September 3, 2015

Docket Operations, M-30

U.S. Department of Transportation (DOT)

1200 New Jersey Ave, SE., Room W12-140

West Building Ground Floor

Washington, DC 20590-0001

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: Connie M. White 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 3 ADVANCED UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95) 

Submitted on September 3, 2015 by:

Dr. Connie White

228 Clay Hill Rd.

Richton, MS 39476

601.689.1405

connie.m.white@gmail.com

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TABLE OF CONTENTS Page 

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

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

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

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

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

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

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CONNIE M. WHITE SEEKS 

EXEMPTION.........................................................................................................................7 

THE EXTENT OF RELIEF CONNIE M. WHITE SEEKS AND THE REASON 

CONNIE M. WHITE SEEKS THE RELIEF......................................................................9 

THE REASONS WHY GRANTING CONNIE M. WHITE'S REQUEST 

WOULD BE IN THE PUBLIC INTEREST .....................................................................11 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY.......................................................................................13 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................19 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT CONNIE M. WHITE’S REQUEST................................................................19

CONCLUSION...............................................................................................................................20 

APPENDICES attached 

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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

GLONASS - Globalnaya Navigazionnaya Sputnikovaya Sistema, or Global Navigation Satellite 

System. GLONASS is Russia's version of GPS (Global Position System)

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 

Connie M. White 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 Connie M. White to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial video and photography of real estate, land 

surveying, building inspections, real estate, agriculture and horticulture over certain areas of the United

States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Connie M. White provides clients with expertise and knowledge in advanced technologies and 

solutions to increase efficiency, productivity and effectiveness. Connie M. White holds a PhD in 

Information Systems from the New Jersey Institute of Technology and has over 20 years of 

professional experience in Information Technology and is recognized as an expert in emerging 

technologies, research and software development, education and real-time decision support systems. 

She has published two books on leveraging mobile devices, emerging technology and real time 

decision support systems and has contributed chapters and published numerous articles on emerging 

technologies. She has over 25 years experience with photography and video production. The objective

Connie M. White’s aerial video and photography operations is to provide high quality imaging for a 

variety of commercial, public, and residential uses, specifically targeting: Precision Agriculture and 

Farming, Insurance, Real estate, Land Surveying, and Building Inspections and to increase 

public/private knowledge of UAS promoting safe UAS operations. 

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BACKGROUND

Unmanned Aircraft System: DJI Phantom 3 Advanced 

Connie M. White seeks an exemption to operate the DJI Phantom 3 Advanced system for compensation

or hire within the NAS. The DJI Phantom 3 Advanced 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 3 Advanced has a maximum gross weight of approximately 2 pounds

11 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum 

speed of approximately 29 knots. The DJI Phantom 3 Advanced is equipped with four main rotors; 

driven by Lithium Polymer battery powered electric motors. The DJI Phantom 3 Advanced UA that 

will be operated by Connie M. White 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, Connie M. White , 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 Professional, DJI 6 Phantom 2 Vision Plus UASs 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, Connie M. White ’s operation of DJI Phantom 3 Professional and DJI 

Phantom 2 Vision Plus 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. 

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Accordingly, Connie M. White 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. 

Connie M. White submits that the requested relief is proper since an equivalent level of safety will be 

ensured. Connie M. White 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 Advanced 

Instruction Manual). Furthermore, Connie M. White will document and maintain all maintenance 

records for the DJI Phantom 3 Advanced UAS. 

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

limitations: Pilot in command, is requested by Connie M. White 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 3 Advanced UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Connie M. White seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the 

DJI Phantom 3 Advanced UAS do not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. As such, Connie M. White submits that he will ensure that the DJI Phantom 3 

Advanced UAS 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 

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

Connie M. White also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom 3 Advanced UAs will not have a typical barometric altimeter onboard. 

However, altitude information of the DJI Phantom 3 Advanced UAs will be provided to the PIC via 

Global Positioning System (GPS) equipment, GLONASS and radio communications telemetry data 

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

information, combined with Connie M. White’s operation of the DJI Phantom 3 Advanced UASs 

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

91.121. 

Additionally, Connie M. White seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Connie M. White submits that safety will not 

be affected by operation of the DJI Phantom 3 Advanced 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 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. The battery life of the Phantom 3 

Advanced is 23 minutes.

In accordance with 14 C.F.R. § 11.81, Connie M. White 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: 

Connie M. White 

228 Clay Hill Rd, 

Richton, MS 39476

601.689.1405

connie.m.white@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Connie M. White Seeks Exemption.

1. Connie M. White 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. Connie M. White 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 

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operate a civil aircraft unless it is in an airworthy condition. 

3. Connie M. White 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. Connie M. White 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. Connie M. White 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. Connie M. White 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. Connie M. White 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. Connie M. White 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-- 11 (i) A description (or reference 

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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. (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 Connie M. White Seeks And The Reason Connie M. White Seeks The

Relief. 

1. Extent Of Relief Connie M. White Seeks And The Reason Connie M. White 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 certificate, and who has met 

certain flight-hour and currency requirements, to conduct the proposed UAS flight operations 

for compensation or hire. This relief is requested since the limitations set forth in Section 

61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an 

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

that business or employment; and (2) The aircraft does not carry passengers or property for 

compensation or hire. 

As set forth more fully below, Connie M. White submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Phantom 3 Advanced UAS 

unless that PIC has met certain flight-hour and currency requirements, demonstrating that the 

PIC is able to safely operate the DJI Phantom 3 Advanced 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, Connie M. White submits that all flights of the DJI Phantom 3 Advanced, conducted by

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the PIC pursuant to the grant of this Petition: (1) will be incidental to Connie M. White’s 

business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief Connie M. White Seeks And The Reason Connie M. White 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 Connie M. White to determine that the DJI Phantom 3 Advanced 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 3 Advanced Instruction

Manual). Connie M. White seeks the requested relief because the DJI Phantom 3 Advanced 

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

H. Therefore, Connie M. White will ensure that the DJI Phantom 3 Advanced UAS is in 

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

Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual) prior to every flight, and 

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

limitations below. 

3. Extent Of Relief Connie M. White Seeks And The Reason Connie M. White 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 Advanced 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), Connie M. White seeks the requested relief because the DJI 

Phantom 3 Advanced UA altimeter may be set on the 14 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 Advanced UA 

is equipped with a barometric pressure sensor and GPS/GLONASS 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 Connie M. White Seeks And The Reason Connie M. White 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 

Advanced 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. Connie M. White 

seeks the requested relief because without an exemption from Section 91.151(b), the flight time 

duration of the battery powered DJI Phantom 3 Advanced UA will severely constrain the 

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practicality of any aerial video or still photo flight operations that Connie M. White proposes to 

conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of

the DJI Phantom 3 Advanced UAS, the DJI Phantom 3 Advanced operating documents, and 

Connie M. White’s proposed operating limitations, ensure that Connie M. White will safely 

operate the battery powered DJI Phantom 3 Advanced 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 Connie M. White Seeks And The Reason Connie M. White 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, Connie M. White requests relief from these Sections

because the DJI Phantom 3 Advanced UAS does not require airworthiness certificates. As set 

forth more fully below, the DJI Phantom 3 Advanced UAS meets the conditions of FMRA 

Section 333 for operation without an airworthiness certificate. Accordingly, Connie M. White 

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 3 Advanced). Furthermore, 

Connie M. White will document and maintain all maintenance records for the DJI Phantom 3 

Advanced UAS. 

D. The Reasons Why Granting Connie M. White’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 Connie M. White to 

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

surveying, building inspections, real estate, agriculture and horticulture over certain areas of the

United States. Additionally, use of the DJI Advanced UAS will decrease congestion of the NAS,

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

Connie M. White’s proposed operation of the DJI Phantom 3 Advanced UAS will be realized 

without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. The DJI Phantom 3 

Advanced 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 3 Advanced 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 Advanced UA does not require an airport to takeoff or land. Likewise, a reduction of

manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, 

and landing phases of flight operations. 

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

UAS. Conducting aerial acquisitions with the DJI Phantom 3 Advanced 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 3 Advanced 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 3 Advanced UA, while reducing the carbon footprint of aerial acquisitions, also 

eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather 

than an internal combustion engine. By using the DJI Phantom 3 Advanced 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 3 Advanced 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 3 Advanced 

UAS Will Benefit The Economy. In addition to being safe and efficient, the DJI Phantom 3 

Advanced UAS is also an economical alternative to using manned aircraft to conduct similar 

aerial operations. As such, operation of the DJI Phantom 3 Advanced UAS will allow United 

States based companies, like Connie M. White’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 3 Advanced 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 Advanced UAS, companies such as Connie M. 

White’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 3 Advanced 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, Connie M. White’s proposed operation of the DJI Phantom 3 

Advanced UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 

Advanced UAS will be operated only in compliance with operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 3 Advanced) 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 Connie M. White Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Advanced 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, Connie M. White’s operation of 

the DJI Phantom 3 Advanced 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, Connie M. White submits that the DJI Phantom 3 Advanced UAS can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI 

Phantom 3 Advanced UAS; (b) the pilot certification requirement; and (c) the specific operating 

limitations. a. The Specifications Of The DJI Phantom 3 Advanced UAS Demonstrate Its Safe 

Characteristics. The DJI Phantom 3 Advanced 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 3 Advanced UAS. The technical

specifications of the DJI Phantom 3 Advanced UAS is set forth by the DJI Phantom 3 Advanced 

Specifications and Data Sheet, attached hereto as Exhibit A. ii. The DJI Phantom 3 Advanced UAS 

Autonomous Flight And Navigation Modes Enable The UASs To Remain Within A Defined 

Operational Area. The DJI Phantom 3 Advanced 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 3 Advanced UAS is provided at pages 11-29 and pages 40-46 of the DJI Phantom 3 Advanced

User Manual, attached hereto as Exhibit B . iii. The DJI Phantom 3 Advanced 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 3 Advanced UA will remain stationary, in flight, for 3 

seconds or more. If, after 3 seconds, the DJI Phantom 3 Advanced UA does not reacquire control link 

data from the GCS and GLONASS, 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 

13
shutdown. A complete description of the Failsafe Functions of the DJI Phantom Advanced UAS are set 

forth at page 14 of the DJI Phantom 3 Advanced User Manual, attached hereto as Exhibit B. There is 

also a RTH (Return to Home) button on the RC which further adds safety features. iv. The DJI 

Phantom 3 Advanced GCS And Its Operation. A complete description of the operation and 

specifications of the DJI Phantom 3 Advanced GCS and flight control software is provided at pages 35 

through 38 of the DJI Phantom 3 Advanced User Manual. In seeking this exemption, Connie M. White 

proposes to commercially operate DJI Phantom 3 Advanced 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 3 Advanced 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. 22 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. 6. The use of first person view (FPV) by the PIC or safety 

observer (SO) is not permitted. 7. All operations must utilize a safety observer (SO). The SO may be 

used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO 

and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not 

permitted during flight operations. The PIC must be designated before the flight and cannot transfer his

or her designation for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 8. The SO must not perform any other duties beyond 

assisting the PIC with seeing and avoiding other air traffic and other ground based 

obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating 

documents and the grant of exemption must be accessible during UAS operations and made available 

to the Administrator upon request. If a discrepancy exists between the conditions and limitations 

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

conditions and limitations contained in the grant of exemption take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating documents. The 

operator may update or revise its operating documents. It is the operator’s responsibility to track such 

revisions and present updated and revised documents to the Administrator upon request. The operator 

must also present updated and revised documents if it petitions for extension or amendment to the grant

of exemption. If the operator determines that any update or revision would affect the basis upon which 

the FAA granted the exemption, then the operator must petition for amendment to its grant of 

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS 

to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe

operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has 

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

must be included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 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. 

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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. 18. The operator may not permit any PIC to operate 

unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate 

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

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

vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 

C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms

of the exemption. However, training operations may only be conducted during dedicated training 

sessions. During training, proficiency, and experience-building flights, all persons not essential for 

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, 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 

15
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 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. 

Connie M. White 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 Advanced UAS unless

that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 Advanced UAS in a manner consistent with the exemption, 

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

vessels, vehicles and structures. 26 Considering Connie M. White’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 3 Advanced UAS, Connie M. White 

submits that the additional manned airmanship experience of a commercially certificated pilot would 

not correlate to the airmanship skills necessary for Connie M. White’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). Connie M. White will not allow any PIC to operate the DJI Phantom 3 

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

DJI Phantom 3 Advanced UAS training and currency requirements, that the PIC is able to safely 

operate the DJI Phantom 3 Advanced 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). 27 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 Connie M. White’s proposed operations. The Administrator 

has held that prior documented flight experience that was obtained in compliance with applicable 

16
regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA 

required that prior to conducting operations for the purpose of motion picture filming (or similar 

operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 

25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a

multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated 

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

used for operations under the exemption. For clarification, the FAA considers these minimum hour 

requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in 

the 10 hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS 

rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings 

in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight-hour 

requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills 

necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior 

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

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

under the grant of exemption to accomplish the required flight time. During training, proficiency, and 

experience-building flights the PIC is required to operate the UA with appropriate distances in 

accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Connie M. White 

will ensure safe operations by not allowing any PIC to operate the DJI Phantom 3 Advanced 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 3 Advanced 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, Connie M. White will ensure that the 

DJI Phantom 3 Advanced 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 3 Advanced 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 Connie 

M. White’s operation of the DJI Phantom 3 Advanced UA within visual line of sight, at or below 400 

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be 

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

point is automatically established by the UASs at ground level. The FAA has previously granted relief 

from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 29 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 Advanced UAS; (2) the 

limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, Connie M. White will ensure that it will safely operate the battery powered DJI Phantom 

17
3 Advanced 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 3 Advanced 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 3 Advanced 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 3 Advanced 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 30 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, Connie M. White 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 

Connie M. White 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 Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual). 

Furthermore, Connie M. White will document and maintain all maintenance records for the DJI 

Phantom 3 Advanced UAS. Since the DJI Phantom 3 Advanced UAS will be inspected as prescribed by

the operating documents, Connie M. White will maintain the equivalent level of safety established by 

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 3 Advanced User 

Manual is attached hereto as Exhibit B; a copy of the DJI Phantom 3 Advanced UAS Maintenance 

LOG is attached hereto as Exhibit C. Likewise, the exemption sought will not adversely affect safety 

because Connie M. White 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 

3 Advanced 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 Connie M. White’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3 Advanced UAS, Connie M. White

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, Connie M. White 

18
requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

Advanced 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 32 over certain areas of the United States for compensation

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

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

provides the authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the 

Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI 

Phantom 3 Advanced 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 3 Advanced 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 

Connie M. White Seeks Exemption: Connie M. White 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 Connie M. White Seeks: 

This exemption will permit Connie M. White 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 Connie M. White’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, Connie M. White’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. 

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. 

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As discussed in detail previously, Connie M. White will operate the DJI Phantom 3 Advanced 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, Connie M. White 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 3 Advanced 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 Connie M. White to 

safely, efficiently, and economically operate the DJI Phantom 3 Advanced UAS

commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Connie M. White 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 Connie M. White to operate the 

DJI Phantom 3 Advanced UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: September 3, 2015

Respectfully submitted,

Dr. Connie White

228 Clay Hill Rd.

Richton, MS 39476

601.689.1405

connie.m.white@gmail.com

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