UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

SPIRIT VISION FILMS LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE 

DJI PHANTOM 2 VISION+ AND DJI ASPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on June 17, 2015

Spirit Vision Films LLC 

302 East Runnion Road

Sequim, WA 98382

Tele: 360-460-8465
2

TABLE OF CONTENTS

Page

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

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

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

BACKGROUND .................................................................................................................4

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SPIRIT VISION FILMS 

LLC SEEKS EXEMPTION.........................................................................................8

THE EXTENT OF RELIEF SPIRIT VISION FILMS LLC SEEKS AND THE

REASON SPIRIT VISION FILMS LLC SEEKS THE RELIEF.................................11

THE REASONS WHY GRANTING SPIRIT VISION FILMS LLC’S REQUEST 

WOULD BE IN THE PUBLIC INTEREST ...............................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................17

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........30

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT SPIRIT VISION FILM LLC’S REQUEST ..........................................32

CONCLUSION.................................................................................................................32
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

C.F.R. Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VO Visual Observer

VTOL Vertical Takeoff and Landing
4

SUMMARY

Spirit Vision Films LLC seeks exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and

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

Modernization and Reform Act of 2012 (FMRA). ). This exemption will permit Spirit Vision 

Films LLC to operate an Unmanned Aircraft System (UAS) for the commercial

purpose of conducting aerial videography and photography, aerial real estate videography and

photography, aerial vineyard and winery videography and photography, and aerial rural timber 

appraisal videography and photography over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Spirit Vision Films LLC is owned and operated by Christopher Enges for the production of 

real estate videography and photography, product videography and photography including 

vineyard and winery clients, rural timber appraisal videography and photography on the North 

Olympic Peninsula and surrounding areas, and documentary videography and photography 

including the greater Pacific Northwest area.

As owner and producer of Spirit Vision Films LLC, I bring over 15 years of experience in 

the videography and photography field. I hold a degree in Multimedia Communications and have 

enjoyed the hobby use of several models of UAS including DJI’s Phantom and Phantom 2 Vision+ 

and a DJI Aspire 1 UAS. 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+ and Aspire 1

Spirit Vision Films LLC seeks an exemption to operate both DJI Phantom 2 Vision+ and 

the DJI Aspire 1 UAS for compensation or hire within the NAS. 
5

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 DJI 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 1UAs 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 Spirit Vision 

Films LLC and will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft,

as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R.

Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner Spirit Vision Films LLC, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA),

Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the

Administrator to commercially operate the DJI Phantom 2 Vision+ and DJI Aspire 1 UAS in the 

National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b).

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

unmanned aircraft and its operation, Spirit Vision Films LLC’s operation of UAS meets the

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

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

Accordingly, Spirit Vision Films LLC requests relief from Sections 91.405(a), 1.407(a)(1),
6

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate.

Spirit Vision Films LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. Spirit Vision Films LLC 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., Spirit Vision Films LLC Preflight Inspection and Maintenance Log, and

DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manuals). Furthermore, Spirit Vision 

Films LLC 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 

privileges and limitations: Pilot in command, is requested by Spirit Vision Films LLC 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 Aspire 1 UAS in a manner consistent with this exemption, including

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

vehicles and structures.

Spirit Vision Films LLC seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 2 Vision+ and DJI Aspire 1 UAS does not require an 

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

Vision Films LLC submits that it will ensure that the DJI Phantom 2 Vision+ and DJI Aspire 1

UAS are in an airworthy condition, prior to every flight, by determining that the UASs are in

compliance with the operating documents (i.e., Spirit Vision Films LLC Preflight Inspection 
7

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

that the aircraft are in a condition for safe flight.

Spirit Vision Films LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, Spirit Vision Films LLC also seeks an exemption from the

requirements of Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ and

DJI Inspire 1 UAs will not have a typical barometric altimeter onboard. However, altitude

information of the DJI Phantom 2 Vision+ and DJI Inspire 1UAs will be provided to the PIC via

Global Positioning System (GPS) equipment and radio communicationstelemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude

information, combined with Spirit Vision Films LLC’s operation of the DJI Phantom 2 Vision+

and DJI Inspire 1 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level

of safety equivalent to Section 91.121.

Additionally, Spirit Vision Films LLC seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Spirit Vision 

Films LLC 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.

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is: 

Spirit Vision Films LLC

302 East Runnion Road

Sequim, Washington 98382

The point of contact for this Petition and specific contact information is as follows: 
8

Christopher Enges, owner of Spirit Vision Films LLC

302 East Runnion Road

Sequim, Washington 98382

Mailing address:

PO Box 1107

Carlsborg, Washington 98324

Tel: (360) 460-8465

Email: cenges@msn.com 

.

 B. The Specific Sections Of 14 C.F.R. From Which Spirit Vision Films LLC 

 Seeks Exemption.

1. Spirit Vision Films LLC Seeks Exemption From The Requirements Of

Section 61.113(a) And (b).

 Section 61.113, entitled Private pilot privileges and limitations: Pilot in 

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

 part:

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

command (PIC) of an aircraft that is carrying passengers or property for

compensation or hire; nor may that person, for compensation or hire, act as PIC 

of an aircraft

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

 aircraft in connection with any business or employment if—

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

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

hire.

2. Spirit Vision Films LLC 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. Spirit Vision Films LLC Seeks Exemption From The Requirements Of

Section 91.121.
9

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part:

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of 

that aircraft, as the case may be, by reference to an altimeter that is set, when operating--

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

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

within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this section, the current reported altimeter setting of an appropriate available

station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of

the departure airport or an appropriate altimeter setting available before departure.

4. Spirit Vision Films LLC Seeks Exemption From The Requirements Of

Section 91.151(b).

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

states the following:

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

wind and forecast weather conditions) there is enough fuel to fly to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 20 

minutes.

5. Spirit Vision Films LLC 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. Spirit Vision Films LLC 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:
10

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

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under § 43.7 

of this chapter[.]

7. Spirit Vision Films LLC Seeks Exemption From The Requirements Of

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

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

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft 

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

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

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

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

with part 21 of this chapter.

8. Spirit Vision Films Seeks Exemption From The Requirements Of 

Sections 91.417(a) And 91.417(b).

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

following:

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

owner or operator shall keep the following records for the periods specified in paragraph 

(b) of this section:

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

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

as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, 

and appliance of an aircraft. The records must include--

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

the work performed; and

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

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

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, 
11

and each rotor.

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

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

the last inspection required by the inspection program under which 

the aircraft and its appliances are maintained.

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

safety directives including, for each, the method of compliance, the 

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

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

required.

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

major alteration to the airframe and currently installed engines, rotors, propellers, 

and appliances.

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

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

the work is repeated or superseded by other work or for 1 year after the work is 

performed.

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

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

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is approved for 

return to service.

C. The Extent Of Relief Spirit Vision Films LLC Seeks And The Reason Spirit 

Vision Films LLC Seeks The Relief.

1. Extent Of Relief Spirit Vision Films LLC Seeks And The Reason

Spirit Vision Films LLC 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
12

medical certificate, and who has met certain flight-hour and currency requirements, to conduct 

the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) 

state that a private pilot may, for compensation or hire, act as PIC of an aircraft in

connection with any business or employment if: (1) The flight is only incidental to that 

business or employment; and 

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

As set forth more fully below, Spirit Vision Films LLC submits that an equivalent 

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

DJI Phantom 2 Vision+ or DJI Aspire 1 UAS unless that PIC has met certain flight-hour

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

Phantom 2 Vision+ or the DJI Aspire 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, Spirit Vision Films LLC submits that all flights of the DJI Phantom 2 Vision+ 

and DJI Aspire 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be

incidental to Spirit Vision Films LLC’s business; and (2) will not carry passengers or property

for compensation or hire.

2. Extent Of Relief Spirit Vision Films LLC Seeks And The Reason Spirit 

Vision Films LLC Seeks Relief From Section 91.7(a).

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

extent required to allow Spirit Vision Films LLC to determine that the DJI Phantom 2 Vision+ 

and DJI Aspire 1 UAS are in an airworthy condition prior to every flight by ensuring that the

UAS is in compliance with the operating documents (i.e., the Spirit Vision Films LLC Preflight 
13

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

Manual).

Spirit Vision Films LLC seeks the requested relief because the DJI Phantom 2 Vision+ 

and DJI Aspire 1 UAS do not require an airworthiness certificates in accordance with 14 C.F.R. 

Part 21, Subpart H. Therefore, Spirit Vision Films LLC will ensure that the DJI Phantom 2 

Vision+ and DJI Aspire 1UAS are in an airworthy condition based upon its compliance with 

the operating documents (i.e., Spirit Vision Films LLC Preflight Inspection and Maintenance

Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual) prior to every flight,

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

and limitations below.

3. Extent Of Relief Spirit Vision Films LLC Seeks And The Reason Spirit 

Vision Films LLC Seeks Relief From Section 91.121.

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

operations of the DJI Phantom 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), Spirit Vision Films LLC 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

flight.

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

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations

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

the DJI Phantom 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.
14

4. Extent Of Relief Spirit Vision Films LLC Seeks And The Reason Spirit 

Vision Films LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is

requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision+

and DJI Inspire 1 UAs during daylight hours in visual meteorological conditions (VMC), under

visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of intended

landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Spirit 

Vision Films LLC 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 Spirit Vision Films LLC 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 Spirit Vision Films LLC’s proposed operating limitations, ensure that Spirit 

Vision Films LLC 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 

flight rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the

first point of intended landing and, assuming normal cruising speed, to fly after that for at least

4.5 minutes.

5. Extent Of Relief Spirit Vision Films LLC Seeks And The Reason Spirit 

Vision Films LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, Spirit Vision Films LLC requests relief from 

these Sections because the DJI Phantom 2 Vision+ and DJI Aspire 1UAS do not require an 

airworthiness certificate. As set forth more fully below, the DJI Phantom 2 Vision+ and DJI 

Aspire 1 UAS meets the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Spirit Vision Films LLC will use trained technicians to perform
15

maintenance, alterations, or preventive maintenance on the UAS using the methods, techniques, 

and practices prescribed in the UAS operating documents (i.e., the Spirit Vision Films LLC

Preflight Inspection and Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 

Instruction Manual). Furthermore, Spirit Vision Films LLC will document and maintain all

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

D. The Reasons Why Granting Spirit Vision Films LLC’s Request Would Be In The

Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing Spirit Vision 

Films LLC to safely, efficiently, and economically perform aerial videography and photography

of real estate, wineries and vineyards, rural timber land, and landscape 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 Spirit Vision Films LLC’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, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain

aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions,

an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI Inspire 1 UAS would reduce

the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the

safety of life and property in the air and on the ground.

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

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

DJI Phantom 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.
16

2. The Public Will Benefit From The Safety 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

UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the

levels of air and noise pollution generated during traditional aerial videography and

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 of leaded 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 17.7 inches respectively, and

with no fuel on board), has less physical potential for collateral damage to life and property on 

the ground, and in the air, compared to the manned aircraft that typically conduct similar

operations (weighing approximately 6,000 pounds with a wingspan of approximately 42 feet, a

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

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 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

1 UASs are also an economical alternative to using manned aircraft to conduct similar aerial
17

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

allow United States based companies, like Spirit Vision Films LLC, to remain competitive and

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

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded

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

in order to remain competitive. Operating the battery powered DJI Phantom 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 manned aircraft.

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

Spirit Vision Films LCC, can remain competitive and profitable, and therefore, provide greater

job stability to employees and contractors, which will ultimately contribute to growth of the

U.S. economy. Improved financial performance of U.S. companies, through commercial use of 

the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs, provides a stable workforce that increases

consumer spending; improves local, state, and federal tax revenues; and allows companies to

invest in research and development in order to remain competitive both in the United States and

abroad.

4. There Are No Privacy Issues.

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

decades, Spirit Vision Films LCC proposed operation of the DJI Phantom 2 Vision+ and DJI 

Aspire 1 UAS will not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ 

and DJI Aspire 1UAS will operate in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the DJI 

Phantom 2 Vision+ and DJI Aspire 1UAS will not be operated closer than 500 feet to any

person, vessel, vehicle, or structure, which is not directly involved in the operation.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 
18

How The Exemption Would Provide A Level Of Safety At Least Equal To That 

Provided By The Rule From Which Spirit Vision Films LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision 2+ and DJI Aspire 1UAS Meets The

Conditions Of The FAA Modernization and Reform Act of 2012 (FMRA)

Section 333.

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

unmanned aircraft and its operation, Spirit Vision Films LCC’s operation of the DJI Phantom2 

Vision+ and DJI Aspire 1 UAS meets the conditions of FMRA Section 333, and will not require

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

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section

333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretary of Transportation 

shall determine if certain unmanned aircraft systems may operate safely in the national

airspace system before completion of the plan and rulemaking required by section 332 of 

this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

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

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operational capability, proximity to airports and populated areas, 

and operation within visual line of sight do not create a hazard to users of the 

national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness 

certification under section 44704 of title 49, United States Code, is required for 

the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this section that 

certain unmanned aircraft systems may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft systems 

in the national airspace system.
19

In seeking this exemption, Spirit Vision Films LCC submits that the DJI Phantom 2 

Vision+ and DJI Aspire 1 UAS 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 Aspire UAS; (b) 

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

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Aspire

UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Aspire UAS 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 Specifications Of The DJI Phantom 2 Vision+ and 

DJI Aspire 1 UAS.

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 Sheets, attached hereto as Exhibit A.

ii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 

Autonomous Flight And Navigation 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 1 User Manuals, attached

hereto as Exhibit B and C.

 iii. The DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Are

Designed For Automatic Return To Home Point Or Hover In 

The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs will

remain stationary, in flight, for 30 seconds or more. If, after 30 seconds, the DJI Phantom 2 
20

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+ UAS 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

B and C.

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

B and C.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs 

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

With A Safety Observer.

Spirit Vision Films LLC 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. Flights Of DJI Phantom 2 Vision+ and DJI Inspire 1 UASs Will Be

Conducted Pursuant To Specific Operating Limitations.

 In seeking this exemption, Spirit Vision Films LLC proposes to commercially operate the 

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 Inspire 1 Unmanned

Aircraft Systems. Proposed operations of any other aircraft will require a new petition
21

or a petition to amend this grant.

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

purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 500 feet above ground level

(AGL), as indicated by the procedures specified in the operating documents unless a

special request is made and approved by ATC. All altitudes reported to ATC must be in

feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times.

This requires the PIC to be able to use human vision unaided by any device other than

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted.

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

VLOS requirement as long as the PIC always maintains VLOS capability. The SO and

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

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

the flight and cannot transfer his or her designation for the duration of the flight. The

PIC must ensure that the SO can perform the functions prescribed in the operating

documents.

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

avoiding other air traffic and other ground based obstacles/obstructions

and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy

exists between the conditions and limitations contained in the

grant of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence and

must be followed. Otherwise, the operator must follow the procedures as outlined in its

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

the operator’s responsibility to track such revisions and present updated and revised

documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for 

extension or amendment to the grant of exemption. If the operator determines that any

update or revision would affect the basis upon which the FAA granted the exemption,

then the operator must petition for amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS-80) may be contacted if questions arise regarding

updates or revisions to the operating documents.

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

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

the UAS, the aircraft is prohibited from operating until the necessary maintenance

has been performed and the UAS is found to be in a condition for safe flight. The

Ground Control Station must be included in the preflight inspection. All

maintenance and alterations must be properly documented in the aircraft records.
22

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

operation or flight characteristics, e.g. replacement of a flight critical component,

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

flight must make an entry in the aircraft records.

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

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

sections of the operating documents.

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

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

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

requirements, in accordance with the operating documents. Maintenance, inspection,

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

aircraft records, including total time in service, description of work accomplished,

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

15. Each 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 thirdclass medical certificate.

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

qualification criteria and demonstrates the ability to safely operate the UAS in a

manner consistent with how the UAS will be operated under the exemption, including

evasive and emergency maneuvers and maintaining appropriate distances from

persons, vessels, vehicles and structures. PIC qualification flight hours must be logged

in a manner consistent with 14 C.F.R.

§ 61.51(b). Flights for the purposes of training the operator’s PICs are permitted

under the terms of the exemption. However, training operations may only be

conducted during dedicated training sessions. During training, proficiency, and

experience-building flights, all persons not essential for flightoperations are

considered nonparticipants, and the PIC must operate the UAwith appropriate distance

from nonparticipantsin accordance with 14 C.F.R. §91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. §

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the

FAA office closest to proposed area of operations. Flights under special visual

flight rules (SVFR) are not authorized.

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

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

with that airport’s management is obtained, and the operation is conducted in

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

agreement with the airport management must be made available to the Administrator

upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.
23

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered in

accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

weather conditions) there is enough power to fly at normal cruising speed to the

intended landing point and land the UA with 25% battery power remaining.

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

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

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

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

operation. All operations shall be conducted in accordance with airspace requirements

in the ATO issued COA including class of airspace, altitude level and potential

transponder requirements.

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

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

be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation

and control of the UA must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

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

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

These documents must be made available to the

Administrator or any law enforcement official upon request.

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

operations and activities at all times.

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

 31. The UA may not be operated over congested or densely populated areas.

32. Flight operations must be conducted at least 500 feet from all nonparticipating persons

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

vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

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

must ensure that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such protection and are

within 500 feet of the UA, flight operations must cease immediately and/or;

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

owner/controller of such vessels, vehicles or structures has granted permission
24

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

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

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not

present an undue hazard to those persons per § 91.119(a).

33. All operations shall be conducted over private or controlled-access property with

permission from the land owner/controller or authorized representative. Permission

from land owner/controller or authorized representative will be obtained for each

flight to be conducted.

34. Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA must be

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

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

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

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

And (b) Would Not Adversely Affect Safety.

Spirit Vision Films LLC submits that the equivalent level of safety established by 

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 flight-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 Spirit Vision Films LLC’s proposed area of operations, and the operating 

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

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the

airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS,

Spirit Vision Films LLC submits that the additional manned airmanship experience of a

commercially certificated pilot would not correlate to the airmanship skills necessary for Spirit 

Vision Films LLC specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, 

in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 
25

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

11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

Spirit Vision Films LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ or 

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements for 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 UAS rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS to be used for operations

under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs

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

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

was obtained in compliance with applicable regulations will ensure an equivalent level of safety

during Spirit Vision Films LLC proposed operations. The Administrator has held that prior

documented flight experience that was obtained in compliance with applicable regulations would

ensure safe operations, stating as follows: 

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

 purpose of motion picture filming (or similar operations), The PIC must have accumulated

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

 rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. 

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

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

 to be used for operations under the exemption. For clarification, the FAA considers these

 minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and

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

 included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements,

 the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency
26

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

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

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

 flight experience that was obtained in compliance with applicable regulations would

 satisfy this requirement. Training, proficiency, and experience-building flights can also be

 conducted under the grant of exemption to accomplish the required flight time. During

 training, proficiency, and experience-building flights the PIC is required to operate the UA 

 with appropriate distances in accordance with 14 C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, Spirit Vision Films LLC will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS unless that PIC has 

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

to safely operate the DJI Phantom 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 Why An Exemption From The Requirements Of Section

 91.7(a) Would Not Adversely Affect Safety.

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

because prior to every flight, Spirit Vision Films LLC 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,

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

 4. Reasons Why An Exemption From The Requirements Of Section 91.12 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because
27

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 Spirit Vision Films LLC’s operation of the DJI Phantom 2 

Vision+ and DJI Inspire 1 UAs within visual line of sight, at or below 500 feet AGL, will

ensure a level of safety equivalent to Section 91.121. The altitude information will be generated

by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation

point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section

91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 

C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 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, Spirit Vision Films LLC will ensure

that it will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 UAs 

during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 

13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly

after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom

2 Vision+ and DJI Inspire 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
28

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 DJI Inspire 1 UASs will descend

and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section

91.151 establish that safety is not adversely affected when the technical characteristics and

operating limitations of the UAS are considered. Relief has been granted for manned aircraft to

operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 

2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 

specific to UAS, in circumstances similar, in all material respects, to those presented herein

(e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 

11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, Spirit Vision Films LLC submits that the equivalent level

of safety with regard to the regulatory maintenance and alteration requirements established by 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met

because Spirit Vision Films LLC 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 Spirit Vision Films LLC Preflight 

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

Manual). Furthermore, Spirit Vision Films LLC will document and maintain all maintenance

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

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

by the operating documents, Spirit Vision Films LLC will maintain the equivalent level of safety

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 
29

Vision+ and DJI Inspire 1 User Manuals are attached hereto as Exhibit B and C; a copy of the 

DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Preflight Inspection and Maintenance Log is 

attached hereto as Exhibit D.

Likewise, the exemption sought will not adversely affect safety because Spirit Vision 

Films LLC will use trained technicians to perform maintenance, alterations or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety 

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

Phantom 2 Vision+ and DJI Inspire 1 UASs will be performed by trained technicians. 

Maintenance will be documented and maintained utilizing the maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not

adversely affected when the technical characteristics and operating limitations of the UAS are

considered.

In consideration of Spirit Vision Films LLC’s proposed operating limitations, the 

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

1 UASs, Spirit Vision Films LLC submits that safety will not be adversely affected by

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2),

and 91.417(a) and (b). The FAA has previously granted relief specific to UAS in

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of

2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, Spirit Vision Films LLC

requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom
30

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

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe

operation of the UAs for the limited purpose of conducting aerial video and photography over

certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the

requirements for considering whether a UAS will create a hazard to users of the NAS or the

public, or otherwise pose a threat to national security; and further, provides the authority for such

UAS to operate without airworthiness certification in accordance with any requirements that

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

Likewise, the Administrator may prescribe special conditions pursuant to 14

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

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

standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled

Special Conditions, states the following:

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

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

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

he prescribes special conditions and amendments thereto for the product. The special

conditions are issued in accordance with Part 11 of this chapter and contain such safety

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to

establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

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

prescribe special conditions for Spirit Vision Films LLC’s 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.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a),

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

F. A Summary That Can Be Published In The Federal Register, stating: 
31

The Rules From Which Spirit Vision Films LLC Seeks Exemption:

Spirit Vision Films LLC seeks exemption from the requirements of 14 C.F.R 

Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

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

A Brief Description Of The Nature Of The Exemption Spirit Vision Films LLC

Seeks:

This exemption will permit Spirit Vision Films LLC to commercially operate an 

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

photography over certain areas of the United States.

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

Spirit Vision Films LLC 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, Spirit Vision Films LLC request for exemption may be

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create 

a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above, Spirit Vision Films LLC will operate the DJI Phantom 2 

Vision+ and the DJI Aspire 1 UAS safely in the NAS, without creating a hazard to users of

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

CONCLUSION

As set forth herein, Spirit Vision Films LLC seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will

permit safe operation of the DJI Phantom 2 Vision+ and DJI Aspire 1 UAS commercially, 
32

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

photography over certain areas of the United States.

By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of 

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

public, by allowing Spirit Vision Films LLC to safely, efficiently, and economically operate the 

DJI Phantom Vision+ and DJI Aspire 1 UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Spirit Vision Films LLC respectfully

requests that the Administrator grant this Petition for an exemption from the requirements of 14 

C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b), and permit Spirit Vision Films LLC to operate the DJI Phantom 

Vision+ and DJI Aspire UAS commercially for the purpose of conducting aerial videography 

and photography over certain areas of the United States.

Dated: June 17, 2015

Respectfully submitted,

Spirit Vision Films LLC

Owner/Christopher Enges

302 East Runnion Road

 Sequim, Washington 98382

 Mailing address:

 PO Box 1107

 Carlsborg, Washington 98324

 Tel: 360-460-8465

 Email: cenges@msn.com