IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

R. C. Tripp 

SSN #: 094-50-0432

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS 

SECTIONS 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 a) DJI PHANTOM 3 and b) DJI INSPIRE 1 

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95) 

Submitted on June 10, 2015

R. C. Tripp

Regnal Tripp, Owner 

143 Marion Oaks Drive 

Ocala, Florida 34473 

 352-817-4857 

langerppirt@aol.com

 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH, R. C. Tripp 

SEEKS EXEMPTION ....................................................................................... 

THE EXTENT OF RELIEF AND THE REASON 

R. C. Tripp SEEKS THE RELIEF .............................................................

THE REASONS WHY GRANTING R. C. Tripp’s REQUEST WOULD 

BE IN THE PUBLIC INTEREST ...................................................................................

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY............................................................................................................ 
			

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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) 

SO Safety Observer 

SOP Standard Operating Procedures 

UA Unmanned Aircraft 
			

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UAS Unmanned Aircraft System 

VFR Visual Flight Rules 

VLOS Visual Line of Site 

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

SUMMARY

 R. C. Tripp seeks exemption from the requirements of 14 C.F.R §§ 

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 R. C. Tripp to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography for real estate photography, wedding 

videography, special events, film sets and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

My name is Regnal Tripp, Owner/President of R. C. Tripp. It is my goal to 

provide my customers with solutions that will increase their efficiency, productivity and 

effectiveness. R. C. Tripp also provides clients with the highest quality digital content for 

use in their commercial, personal, and non-profit multimedia projects. The objective of 

R. C. Tripp’s aerial video and photography operations is to provide high quality imaging 

for a variety of commercial, public, and residential uses, specifically targeting: 

• Real Estate Videography and Photography 

• Wedding Videography and Photography 

• Land survey & appraisals 

• Equipment Inspections 

• Roof Inspections 

• Construction sites 
			

4			

• Agriculture 

• Commercial messages for Television. 

• Search and Rescue Operations 

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3, and DJI Inspire 1 UASs 

R. C. Tripp seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 3 and DJI Inspire 1 are vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The DJI Phantom 3 has a maximum gross 

weight of approximately 2 pounds 8 ounces, while having a length of 16.2 inches width 

of 16 inches, height of 8 inches, and a maximum speed of approximately 30 knots. The 

DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 

inches, width of 17.7 inches, height of 11.8 inches, and a maximum speed of 

approximately 42 knots. The DJI Phantom 3 and DJI Inspire 1 UAs are equipped with 

four main rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by DRONE NY, Inc. 

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, R. C. Tripp, 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 3, DJI Inspire 1 UASs 

in the National Airspace System (NAS), and for an exemption from the requirements of 14 

C.F.R §§ 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, R. C. Tripp operation of DJI Phantom 3 and 

DJI Inspire 1 UASs 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, R.C. Tripp 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. 
			

5			

R. C. Tripp submits that the requested relief is proper since an equivalent level of 

safety will be ensured. I 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 3 and DJI Inspire 1 Instruction Manual). Furthermore, I will 

document and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 

UASs. 

R. C. Tripp seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3 and DJI Inspire 1 UASs do not require an airworthiness 

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

that he will ensure that the DJI Phantom 3 and DJI Inspire 1 UASs are 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 3 and DJI Inspire 

1 Instruction Manual), and that the aircraft are in a condition for safe flight. 

R. C. Tripp also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Phantom 3

and DJI Inspire 1UAs 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 R. C. Tripp’s operation of the DJI Phantom 3 and DJI Inspire 1 UASs within visual 

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

91.121. 

Additionally, R. C. Tripp seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. R. C. Tripp submits 

that safety will not be affected by operation of the DJI Phantom 3 and DJI Inspire 1 UAs during 

daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with 

enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of 

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

In accordance with 14 C.F.R. § 11.81, R. C. Tripp 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: 

Regnal Tripp, DBA R. C. Tripp

143 Marion Oaks Drive

Ocala, Florida, 34473
			

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Tel: (352) 817-4857

Email: langerppirt@aol.com

B. The Specific Sections of 14 C.F.R. From Which R. C. Tripp Seeks Exemption. 

1. R. C. Tripp Seeks Exemption from The Requirements Of Section Part 21, 

Subpart H 

14 C.F.R. Part 21, Subpart H, establishes the procedural requirements for the 

issuance of airworthiness certificates as required by 14 C.F.R. §91.203(a)(1) 

2. R. C. Tripp 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. R. C. Tripp 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--

 (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. R. C. Tripp Seeks Exemption from The Requirements Of Section 

 91.151(b). 

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

(b), states the following: 

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

(considering wind and forecast weather conditions) there is enough fuel to fly to 

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

after that for at least 20 minutes. 

5. R. C. Tripp Seeks Exemption from The Requirement Of Section 

 91.405(a). 
			

7			

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. R. C. Tripp 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. R. C. Tripp Seeks Exemption From The Requirements Of Sections 91.409(a)(1) 

And 91.409(a)(2). 

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

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

 aircraft unless, within the preceding 12 calendar months, it has had -- (1) An 

annual inspection in accordance with part 43 of this chapter and has been 

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

chapter; or 

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

with part 21 of this chapter. 

8. R. C. Tripp 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 
			

8			

(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. 

(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 R. C. Tripp Seeks and The Reason R. C. Tripp Seeks The Relief. 

1. R. C. Tripp Seeks Exemption from the Requirements Of Section Part 21, 

Subpart H 

Given the size and limited operating area associated with the UAS to be utilized by R. C. 

Tripp 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 
			

9			

be at least as safe, or safer, than a conventional rotorcraft operating with an airworthiness 

certificate without the restrictions and conditions of the proposed UAS operations.

2Extent Of Relief R. C. Tripp Seeks And The Reason R. C. Tripp 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 R. C. Tripp to determine that the DJI Phantom 3 and DJI Inspire 1 UASs 

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

with the operating documents (i.e., the Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). 

R. C. Tripp seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 UASs do 

not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. Therefore, R. C. Tripp will ensure that the DJI Phantom 3 and DJI 

Inspire 1 UASs are in airworthy condition based upon its compliance with the operating 

documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 

Instruction Manual) prior to every flight, and further, determine that the aircraft are in 

condition for safe flight, as stated in the conditions and limitations below. 

3.Extent Of Relief R. C. Tripp Seeks And The Reason R. C. Tripp 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 3 and DJI Inspire 1 UASs, which utilize a barometric 

pressure sensor, GPS equipment, and a radio communications telemetry data link to 

downlink altitude information from the UA to the PIC at the ground control station 

(GCS). Since the FAA requires that any altitude information concerning UAS operations 

be reported to air traffic control (ATC) in feet above ground level (AGL), R. C. Tripp

seeks the requested relief because the DJI Phantom 3 and DJI Inspire 1 UA’s altimeter 

may be set on the ground to zero feet AGL, rather than the local barometric pressure or 

field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

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

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

maintained since the DJI Phantom 3 and DJI Inspire 1 UAs are equipped with a 

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

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

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

4. Extent Of Relief R.C. Tripp Seeks And The Reason R. C. Tripp 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 3
			

10 			

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

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

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. R. C. Tripp seeks the requested relief because without an exemption from 

Section 91.151(b), the flight time duration of the battery powered DJI Phantom 3 and DJI 

Inspire 1 UAs will severely constrain the practicality of any aerial video or still photo 

flight operations that R. C. Tripp proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 3 and DJI

Inspire 1 UASs, the DJI Phantom 3 and DJI Inspire 1 operating documents, and R. C. 

Tripp’s proposed operating limitations, ensure that R. C. Tripp will safely operate the 

battery powered DJI Phantom 3 and DJI Inspire 1 UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

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

5.Extent Of Relief R. C. Tripp Seeks And The Reason R. C. Tripp 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, R. C. Tripp requests relief from these 

Sections because the DJI Phantom 3 and DJI Inspire 1 UASs do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 3 and DJI Inspire 1 UASs meet 

the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, R. C. Tripp will use trained technicians to perform maintenance or preventive 

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

UAS operating documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). Furthermore, R. C. Tripp will 

document and maintain all maintenance records for the DJI Phantom 3 and DJI Inspire 1 

UASs

.

D. The Reasons Why Granting R. C. Tripp’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 R. C. Tripp to 

safely, efficiently, and economically perform aerial video and photography of, real estate, 

wedding films, special events, precision agriculture, land survey & appraisal, construction

sites, equipment & roof inspections, film sets and landscape over certain areas of the 

United States. 

Additionally, use of the DJI Phantom 3 and DJI Inspire 1 UASs will decrease congestion of 

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

benefits of R. C. Tripp’s proposed operation of the DJI Phantom 3 and DJI Inspire 1 UASs 

will be realized without implicating any privacy issues. 

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

11 			

The DJI Phantom 3 and DJI Inspire 1 UAs are battery powered and serve as a safe, 

efficient, and economical alternative to the manned aircraft traditionally utilized to obtain 

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

acquisitions, an exemption allowing the use of a DJI Phantom 3 or DJI Inspire 1 UAS 

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

well as increase the safety of life and property in the air and on the ground. 

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

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

DJI Phantom 3 and DJI Inspire 1 UAs do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial video and photography missions 

would result in fewer aircraft that must be handled by air traffic control during the ground, 

takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 and DJI 

Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UAS’s, 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 3 and DJI 

Inspire 1 UASs produce no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal combustion engine aircraft that are 

typically utilized for aerial video and photography, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The DJI Phantom 3 and DJI Inspire 1 UAs, while 

reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

UAs are propelled by battery powered electric motors, rather than an internal combustion 

engine. 

By using the DJI Phantom 3 and DJI Inspire 1 UAS’s 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 3 and DJI Inspire 1 UAs (weighing approximately 2 pounds 11 

ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with 

lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches 

respectively, and with no fuel on board), has less physical potential for collateral damage 

to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a 

wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 

gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 3 and 

DJI Inspire 1 UASs Will Benefit The Economy. 
			

12 			

In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 UASs are 

also an economical alternative to using manned aircraft to conduct similar aerial 

operations. As such, operation of the DJI Phantom 3 and DJI Inspire 1 UASs will allow 

United States based companies, like R. C. Tripp, 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 3 and DJI 

Inspire 1 UASs is one such technology that not only allows companies greater operational 

flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 3 and DJI Inspire 1 UASs, companies such as R. C. Tripp

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 3 and DJI Inspire 1 UASs, provides a stable workforce that increases 

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

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

States and abroad. 

4. There Are No Privacy Issues. 

R. C. Tripp’s proposed operation of the DJI Phantom 3 and DJI Inspire 1 UASs will not 

implicate any privacy issues. Specifically, the DJI Phantom 3 and DJI Inspire 1 UASs will be 

operated only in compliance with operating documents (i.e., the Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual) 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. 

 

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 R. C. Tripp Seeks Exemption. 

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 UAs Meet 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, R. C. Tripp’s operation of the DJI Phantom 3 and DJI

Inspire 1 UAS’s 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. 

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 
			

13 			

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, R. C. Tripp submits that the DJI Phantom 3 and DJI Inspire 1 

UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) 

the characteristics of the DJI Phantom 3 and DJI Inspire 1 UASs; (b) the pilot certification 

requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs Demonstrate Its Safe

Characteristics. 

The DJI Phantom 3 and DJI Inspire 1 UASs do not create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs. The 

technical specifications of the DJI Phantom 3 and DJI Inspire 1 UASs are set forth by the 

DJI Phantom 3 and DJI Inspire 1 Specifications and Data Sheet, attached hereto as 

Exhibit A and B.

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous Flight And 

Navigation Modes Enable The UASs To Remain Within A Defined Operational 

Area. 
			

14 			

The DJI Phantom 3 and DJI Inspire 1 UASs may be operated in both manual and fully

autonomous flight modes. A complete description of the flight and navigational modes of 

the DJI Phantom 3 and DJI Inspire 1 UASs are provided at pages 2341 of the DJI 

Phantom 3; and pages 12-18 and 45-52 of the DJI Inspire 1 User Manuals, attached hereto 

as Exhibit C and D. 

iii. The DJI Phantom 3 and DJI Inspire 1 UASs Are Designed For Automatic 

Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or 

Navigation. 

When the Control Link is lost, the DJI Phantom 3 and DJI Inspire 1 UAs will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 and DJI

Inspire 1 UAs do not reacquire control link data from the GCS, the UAs will assume that 

the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) 

via GPS, and will descend to the takeoff position and shutdown. A complete description 

of the Failsafe Functions for the DJI Phantom 3 UAS are set forth at pages 32 through 34 

of the DJI Phantom 3 User Manual; and for the DJI Inspire 1 at pages 13 through 15 of 

the DJI Inspire 1 User Manual, attached hereto as Exhibit C and D. 

iv. The DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation. A complete 

description of the operation and specifications of the DJI Phantom 3 and DJI Inspire 1 

GCS and flight control software is provided at pages 7 through 17 of the DJI Phantom 3

User Manual; and pages 24 through 34 of the DJI Inspire 1 User Manual. DJI Phantom 3

and DJI Inspire 1 User Manuals are attached hereto as Exhibits C and D. 

b. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UASs Are Limited To 

The Line Of Sight Of A Pilot in Command With A Safety Observer. 

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

(b) Would Not Adversely Affect Safety. 

R. C. Tripp 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 3 and DJI Inspire 1 UASs unless that PIC has demonstrated that the PIC is a

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, R. C. Tripp will ensure that the DJI Phantom 3 or DJI Inspire 

1 UAS is in an airworthy condition based upon the UAS’s compliance with its operating 

documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 

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

15 			

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 3 and DJI Inspire 1 UAs will be 

provided to the PIC via GPS equipment and a radio communications telemetry data link, 

which downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with operation of the DJI Phantom 3 and DJI

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

safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. 

Prior to each flight, a zero altitude initiation point is automatically established by the UASs 

at ground le. 

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 3 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; 

and (3) the location of the proposed flight operations. Accordingly, R. C. Tripp will 

ensure that it will safely operate the battery powered DJI Phantom 3 and DJI Inspire 1 

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

duration of 13.5 minutes to the first point of intended landing and, assuming normal 

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

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

3 and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and the 

location of the proposed operations, will ensure an equivalent level of safety established 

by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 3

and DJI Inspire 1 UASs 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 3 and DJI Inspire 1 UASs will descend 

and land automatically. 

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, I submit 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 We will use 

trained technicians to perform maintenance or preventive maintenance on the UASs using the 

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

16 			

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 

Instruction Manual.

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

The Rules From Which R. C. Tripp Inc. Seeks Exemption: 

R. C. Tripp seeks exemption from the requirements of 14 C.F.R Sections 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 R. C. Tripp Seeks: 

This exemption will permit R. C. Tripp to commercially operate an Unmanned Aircraft 

System (UAS) for the purpose of conducting aerial video and photography over certain 

areas of the United States. 

In accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of 2012, Section 333, R. C. Tripp respectfully request that the Administrator grant this 

petition for an exemption from the requirements of 14 C.F.R Sections 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).

Dated: June 10, 2015

Respectfully submitted,

_______________________

Regnal Tripp, Owner

R. C. Tripp

143 Marion Oaks Drive

Ocala, Fl 34473

(352) 817-4857

langerppirt@aol.com
			

17 			

APPENDIX – A 

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS 

1.1 DJI Phantom 3

1.1.1 Aircraft 

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 

1.1.1.4 Max Yaw Angular Velocity - 200/s 

1.1.1.5 Max Tilt Angel - 35

1.1.1.6 Max Ascent Speed – 6m/s 

1.1.1.7 Max Descent Speed – 2m/s 

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

1.1.2 Gimbal 

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

1.1.2.2 Control Accuracy - ±0.03

1.1.2.3 Controllable Range – Pitch: -90 - 0

1.1.2.4 Maximum Angular Speed – Pitch: 90/s 

1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 32F - 104F (0C - 40C) 

1.1.3.2 Sensor Size – 1/2.3” 

1.1.3.3 Effective Pixels – 14M 

1.1.3.4 Resolution – 4384x3288 

1.1.3.5 HD Video Recording – 1080p30 & 720p 

1.1.3.6 Recording Field of View - 110/85

1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz 

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 
			

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1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm 

1.1.4.4 Transmitter Power – FCC Compliance: 100mW 

1.1.4.5 Working Voltage – 120mA@3.7V 

 

1.1.5 Range Extender 

1.1.5.1 Operating Frequency – 2412-2462MHz 

1.1.5.2 Communication Distance (unobstructed) – 500-700m 

1.1.5.3 Transmitter Power – 20dB

APPENDIX – B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

2.2 DJI Inspire 1 

2.2.1 Aircraft 

2.2.1.1 Model – T600 

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g) 

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 2.5m 

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 

2.2.1.5 Max Tilt Angle - 350 

2.2.1.6 Max Ascent Speed – 5m/s 

2.2.1.7 Max Descent Speed – 4m/s 

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT RECOMMENDED) 

2.2.1.9 Max Flight Altitude – 4500m 

2.2.1.10 Max Wind Resistance – 10m/s 

2.2.1.11 Max Flight Time – Approximately 18 minutes 

2.2.1.12 Motor Model – DJI 3510 

2.2.1.13 Propeller Model – DJI 1345 

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 400C) 

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal 

2.2.2.1 Model – ZENMUSE X3 

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 

2.2.2.3 Operating Current – Static: 750mA; In Motion: 900mA 

2.2.2.4 Angular Vibration Range - ±0.030 

2.2.2.5 Mounting – Detachable 

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 

2.2.2.7 Mechanical Range – Pitch: -1250 to 450; Pan: ±3300 

2.2.2.8 Max Controllable Speed – Pitch: 1200/s; Pan: 1800/s 

2.2.3 Camera 
			

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2.2.3.1 Name – X3 

2.2.3.2 Model – FC350 

2.2.3.3 Total Pixels – 12.76M 

2.2.3.4 Effective Pixels – 12.4M 

2.2.3.5 Image Max Size – 4000x3000 

2.2.3.6 ISO Range – 100-3200 

2.2.3.7 Field of View - 940 

2.2.3.8 CMOS – Sony EXMOR 1/2.3” 2.2.3.9 

HD Video Recording – UHD(4K): 

 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60;