August 24, 2015 

US Department of Transportation 

Docket management System 

1200 New Jersey Ave., SE Washington, DC 20590 

RE: Exemption request under Section 333 of the FAA Rreform Act and Part 11 of the Federal Aviation 

Regulations. 

Dear Sir or Madam: 

Pursuant to Section 333 of the FAA modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. 

part 11, Diebold Resources, LLC (the "Operator") of the DJI products including the Phantom 2 (Standard and 

Vision Plus V+), Phantom 3 (Standard, Advanced and Professional), and Inspire 1 small Unmanned Aircraft 

Systems ("sUAS") seeks and exemption fro the Federal Aviation Regulations ("FARs") listed below and 

discussed in Appendix A. User manuals for the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 

(Standard, Advanced and Professional), and DJI inspire 1 sUAS are attached in Appendices C through E. 

Attached as Appendix B is a summary of this request. 

The requested exemption would permit Diebold Resources, LLC commercial operation of company owned 

sUAS: DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), 

and DJI inspire 1 which weigh 2.7 lbs, 2.8 lbs, and 6.5 lbs respectively. Onboard cameras are used to perform 

aerial video and photography services. the sUAS's cameras produce high quality images and video that is then 

edited and sorted and combined with images and video taken from land based photography equipment. 

Applications can include commercial and residential real estate, aerial survey, mapping, 3D modeling, general 

aerial photography, and flight training. 

Operations under the exemption will be sugject to strict operating requirements and conditions to ensure at least 

an equivelant level of safety to currently authorized operations using manned aircraft and under conditions as 

may be modified by the FAA as required by Section 333. 

As described more fully below, the requested exemption would authorize Diebold Resources to perform 

commercial operations of aerial video and photography using it's company owned sUAS that are small in size 

and powered electrically by battery. The sUAS will be operated under controlled conditions at low altitude in 

airspace that is limited in scope, as described more fully herein; it will have automated control features, as 

described below. the sUAS is designed to be operated by one person but flight operations generally involve two 

people: an operator and an observer. The operator is responsible for flying the sUAS, monitoring it's status and 

flight 

dynamics while maintaining visual line of sight (vLOS), and keeping the flight within the specified factory 

limitations (wind, flight range, battery life, etc.) to ensure safe operation of the sUAS itself. The observer is 

responsible for monitoring the airspace for other aircraft and hazards and instructing the operator before and 

during flight as necessary to ensure safe separation with other aircraft and hazards. Finally, the airspace in 

which the sUAS will operate will be disclosed to and approved, as needed, by the FAA in advance. 

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The sUAS that will be operated by Diebold Resources 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.

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

it's operation, Diebold Resources' operation of DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 

(Standard, Advanced and Professional), and DJI inspire 1 sUAS 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, Diebold Resources 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. 

Diebold Resources submits that the requested relief is proper since and equivalent level of safety will be 

ensured. Diebold Resources will use experienced personnel or technicians to perform maintenance, alterations, 

or preventive maintenance on the sUAS using the methods, techniques, and practices prescribed in the operating 

documents (i.e., of DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and 

Professional), and DJI inspire 1 user manuals). Furthermore, Diebold Resources will document and maintan all 

maintenance records for the of DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, 

Advanced and Professional), and DJI inspire 1 sUAS. 

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

Pilot in command, is requested by Diebold Resources to the extent necessary to allow a Pilot in Command 

(PIC) holding a sport pilot or higher certificate, as well as an airman medical certificate or valid driver's license. 

The PIC must also be able to safely operate the of DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 

3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaing appropriate distances from people, vessels, vehicles 

and structures. 

Diebold Resources requests relief from Section 45.23(b), entitled Marking of the Aircraft, as the DJI Phantom 2 

(Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 have 

no entrances to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size of the 

sUAS, two-inch lettering will be impossible. Official marking systems for small sUAS have not yet been 

established for operations inside the NAS. Diebold Resources proposes to mark the top of the vehicle with the 

registration number with marking as large as practicable. 

Diebold Resources seeks relief from Section 91.119, entitled Minimum Safe Altitudes. As set forth herein, the 

sUAS will never operate at higher than 500 feet AGL. It will, however, be operated to avoid congested or 

populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, mapping and 

inspection work general aerial photography must be accomplished at relatively low altitudes and at altitudes less 

than 500 feet AGL, an exemption from Section 91.119(c) is needed. 

Diebold Resources asks for relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI 

Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI 

inspire 1 sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As 

such, Diebold Resources submits that it will ensure that the DJI Phantom 2 (Standard and Vision Plus V+), DJI 

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Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS are in an airworthy condition, prior 

to every flight, by determining that the sUAS are in compliance with the operating documents (i.e. DJI Phantom 

2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 user 

manuals), and that the aircraft are in a condition for safe flight. 

Diebold Resources also seeks an exemption from the requirements of Section 91.121, entitled Altimeter 

Settings, as the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and 

Professional), and DJI inspire 1 sUAS will not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and 

Professional), and DJI inspire 1 sUAS 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 Diebold Resources' operation of DJI 

Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI 

inspire 1 sUAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. 

Additionally, Diebold Resources seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions Diebold Resources submits that safety will not be affected by 

operation of the DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and 

Professional), and DJI inspire 1 sUAS 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. 

Name and address of the Petitioner:

Diebold Resources 

Attn: Darin Diebold 

4604 Games Trail 

Minnetrista, MN 55375 

612.208.3766 (c) 

darin.diebold@gmail.com 

The Specific Sections Of 14 C.F.R. From Which Diebold Resources Seeks Exemption. 

14 C.F.R. 45.23(b); 

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

14 C.F.R. 91.7(a); 

14 C.F.R. 91.119; 

14 C.F.R. 91.121; 

14 C.F.R. 91.151(a); 

14 C.F.R. 91.405(a); 

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

14 C.F.R. 91.409(a)(2); 

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

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Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in 

this letter are appropriate, provide an equivalent level of safety, and are in the public interest. 

Mandatory Operating Conditions: 

Grant of the exemption to Diebold Resources will be subject to the following mandatory conditions, which are 

based upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of 

Authorization, with additional restrictions: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the 

operating documents, rotorcraft sUAS weighing less than 55 pounds maximum gross weight: DJI Phantom 2 

(Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1. 

2. sUAS operations under this exemption will be limited to conducting operations for the purpose of aerial 

video and photography. 

3. The sUAS may not be flown at an indicated airspeed not exceeding 85 knots 

4. The sUAS must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated 

by the procedures specified in the operating documents unless a special request is made and approved by ATC. 

All altitudes reported to ATC must be in feet AGL. 

5. The sUAS 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. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight 

(VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the 

PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. 

7. This exemption and all documents needed to operate the sUAS and conduct its operations in accordance with 

the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating 

documents. The operating documents must be accessible during sUAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and 

the procedures outlined in the operating documents, the conditions and limitations herein 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 or any law enforcement official upon 

request. The operator must also present updated and revised documents if it petitions for extension or 

amendment to this grant of exemption. If the operator determines that any update or revision would affect the 

basis upon which the FAA granted this exemption, then the operator must petition for an 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. 

8. The operator is responsible for maintaining and inspecting the sUAS to ensure that it is in a condition for safe 

operation. 

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9. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the sUAS is in a condition for 

safe flight. The pre-flight inspection must account for all potential discrepancies, e.g., inoperable components, 

items, or equipment. If the inspection reveals a condition that affects the safe operation of the sUAS, the aircraft 

is prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in 

a condition for safe flight. 

10. The operator must follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, 

replacement, inspection, and life limit requirements. 

11. Each sUAS operated under this exemption must comply with all manufacturer Safety Bulletins. 

12. The authorized person must make an entry in the aircraft record of the corrective action taken against 

discrepancies discovered between inspections. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, 

or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. 

driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

Government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft 

in which the PIC is rated on his or her pilot certificate. 

14. 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 sUAS in a manner consistent with how the sUAS 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). 

15. sUAS 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. 

16. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAApublished 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. 

17. 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. 

18. 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. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the 

operating documents. 

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20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) 

there is enough available power for the UA to conduct the intended operation and to operate after that for at 

least 5 minutes or with the reserve power recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be 

conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new or amended 

COA if it intends to conduct operations that cannot be conducted under the terms of the original COA. 

22. 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. 

23. Documents used by the operator to ensure the safe operation and flight of the sUAS and any documents 

required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the 

sUAS any time the aircraft is operating. These documents must be made available to the Administrator or any 

law enforcement official upon request. 

24. The sUA must remain clear and yield the right of way to all manned aviation operations and activities at all 

times. 

25. The sUAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 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 in a manner ensuring the safety of 

nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer 

to those objects 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. 

*The PIC, VO, operator trainees or essential persons are not considered. 

27. 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. 

28. 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 (AFS80) within 24 hours. Accidents must be reported to the National Transportation Safety Board 

Page 6 of 14
As set forth herein, Diebold Resources seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 

(Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS 

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 Diebold Resources to safely, efficiently, and economically operate the 

DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI 

inspire 1 sUAS commercially within the NAS. 

Respectfully submitted, 

/e/ Darin Diebold 

Darin Diebold 

Diebold Resources, LLC 

4604 Games Trail 

Minnetrista, MN 55375 

612.208.3766 

Appendices: 

A – Exemption Request and Equivalent Level of Safety Showing Under Applicable Rules Subject to Exemption 

B – Summary of Diebold Resources Section 333 Exemption Request 

C – DJI Phantom 2 Manufacturer’s User Manual 

D – DJI Phantom 3 Manufacturer’s User Manual 

E – DJI Inspire 1 Manufacturer’s User Manual 

Page 7 of 14
APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION

Diebold Resources requests an exemption from the following regulations as well as any additional regulations 

that may technically apply to the operation of its sUAS: 

14 C.F.R. § 45.23: Marking of the Aircraft 

Regulation 45.23 provides: 

(a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter 

“N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix 

letter used in the marks displayed must also be a Roman capital letter. 

(b) When marks include only the Roman capital letter “N” and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, 

the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport,” 

“experimental,” or “provisional,” as applicable. 

The DJI Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), and 

DJI inspire 1 have no entrances to the cabin, cockpit, or pilot station on which the markings can be placed. 

Given the size of the sUAS, two-inch lettering will be impossible. Official marking systems for small UAS have 

not yet been established for operations inside the NAS. Diebold Resources proposes to mark the top of the 

vehicle with the registration number with marking as large as practicable. 

14 C.F.R. § 61.113(a) & (b): Private Pilot Privileges and Limitations; Pilot in Command. 

Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that 

carries a pilot, passengers, and cargo, the Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, 

Advanced and Professional), and DJI inspire 1 are in this case remotely controlled with no passengers or 

property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be 

pilot in command of an aircraft for compensation or hire. Diebold Resources respectfully proposes that operator 

requirements should take into account the characteristics of the particular sUAS. 

Diebold Resources respectfully proposes to allow a Pilot in Command (PIC) holding a sport, recreational, 

private pilot or higher level certificate, as well as an airman medical certificate or valid driver’s license to 

operate the sUAS. And that the PIC is able to safely operate the Phantom 2 (Standard and Vision Plus V+), DJI 

Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS in a manner consistent with this 

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

vessels, vehicles and structures. 

14 C.F.R. § 91.7(a): Civil aircraft airworthiness. 

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This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Due to the 

fact that the Phantom 2 (Standard and Vision Plus V+), DJI Phantom 3 (Standard, Advanced and Professional), 

and DJI inspire 1 sUAS do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, 

Subpart H. As such, Diebold Resources submits that it will ensure that the Phantom 2 (Standard and Vision Plus 

V+), DJI Phantom 3 (Standard, Advanced and Professional), and DJI inspire 1 sUAS are in an airworthy 

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

(i.e., DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 user manuals), and that the aircraft are in a condition for 

safe flight. 

14 CFR § 91.119: Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 91.119(c) limits aircraft 

flying over areas other than congested areas to an altitude of 500 feet above the surface, except over open water 

or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. 

As set forth herein, the sUAS will never operate at higher than 500 feet AGL. It will, however, be operated to 

avoid congested or populated areas that are depicted in yellow on VFR sectional charts. Because aerial survey, 

mapping and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feet 

AGL, an exemption from Section 91.119(c) is needed. 

The equivalent level of safety will be achieved given the size, weight, speed, and material with which the DJI 

Phantom 2, DJI Phantom 3, and DJI Inspire 1 are built. Also, no flight will be taken without the permission of 

the land owner or those who control the land. Because of the advance notice to the landowner, all affected 

individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or 

rotorcraft weighing far more than 6 lbs. and carrying flammable fuel, any risk associated with these operations 

will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. 

Indeed, the low-altitude operations of the sUAS will maintain separation between these sUAS operations and 

the operations of conventional aircraft that must comply with Section 91.119. 

14 CFR § 91.121: Altimeter Settings 

Section 91.121 requires that each person operating an aircraft shall maintain cruising altitude or flight level by 

reference to an altimeter that is appropriately set to the specified source. 

 

The DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS 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 Diebold Resources's operation of the DJI Phantom 2, DJI Phantom 3, and DJI 

Inspire 1 sUAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. 

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

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This regulation prohibits an individual from beginning “a flight in an airplane 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 – (1) During the day, to fly after that for at least 30 minutes; or (2) 

At night, to fly after that for at least 45 minutes.” 

Diebold Resources submits that safety will not be affected by operation of the DJI Phantom 2, DJI Phantom 3, 

and DJI Inspire 1 sUAS 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 FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 10673 and 10808. 

14 C.F.R. § 91.405(a); 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections 

Section 91.405(a) requires that an aircraft operator or owner “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 ...” Section 91.407 similarly makes reference 

to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance of an air 

worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain 

maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service. 

Diebold Resources requests relief from these sections as they set forth requirements for maintenance that only 

apply to aircraft with an airworthiness certificate. Diebold Resources submits that the request is proper since an 

equivalent level of safety will be ensured. Diebold Resources will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the sUAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 user 

manuals). Furthermore, Diebold Resources will document and maintain all maintenance records for the DJI 

Phantom 2, DJI Phantom 3, and DJI Inspire 1 sUAS. 

Page 10 of 14
APPENDIX B: 

SUMMARY OF DIEBOLD RESOURCES SECTION 333 EXEMPTION REQUEST

Diebold Resources hereby provides pursuant to Part 11 a summary of its exemption application to allow 

commercial operation of the DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1 small unmanned system in aerial 

video and photography applications. An exemption is requested from the following regulations: 

14 C.F.R. 45.23(b); 

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

14 C.F.R. 91.7(a); 

14 C.F.R. 91.119; 

14 C.F.R. 91.121; 14 C.F.R. 91.151(a); 

14 C.F.R. 91.405(a); 

14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2); 14 C.F.R. 91.417(a). 

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APPENDIX C: 

DJI PHANTOM 2 MANUFACTURER'S USER MANUAL

Page 12 of 14
APPENDIX D: 

DJI PHANTOM 3 MANUFACTURER'S USER MANUAL

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Page 14 of 14

APPENDIX E: 

DJI INSPIRE 1 MANUFACTURER'S USER MANUAL