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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

USDRONECAM 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 DJI PHANTOM 2 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

s

Submitted on October 26, 2015

USDRONECAM LLC

231 HILLSIDE AVE FL 1

 LEONIA, NJ 07605
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Table of Contents

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

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

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

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

BASIS	FOR	PETITION..............................................................................................................................4

A. NAME	AND	ADDRESS	OF	THE	PETITIONER....................................................................................................6

B. THE	SPECIFIC	SECTIONS	OF	14 C.F.R. FROM	WHICH	USDRONECAM LLC SEEKS	EXEMPTION. ......6

C. THE	EXTENT	OF	RELIEF	USDRONECAM LLC SEEKS	AND	THE	REASON	USDRONECAM...............9

LLC SEEKS	THE	RELIEF..........................................................................................................................................9

D. THE	REASONS	WHY	GRANTING	USDRONECAM LLC’S	REQUEST	WOULD	BE	IN	THE.....................11

PUBLIC	INTEREST; THAT	IS, HOW	IT	WOULD	BENEFIT	THE	PUBLIC	AS	A WHOLE. ................................11

E. 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	FROM	WHICH	USDRONECAM LLC SEEKS	EXEMPTION. ...................................................13

F. A SUMMARY	THAT	CAN	BE	PUBLISHED	IN	THE	FEDERAL	REGISTER, STATING: THE	RULES.............23

FROM	WHICH	USDRONECAM LLC SEEKS	EXEMPTION: ............................................................................23

G. ANY	ADDITIONAL	INFORMATION, VIEWS, OR	ARGUMENTS	AVAILABLE	TO	SUPPORT........................23

USDRONECAM LLC’S	REQUEST......................................................................................................................23

CONCLUSION........................................................................................................................................... 24

APPENDIX	– A......................................................................................................................................... 25
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GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR 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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
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SUMMARY

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

commercial purpose of conducting aerial video and photography of construction sites, 

real estate, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

USDRONECAM LLC creates local jobs generates economic activity through 

various technological offerings. USDRONECAM LLC has been 2 years of professional 

experience in videography, and multimedia promotion. They have experience with 

recreational drone use, and has flown UA for 3 years. The goal with USDRONECAM

LLC’s services will be to provide aerial video and photography for businesses to use as 

marketing collateral. This could include whitewater rafting, zip lines, real estate and 

nature photography.

These industries include:

• Real estate and private property aerial photography

• Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

Unmanned Aircraft Systems: DJI PHANTOM 2

USDRONECAM LLC seeks an exemption to operate DJI systems for 

compensation or hire within the NAS. The DJI PHANTOM 2 is a 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 has a maximum gross 

weight of approximately 2.81 pounds, 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 

PHANTOM 2 is equipped with four main rotors; driven by Lithium Polymer battery

powered electric motors.

The DJI PHANTOM 2 UAS that will be operated by USDRONECAM LLC 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, USDRONECAM LLC, pursuant to the provisions of the Federal 
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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 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 speed, weight, size, and limited operating area associated

with the unmanned aircraft and its operation, USDRONECAM LLC’s operation of DJI 

PHANTOM 2 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, USDRONECAM LLC 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.

USDRONECAM LLC submits that the requested relief is proper since an 

equivalent level of safety will be ensured. USDRONECAM 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., Monthly Maintenance Log, and DJI PHANTOM 2 Instruction Manual). 

Furthermore, USDRONECAM LLC will document and maintain all maintenance records 

for the DJI PHANTOM 2 UAS.

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

pilot privileges and limitations: Pilot in command, is requested by USDRONECAM 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 UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

USDRONECAM LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI PHANTOM 2 UAS does not require an airworthiness 

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

LLC submits that he will ensure that the DJI PHANTOM 2 UAS is in an airworthy

condition, prior to every flight, by determining that the UAS is in compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI PHANTOM 2 Instruction 

Manual), and that the aircraft is in a condition for safe flight.

USDRONECAM LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI PHANTOM 2 UA will not have a typical 

barometric altimeter onboard. However, altitude information of the DJI PHANTOM 2

UA 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 

USDRONECAM LLC’s operation of the DJI PHANTOM 2 UAS within visual line of 

sight, at or below 400 feet AGL, will ensure a level of safety equivalent to Section 

91.121.

Additionally, USDRONECAM LLC seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. 
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USDRONECAM LLC submits that safety will not be affected by operation of the DJI 

PHANTOM 2 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 

approximately 14.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, USDRONECAM LLC provides the 

following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

USDRONECAM LLC

231 HILLSIDE AVE FL 1

LEONIA, NJ 07605

B. The Specific Sections Of 14 C.F.R. From Which USDRONECAM LLC Seeks 

Exemption.

1. USDRONECAM 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. USDRONECAM 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. USDRONECAM LLC Seeks Exemption From The Requirements Of Section

91.121.

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--
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(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. USDRONECAM LLC Seeks Exemption From The Requirements Of 

Section91.151(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. USDRONECAM 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. USDRONECAM 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:

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

accordance with part 21 of this chapter.

8. USDRONECAM LLC 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, 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.
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(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 USDRONECAM LLC Seeks And The Reason USDRONECAM

LLC Seeks The Relief.

1. Extent Of Relief USDRONECAM LLC Seeks And The Reason USDRONECAM

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 medical

12 certificates, 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, USDRONECAM LLC submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI PHANTOM 

2 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 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, USDRONECAM LLC submits that all flights of the DJI PHANTOM 2

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

USDRONECAM LLC’s business; and (2) will not carry passengers or property for 

compensation or hire.

2. Extent Of Relief USDRONECAM LLC Seeks And The Reason USDRONECAM

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 USDRONECAM LLC to determine that the DJI PHANTOM 

2 UAS is in airworthy condition prior to every flight by ensuring that the UAS is in 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI 

PHANTOM 2 Instruction Manual).

USDRONECAM LLC seeks the requested relief because the DJI PHANTOM 2

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

Subpart H.

Therefore, USDRONECAM LLC will ensure that the DJI PHANTOM 2 UAS is in 

airworthy condition based upon its compliance with the operating documents (i.e., 

Monthly Maintenance Log, and DJI PHANTOM 2 Instruction Manual) prior to every

flight, and further, determine that the aircraft is in condition for safe flight, as stated in 
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the conditions and limitations below.

3. Extent Of Relief USDRONECAM LLC Seeks And The Reason USDRONECAM

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 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), USDRONECAM LLC seeks 

the requested relief because the DJI PHANTOM 2 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 UA is 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. Extent Of Relief USDRONECAM LLC Seeks And The Reason USDRONECAM 

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 UA 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. USDRONECAM 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 UA will severely constrain the practicality of any aerial video or still photo flight 

operations that USDRONECAM LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI 

PHANTOM 2 UAS, the DJI PHANTOM 2 operating documents, and USDRONECAM

LLC’s proposed operating limitations, ensure that USDRONECAM LLC will safely 

operate the battery powered DJI PHANTOM 2 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 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 USDRONECAM LLC Seeks And The Reason Dragonfly

Live 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, USDRONECAM LLC 

requests relief from these Sections because the DJI PHANTOM 2 UAS does not require 
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airworthiness certificates. As set forth more fully below, the DJI PHANTOM 2 UAS 

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

certificate. Accordingly, USDRONECAM LLC 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., Monthly

Maintenance Log, and DJI PHANTOM 2). Furthermore, USDRONECAM LLC will 

document and maintain all maintenance records for the DJI PHANTOM 2 UAS.

D. The Reasons Why Granting USDRONECAM 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 

USDRONECAM LLC to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the 

United States.

Additionally, use of the DJI PHANTOM 2 UAS will decrease congestion of the NAS, 

reduce pollution, and provide significant benefits to the economy. Notably, the benefits 

of USDRONECAM LLC’s proposed operation of the DJI PHANTOM 2 UAS will be 

realized without implicating any privacy issues.

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

The DJI PHANTOM 2 UA is battery powered and serves 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 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 UAS 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 UAS.

Conducting aerial acquisitions with the DJI PHANTOM 2 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 UAS produces 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 UA, while reducing the carbon footprint of aerial 

acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered 
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electric motors, rather than an internal combustion engine.

By using the DJI PHANTOM 2 UAS 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 UA (weighing approximately 2 pounds 11 ounces, at 

its maximum gross weight with a 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 Operations With The DJI

PHANTOM 2 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI PHANTOM 2 UAS is also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI PHANTOM 2 UAS will allow United States based companies, 

like USDRONECAM LLC’s, 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 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 UAS, companies such as USDRONECAM

LLC’s, 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 UAS, 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, USDRONECAM LLC’s proposed operation of the DJI

PHANTOM 2 UAS will not implicate any privacy issues. Specifically, the DJI

PHANTOM 2 UAS will be operated only in compliance with operating documents (i.e., 

Monthly Maintenance Log, and DJI PHANTOM 2) which requires property owner 

involvement as well as local law enforcement notification, and in accordance with the 

Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. 

§ 91.119.
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E. 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 From Which USDRONECAM LLC Seeks Exemption.

1. Reasons Why The DJI PHANTOM 2 UA 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, USDRONECAM LLC’s operation of the 

DJI PHANTOM 2 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.

In seeking this exemption, USDRONECAM LLC submits that the DJI 

PHANTOM 2 UAS can operate safely in the NAS pursuant to FMRA Section 

333, as demonstrated by: (a) the characteristics of the DJI PHANTOM 2 UAS; (b) 

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

a. The Specifications Of The DJI PHANTOM 2 UAS Demonstrate Its Safe
14

Characteristics.

The DJI PHANTOM 2 UAS does 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 UAS.

The technical specifications of the DJI PHANTOM 2 UAS is set forth by the DJI

PHANTOM 2 Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI PHANTOM 2 UAS Autonomous Flight And Navigation Modes

Enable The UASs To Remain Within A Defined Operational Area.

The DJI PHANTOM 2 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 UAS is provided at pages 21-28 of the DJI 

PHANTOM 2 and pages 29-32 User Manual, attached hereto as Exhibit B .

iii. The DJI PHANTOM 2 UAS is 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 UA will remain stationary, 

in flight, for 3 seconds or more. If, after 3 seconds, the DJI PHANTOM 2 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 UAS 

are set forth at pages 23 of the DJI PHANTOM 2 User Manual, attached hereto as 

Exhibit

B.

iv. The DJI PHANTOM 2 GCS And Its Operation.

A complete description of the operation and specifications of the DJI PHANTOM 

2 GCS and flight control software is provided at pages 5 through 10 of the DJI

PHANTOM 2 User Manual. DJI PHANTOM 2 User Manual is attached hereto as 

Exhibits B.

b. Flight Operations Of DJI PHANTOM 2 UAS is Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer.

USDRONECAM 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 UAS. Additionally, a safety observer will assist all pilots during 

flight time.

c. Flights Of DJI PHANTOM 2 UAS Will Be Conducted Pursuant To 

Specific Operating Limitations.

In seeking this exemption, USDRONECAM LLC proposes to commercially 

operate
15

DJI PHANTOM 2 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

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 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 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 UA 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 then 

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 
16

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 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 UAS 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 

third- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the 
17

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 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 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 

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, 
18

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 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. 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 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).

32. 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.

33. 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 
19

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.

USDRONECAM LLC submits that the equivalent level of safety established by

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate 

the DJI PHANTOM 2 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 UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Considering USDRONECAM 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 UAS, 

USDRONECAM LLC submits that the additional manned airmanship experience of a 

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

USDRONECAM LLC’s 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. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

USDRONECAM LLC will not allow any PIC to operate the DJI PHANTOM 2 UAS 

unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the 

DJI PHANTOM 2 UAS training and currency requirements, that the PIC is able to safely 

operate the DJI PHANTOM 2 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 USDRONECAM LLC’s 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 
20

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 purposes). The FAA finds that at a minimum, the flighthour 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, USDRONECAM LLC will ensure safe operations by not allowing 

any PIC to operate the DJI PHANTOM 2 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 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, USDRONECAM LLC will ensure that the DJI PHANTOM 

2 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 91.121

Would Not Adversely Affect Safety.

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

because the altitude information of the DJI PHANTOM 2 UA 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 USDRONECAM LLC’s operation of the DJI PHANTOM 2

UA within visual line of sight, at or below 400 feet AGL, will ensure a level of safety 
21

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 UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, USDRONECAM LLC will 

ensure that it will safely operate the battery powered DJI PHANTOM 2 UA 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 UAS; 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

UAS provide audible and visual warnings to the PIC at the GCS when the 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 2 UAS 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, USDRONECAM 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 USDRONECAM LLC will use trained technicians to perform 

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

techniques, and practices prescribed in the operating documents (i.e., Monthly
22

Maintenance Log, and DJI PHANTOM 2 Instruction Manual). Furthermore, 

USDRONECAM LLC will document and maintain all maintenance records for the DJI 

PHANTOM 2 UAS. 

Since the DJI PHANTOM 2 UAS will be inspected as prescribed by the operating 

documents, USDRONECAM LLC will maintain the equivalent level of safety 

established by 30 Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI

PHANTOM 2 User Manual is attached hereto as Exhibit B; a copy of the DJI

PHANTOM 2 UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because 

USDRONECAM 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 UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly 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 USDRONECAM LLC’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI PHANTOM 2 UAS, 

USDRONECAM 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, USDRONECAM LLC 

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

PHANTOM 2 UAS, 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 
23

C.F.R. § 21.16, for operation of the DJI PHANTOM 2 UAS, 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 Leading Edge’s intended operation of the DJI 

PHANTOM 2 UAS, 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: The Rules

From Which USDRONECAM LLC Seeks Exemption:

 USDRONECAM 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 USDRONECAM LLC

Seeks:

This exemption will permit USDRONECAM LLC to commercially operate an

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

photography over certain areas of the United States.

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

USDRONECAM LLC’s 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, USDRONECAM LLC’s 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. 
24

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 33 security; and further, provides the authority for such UAS to operate without 

airworthiness certification.

As discussed in detail above, USDRONECAM LLC will operate the DJI 

PHANTOM 2 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, USDRONECAM 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 UAS commercially, 

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

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 USDRONECAM LLC to safely, efficiently, and economically operate the 

DJI PHANTOM 2 UAS commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, USDRONECAM 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 

USDRONECAM LLC to operate the DJI PHANTOM 2 UAS commercially for the 

purpose of conducting aerial video and photography over certain areas of the United 

States.

Dated: October 25, 2015

Respectfully submitted,

USDRONECAM LLC

_________________________

USDRONECAM LLC

231 HILLSIDE AVE FL 1

 LEONIA, NJ 07605

 Tel) 551/655-2072

 
25

Appendices:

A – DJI PHANTOM 2 Specifications Data Sheet

B – DJI PHANTOM 2 Manufacturer’s User Manual

C – Monthly Maintenance Log

APPENDIX – A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

USDRONECAM LLC only utilizes safe and reliable UASs. DJI is an industry leader in 

small UAS production. DJI UASs are loaded with ground breaking software enabling the 

user to set parameters which will not allow flight into controlled airspace. Parameters can 

also be set to limit flight to no higher than a predetermined and set altitude as well as 

limit flight to a predetermined and set distance. In addition, DJI software provides realtime altitude and location information to the PIC via the linked monitor 

1.1PHANTOM 2

1.1.1 Aircraft

1.1.1.1.Weight (Battery & Propellers included) 1000g

1.1.1.2 Hover Accuracy (Ready to Fly)

 Vertical: 0.8m;

 Horizontal: 2.5m

1.1.1.3 Max Yaw Angular Velocity 200°/s

1.1.1.4 Max Tilt Angle 35°

1.1.1.5 Max Ascent / Descent Speed

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

1.1.1.6 Max Flight Speed 15m/s(Not Recommended)

1.1.1.7 Diagonal Length 350mm

1.1.1.8 Flight Time 25mins

1.1.1.9 Take-off Weight ≤1300g

1.1.1.10 Operating Temperature -10°C ~ 50°C

1.1.2 Supported Battery

1.1.2.1 DJI Smart Battery

1.1.2.2 DJI Smart Battery Type 3S LiPo

1.1.2.3 Capacity 5200mAh, 11.1V

1.1.2.4 Charging Environment Range 0°C to 40°C

1.1.2.5 Discharging Environment Range -20°C to 50°C

1.1.3 Remote Control 

1.1.3.1 Operating Frequency 2.4GHz ISM

1.1.3.2 Communication Distance (open area) 1000m

1.1.3.3 Receiver Sensitivity (1%PER) -97dBm

1.1.3.4 Working Current/Voltage 120 mA@3.7V

1.1.3.5 Built-in LiPo Battery Working Current/Capacity 3.7V, 2000mAh
26

1.1.4 On Screen Display iOSD

1.1.4.1 Size		 33.2	*	28.0	*	10.55(mm)		

1.1.4.2	Weight	14g

1.1.4.3	Performance	Parameter	

													 Video	Input	Model PAL/NTSC

														Video	Output	Model			PAL/NTSC

1.1.4.4 Physical	Parameter	

														Temperature		-20°C~60°C

														Voltage 6V

													 Current (Typical	Value) 180mA@6V

1.1.5	Gimbal Zenmuse	H3-3D

1.1.5.1 Camera		 GoPro3+	Black	

1.1.5.2 GCU	Input	Power 3S~6S	LiPo	(12V~26V)

1.1.5.3 Mechanical	&	Electrical	

														Gimbal	Operating	Current

														•Static	current:	400mA	(@12V)

														•Dynamic	current:	600mA	(@12V)

															 Gimbal	Input	Power 3S~6S	(12V	~	26V)

		1.1.5.4	Operating	Temperature -10°C	~	50°C

		1.1.5.5	Gimbal	Weight 168g	(camera	excluded)

		1.1.5.6 Gimbal	Dimensions	(With	Damping	Unit) 97mm	X	95mm	X	73mm

		1.1.5.7	GCU	Weight 22g

		1.1.5.8 GCU	Dimensions		42	mm	X	32	mm	X	9.3	mm

		1.1.5.9 Performance	

															Controlled	Angle	Accuracy

															Tilt/Roll:	±0.02°;

														 Yaw:	±0.03°

			1.1.5.10 Maximum	Controlled	Rotation	Speed Tilt	axis:	±130°/s

			1.1.5.11	Controlled	Rotation	Range

																			Tilt	axis	control:	-130	~	+45°

		 1.1.5.12	Regulatory	Approvals			FCC	(USA) Yes

			1.1.6	Monitor LILLIPUT with	5.8GHz	Wireless	Receiver

			1.1.6.1	Antenna	Connector	:	SMA	Female

			1.1.6.2	Panel	:	7"	IPS

			1.1.6.3	Physical	Resolution	:	1280×800

			1.1.6.4	Aspect	Ratio	: 16	:	9

			1.1.6.5 Brightness	:	400cd/m2

			1.1.6.6	Contrast	:	800	:	1

			1.1.6.7	Viewing	Angle	:	178°/178°(H/V)

			1.1.6.8	Input	:	AV	X	1,	HDMI	X1

			1.1.6.9 Sound	:	Built-in	Speaker	X	1,	Ear	Phone	Slot	X	1

			1.1.6.10	Current	:	960mA

			1.1.6.11	Input	Voltage	:	7~24V
27

			1.1.6.12	Battery	Plate	:	V-mount	/	Anton	Bauer	mount	/	F970	/	QM91D	/	DU21	/			

LP-E6

			1.1.6.13	Power	Consumption	:	≤12W

			1.1.6.14	Operating	Temperature	:	-20°C~60°C

			1.1.6.15 Storage	Temperature	:	-30°C~70°C

			1.1.6.15	Dimension(LWD)	:	184.5×131×23mm

			1.1.6.16 Weight	:	365g

		1.1.7	Camera GO	PRO	3+

1.1.7.1 Weight	 2.61	oz	

1.1.7.2 Optical	Sensor	Type	CMOS	

		1.1.7.3	Wireless	Connection Wireless	LAN	

		1.1.7.4	Digital	Video	Format	H.264	

1.1.7.5 Camcorder	Sensor	Resolution 12	pixels	

		1.1.7.6	Effective	Photo	Resolution	12	Megapixel		

		1.1.7.7	Lens	System/

															Type	Lens	- f/2.8	

1.1.7.8 Li-ion	rechargeable	battery	- 1050	mAh	

															

DJI	PHANTOM	2	Manufacturer’s	User	Manual (Attached)																																															

APPENDIX – B