Petitioner: 

Vijna Consulting LLC 

Akash Gupta, President 

6 Sunshine Lane 

Edison, NJ 

Email: akash.gupta@vijnaconsulting.com

Website: www.vijnaconsulting.com

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, Vijna Consulting, a registered company in operation for 7 years, and serving the technology needs of the 

banking, commercial insurance and retail industry, hereby applies for an exemption from the Federal Aviation 

Regulations (FARs) listed below, to allow operation of our Small Unmanned Aircraft System (sUAS) commercially

for purposes of obtaining aerial imagery that will help in property & crop damage assessment, loss estimation and 

implementation of loss prevention measures for our property insurance clients. These services will benefit both the 

insurers and their clients to assess property damage and settle claims faster. All operations will be conducted within 

and under the conditions and limitations outlined by the FAA as required by Section 333 and additional rules inforce at any time in the future. 

1. Regulations from which exemption is sought

14 C.F.R. Part 21 

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. 91.9(b) (2) 

14 C.F.R. 91.109 

14 C.F.R. 91.119 

14 C.F.R. 91.121 

14 C.F.R. 91.151(a) 

14 C.F.R. 91.203(a) & (b) 

14 C.F.R. 91.205(b) 

14 C.F.R. 91.215 

14 C.F.R. 91.401 - 91.417 

2. Commercial operations planned for which relief is requested

Commercial operation of sUAS, as described herein, using sUAS equipped with cameras and sensors, would 

provide the following services 

a) Aerial inspection / photography of residential / commercial building damage including rooftop damage to 

assess damage and settle insurance claims 

b) Aerial inspection / photography of residential / commercial property locations including parking lots, sheds 

etc to determine possible loss drivers and to suggest loss remediation measures. 

c) Aerial photography and / or video of residential / commercial utility infrastructure including but not limited 

to cell phone towers, electrical power lines, rail yards, building construction equipment and car dealer 

parking lots 
d) Aerial inspection / photography of commercial farms to detect crop damage due to insect or natural 

catastrophe causes such as tornado / hail / flood. Detection of pre-drought / drought / frost damage 

conditions in crops using image analysis. Detection of broken fences and sick animals on farms. 

e) Training to individuals and / or employees of private / public organizations is use of sUAS with focus on 

ensuring awareness and safety consideration in use of UAS within the NAS. 

3. Anticipated Public benefit of above listed commercial operations

a) Overall reduction in operating cost of insurance (damage assessment, claims processing) will help drive 

down the cost of commercial insurance, especially to small and medium sized businesses. This will be 

beneficial to the overall economy in the long run 

b) Aerial inspection of large commercial properties, car dealer parking lots etc will help to put effective loss 

prevention mechanisms (replacement for broken fences, shed roof damage repair etc, replacement of 

broken windows etc) that will reduce attritional losses of firms. 

c) Aerial inspection of farms will help to prevent and mitigate losses from crop damage, crop failure, sick 

animals and livestock, disease containment and prevention etc). 

Unmanned Aircraft System sUAS are often seen as superior to helicopters as an aerial video gathering platform 

due to the smaller devices cheaper equipment and personnel cost, reduced noise and as such, a much smaller 

environmental impact which promotes public safety. 

4. Commitment to regulation compliance and safety considerations

Vijna Consulting commits to ensure that all sUAS flights and operations shall 

a) Be in compliance with and in accordance with the rules governing sUAS flights at any given time, being 

rules 

b) Occur over private and access controlled property with explicit authorization and consent by the property 

owner(s), including consent for any photographs / aerial imagery obtained from the flight. 

c) Always be in compliance with all rules, guidelines, limitations, current and future legislation set forth by 

the FAA as well as with other federal, state and local ordinances and laws regarding operation of sUAS. 

d) Occur in ordinance with any state or local laws regarding privacy. 

e) Be conducted by operator who is qualified, trained, certified and is medially fit to fly the sUAS 

f) Be conducted in accordance with an ATO-issued COA. 

I, THE OPERATOR, ASSUME THE FOLLOWING RESPONSIBILITIES 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 when weighing less than 55 

pounds including payload. 

2. Operations for the purpose of closed-set motion picture and television filming are not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use 

either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will 

the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer. 

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

reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be 

able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued 

airman medical certificate or U.S. driver’s license. 
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; 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 VO can perform the 

duties required of the VO. 

7. This exemption and all documents needed to operate the UAS 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 UAS operations and made available to the Administrator upon 

request. If a discrepancy exists between the conditions and 4 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. 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 prior to conducting further 

operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain 

at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose

an undue hazard to persons and property. 

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

operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 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 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. 

11. The operator must follow the UAS manufacturer’s maintenance; overhaul, replacement, inspection, and life limit 

requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins. 

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. 5 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the 

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

emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for 

the purposes of training the operator’s PICs and VOs (training, proficiency, and experience-building) and 

determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this 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 CFR § 91.119. 
15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be 

conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not 

authorized. 

16. The UAS may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current

FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as 

denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement 

with the airport management must be made available to the Administrator or any law enforcement official 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 UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location 

within the private or controlled-access property. 

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

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 five 

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 attached COA. 6 

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in 

accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR 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 UAS 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 UAS any time 

the aircraft is operating. These documents must be made available to the Administrator or any law enforcement 

official upon request. 

24. The UA must remain clear and give way to all manned aviation operations and activities at all times. 

25. The UAS 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 

nonparticipating persons under this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission from the property 

owner/controller or authorized representative. Permission from property 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 (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. 
Vijna Consulting is petitioning for an exemption to operate a DJI Phantom 3 Professional with a built-in stabilized 

HD camera and GPS safety features which limit its ability to limit the height it flies above ground level (AGL), to 

limit the radius of the distance it flies from the operator and to exclude it from operations within designated Class B, 

C and D airspace including a no-fly zone feature. The DJI Phantom 3 also has a failsafe function that is triggered in 

the event communication is lost between the sUAS and the main controller transmitter. At that time, the sUAS will 

return to its point of takeoff and land safety. If the connection is restored, the PIC can regain control of flight and 

land manually. 

These specifications meet with the Aircraft Operating Standards as set below and outlined in section B of the FAA 

NPRM published and available at 

https://www.faa.gov/regulations_policies/rulemaking/recently_published/media/2120-AJ60_NPRM_2-15-

2015_joint_signature.pdf 

Operational Limitations

• Unmanned aircraft must weigh less than 55 lbs. (25 kg). 

• Visual line-of-sight (VLOS) only; the unmanned aircraft must remain within VLOS of the operator or 

visual observer. 

• At all times the small unmanned aircraft must remain close enough to the operator for the operator to be 

capable of seeing the aircraft with vision unaided by any device other than corrective lenses. 

• Small unmanned aircraft may not operate over any persons not directly involved in the operation. 

Daylight-only operations (official sunrise to official sunset, local time) 

• Must yield right-of-way to other aircraft, manned or unmanned. 

• May use visual observer (VO) but not required. 

• First-person view camera cannot satisfy “see-and avoid” requirement but can be used as long as 

requirement is satisfied in other ways. 

• Maximum airspeed of 100 mph (87 knots). 

• Maximum altitude of 500 feet above ground level. 

• Minimum weather visibility of 3 miles from control station. 

• No operations are allowed in Class A (18,000 feet & above) airspace. 

• Operations in Class B, C, D and E airspace are allowed with the required ATC permission. 

• Operations in Class G airspace are allowed without ATC permission 

• No person may act as an operator or VO for more than one unmanned aircraft operation at one time. 

• No operations from a moving vehicle or aircraft, except from a watercraft on the water. 

• No careless or reckless operations. 

• Requires preflight inspection by the operator. 

• A person may not operate a small unmanned aircraft if he or she knows or has reason to know of any 

physical or mental condition that would interfere with the safe operation of a small UAS. 

Operator Certification and Responsibilities

• Pilots of a small UAS would be considered “operators”. 

• Operators would be required to: 

o Pass an initial aeronautical knowledge test at an FAA-approved knowledge testing center. O Be 

vetted by the Transportation Security Administration. 

o Obtain an unmanned aircraft operator certificate with a small UAS rating (like existing pilot 

airman certificates, never expires). 

o Pass a recurrent aeronautical knowledge test every 24 months. 
o Be at least 17 years old. 

o Make available to the FAA, upon request, the small UAS for inspection or testing, and any 

associated documents/records required to be kept under the proposed rule. 

o Report an accident to the FAA within 10 days of any operation that results in injury or property 

damage. 

o Conduct a preflight inspection, to include specific aircraft and control station systems checks, to 

ensure the small UAS is safe for operation. 

Enclosures:

1. UAS Operation Safety Checklist
DJI Phantom 3 Professional Manufacturer Specifications 

Full user manual can be found at http://www.dji.com/product/phantom-3/download