EMJ Page 1
 

2034 Hamilton Place Blvd ∙ Suite 400 ∙ Chattanooga, TN 37421

WWW.EMJCORP.COM

PETITION CONTENTS

This petition letter includes the following required information in the order listed below:

 Name and mailing address of company contact (Page 2)

 Specific sections of 14 CFR from which we seek an exemption (Pages 2-3)

 The extent to which we are seeking relief (Page 3)

 Proposed equipment (Page 3)

 sUAS equipment & operation guidelines for EMJ Corporation (Pages 3-4)

 Benefit to the public as a whole (Page 5)

 Safety considerations (Page 5)

 Summary to be posted to the Federal Register (Page 6)

 Additional Information (Page 6)

 Geographic reach of petition (Page 6)

 Attachment A - DJI Phantom II Specs and User Manual (Pages 7-46)

 Attachment B – DJI Phantom III Advanced Specs and User Manual (Pages 47-112)

NAME AND MAILING ADDRESS OF COMPANY CONTACT

EMJ Corporation

Attn: Jonathan Deming, Director of BIM and Construction Technology

2034 Hamilton Place Blvd. Suite 400

Chattanooga, TN 37421

Phone: 423-855-1550

Email: jonathan.deming@emjcorp.com

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WE SEEK AN EXEMPTION

14 C.F.R. Part 21

14 C.F.R. 45.23(b)

14 C.F.R. 61.113(a)&(b)

14 C.F.R. Part 67

14 C.F.R. 91.7(a) 

14 C.F.R. 91.9 (b)(2)

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2034 Hamilton Place Blvd ∙ Suite 400 ∙ Chattanooga, TN 37421

WWW.EMJCORP.COM

14 C.F.R. 91.103

14 C.F.R. 91.109

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) and (b)

14 C.F.R. 91.405(a)

14 C.F.R. 91.407(a)(1)

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

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

THE EXTENT AND REASONS WE ARE SEEKING RELIEF

EMJ Corporation is seeking relief in specific Subparts of Title 14 C.F.R., which would allow us 

to effectively use an sUAS for aerial data collection on all of our construction sites, real estate, 

and landscapes. We seek this exemption so that we may operate our proposed uSAS within the 

confines of all EMJ Construction project sites throughout the United States. EMJ also requests 

that the FAA grant a “blanket” Certificate of Waiver or Authorizations (COA), in accordance 

with explicit FAA restrictions as stipulated such as sUAS weight and altitude limitations. 

PROPOSED EQUIPMENT

EMJ has selected the following sUAS make and models for use in conjunction with this section 

333 Exemption Petition:

1. DJI Phantom II 

2. DJI Phantom III Advanced

Product specifications and user manuals for the DJI Phantom II and the DJI Phantom III 

Advanced are provided at the rear of this petition as Attachments A and B.

sUAS EQUIPMENT & OPERATION GUIDELINES FOR EMJ CORPORATION

By following the below guidelines, EMJ Corporation assures the FAA, the general public, and 

our own employees that our sUAS missions will not create a hazard to users of the national 

airspace system or the public as required per the Reform Act Section 333 (b). 

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2034 Hamilton Place Blvd ∙ Suite 400 ∙ Chattanooga, TN 37421

WWW.EMJCORP.COM

1. Flights will be conducted at or below 400 feet in elevation at all times, in a 

predetermined, approved flight path.

2. sUAS equipment will weigh less than 55 pounds The DJI Phantom II weighs less than 3 

pounds and the DJI Phantom III Advanced weighs less than 3 pounds as well. 

3. Maximum flight speed will be kept below the manufacturer maximum recommendations 

of 15m/s or 33.5 mph for the DJI Phantom II or 16m/s or 35.8 mph for the DJI Phantom 

III Advanced.

4. Flights will operate during daytime Visual Flight Rules (VFR) conditions at all times

5. Flights will not occur in congested areas

6. Operation of sUAS units will always take place within a visual line of sight (VLOS) of 

the pilots 

7. Operation will respect distance rules from airports or heliports as follows:

a. No operation within 5 nautical miles (NM) from an airport having an operational 

control tower; or

b. 3 NM from an airport with a published instrument flight procedure, but not an 

operation tower; or

c. 2 NM from an airport without a published instrument flight procedure or an 

operational tower; or 

d. 2 NM from a heliport with a published instrument flight procedure

8. sUAS aircraft will be equipped with and utilize GPS/GLONASS technology to ensure 

that flight parameters meet the above requirements as well as prescribed flight path 

taking into account our construction site boundaries.

9. sUAS operators will undergo and maintain appropriate training per DJI Phantom II or III 

Advanced user manuals and/or per EMJ Construction sUAS standards and practices, 

whichever is more stringent.

10. Aircraft markings shall be incorporated as practicable onto the largest available surface of 

the DJI Phantom II or DJI Phantom III Advanced as required per FAA guidelines.

11. EMJ Specific sUAS guidelines shall be incorporated in order to ensure compliance with 

other FAA guidelines not listed here such as right-of-way yielding requirements, the use 

of a visual observer (VO) in certain instances, cloud-cover and/or weather restrictions, 

and conducting operations on construction sites that are unoccupied as opposed to in 

operation with workers underneath the flight path (not allowed). 

12. Approval shall be sought and granted by property owners at location of proposed sUAS 

operation.

13. Any deviations to the above operating procedures or any out-of-the ordinary proposed 

uses shall be submitted to the appropriate governmental agencies for approval prior to 

operation.

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2034 Hamilton Place Blvd ∙ Suite 400 ∙ Chattanooga, TN 37421

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BENEFIT TO THE PUBLIC AS A WHOLE

EMJ Corporation consists of a family of companies with a common mission to provide 

construction services to the industry while striving to serve with honesty, transparency and 

respect. As such, it is our obligation to our clients to provide up-to-date information about their 

projects, and one way to accomplish this is through aerial photography and video footage. 

Traditional methods of hiring manned aircraft are not practical on most of our construction 

projects and could pose a safety risk to the public in urban or congested settings. Additionally, 

these manned aircraft flights are not only costly but impose undue environmental emissions and 

noise pollution impacts to the surrounding public. The use of sUAS’s greatly alleviates things of 

this nature. 

By utilizing uSAS’s per manufacturer guidelines and under FAA guidelines, EMJ 

Corporation proposes to accomplish our site surveillance goals in safer more efficient way than 

through manned aircraft. By allowing us to conduct necessary tasks through use of uSAS’s, 

both construction site staff and the surrounding public as a whole are safer. 

SAFETY CONSIDERATIONS

EMJ sUAS operators shall be trained and required to follow the DJI user manual and the 

flight safety recommendations. Prior to each flight, the sUAS operator shall be required to 

conduct a flight safety inspection to check for damaged or worn propellers, batteries, and other 

parts that should be replaced or repaired before flight. Our sUAS operator must ensure that our 

flight batteries, remote controller, wi-fi range extenders(if used) and any other necessary items 

are fully charged prior to use. Prior to utilization of an sUAS on one of EMJ’s construction sites, 

our operator shall submit a flight plan and maintenance plan to the responsible Construction 

Managers and or Property Owners. This plan shall extensively cover the preparation of 

equipment prior to the flight, the protocols and timing of the flight missions (taking into account 

both site operations and public surroundings), and clearly list out the limits of the sUAS 

equipment in relation to that specific construction jobsite.

Additionally, the use of sUAS’s on our construction sites would allow us to perform 

inspection and survey tasks without having to endanger the lives of our workers. Traditional 

methods of site inspection and surveying also incur a high risk of falls by workers trying to 

perform these tasks in precarious locations or situations. The use of sUAS’s in these instances 

would greatly reduce the risk of these unfortunate instances taking place.

With due diligence, EMJ is confident that an sUAS level of safety can be achieved that 

meets or exceeds that of current FAA regulations regarding sUAS usage. 

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2034 Hamilton Place Blvd ∙ Suite 400 ∙ Chattanooga, TN 37421

WWW.EMJCORP.COM

SUMMARY TO BE POSTED TO THE FEDERAL REGISTER

EMJ Corporation and its’ family of companies seeks to secure a Section 333 Exemption 

seeking relief from the requirements of certain sections of Title 14 of the Code of Federal 

Regulations allowing for commercial operation of sUAS equipment. EMJ Corporation is 

seeking authorization to perform aerial video and photography of construction sites, real estate, 

and landscape. In addition, EMJ Corporation requests that the FAA grant a Certificate of Waiver 

or Authorization (COA) at the same time of the exemption request approval (within the confines 

of the current guidelines and restrictions thereof).

ADDITIONAL INFORMATION

Product specifications and user manuals are included at the end of this exemption request 

showing the specific equipment that EMJ requests for utilization on our construction sites.

 Attachment A: DJI Phantom II

 Attachment B: DJI Phantom III Advanced

GEOGRAPHIC REACH OF PETITION

This exemption request only applies to all construction sites associated with EMJ 

Corporation and their family of companies within the United States.

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