City of Burleson-Public Works Department, UAV Petition for Exemption 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

Kevin North 

Assistant Director of Public Works 

City of Burleson 

141 West Renfro Street 

Burleson,Texas76028 

BASIS FOR PETITION 

Petitioner, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, 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+, in the National Airspace System (NAS), and for an 

exemption from the requirements of: 

14 C.F.R §§ 61.113{a) & {b) 

14 CFR 45.23{b) 

91.7{a), 91.121, 

91.151{b), 

91.405(a), 91.407{a){1), 91.409{a)(1) & (a){2), and 91 

Name and Address of the Petitioner 

The name and address of the Petitioner and point of contact is: 

Kevin North 

Assistant Director of Public Works 

City of Burleson 

Burleson, Texas 76028 

Office: (817)426-9830 

Email: knorth@burlesontx.com 

PREFACE: 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

that includes UAS, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702- 44716 of this title if the Administrator finds 
City of Burleson-Public Works Department, UAV Petition for Exemption 

the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 

CFR §91.203 (a) (1). 

The City of Burleson-Public Works Department proposes to use one or more Unmanned Aerial Drones 

(DJI PHANTOM 2 Vision+), for the following uses: 

• Inspections of city-owned stormwater systems 

• Inspections of city-owned water and wastewater infrastructure systems 

• Inspections of city-owned rights-of-way 

• Inspections of city-owned or city-funded infrastructure improvement projects 

• Bridge inspections 

• Assist with damage assessments or situational status reports during emergency response 

operations 

• Evaluations within the city related to flora & fauna (vegetation & wildlife) issues. 

• Support to law enforcement and fire departments during response operations. 

• Assist with site security during city-sponsored events (i.e. Summer Concert Series, parades, 

etc.) 

This aircraft has four rotors and four motors in a quadcopter configuration (X4). It is only capable of 

vertical takeoff and landings. This UAS weighs less than 55 lbs. including payload, can fly, under normal 

conditions at a speed of no more than 30 knots and has the capability to hover, and move in the vertical 

and horizontal plane simultaneously. This UAS is equipped with GPS and auto-return function to the 

predetermined safe landing area as well as allowing reading of magnetic interference that can cause loss 

off GPS signal. The UAS will operate only in line of sight and will operate only within the limits of public 

rights of way or easements. Such operations will be conducted to insure that the UAS will "not create a 

hazard to users of the national airspace system or the public." (Reform Act Section 333 (b)). 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before 

completion of the rule making required under Section 333 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UASs do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act§ 333 (a). Secretary determines that such vehicles "may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system." ld. §333(c). 
City of Burleson-Public Works Department, UAV Petition for Exemption 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory 

authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act, 

that includes UAS, from the requirement that all civil aircraft must have a current airworthiness 

certificate. 

The Administrator may grant an exemption from a requirement of a regulation prescribed under 

subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds 

the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 

CFR §91.203 (a) (1). 

RELIEF OVERVIEW 

Given the small size ofthe UAS involved and the restricted environment within which they will operate, 

the applicant falls within that zone of safety (an equivalent level of safety) in which Congress envisioned 

that the FAA allow commercial operations of UASs to commence immediately. Also due to the size of 

the UASs and the restricted areas in which the relevant UAS will operate, approval of the application 

presents no national security issue. 

Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal 

Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, 

and the significant public benefit, including enhanced safety, reduction in environmental impacts, 

including reduced emissions associated with allowing UASs for aerial inspections, surveying, 

photography and videography, the grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY 

CITY OF BURLESON-PUBLIC WORKS DEPARTMENT proposes that the exemption requested herein apply 

to civil aircraft that have the characteristics and that operate with the limitations listed herein. These 

limitations provide for at least an equivalent or even higher level of safety to operations under the 

current regulatory structure because the proposed operations represent a safety enhancement to the 

already safe aerial inspections, surveying and photography and videography operations conducted with 

conventional aircraft. 

These limitations and conditions to which CITY OF BURLESON-PUBLIC WORKS DEPARTMENT agrees to be 

bound when conducting commercial operations under an FAA issued exemption include: 

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of a Pilot-In Command (PIC) and a Safety 

Observer (SO). 

3. Maximum total flight time for each operational flight will be 30 minutes or less. Flights will 

be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 
City of Burleson-Public Works Department, UAV Petition for Exemption 

4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 

feet above an elevated platform for which filming is planned. 

5. Minimum crew for each operation will consist of the UAS Pilot and one Visual Observer. 

6. The UAS will only operate within the defined project area, the boundaries of which will be 

determined by the UAS Pilot-In-Command (PIC) based on the site-specific activities and 

speed of the UAS required for the operation, and coordinated with the jurisdictional FAA 

FSDO and local government officials as applicable. 

7. A briefing will be conducted in regards to the planned UAS operations prior to each day's 

operation. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the project be present for this briefing. 

8. The UAS Pilot and Safety Observer will be able to communicate by voice and/or two way 

radio communication system at all times. 

9. The operations of the UAS will be limited to daylight-only operations. 

10. If the UAS loses communications or loses its GPS signal, the UAS will have the capability to 

return to a pre- determined location within the Project Perimeter and land safely. 

11. The UAS will have the capability to abort flight in case of unpredicted obstacles or 

emergencies. 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) 

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance 

of airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area 

associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets 

the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The 

Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to 

exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, 

weight, speed, operational capability, and proximity to airports and populated areas of the particular 

UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions proposed will be at 

least as CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption safe, or safer, 

than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without 

the restrictions and conditions proposed. 

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

aircraft and its operation, the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's operation of DJI 

Phantom 2 Vision+, 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, the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT requests relief from Sections 

91.405(a), 91.407(a)(1), 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. CITY OF 

BURLESON-PUBLIC WORKS DEPARTMENT submits that the requested relief is proper since an equivalent 
City of Burleson-Public Works Department, UAV Petition for Exemption 

level of safety will be ensured. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT will use experienced 

personnel or technicians as needed to perform maintenance, alterations, or preventive maintenance on 

the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, CITY OF 

BURLESON-PUBLIC WORKS DEPARTMENT will document and maintain all maintenance records for the 

DJI Phantom 2 Vision+ UAS. 

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

Private pilot privileges and limitations: Pilot in command, is requested by CITY OF BURLESON-PUBLIC 

WORKS DEPARTMENT to the extent necessary to allow a Pilot in Command (PIC) meet or exceed the 

described requirements of operations set by manufacturer, and who has demonstrated, that the PIC is 

able to safely operate the DJI Phantom 2 Vision+ UAS in a manner consistent with this exemption, 

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

vessels, vehicles and structures. 

CITY OF BURLESON-PUBLIC WORKS DEPARTMENT seeks relief from Section 9L7(a), entitled 

Civil aircraft airworthiness, because the DJI Phantom 2 Vision+ UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, CITY OF BURLESON-PUBLIC WORKS 

DEPARTMENT submits that he will ensure that the DJI Phantom 2 Vision+ UAS is in an airworthy 

condition, prior to every flight, by determining that the UASs are in compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual), and that the 

aircraft are in a condition for safe flight. 

CITY OF BURLESON-PUBLIC WORKS DEPARTMENT also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vision+ will be 

provided to the PIC via Global Positioning System {GPS) equipment and radio communications telemetry 

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

information, combined with CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's operation of the DJI 

Phantom 2 Vision+ UAS within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 

equivalent to Section 91.121. 

Additionally, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT seeks an exemption from the 

requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. JWR submits 

that safety will not be affected by operation of the DJI Phantom 2 Vision+ 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 30 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. 

EXTENT AND REASONING WHY CITY OF BURLESON-PUBLIC WORKS 

DEPARTMENT SEEKS RELIEF FROM THE LISTED SECTIONS ABOVE: 

1. Section 61.113(a) & b). 
City of Burleson-Public Works Department, UAV Petition for Exemption 

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 meet all requirements as described in the DJI Phantom 2 Vision+ owner's manual 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 City of Burleson, UAV Petition for Exemption 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, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 

2 Vision+ UAS unless that PIC has demonstrated that the PIC is able to safely operate either the DJI 

Phantom 2 Vision+ 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, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submits that all flights of the DJI Phantom 2 

Vision+ 1 UAS, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to CITY 

OF BURLESON-PUBLIC WORKS DEPARTMENT's business; and (2) will not carry passengers or property for 

compensation or hire. 

2. 91.7(a). 

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

allow CITY OF BURLESON-PUBLIC WORKS DEPARTMENT to determine that the DJI Phantom 2 Vision+ 

UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT Operations Manual, 

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

CITY OF BURLESON-PUBLIC WORKS DEPARTMENT seeks the requested relief because the DJI Phantom 2 

Vision+ UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart 

H. Therefore, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT will ensure that the DJI Phantom 2 

Vision+ UAS are in airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2 Vision+ 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. 91.121. 

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

DJI Phantom 2 Vision+ UAS, 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), CITY OF BURLESON-
City of Burleson-Public Works Department, UAV Petition for Exemption 

PUBLIC WORKS DEPARTMENT seeks the requested relief because the DJI Phantom 2 Vision+ UA 

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+ UA are 

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

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

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

4. 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+ UA during daylight hours 

in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 25 

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

at least 5 minutes. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT 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+ UA will severely constrain the practicality of any aerial video or still photo flight 

operations that CITY OF BURLESON-PUBLIC WORKS DEPARTMENT proposes to conduct pursuant to this 

Petition. 

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

Phantom 2 Vision+ operating documents, and CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's 

proposed operating limitations, ensure that CITY OF BURLESON-PUBLIC WORKS DEPARTMENT will safely 

operate the battery powered DJI Phantom 2 Vision+ UA during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 

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

for at least 4.5 minutes. 

14 CFR 45.23(b) 

Marking of the Aircraft; 

Applicable codes of Federal Regulation require aircraft to be marked according to certain 

specifications. UAV Field Services UASs are, by definition, unmanned. They therefore do not have a 

cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two inch lettering is 

difficult to place on such small aircraft. CITY OF BURLESON-PUBLIC WORKS DEPARTMENT petition for 

exemption by placing the "N "number on its fuselage as required by 14 CFR 45.29 (f) so that the pilot, 

technician, spotter and others working with the UAV will see the markings. The FAA has previously 

issued exemptions to this regulation through- Exemption No 10167 and 10700 

5. 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). 
City of Burleson-Public Works Department, UAV Petition for Exemption 

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, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT requests relief from 

these Sections because the DJI Phantom 2 Vision+ UAS do not require airworthiness certificates. As set 

forth more fully below, the DJI Phantom 2 Vision+ UAS meet the conditions of FMRA Section 333 for 

operation without an airworthiness certificate. Accordingly CITY OF BURLESON-PUBLIC WORKS 

DEPARTMENT will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating 

documents (i.e., the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, CITY OF 

BURLESON-PUBLIC WORKS DEPARTMENT will document and maintain all maintenance records for the 

DJI Phantom 2 Vision+ UAS. 

The Reasons for granting this request are entirely beneficial to the public and community as a whole. 

Granting the present Petition will further the public interest by allowing CITY OF BURLESON-PUBLIC 

WORKS DEPARTMENT to safely, efficiently, and economically perform aerial video and photographic 

surveys and inspections of construction sites, rights of way, utility easements, and other sites within the 

City of Burleson, Texas and its extraterritorial jurisdiction (ETJ). 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333{a) 

through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether 

certain unmanned aircraft systems may operate safely in the national airspace system {NAS) before 

completion of the rule making required under Section 332 of the Reform Act. In making this 

determination, the Secretary is required to determine which types of UAS do not create a hazard to 

users of the NAS or the public or pose a threat to national security in light of the following: 

• The UAS's size, weight, speed and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 

Reform Act § 333 (a). Lastly, the Secretary determines that such vehicles 11may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe operation of such 

aircraft in the national airspace system." ld. §333{c). 

Given the small size of the UAS involved and the restricted sterile environment within which they will 

operate, the applicant falls squarely within that zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to 

commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant 

UAS will operate, approval of the application presents no national security issue. Given the clear 

direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding the proposed operations, and the significant 

public benefit, including enhanced safety, reduction in environmental impacts, including reduced 

emissions associated with allowing UASs for video and photographic operations, the grant of the 

requested CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption is in the public 

interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption. 

REASONS BENEFICIAL TO THE PUBLIC/COMMUNITY 
City of Burleson-Public Works Department, UAV Petition for Exemption 

1. The Public Will Benefit from Decreased Congestion of the NAS. 

The DJI Phantom 2 Vision+ UA 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+ 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+ UA does 

not require an airport to takeoff or land. likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer aircraft that must be handled by air traffic control 

during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 Vision+ UAS. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of manned aircraft, will 

greatly benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and electric 

motors, the DJI Phantom 2 Vision+ UAS 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+ UA, 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+ UAS to perform aerial observation, 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+ UA (weighing approximately 2 pounds 

11 ounces, at their maximum gross weights with length of 16 inches, widths of 16 inches, 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, Surveys and Inspections, Operations with the DJI Phantom 

2 Vision+ UAS Will Benefit the Economy. 

In addition to being safe and efficient, the DJI Phantom 2 Vision+ UAS are also provides an economical 

alternative to using manned aircraft to conduct similar aerial operations. As such, operation 

CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption of the DJI Phantom 2 

Vision+ UAS will allow the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT, to provide quality services 

to the residents and businesses of the City and the Region at minimum costs. Specifically, with the rising 

cost of aviation fuel and the Environmental Protection Agency {"EPA") regulatory actions phasing out 
City of Burleson-Public Works Department, UAV Petition for Exemption 

leaded aviation fuels, agencies must adopt new and alternative technology in continue to provide 

required services at reasonable costs. Operating the battery powered DJI Phantom 2 Vision+ UAS is one 

such technology that not only allows agencies & 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+ UAS, the CITY OF BURLESON-PUBLIC WORKS DEPARTMENT can 

maintain and hopefully improve our ability to operate and maintain critical infrastructure and at the 

same time collect important data for further development of system-wide modeling of water, 

wastewater, stormwater, and roadway systems as well as provide accurate and current data related to 

environmental issues such as ground cover, vegetation & wildlife habitats. 

4. There Are No Privacy Issues. 

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

CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's proposed operation of the DJI Phantom 2 Vision+ 

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

only in compliance with operating documents (i.e., the CITY OF BURLESON-PUBLIC WORKS 

DEPARTMENT Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

Instruction Manual) which requires property owner involvement as well as local law enforcement 

notification, and in accordance with the Federal Aviation Regulations, including the maximum altitude 

limitations as per the requirements of 14 C.F.R. § 91.119. 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY, OR HOW THE 

EXEMPTION WOULD PROVIDE A LEVEL OF SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FR 

OM WHICH CITY OF BURLESON-PUBLIC WORKS DEPARTMENT SEEKS EXEMPTION. 

1. Reasons Why The DJI Phantom 2 Vision+ UA Meet The Conditions Of The FAA Modernization and Refo 

rm 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, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT's operation of the DJI 

Phantom 2 Vision+ UAS meet the conditions of FMRA Section 333, and will not require an airworthiness 

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

In seeking this exemption, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT submits that the DJI 

Phantom 2 Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated 

by: (a) the characteristics of the DJI Phantom 2 Vision+ UAS; (b) the pilot certification requirement; and 

(c) the specific operating limitations. 

a. The Specifications OfThe DJI Phantom 2 Vision+ UAS Demonstrate Its Safe Characteristics. 

The DJI Phantom 2 Vision 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 ofThe DJI Phantom 2 Vision+ UAS. 
City of Burleson-Public Works Department, UAV Petition for Exemption 

The technical specifications of the DJI Phantom 2 Vision+ UAS are set forth by the DJI 

Phantom 2 Vision+ Specifications and Data Sheet attached. 

ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And Navigation Modes Enable The 

UAS To Remain Within A Defined Operational Area. 

The DJI Phantom 2 Vision+ UAS 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+ UAS are included in the User Manuals. 

iii. The DJI Phantom 2 Vision+ 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+ UA will remain stationary, in 

flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ UA does 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+ UA are set 

forth in the DJI Phantom 2 Vision+ User Manual. 

iv. The DJI Phantom 2 Vision+ GCS And Its Operation. 

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

GCS and flight control software is provided in the DJI Phantom 2 Vision+ User Manual. 

b. Flights Of DJI Phantom 2 Vision+ UAS Will Be Conducted Pursuant To Specific Operating 

Limitations. 

In seeking this exemption, CITY OF BURLESON-PUBLIC WORKS DEPARTMENT proposes 

to commercially operate DJI Phantom 2 Vision+ UAS 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+ Unmanned Aircraft Systems. 

Proposed operations of any other aircraft will require a new petition 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 UA may not be flown at an indicated airspeed exceeding 20 knots. 
City of Burleson-Public Works Department, UAV Petition for Exemption 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

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

special 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 camera to satisfy the visual line of site 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. 

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 
City of Burleson-Public Works Department, UAV Petition for Exemption 

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 meet or exceed all requirements as set forth by manufacturer in order 

to justifiably operate the DJI Phantom 2 Vision+, or hold an equivalent pilot license 

approved by the FAA. 

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 CITY OF 

BURLESON-PUBLIC WORKS DEPARTMENT, UAV Petition for Exemption 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 flight 

operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS 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 
City of Burleson-Public Works Department, UAV Petition for Exemption 

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. 

22. If the UA loses communications or loses its GPS signal, it must return to a 

pre- determined 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 

{N- Number) 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 UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

30. All operations shall be conducted over publicly owned or controlled property. Any 

operation over privately owned property would require 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. 

31. 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 
City of Burleson-Public Works Department, UAV Petition for Exemption 

reported to the National Transportation Safety Board (NTSB) per instructions contained 

on the NTSB Web site: www.ntsb.gov 

THE CITY OF BURLESON-PUBLIC WORKS DEPARTMENT AFFIRMS ALL INFORMATION LISTED ABOVE TO BE 

TRUE AND BINDING UPON FAA'S FINDINGS OF EXEMPTION REGARDING COMMERCIAL OPPERATIONS OF 

LISTED UAS, UNTIL FURTHER NOTICE OF LAWS OR REGULATIONS DECIDED BY THE 

GOVERNEMENT/FAA. THANK YOU FOR YOUR CONSIDERATION. 

KEVIN NORTH 

ASSISTANT DIRECTOR OF PUBLIC WORKS 
Appendix 

Rear LED Flight Indicators Normal status 

...... (Red, Green, Yellow flashes in turn) Power On Self-Test 

:.·s··-:1:} ...... (Green, Yellow flashes in turn) Warming Up 

:J:?;i· ······(Slow Green flashes) Ready to Fly 

',YJ: ······(Slow Yellow flashes) Ready to Fly (non-GPS) 

Rear LED Flight lndicat~rs Abnormal status 

...... (Quick Yellow flashes) Remote Controller Signal Lost 

······(Slow Red flashes) Low Battery Level Warning 

.R' ...... (Quick Red flashes) Critical Low Battery Level Warning 

· • ···(Three Red flashes off and on) Not Stationary or Sensor Bias is too big 

Error• 

...... (Red, Yellow flashes in turn) Compass Needs Calibration 

'You can learn more about error by connecting the Phantom 2 Vision+ to the Assistant. 

Aircraft 

Supported Battery DJI 5200mAh Li-Po Battery 

Weight (Battery & Propellers included) 1242g 

Recommend payload ,;;1300g 

)> 

3 

Maximum payload 1350g 

3 

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

:0. 

x· Max Yaw Angular Velocity 200°/S 

Max Tillable Angle 35° 

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

Max Flight Speed 15rn/s (Not Recommended) 

Motor Diagonal Length 350mm 

3-axial stabilized Gimbal 

Working Current Static : 750mA; Dynamic : 900mA 

Control Accuracy ±0.03° 

Controllable Range Pitch : -90'- 0' 

Maximum Angular Speed Pitch : 90' /s 

Camera 

Operating Environment Temperature O'C- 40'C 

Sensor Size 1/2.3" 

Effective Pixels 14 Megapixels 

Resolution 4384x3288 

HD Recording 1 080p30 /1 080i60 

Recording FOV 110' /85' 

48 
Remote Controller 

Operating Frequency 

Communication Distance (open area) 

Receiver Sensitivity (1 %PER) 

Transmitting Power (EIRP) 

Working CurrenWoltage 

Battery 

Range Extender 

Operating Frequency 

Communication Distance {open area) 

Transmitting Power 

Power Consumption 

5. 728 GHz - 5.85 GHz 

CE Compliance: 400m; FCC Compliance: BOOm 

-93dBm 

CE Compliance: 25mW; FCC Compliance: 100mW 

120mA@3.7V 

2000mAh rechargeable LiPo battery 

2412MHz- 2462MHz 

500m-700m 

20dBm 

2W 

3.1 How to solve large margin(s) mid-point error? 

Appendix 

If the Remote Controller stick{s) mid-point margin of error is too big, the motors will fail to start when you execute the 

CSC and the Phantom will not take off. The below are some possible fixes for this. 

(1) One of the Remote Controller's stick positions (except the throttle stick) is not centered when powering on the 

Phantom 2 Vision+. 

Solution: Place all Remote Controller sticks at their mid-point positions and then power cycle the Phantom 2 Vision+ 

to re-record the mid-point. 

(2) The Remote Controller sticks have been trimmed, leading to a deviation in the mid-point position. 

Solution: Use Assistant to perform a Remote Controller calibration. 

a) Connect to Assistant, tap Basic -> RC -> Command Sticks Calibration and push all Remote Controller sticks 

through their complete travel range to see if any stick cannot reach its outermost position. 

b) Power cycle the Phantom 2 Vision+. Power cycling is required. 

c) Re-attempt Remote Controller calibration in Assistant. 

If the above solutions do not solve your issue, please send your Remote Controller to DJI Customer service for repair. 

3.2 How to restore a video file if power is turned off during a recording session? 

Solution: Keep or place the Micro-SO card back into the camera. Power cycle the camera and wait about 30 seconds for 

the video file to be restored. 

3.3 Failure to acquire the SSID. 

Solution: Double check whether both the camera and Range Extender are powered on and the power switch of the 

camera is switched to "Wi-Fi ON." 

3.4 What to do if Phantom 2 Vision+ is out of sight and the Wi-Fi connections is lost? 

Solution: Turn off the Remote Controller to trigger the Failsafe mode and the aircraft will start to fly back, descend, and 

land at the Home point. Please make sure there are no obstacles between the Phantom and the home point and that you 

are familiar with the procedure for regaining control. 

3.5 Wi-Fi connection fails all the time. 

Solution: Double check the current Wi-Fi connection status of the mobile device. The mobile device may be connecting 

to other Wi-Fi networks after a connection breaks with the Phantom 2 Vision+. 

3.6 Files fail to synchronize. 

Solution: Video files that are too large (file sizes close to 4GB) cannot be synchronized to the mobile device. Some 

mobile devices do not support the synchronization of the 1080i60 video files. 

49