as long as 

requirement is satisfied in other ways.
Maximum airspeed of 100mph (87 knots)

Maximum altitude of 500 feet above ground level

Minimum weather visibility of 3 miles from control station

No operations are allowed in Class A (18,000 feet and above) airspace

Operations in Class B, C, D, and E airspace are allowed with the required ATC permission

Operations in Class G airspace are allowed with ATC permission

No persons may act as an operator or VO for more than one unmanned aircraft operation at one time

No careless or reckless operations

Requires preflight inspection by operator

A person may not operate a small unmanned aircraft if he or she knows or has reason to know of any

physical or mental condition that would interfere with the safe operation of a small UAS.

I request an exemption from 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance 

Inspections since they only apply to aircraft with an airworthiness certificate. I will, however, perform 

a preflight inspection of my UAS before each flight as outlined in the operating documents.

I request exemption from 91.151. The Pilot in Command will abide by the following personal 

protocols and controls:

Operator will only operate in reasonably safe environments that are strictly controlled, are away from 

power lines, elevated lights and airports. Operator will conduct extensive preflight inspections and 

protocols as outlined in the operating documents.

Operate the UAS below 500 feet and within a radius distance of 1500 feet from the controller while 

maintaining direct line of sight visual observation (VLOS)

Land the UAS before the manufacturer's recommended minimum battery level.

Use the UAS' GPS flight safety feature whereby the aircraft raises to a predetermined safe altitude 

and then returns to point of take off should communication with the remote control operator is lost

Contact respective airports and/or Flight Standard District Offices if operations will be within 5 miles 

to advise them of my estimated flight time, flight duration, elevation of flight and other pertinent 

information.

Have procedures in place to abort flights in the event of a safety breach or potential danger.

91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. I assert that since 

there is currently no certificate applicable to my operation, this regulation is inapplicable.

91.119 prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be 

operated at lower altitudes in certain condition. Operator will not operate the UAS above the altitude 

of 500 feet above ground level (AGL) and will also only operate in safe areas away from the public and 

traffic, thus providing a level of safety at least equivalent to or below those in relation to minimum safe 

altitudes.

91.121 Altimeter Settings is inapplicable since my UAS utilizes electronic GPS with a barometer 

sensor

Very Respectfully,
Brock W Holliday

President, Flagship Drones

44-179 Elba Court

Palm Desert, CA 92260

760-567-2680
Aircraft

Model Inspire 1

T600

Weight (Battery Included)

2935 g

Hovering Accuracy (GPS mode)

Vertical: 0.5 m

Horizontal: 2.5 m

Max Angular Velocity

Pitch: 300°/s

Yaw: 150°/s

Max Tilt Angle

35°

Max Ascent Speed

5 m/s

Max Descent Speed

4 m/s

Max Speed

22 m/s (ATTI mode, no wind)

Max Flight Altitude

4500 m

Max Wind Speed Resistance

10 m/s

Max Flight Time

Approximately 18 minutes
Motor Model

DJI 3510

Propeller Model

DJI 1345

Indoor Hovering

Enabled by default

Operating Temperature Range

-10° to 40° C

Diagonal Distance

559 to 581 mm

Dimensions

438x451x301 mm

Power Spectral Density

9.06mW/MHz

Gimbal

Model

ZENMUSE X3

Output Power (with camera)

Static: 9 W

In Motion: 11 W

Operating Current

Station: 750 mA

Motion: 900 mA

Angular Vibration Range

±0.03°
Mounting

Detachable

Controllable Range

Pitch: -90° to +30°

Pan: ±320°

Mechanical Range

Pitch: -125° to +45°

Pan: ±330°

Max Controllable Speed

Pitch: 120°/s

Pan: 180°/s

Camera

Name

X3

Model

FC350

Total Pixels

12.76M

Effective Pixels

12.4M

Image Max Size

4000x3000

ISO Range

100-3200 (video)

100-1600 (photo)

Electronic Shutter Speed
8s - 1/8000s

FOV (Field of View)

94°

CMOS

Sony EXMOR 1/2.3”

Lens

20mm (35mm format equivalent)f/2.8 focus at ∞

9 Elements in 9 groups

Anti-distortion

Still Photography Modes

Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes

UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

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

Max Bitrate of Video Storage

60 Mbps

Supported File Formats

FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range

0° to 40° C
Remote 

Controller

Name

C1

Operating Frequency

922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (outdoor and unobstructed)

2 km

EIRP

10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port

USB, mini-HDMI

Power Supply

Built-in battery

Charging

DJI charger

Dual User Capability

Host-and-Slave connection

Mobile Device Holder

Tablet or Phone

Max Mobile Device Width

170mm

Output Power

9 W
Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0-40° C

Battery

6000 mAh LiPo 2S

Charger

Model

A14-100P1A

Voltage

26.3 V

Rated Power

100 W

Battery 

(Standard)

Name

Intelligent Flight Battery

Model

TB47

Capacity

4500 mAh

Voltage

22.2 V

Battery Type
LiPo 6S High voltage battery

Energy

99.9 Wh

Net Weight

570 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W
Battery 

(Optional)

Name

Intelligent Flight Battery

Model

TB48

Capacity

5700 mAh

Voltage

22.8 V

Battery Type

LiPo 6S

Energy

129.96 Wh

Net Weight

670 g

Operating Temperature Range

-10° to 40° C

Storage Temperature Range

Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range

0° to 40° C

Max Charging Power

180 W

Vision Velocity Range
Positioning Below 8 m/s (2 m above ground)

Altitude Range

5-500 cm

Operating Environment

Brightly lit (lux > 15) patterned surfaces

Operating Range

0-250 cm

DJI GO App

Mobile Device System Requirements

iOS 8.0 or later, Android 4.1.2 or later

Supported Mobile Devices

* Compatible with iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + 

Cellular, iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + 

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized for 

iPhone 5s, iPhone 6, and iPhone 6 Plus.

* Compatible with Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, 

Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia Z7 mini, 

SONY Z3 EXPERIA, MI 3, MI PAD

*Support for additional Android devices available as testing and development 

continues.

Phantom 3 Specs
Aircraft

Weight (including battery and propellers)

1280 g

Diagonal size (including propellers)

590 mm

Max Ascent Speed

5 m/s

Max Descent Speed

3 m/s

Hover Accuracy

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

 Horizontal: +/- 1.5 m

Max Speed

16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level

6000 m

Operating Temperature

0°C to 40°C

GPS Mode

GPS/GLONASS

Camera

Sensor

Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 12.76 M)

Lens

FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range
100-3200 (video) 100-1600 (photo)

Shutter Speed

8s -1/8000s

Image Max Size

4000 x 3000

Still Photography Modes

 Single Shot

 Burst Shooting: 3/5/7 shots

 Auto Exposure Bracketing (AEB): 3/5

 Bracketed Frames at 0.7EV Bias

 Time-lapse

Video Recording Modes

Phantom 3 Professional

 UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Phantom 3 Advanced

 2.7K: 2704 x1520p 24/25/30 (29.97)

 FHD: 1920x1080p 24/25/30/48/50/60

 HD: 1280x720p 24/25/30/48/50/60

Supported SD Card Types

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate of Video Storage

Phantom 3 Professional

60 Mbps

Phantom 3 Advanced
40 Mbps

Supported File Formats

 FAT32/exFAT

 Photo: JPEG, DNG

 Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature

0°C to 40°C
Gimbal

Controllable Range

Pitch -90° to +30°

Stabilization

3-axis (pitch, roll, yaw)

Vision 

Positioning

Max Velocity

Less than 8 m/s (when 2 m above ground)

Altitude Range

30 cm-300 cm

Operating Range

30 cm-300 cm

Operating Environment

Surface with clear pattern and adequate lighting (Lux > 15)

Remote 

Controller

Operating Frequency

2.400 GHz-2.483 GHz

Max Distance

2000m (outdoors and unobstructed)

Video Output Port

USB

Operating Temperature

0°C- 40°C

Battery

6000 mAh LiPo 2S

Mobile Device Holder

For tablet or phone
Receiver Sensitivity (1%PER)

-101 dBm ±2 dBm

Transmitter Power (EIRP)

 FCC: 20 dBm

 CE: 16 dBm

Working Voltage

1.2 A @7.4 V

Battery 

Charger

Voltage

17.4 V

Rated Power

Phantom 3 Professional

 100 W

Phantom 3 Advanced

 57 W

Intelligent 

Flight Battery

Capacity

4480 mAh

Voltage

15.2 V

Battery Type

LiPo 4S

Energy

68 Wh

Net Weight

365 g
Max Flight Time

Approximately 23 minutes

Operating Temperature

-10°C to 40°C

Max Charging Power

100 W

App / Live 

View

Mobile App

DJI GO

EIRP

100mW

Power Spectral Density

6.9mW/MHz

Live View Working Frequency

2.4GHz ISM

Live View Quality

720P @ 30fps (depending on conditions and mobile device)

Latency

220ms (depending on conditions and mobile device)

Required Operating Systems

 iOS 8.0 or later

 Android 4.1.2 or later

Recommended Devices

 iOS: iPhone 5s, iPhone 6, iPhone 6 Plus, iPad Air, iPad Air Wi-Fi + Cellular, 

iPad mini 2, iPad mini 2 Wi-Fi + Cellular, iPad Air 2, iPad Air 2 Wi-Fi + 

Cellular, iPad mini 3, and iPad mini 3 Wi-Fi + Cellular. This app is optimized 

for iPhone 5s, iPhone 6, and iPhone 6 Plus

 Android: Samsung tabs 705c, Samsung S6, Samsung S5, Samsung NOTE4, 
Samsung NOTE3, Google Nexus 9, Google Nexus 7 II, Ascend Mate7, Nubia 

Z7 mini, SONY Z3 EXPERIA, MI 3, MI PAD

*Support for additional Android devices available as testing and development 

continues.