Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 1 of 21

November 25, 2015

U.S. Department of Transportation 

Docket Operations

West Building Ground Floor, Room w12-140

1200 New Jersey Ave., SE 

Washington, DC 20590

RE: Petition for Section 333 Exemption Under FAA Modernization and Reform Act of 2012

Petitioner : Leading Edge Aviation Resources, LLC 

Petitioner’s sUAS(s) Models : DJI Inspire 1; DJI Phantom 2 Vision+; 

DJI Phantom 3; DJI S900;

3D Robotics X8 M

Petitioner’s sUAS(s) Operations : Aerial Imagery; Aerial Photography; 

Aerial Videography; 3D Mapping; Aerial 

Agricultural, Environmental, Structural, 

and Exploratory Mapping; Agricultural 

Spraying; Aerial Surveying; Education, 

Research and Development

Regulations Requiring Exemption : 14 CFR §§ 61.23(a) and (c); 

14 C.F.R. §§ 61.101(e)(4) and (5)

14 C.F.R. § 61.113(a); 

14 C.F.R. §61.315(a)

14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119(c)

14 C.F.R. §91.121; 

14 C.F.R. §91.151(a)(1)

14 C.F.R. §91.405(a); 

14 C.F.R. §91.407(a)(1)

14 C.F.R. §§ 91.409(a)(1) and (2); and

14 C.F.R. 91.417(a) and (b)

To whom it may concern, 

On behalf of Leading Edge Aviation Resources, LLC (hereinafter “L.E.A.R.”), a Lakeland, FL

company specializing in aerial imagery, aerial photography, aerial videography, 3D mapping, 
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 2 of 21

aerial agricultural, environmental, structural, and exploratory mapping, and agricultural spraying,

aerial surveying, and research and development, the undersigned counsel for L.E.A.R. hereby 

applies for Section 333 exemption pursuant to the FAA Modernization and Reform Act of 2012, 

Public Law 112-95 (P.L. 112-95), and 14 C.F.R. Part 11. 

The owner and operator for Leading Edge Aviation Resources, Mr. Anthony G. Ison, holds a 

Private Pilot, Airplane, Single Engine, Land (PVT) certificate. Consequently, Mr. Ison and his 

employees understand the importance of safe flight operations and are acutely aware of the 

importance of complying with all Federal Aviation Regulations (F.A.R.s). As such, L.E.A.R., 

through the careful oversight and tutelage of Mr. Ison, will ensure that all sUAS flight operations 

are conducted in the safest possible manner. To that end, L.E.A.R. will comply with any flight or 

atmospheric condition limitations imposed upon the commercial operation of all sUAS flight.

This petition will address the following topics, as they relate to L.E.A.R. commercial sUAS flight 

operations: the nature of L.E.A.R. commercial drone operations, as well as the particular sUAS 

models for which L.E.A.R. seeks exemption; L.E.A.R.’s proposed sUAS flight operations and

conditions; privacy concerns; public interest and safety concerns; and, the above specified F.A.R.s 

requiring exemption. Under Section 333(b)(1), L.E.A.R.’s petition will give the FAA good cause 

to issue a Certificate Of Waiver or Authorization by showing that the size, weight, speed, 

operational capacity, proximity to airports and populated areas, and operations within the Visual 

Line of Sight of the Pilot in Command and Visual Observer of L.E.A.R.’s sUAS models neither 

creates a hazard to users of the National Airspace System or public nor poses a threat to national 

security. 

Additionally, this petition will prove that L.E.A.R.’s flight operations for the commercial usage of 

its sUAS models provides an equivalent level of safety when compared to the F.A.R.s requiring 

exemption. To that end, this petition will highlight some of the numerous, granted petitions for 

Section 333 exemption for similar commercial operations of L.E.A.R.’s sUAS models.

Please refer to the “Table of Contents” beginning on page three (3) to assist your review of 

L.E.A.R.’s petition for Section 333 exemption. If we may provide additional insight or information 

regarding L.E.A.R.’s petition, please do not hesitate to contact The Ison Law Group at 863-712-

9475 or Christopher@thepilotlawyer.com.

Sincerely, 

THE ISON LAW GROUP

Christopher Ison, Esq.

Enclosures

TABLE OF CONTENTS
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 3 of 21

I. Glossary of Terms ................................................................................4

II. Publishable Summary ................................................................................5

III. Petitioner’s Contact Information ..............................................................5

IV. L.E.A.R. Overview ................................................................................6

V. L.E.A.R. sUAS Models .......................................................................6

a. DJI Inspire 1 Specifications ..............................................................6

b. DJI Phantom 2 Vision+ Specifications ............................................9

c. DJI Phantom 3 Specifications ...................................................10

d. DJI S900 ..............................................................................12

e. 3D Robotics Specifications ............................................................13

VI. Flight Conditions and Operating Procedures ...................................................14

VII. Privacy .......................................................................................17

VIII. Public Interest and Safety .....................................................................17

IX. Regulations from Which Exemption is Requested ..........................................18

a. 14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration ...............18

b. 14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations ...............18

c. 14 C.F.R. § 61.113(a): Private Pilot Privileges and Limitations: Pilot in Command ......18

d. 14 C.F.R. §61.315(a): What Are The Privileges and 

Limits of My Sport Pilot Certificate? ...................................................18

e. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness...................................................19

f. 14 C.F.R. § 91.119(c): Minimum Safe Altitude: General ..........................................19

g. 14 C.F.R. §91.121: Altimeter Settings ............................................................20

h. 14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions ...............20

i. 14 C.F.R. §91.405(a): Maintenance Required ...................................................20

j. 14 C.F.R. §91.407(a)(1): Operation After Maintenance, 

Preventative Maintenance, Rebuilding, Or Alteration ..................................20

k. 14 C.F.R. §§ 91.409(a)(1) and (2): Inspections ...................................................20

l. 14 C.F.R. 91.417(a) and (b): Maintenance Records ..........................................20

GLOSSARY OF TERMS
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 4 of 21

Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United 

States Code (49 USC) § 40102).

National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities, 

equipment and services, airports or landing areas; aeronautical charts, information and services; 

rules, regulations and procedures, technical information, and manpower and material.

Operational Control: with respect to a flight, means the exercise of authority over initiating, 

conducting or terminating a flight (14 CFR § 1.1).

Pilot in Command (PIC): the person who has final authority and responsibility for the operation 

and safety of the flight; has been designated as PIC before or during the flight; and holds the 

appropriate category class and type-rating, if appropriate, for the conduct of the flight (14 CFR § 

1.1).

Small Unmanned Aircraft System (sUAS): an unmanned aircraft and associated elements, 

including communication links and the components that control the unmanned aircraft, that are 

required for the pilot in command to operate safely and efficiently in the national airspace system 

(P.L. 112-95, Section 331), weighing less than 55 pounds, including payload. 

UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air Traffic 

Organization to an operator for a specific unmanned aircraft activity.

Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) visual 

contact between a pilot in command and an unmanned aircraft sufficient to maintain safe 

operational control of the aircraft, know its location, and be able to scan the airspace in which it is 

operating to see and avoid other air traffic or objects aloft or on the ground.

PUBLISHABLE SUMMARY
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 5 of 21

Pursuant to 14 C.F.R §11.81(f), should the FAA require a publishable summary for the Federal 

Register, Leading Edge Aviation Resources, LLC (“L.E.A.R.”), submits the following 

information:

L.E.A.R. seeks exemption from the following Federal Aviation Regulations (F.A.R.s): 

14 CFR §§ 61.23(a) and (c); 14 C.F.R. §§ 61.101(e)(4) and (5); 14 C.F.R. § 

61.113(a); 14 C.F.R. §61.315(a); 14 C.F.R. § 91.7(a); 14 C.F.R. § 91.119(c); 14 

C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.405(a); 14 C.F.R. 

§91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b).

L.E.A.R. seeks exemption from the above listed F.A.R.s for the purpose of commercially operating 

Small Unmanned Aircraft Systems (sUAS), to wit: the DJI Inspire 1, DJI Phantom 2 Vision+, DJI 

Phantom 3, DJI S900 and the 3D Robotics X8-M. L.E.A.R. intends to commercially operate these

sUAS models for aerial imagery, aerial photography, aerial videography, 3D mapping, aerial 

agricultural, environmental, structural, and exploratory mapping, agricultural spraying, aerial 

surveying, education, and research and development. As such, this petition will prove that 

L.E.A.R.’s flight operations for the commercial usage of this sUAS model provides an equivalent 

level of s afety when compared to the F.A.R.s requiring exemption. 

In support of this petition, L.E.A.R. notes that the FAA has already granted numerous exemptions 

for similar commercial operators of these above mentioned sUAS models. To that end, L.E.A.R.’s 

petition will highlight some of the numerous, granted petitions for Section 333 exemption for 

similar commercial operations of the foregoing sUAS models.

Under Section 333(b)(1) of the FAA Modernization and Reform Act of 2012, L.E.A.R.’s petition 

will give the FAA good cause to issue a Certificate Of Authorization by showing that the size, 

weight, speed, operational capacity, proximity to airports and populated areas, and operations 

within the Visual Line of Sight of the Pilot in Command and Visual Observer of L.E.A.R.’s sUAS 

models neither creates a hazard to users of the National Airspace System or public nor poses a 

threat to national security. To that end, L.E.A.R. seeks exemption from the above specified 

F.A.R.s as L.E.A.R.’s flight operations provide an equivalent level of safety when compared to 

the F.A.R.s to be exempted. L.E.A.R. will adhere to any flight or atmospheric condition limitation 

imposed by the FAA.

PETITIONER’S CONTACT INFORMATION

Petitioner: Counsel for Petitioner:

Anthony G. Ison, Owner The Ison Law Group

Leading Edge Aviation Resources, LLC 2073 US Hwy 92 West, Suite 104

2073 US Hwy 92 West, Suite 104 Winter Haven, FL 33881

Winter Haven, FL, 33881 Phone: 863-712-9475

Phone: 863-712-9472 Email: Christopher@thepilotlawyer.com

LEADING EDGE AVIATION RESOURCES, LLC’s PETITION 
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 6 of 21

FOR SECTION 333 EXEMPTION 

Leading Edge Aviation Resources 

Overview

Leading Edge Aviation Resources (hereinafter “L.E.A.R.”) is a Lakeland, Florida, based company 

specializing in aerial imagery, aerial photography, aerial videography, 3D mapping, aerial 

agricultural, environmental, structural, and exploratory mapping, agricultural spraying, aerial 

surveying, education, and research and development. L.E.A.R. provides services to various 

companies requiring aerial real estate, agricultural, environmental, structural, and exploratory 

mapping and photography. Furthermore, L.E.A.R. provides services to companies requiring aerial 

photography and event photography.

As detailed below, L.E.A.R. will only allow commercial sUAS operations of its sUAS models by 

certificated airmen, holding at the bare minimum a sport pilot certificate. Currently, Mr. Anthony 

Ison, owner of L.E.A.R., holds his Private Pilot, Single Engine, Land certificate. Mr. Ison has 

approximately 100 hours of Pilot-In-Command time in fixed-wing aircraft, as well as roughly 5 

hours of Pilot-In-Command time in a rotorcraft aircraft. Consequently, Mr. Ison and the employees 

of L.E.A.R. understand safe flight operations and will apply that knowledge during all commercial 

sUAS operations. 

Based upon L.E.A.R.’s intended use and proposed flight operations and conditions limitations, 

L.E.A.R. would like an exemption from the following Federal Aviation Regulations (F.A.R.s) to 

commercially operate the above specified sUAS models: 14 CFR §§ 61.23(a) and (c); 14 C.F.R. 

§§ 61.101(e)(4) and (5); 14 C.F.R. § 61.113(a); 14 C.F.R. §61.315(a); 14 C.F.R. § 91.7(a); 14 

C.F.R. § 91.119(c); 14 C.F.R. §91.121; 14 C.F.R. §91.151(a)(1); 14 C.F.R. §91.405(a); 14 C.F.R.

§91.407(a)(1); 14 C.F.R. §§ 91.409(a)(1) and (2); and 14 C.F.R. 91.417(a) and (b).

L.E.A.R.’s sUAS Model

L.E.A.R.’s requested exemption from the above specified F.A.R.s will allow for L.E.A.R.’s use of 

the DJI Inspire 1, DJI Phantom 2 Vision+, DJI Phantom 3, DJI S900 and the 3D Robotics X8-M 

which L.E.A.R. intends to use for commercial aerial imagery, aerial photography, aerial 

videography, 3D mapping, aerial agricultural, environmental, structural, and exploratory mapping, 

agricultural spraying, aerial surveying, education, and research and development within the United 

States of America. These sUAS models are either similar to, or the same as, sUAS model that the 

FAA has already granted exemption for similar commercial flight operations in Exemption 

Numbers, 11693, 11109, and 11213, 11824, 11617, 11699, 11693, 11062, 11109, 11112, 11213, 

11656, 11845, and 12042. 

DJI Inspire 1 and DJI Phantom 2 Vision+

The DJI Phantom 2 Vision+ and DJI Inspire 1 are quad-copter sUAS models, capable of providing 

hover flight in both the vertical and horizontal planes. As such, both sUAS models provide 

excellent maneuverability and ease of control for the PIC. The ease with which a PIC can control 

these sUAS models is evidenced by the fact that both sUAS models are commercially available 

for RC hobbyists, requiring no training or experience prior to flight. 
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 7 of 21

Both the DJI Phantom 2 Vision+ and DJI Inspire 1 additionally provide excellent situational 

awareness for the PIC. Both sUAS models allow the PIC to determine the exact altitude of the 

sUAS via GPS technology and monitoring. In addition, both sUAS models provide the PIC with 

the ability to monitor the available remaining battery life, allowing the PIC to make informed, safe 

decisions regarding the duration and continuation of a particular flight.

L.E.A.R.’s primary objective with each commercial flight is the safe return of the sUAS without 

injury to property or person. Both the DJI Phantom 2 Vision+ and DJI Inspire 1 incorporate unique 

operating modes that provide for the safe return of the sUAS should the PIC experience a loss of 

signal connectivity between the sUAS model’s transmitter and receiver. The DJI Inspire 1 

incorporates three safe modes in such a situation: Failsafe, Return to Home, and Dynamic Home 

Point. Likewise, the DJI Phantom 2 Vision+ incorporates a failsafe function should the sUAS 

experience loss of signal connectivity. Both models will guide the sUAS back to a predetermined, 

safe landing zone should the model experience issues. 

Below are the specifications for these sUAS models:

DJI Inspire 1:

Aircraft

Weight (Battery Included): 2935 grams

Hovering Accuracy (P Mode): Vertical: 0.5m; Horizontal: 2.5m

Max Angular Velocity: Pitch: 300֯/s; Yaw: 150/s֯

Max Tilt Angle: 35֯

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: -10֯C to 40֯C

Diagonal Distance: 559 to 581 mm

Dimensions: 438x451x301mm

Gimbal

Model: ZENMUSE X3

Output Power (with Camera): Static: 9W; In Motion: 11W

Operating Current: Station: 750mA; Motion: 900mA

Angular Vibration Range: ±0.03֯

Mounting: Detachable

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

Mechanical Range: Pitch: -125֯to +45֯; Pan: ±330֯

Max Controllable Speed: Pitch: 120֯/s; Pan: 180/s֯
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

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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)

Remote Controller

Name: C1

Operating Frequency: 5.725~5.825GHz; 2.400~2.483GHZ

Transmitting Distance: 2km (Outdoor and Unobstructed)

EIRP: 10dBM@900, 12dBm@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 Devise Holder: Tablet or Smart Phone

Output Power: 9W

Operating Temperature Range: -10֯C to 45֯C

Charging Temperature Range: 0-40֯C

Battery: 6000 mAh LiPo 2S

Charger

Model: A11-100P1A

Voltage: 26.3V

Rated Power: 100W

Battery (Standard)

Name: Intelligent Flight Battery

Model: TB47

Capacity: 4500mAh

Voltage: 22.2V

Battery Type: LiPo 6S High voltage battery

Energy: 99.9Wh

Net Weight: 570g

Operating Temperature Range: -10֯C to 40֯C

Charging Temperature Range: 0-40֯C

Max Charging Power: 180W
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 9 of 21

DJI Phantom 2 Vision+: 

Aircraft Specifications:

Supported Battery: DJI 5200mAh Li-Po Battery

Weight (Battery & Propellers included): 1242 grams

Recommended Payload: ≤1300 grams

Maximum Payload: 1350 grams

Hovering Accuracy (Ready to Fly): Vertical: 0.8m; Horizontal: 2.5m

Max Yaw Angular Velocity: 200֯/second

Max Tiltable Angle: 35 ֯

Max Ascent/Descent Speed: Ascent: 6 m/s; Descent: 2 m/s

Max Flight Speed: 15 m/s

Motor Diagonal Length 350 mm

3-axial Stabilized Gimbal Specifications:

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

Control Accuracy: ±0.03֯

Controllable Range: Pitch: -90֯- 0֯

Maximum Angular Speed: Pitch: 90֯/second

Camera

Operating Environment Temperature: 0֯C - 40֯C

Sensor Size: 1/2.3”

Effective Pixels: 14 Megapixels

Resolution: 4384x3288

HD Recording: 1080p30/1080i60

Recording FOV: 110֯/85֯

Remote Controller

Operating Frequency: 5.728 GHz – 5.85 GHz

Communication Distance (open area): CE Compliance: 400m; FCC Compliance: 800m

Receiver Sensitivity (1%PER): -93dBm

Transmitting Power (EIRP): CE Compliance: 25mW; FCC Compliance: 100mW

Working Current/Voltage: 120mA@3.7V

Battery: 2000mAh rechargeable LiPo battery

Range Extender

Operating Frequency: 2412MHz-2462MHz

Communication Distance (open area): 500m-700m

Transmitting Power: 20dBm

Power Consumption: 2W

DJI Phantom 3 
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 10 of 21

The DJI Phantom 3 is a quad-boom, four (4) motor sUAS, capable of providing hover flight in 

both the vertical and horizontal planes. As such, the DJI Phantom 3 provides excellent 

maneuverability and ease of control for the PIC. The ease with which a PIC can control this sUAS 

model is evidenced by the fact that the DJI Phantom 3 is commercially available for RC hobbyists, 

requiring no training or experience prior to recreational usage. 

Like previous DJI Phantom predecessors, the DJI Phantom 3 provides innovative features that 

culminate in a safe flying experience. For example, the Phantom 3 now uses DJI’s Intelligent Flight 

Battery, featuring upgraded battery cells and an advanced power management system. Likewise, 

the flight controller found in the Phantom 3 has been updated to provide a safer, more reliable 

experience through a newly implemented flight recorder. Moreover, the flight controller now uses 

a Vision Positioning System, which, when combined with the remote controller’s flight recorder, 

enhances hovering precision when flying in environments where GPS is unavailable. 

In an effort to ensure the safety of each flight, L.E.A.R. chose the DJI Phantom 3 due to the 

enhanced safety features found in this sUAS. The DJI Phantom 3 boasts various Return-to-Home 

(RTH) modes which bring the sUAS back to the last recorded Home point, allowing for the safe 

landing and return of the sUAS, should an unforeseen emergency arise. As such, the DJI Phantom 

3 allows for Smart RTH, Low Battery RTH, and Failsafe RTH. 

In Smart RTH, the DJI Phantom 3 will automatically return to the last recorded Home Point. 

During this operation, the PIC may use the remote controller’s control sticks to control the sUAS 

to avoid any collisions. The Low Battery RTH failsafe is triggered when the DJI Intelligent Flight 

Battery is depleted to a point that may affect the safe return on the sUAS. When the DJI Pilot App 

notifies the PIC that the battery is low, the sUAS will begin the RTH procedure, unless otherwise 

prompted by the PIC. Lastly, the Failsafe RTH allows the sUAS to return to a pre-recorded location 

if the remote controller signal is lost for more than three (3) seconds. If the PIC regains remote 

controller connectivity, the PIC may resume control of the sUAS and continue the flight. 

In addition to the above safety features, the DJI Phantom 3 also incorporates an anti-drop kit for 

the gimbal. The anti-drop kit ensures that the gimbal and camera remain connected to the sUAS, 

so as to preclude the possibility of the gimbal/camera from disconnecting during flight operations. 

Moreover, the DJI Pilot App provides an incredible wealth of information that will supplement the 

PIC’s situational awareness while operating the DJI Phantom 3 by providing the following 

information: current flight mode, GPS signal strength, system status, battery level indicator, 

remote controller signal strength, flight telemetry (height, distance, and airspeed), and area map. 

By enhancing the PIC’s situational awareness, the PIC will be able to focus on safe flight 

operations, thereby reducing the likelihood of an incident which would lead to property damage 

or injury to persons. 

Below are the specifications for this sUAS model:

DJI Phantom 3:

Aircraft:
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Leading Edge Aviation Resources, LLC

Page 11 of 21

Weight: 1280 g

Maximum Ascent Speed: 5 m/s

Maximum Descent Speed: 3 m/s

Maximum Speed: 16 m/s

Maximum Flight Altitude: 6000 m

Maximum Flight Time: 23 minutes (Approximately)

Operating Temperature Range: 0֯C to 40C֯

GPS: GPS/GLONASS

Gimbal:

Controllable Range: Pitch: -90֯to +30֯

Vision Positioning:

Velocity Range: <8 m/s (Altitude 2 m)

Altitude Range: 30 cm – 300 cm

Operating Range: 30 cm – 300 cm

Operating Environment: Surface w/Clear Pattern and 

Adequate Lighting (Lux > 15)

Camera:

Sensor: Sony Exmor 1/2.3” 

Operating Temperature Range: 0֯C to 40C֯

Remote Controller:

Operating Frequency: 2.400 GHz – 2.483 GHz

Maximum Transmission Distance: 2 km (outdoors and unobstructed)

Operating Temperature Range: 0֯C to 40֯C

Battery: 6000 mAh LiPo 2S

Mobile Device Holder: Tablets and smartphones

Transmitter Power (EIRP): FCC: 20 dbm; CE: 16 dbm

Working Voltage: 1.2 A @ 7.4 V

Charger:

Voltage: 17.4 V

Rated Power: 57 W

Intelligent Flight Battery (PH3-4480 mAh 15.2V):

Capacity: 4480 mAh

Voltage: 15.2 V

Battery Type: LiPo 4S

Energy: 68 Wh

Net Weight: 365 g

Operating Temperature: -10֯C to 40֯C

Max Charging Power: 100 W

DJI S900
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

Page 12 of 21

The DJI S900 is a six-boom, six (6) motor sUAS, capable of providing hover flight in both the 

vertical and horizontal planes. As such, the DJI S900 provides excellent maneuverability and ease 

of control for the PIC. The ease with which a PIC can control this sUAS model is evidenced by 

the fact that the DJI S900 is commercially available for RC hobbyists, requiring no training or 

experience prior to recreational usage. 

In an effort to ensure the safety of each flight, L.E.A.R. chose the DJI S900 due to the enhanced 

safety features found in this sUAS. The DJI S900 boasts various Return-to-Home (RTH) modes 

which bring the sUAS back to the last recorded Home point, allowing for the safe landing and 

return of the sUAS, should an unforeseen emergency arise. As such, the S900 allows for Ground 

Station Signal RTL, Low Battery RTL, GPS Failsafe RTL, RC Controller Failsafe, and an Altitude 

Failsafe. 

To that end, the DJI S900’s V-type mixer design provides large amounts of propulsion while 

improving power efficiency. From a safety perspective, the DJI flight controllers, when combined 

with the A2, allows the S900 to remain stable even with the loss of a rotor. Additionally, the AS150 

spark-proof plug and an XT150 plug prevents creators from mixing up polarity when plugging in 

the battery, thus preventing short circuits. 

The DJI S900 is designed for professional aerial photography and cinematography. It is user 

friendly, safe, stabilized and easy to fly while its integrated design makes assembly and 

configuration simple and fast. Retractable landing gear, vibration dampers, slightly angled arms 

provide for a safe flight environment.

Below are the specifications for this sUAS model:

Frame:

Diagonal Wheelbase 900mm 

Frame Arm Length 358mm 

Frame Arm Weight 316g

Center Frame Diameter 272mm 

Center Frame Weight 1185g 

Landing Gear Size 460mm(Length)×450mm(Width)×360mm(Height)

Motor:

Stator Size 41×14mm 

kV 400rpm/V 

Max Power 500W 

Weight (with Cooling Fan) 158g 

ESC:

Working Current 40A 

Working Voltage 6S LiPo 

Signal Frequency 30Hz ~ 450Hz 

Drive PWM Frequency 8KHz 

Weight (with Radiators) 35g 
Petition for Section 333 Exemption

Leading Edge Aviation Resources, LLC

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Foldable Propeller (1552/1552R):

Material High strength performance engineered plastics 

Size 15×5.2 inch 

Weight 13g 

Flight Parameters:

Takeoff Weight 4.7Kg ~ 8.2Kg 

Total Weight 3.3Kg 

Power Battery LiPo (6S, 10000mAh ~ 15000mAh, 15C(Min)) 

Max Power Consumption 3000W 

Hovering Power Consumption 1000W (@6.8Kg Takeoff Weight) 

Hovering Time 18min (@12000mAh & 6.8Kg Takeoff Weight) 

Working Environment Temp. -10°C ~ 40°C

3D Robotics X8-M 

The 3D Robotics X8-M is a quad-boom, four (4) motor sUAS, capable of providing hover flight 

in both the vertical and horizontal planes. As such, the 3D Robotics X8-M provides excellent 

maneuverability and ease of control for the PIC. The ease with which a PIC can control this sUAS 

model is evidenced by the fact that the 3D Robotics X8-M is commercially available for RC 

hobbyists, requiring no training or experience prior to recreational usage. 

In an effort to ensure the safety of each flight, L.E.A.R. chose the 3D Robotics X8-M due to the 

enhanced safety features found in this sUAS. The 3D Robotics X8-M boasts various Return-toHome (RTH) modes which bring the sUAS back to the last recorded Home point, allowing for the 

safe landing and return of the sUAS, should an unforeseen emergency arise. As such, the X8-M 

allows for Ground Station Signal RTL, Low Battery RTL, GPS Failsafe RTL, RC Controller 

Failsafe, and an Altitude Failsafe. 

The 3D Robotics X8-M provides innovative features that culminate in a safe flying experience. 

For example, the X8-M uses failsafe technology designed to prevent a crash in the event of an 

unsafe situation. All X8-M models equipped with the ArduCopter firmware include a GPS failsafe 

activated by default. 3DR RTF copters are also preset with radio control (RC) and low battery 

failsafe behaviors. For instance, if the X8-M loses GPS signal in a flight mode that requires GPS 

(loiter, auto, return-to-launch, guided), it will land automatically, as indicated by a blinking blue 

and yellow status LED and a high-high-high-low tone on the controller. Furthermore, if the drone 

loses contact with the RC transmitter, it will land automatically, as indicated by a blinking yellow 

status LED on the controller. Beyond that, if the drone’s battery reaches 25% charge or less, the 

drone will land automatically, indicated by a blinking yellow status LED and a quick repeating 

tone. Lastly, if the battery runs low during a mission, the drone will return to the launch point 

before landing.

Below are the specifications for this sUAS model:

3D Robotics X8-M:

Aircraft dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm) 
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Case dimensions: 60.7 in x 14.5 in x 15.5 in (154 cm x 37 cm x 39 cm)

Weight: 7.7 lbs (3.5 kg)

Radio range: .6 miles* (1 km) 

Flight time: 14 min (with ideal conditions)

Maximum operational wind speed: 25 mph (11 m/s) 

Landing accuracy: 8.2 ft (2.5 m) 

Recommended flight speed: 11 mph (5 m/s)

Autopilot: 3DR Pixhawk V2.4.5 

Firmware: ArduCopter 3.2 

GPS: 3DR u-blox GPS with Compass 

Telemetry radio: 3DR Radio v2 (915 mHz or 433 mHz) 

Motors: SunnySky V2216-12 800 kV II 

Frame: X 

Propellers: APC 11X4.7 SFP (4), APC 11X4.7 SF (4) 

Battery: 4S 10000 mAh 10C lithium polymer 

Aircraft dimensions: 13.7 in x 20.1 in x 11.8 in (35 cm x 51 cm x 30 cm) 

Case dimensions: 60.7 in x 14.5 in x 15.5 in (154 cm x 37 cm x 39 cm)

Proposed Flight Conditions and Operating Procedures

L.E.A.R.’s primary objective with every flight is the safe return of the above specified sUAS model 

without injury to property or person. In order to obtain this desired objective, L.E.A.R. will abide 

by the following flight and atmospheric conditions limitations when performing commercial flight 

operations with the above specified sUAS models:

1. L.E.A.R. will not operate the sUAS model when weighing more than 55 pounds, 

including payload. 

2. L.E.A.R. will not operate the sUAS model at a speed exceeding 87 knots (100 miles 

per hour). L.E.A.R. will use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. 

3. L.E.A.R. will not operate the sUAS model at an altitude of more than 400 feet above 

ground level (AGL). L.E.A.R. will monitor altitude in feet AGL via GPS 

technology and monitoring. 

4. L.E.A.R. will only operate the sUAS modes within VLOS of the PIC at all times. 

L.E.A.R. will require 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 or U.S. driver’s license. 

5. L.E.A.R. requires the utilization of a visual observer (VO) on all commercial sUAS 

flights. The sUAS model will be operated within VLOS of the PIC and VO at all 

times. The VO may be used to satisfy the VLOS requirement as long as the PIC 

always maintains VLOS capability. L.E.A.R. requires that the VO and PIC be able 

to communicate verbally at all times. L.E.A.R. does not permit electronic 

messaging or texting during flight operations. L.E.A.R. requires the sUAS PIC to 
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be designated before the flight and does not allow transfer of his or her designation 

during the flight. The PIC must ensure that the VO can perform the duties required 

of the VO. 

6. L.E.A.R. requires that all operating documents (defined as the granted exemption 

and all documents needed to operate the UAS model and conduct its operations in 

accordance with all grants conditions and limitations) must be accessible during 

sUAS operations and made available to the Administrator upon reasonable request. 

7. L.E.A.R. will require a functional test should any sUAS model undergo 

maintenance or alterations that affect the sUAS model’s operation or flight 

characteristics, e.g., replacement of a flight critical component, must undergo a 

functional test flight prior to conducting further operations under this exemption. 

L.E.A.R. requires that all function flights be conducted by a PIC with a VO and 

remain at least 500 feet from other people. L.E.A.R. further requires that the 

functional test flight be conducted in such a manner so as to not pose an undue 

hazard to persons and property. 

8. L.E.A.R. will be responsible for maintaining and inspecting the sUAS model to 

ensure that the sUAS model is in a condition for safe operation. 

9. L.E.A.R. requires that, prior to each flight, the PIC conduct a pre-flight inspection 

and determine whether the sUAS model is in a condition for safe flight. L.E.A.R. 

requires that the pre-flight inspection must account for all potential discrepancies, 

e.g., inoperable components, items, or equipment. Should the inspection reveal a 

condition that affects the safe operation of the sUAS model, L.E.A.R. prohibits the 

aircraft from operating until the necessary maintenance has been performed and the 

sUAS is found to be in a condition for safe flight.

10. L.E.A.R. requires compliance with the component manufacturer’s maintenance, 

overhaul, replacement, inspection, and life limit requirements for the components 

that combine to assemble the sUAS model. 

11. L.E.A.R. requires compliance with all sUAS model manufacture’s safety bulletins 

for the sUAS model. 

12. L.E.A.R. requires all sUAS PICs to hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. Further, L.E.A.R. requires the PIC to 

also hold a current FAA airman medical certificate or a valid U.S. driver’s license 

issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or 

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

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

pilot certificate. 

13. L.E.A.R. prohibits any PIC to operate the sUAS model unless the PIC demonstrates 

the ability to safely operate the sUAS model in a manner consistent with how the 

sUAS will be operated under this petition for exemption, including evasive and 
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emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. To that end, L.E.A.R. requires the PIC’s qualification flight 

hours and currency to be logged in a manner consistent with 14 CFR § 61.51(b). 

14. L.E.A.R. prohibits flight operations of the sUAS model during night, as defined in 

14 CFR § 1.1. All flight operations will be conducted under visual meteorological 

conditions (VMC). L.E.A.R. will not allow the sUAS model to be flown during 

special visual flight rules (SVFR).

15. L.E.A.R. will not operate the sUAS model within 5 nautical miles of an airport 

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

(AFD) or for airports not denoted with an ARP, the center of the airport symbol as 

denoted on the current FAA-published aeronautical chart, unless a letter of 

agreement with that airport’s management is obtained or otherwise permitted by a 

COA issued to the exemption holder. L.E.A.R. will make the letter of agreement 

with the airport management available to the Administrator or any law enforcement 

official upon request. 

16. L.E.A.R. will operate the sUAS model at least 500 feet below and/or no more than 

2,000 feet horizontally from a cloud. L.E.A.R. will not operate the sUAS model

when visibility is less than 3 statute miles. 

17. L.E.A.R. requires the sUAS model to return to a pre-determined location within the 

private or controlled-access property should the sUAS model lose communications 

or lose its GPS signal. 

18. L.E.A.R. requires the PIC of any sUAS model to abort the flight in the event of 

unpredicted obstacles or emergencies.

19. L.E.A.R. prohibits the PIC of any sUAS model from beginning a flight unless 

(considering wind and forecast weather conditions) there is enough available power 

for the sUAS model to conduct the intended operation and to operate after that for 

at least 5 minutes or with the reserve power recommended by the manufacturer if 

greater. 

20. L.E.A.R. requires that all documents used to ensure safe operation and flight of the 

sUAS model and any documents required under 14 CFR §§ 91.9 and 91.203 to be 

available to the PIC at the Ground Control Station of the sUAS model any time the 

aircraft are operating. L.E.A.R. will make these documents available to the 

Administrator or any law enforcement official upon reasonable request. 

21. L.E.A.R. requires that during all flights, the sUAS model PIC remain clear and give 

way to all manned aviation operations and activities at all times. 

22. L.E.A.R. prohibits the PIC of any sUAS model from operating the sUAS model 

from any moving device or vehicle. 
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23. L.E.A.R. requires all flight operations of all sUAS models to be conducted at least 

500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the sUAS and/or debris in the event of an accident. L.E.A.R. 

will 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 sUAS, L.E.A.R. requires flight operations to cease 

immediately in a manner ensuring the safety of nonparticipating persons; 

and 

b. The owner/controller of any vessels, vehicles or structures has granted 

permission for operating closer to those objects and the PIC has made a 

safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard. 

24. L.E.A.R. will operate all sUAS flights over private or controlled-access property 

with permission from the property owner/controller or authorized representative. 

L.E.A.R. will obtain permission from the property owner/controller or authorized 

representative prior to each flight to be conducted. 

PRIVACY

L.E.A.R. use of the aforementioned sUAS models will not implicate any privacy concerns. Since 

L.E.A.R. will only commercially operate the sUAS model at the request of the property and/or 

business owner(s), L.E.A.R. will have the express consent and permission of the property and/or 

business owner(s) prior to flying over private property. L.E.A.R.’s use of the aforementioned 

sUAS models poses no greater privacy concerns than the use of traditional fixed wing or rotorcraft 

aircraft for similar commercial operations. Should L.E.A.R.’s commercial sUAS activity require 

aerial based photographic and video imagery, images taken will be of individuals who have 

consented to being photographed/filmed or otherwise have agreed to be in the area where aerial 

photographic or video imagery will take place.

PUBLIC INTEREST AND SAFETY

Unlike traditional fixed wing or rotorcraft aircraft, the use of the above specified sUAS models for 

the aforementioned reasons promotes public interest and safety. Whereas traditional fixed wing or 

rotorcraft aircraft are large, heavy, noisy, require flammable fuels and manned operators (placing 

the pilot’s life in jeopardy should there be an emergency), these sUAS models are small, light, 

quite, and do not require flammable fuels or a manned operator (i.e. not risking human life for the 

purpose of operation). 

The use of L.E.A.R.’s sUAS models also benefits the public from a safety perspective since these

sUAS models do not run on fossil fuels. Since these sUAS models are battery powered, its use 

over the traditional fixed wing or rotorcraft aircraft will be more environmentally and ecologically 
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friendly. In addition to the non-use of flammable fuels, given the extreme lightness of these sUAS 

models, should an emergency result in a forced landing, injury to property or persons would be 

negligible compared to the catastrophic injury to property or persons that would result in an 

emergency landing of a traditional fixed wing or rotorcraft aircraft. 

Apart from the added safety benefits of sUAS flight operations, the use of the aforementioned 

sUAS models for the above noted aerial based applications creates new economic opportunities 

that could fuel the continued growth of aviation and aviation related interests. Consequently, the 

public will benefit from the use of these sUAS models for commercial purposes as companies like 

L.E.A.R. will provide new jobs and economic opportunities, fueling innovation and creativity. 

REGULATIONS FROM WHICH EXEMPTION IS REQUESTED

14 CFR §§ 61.23(a) and (c): Medical Certificates Requirement and Duration

L.E.A.R. requests exemption from 14 CFR §§ 61.23(a) and (c) which provides for certain flight 

operations requiring medical certificates. L.E.A.R.’s petition for exemption provides an equivalent 

level of safety in that L.E.A.R. would require a sUAS PIC to hold either a current medical 

certificate, of any class, or a valid U.S. Driver’s License. L.E.A.R.’s petition for exemption 

provides an equivalent level of safety as provided in 14 C.F.R. §§61.23(a) and (c). 

14 C.F.R. §§ 61.101(e)(4) and (5): Recreational Pilot Privileges and Limitations; 14 C.F.R. § 

61.113(a): Private Pilot Privileges and Limitations: Pilot in Command; and 14 C.F.R. 

§61.315(a): What Are The Privileges and Limits of My Sport Pilot Certificate?

L.E.A.R. requests exemption from 14 C.F.R. §§ 61.101(e)(4) and (5) which prohibits recreational 

pilots from receiving compensation for hire or providing flight services in furtherance of a 

business, respectively. In addition, L.E.A.R. requests exemption from 14 C.F.R. §61.113(a), which 

prohibits a certificated private pilot from receiving compensation or flying for hire when acting as 

PIC; and from 14 C.F.R. §61.315(a), which provides the holder of a sport pilot certificate may 

only act as pilot in command of a light-sport aircraft.

L.E.A.R.’s petition for exemption provides an equivalent level of safety in that L.E.A.R. requires 

the sUAS PIC, at the bare minimum, to hold the privileges of a sport pilot certificate under 14 

C.F.R. §61 Subpart J, hold either a medical certificate or valid U.S. Driver’s License, and to 

demonstrate proficiency in the PIC’s ability to safely operate the sUAS model in a manner 

consistent with how the sUAS will be operated under this petition for exemption.

Distinct comparisons between the commercial activities of L.E.A.R. and other businesses 

operating traditional fixed wing or rotorcraft aircraft expose the unnecessary limitations placed 

upon sport, recreational and private certificated pilots when considering PIC privileges of 

commercial sUAS flight operations. Whereas requiring pilots of traditional fixed wing and 

rotorcraft aircraft to hold commercial and Airline Transport Pilot (ATP) ratings ensures that the 

pilots possess the necessary skills, training and experience to safely transport persons and/or cargo 

from the point of departure to the intended point of destination, the same correlation for sUAS 

pilots and should not apply to the sUAS flight operations of L.E.A.R. 
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In the case of L.E.A.R.’s sUAS flight operations, no persons or third-party cargo will be carried 

by the sUAS model during L.E.A.R.’s aerial based commercial operations. Unlike traditional fixed 

wing or rotorcraft aircraft, which must traverse over a greater distance, greater amount of property, 

and a greater amount of people in order to get from the point of departure to the intended point of 

destination, L.E.A.R.’s sUAS will only fly over property authorized by L.E.A.R.’s clients. In other 

words, the sUAS model will not have to originate flight from a different location and traverse over 

the properties of disinterested parties in order to fulfill the purpose of L.E.A.R.’s commercial flight 

operations. As such, the risk of injury to disinterested parties is substantially decreased by the use 

of a sUAS for aerial based commercial applications described within this petition. 

Consequently, L.E.A.R.’s requirement that the sUAS PIC hold, at least, a sport pilot certificate 

provides an equivalent level of safety to the requirement that a commercial or ATP rated pilot 

transport persons and/or cargo for hire in manned aircraft. 

14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

L.E.A.R. requests an exemption from 14 C.F.R. §91.7(a) which prohibits the operation of civil 

aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for 

L.E.A.R.’s sUAS models, no standard will exist for determining airworthiness. In any event, 

L.E.A.R.’s proposed Flight Conditions and Operating Procedure will ensure an equivalent level of 

safety with 14 C.F.R. §91.7(a). 

14 C.F.R. § 91.119(c): Minimum Safe Altitude: General

L.E.A.R. requests an exemption from 14 C.F.R §91.119(c) which provides that except when 

necessary for takeoff or landing, no person may operate an aircraft below an altitude of 500 feet 

above the surface. Furthermore, this section provides that an aircraft may not be operated closer 

than 500 feet to any person, vessel, vehicle, or structure. L.E.A.R.’s petition requests that the DJI 

Inspire 1 be flown at an altitude no higher than 400 feet AGL and, when complying with the 

conditions set forth in §23(b) of L.E.A.R.’s Flight Conditions and Operating Procedures, at 

distances closer than 500 feet from any person, vessel, vehicle, or structure. 

The requirement that the sUAS models maintain 400 feet or less AGL helps ensure that signal 

connectivity between the transmitter and receiver will not be lost. In addition, this height restriction 

ensures that the PIC will be able to maintain VLOS while simultaneously limiting the possibility 

of the sUAS model’s interference with other NAS traffic. Moreover, this requirement ensures at 

least 100 feet of vertical separation between sUAS commercial operators and manned aircraft 

operating within the NAS.

Traditional principles requiring a 500 foot AGL minimum for fixed-wing or rotorcraft aircraft 

stemmed from a desire to protect the public should the need for a forced landing arise due to an 

unforeseen emergency situation or loss of power. These same concerns are not present with 

L.E.A.R.’s sUAS model as they are extremely lightweight and small. Any injury to property or 

person would be negligible when compared to the catastrophic damage that a fixed wing or 

rotorcraft aircraft would inflict due to a forced landing. Consequently, L.E.A.R.’s Flight 

Conditions and Operating Procedures provide for an equivalent level of safety when compared to 

14 C.F.R §91.119(c).
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14 C.F.R. §91.121: Altimeter Settings

L.E.A.R. requests exemption from 14 C.F.R. §91.121 which provides guidelines for the use of 

altimeter settings while operating an aircraft. L.E.A.R.’s petition for exemption provides an 

equivalent level of safety such that the sUAS models PIC will be able to determine the AGL height 

of the sUAS model due to GPS technology. The AGL height of the sUAS will be displayed for the 

PIC during all flight operations. As such, the PIC will be able to maintain the requirement that the 

sUAS models fly no higher than 400 feet AGL during all flight operations. 

14 C.F.R. §91.151(a)(1): Fuel Requirements For Flight In VFR Conditions

L.E.A.R. requests exemption from 14 C.F.R. §91.151(a)(1) which provides that no person may 

begin a flight in an airplane under VFR conditions with less than 30 minutes of reserve fuel. 

L.E.A.R.’s petition for exemption provides an equivalent level of safety due to L.E.A.R.’s 

prohibition against the PIC from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the sUAS model to conduct the intended operation 

and to operate after that for at least 5 minutes or with the reserve power recommended by the 

manufacturer if greater. 

Given the design and technology of aforementioned sUAS models, L.E.A.R.’s PIC will have 

access to all relevant information concerning the sUAS model’s battery life. The PIC will be able 

to make an accurate determination as to whether the PIC can comply with L.E.A.R.‘s “fuel” 

requirements for each flight. Consequently, L.E.A.R.’s Flight Conditions and Operating 

Procedures provide for an equivalent level of safety when compared to 14 C.F.R §91.151(a)(1).

14 C.F.R. §91.405(a): Maintenance Required; 14 C.F.R. §91.407(a)(1): Operation After 

Maintenance, Preventative Maintenance, Rebuilding, Or Alteration; 14 C.F.R. §§ 

91.409(a)(1) and (2): Inspections; 14 C.F.R. 91.417(a) and (b): Maintenance Records

L.E.A.R. requests exemption from the following F.A.Rs: 14 C.F.R. §91.405(a), which provides 

the owner or operator of aircraft shall have the aircraft inspected pursuant to Subpart E of 14 C.F.R; 

14 C.F.R. §91.407(a)(1), which provides that no person may operate any aircraft having undergone 

preventive maintenance unless approved for return to service by a person authorized under §43.7; 

14 C.F.R. §§91.409(a)(1) and (2), which provides that no person may operate an aircraft within 

the preceding 12 calendar months unless an annual inspection has been performed; and 14 C.F.R. 

§§91.417(a) and (b), which provides for the recording of an aircraft’s maintenance if the aircraft 

holds an airworthiness certificate.

L.E.A.R.’s petition for exemption provides an equivalent level of safety since L.E.A.R. requires

compliance with the sUAS manufacturer’s maintenance, overhaul, replacement, inspection, and 

life limit requirements for the aforementioned sUAS models. Due to the nature of a sUAS, 

compliance with certain maintenance requirements under Subpart E of 14 C.F.R. are either 

impossible or cost prohibitive to implement when applied to a sUAS. As such, L.E.A.R. should be 

exempt from these regulations as L.E.A.R.’s Flight Conditions and Operating Procedures provide 

for an equivalent level of safety when compared to these F.A.R.s.