UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

ALADTEC, INC.

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.101(e)(4) & (5), 61.113(a) & (b), 61.23(a), 61.315(a), 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

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on June 8, 2015

Jesse Feyereisen

ALADTEC, INC.

906 Dominion Dr.

Hudson WI, 54016 

Tel: (888) 749-5550

Email:jesse@aladtec.com
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 ALADTEC, INC.

SEEKS EXEMPTION.............................................................................................. 8 

THE EXTENT OF RELIEF ALADTEC, INC. SEEKS AND THE

REASON ALADTEC, INC. SEEKS THE RELIEF............... . .............................11 

THE REASONS WHY GRANTING ALADTEC, INC. 

REQUEST WOULD BE IN THE PUBLIC INTEREST .......... ........................... 15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY ......................................................................... 19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER. .... 34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT ALADTEC, INC.’S REQUEST....

.............................................................................................................................. ...34 

CONCLUSION ............................................................................................................................ 35

APPENDICES........................................................................................37 

2 
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control 

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization 

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command 

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

SO Safety Observer

SOP Standard Operating Procedures 

UA Unmanned Aircraft 

UAS Unmanned Aircraft System

VFR Visual Flight Rules 

VLOS Visual Line of Site

VMC Visual Meteorological Conditions 

VTOL Vertical Takeoff and Landing 

3 
SUMMARY

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

61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Aladtec, Inc. to operate an Unmanned Aircraft 

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

Public Safety services, such as our clients in EMS, Fire Rescue, Law Enforcement, 

Communication/Dispatch Centers, Healthcare, Public Works and Security Services within 

the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Aladtec, Inc. will use its high quality digital content for use in Aladtec, Inc. 

promotional multimedia projects. Aladtec, Inc. offers an online employee scheduling and 

workforce management system that is suitable for both small volunteer services and large 

multi-location corporations. Aladtec provides an efficient, and cost-effective, solution to 

effectively manage employee scheduling and personnel data for many industries. The 

objective of Aladtec, Inc. aerial video and photography operations is to provide high 

quality photography and videography of Public Safety, services, specifically targeting: 

• EMS

• Fire Rescue

• Law Enforcement

• Communication/Dispatch Centers

• Healthcare

• Public Works

• Security

4 
BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 Professional UAS

Aladtec, Inc. seeks an exemption to operate DJI systemsfor marketing use within the 

NAS. The DJI Phantom 3 Professional is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. The Phantom 3 is an electric powered rotary wing UAS that is capable of 

transmitting live airborne video images and location information to a Ground Control 

Station (GCS). The Phantom 3 stores photographs and data on board and makes them 

available for download after completion of the flight. The Phantom 3 is 2.82 pounds. 23.2 in 

x 23.2 in x 7.25 in. Well under the 55 lbs mandated in the FMRA. The Phantom has a 

maximum cruising speed of 35mph. The Phantom 3 is battery powered, has a flight 

endurance of approximately 23 minutes and can operate in temperatures ranging from 32° to 

104° F. The Phantom 3 has an omni-directional antenna with a range of 1.24 miles (Outdoor 

and Unobstructed) and operating in the 2.420 – 2.483 GHz frequency range. 

The Phantom 3 that will be operated by Aladtec, Inc. will be registered in accordance 

with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45,

Identification and Registration Marking. 

BASIS FOR PETITION

The petitioner, Aladtec, Inc., 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 Phantom 3 in the National Airspace 

System (NAS), and for an exemption from the requirements of 14 C.F.R §§

5 
61.101(e)(4) and (5), 61.315(a), 61.23(a), 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, Aladtec, Inc.’s operation of the DJI Phantom 

3 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, Aladtec, Inc. 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. 

Aladtec, Inc. submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Aladtec, Inc. will use experienced personnel and technicians to 

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

methods, techniques, and practices prescribed in the operating documents (i.e., Phantom 3

Instruction Manual). Furthermore, Aladtec, Inc. will document and maintain all 

maintenance recordsfor the Phantom 3 UAS. 

Relief from certain requirements of Section 61.101(e)(4) and (5) entitled 

Recreational pilot privileges and limitations: Pilot in command, and from Section 

61.315(a) entitled What are the privileges and limits of my sport pilot certificate, and from 

Section 61.23(a) entitled Medical certificates: Requirements and duration, is requested by 

Aladtec, Inc. to the extent necessary to allow a Pilot in Command (PIC) holding a sport 

pilot or higher level certificate, as well as a valid driver’s license, and who has 

demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is 

able to safely operate the DJI Phantom 3 UAS in

6 a manner consistent with this
exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

Aladtec, Inc. seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3 UAS does not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Aladtec, Inc. submits that it will 

ensure that the DJI Phantom 3 UAS is in an airworthy condition, prior to every flight, by 

determining that the UAS is in compliance with the operating documents (i.e., DJI 

Phantom 3 Instruction Manual), and that the aircraft is in a condition for safe flight. 

Aladtec, Inc. also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the Phantom 3 UAS does not have a typical barometric 

altimeter on board. However, altitude information of the Phantom 3 UAS will be provided 

to the PIC via Global Positioning System (GPS) equipment and radio communications 

telemetry data link, which downlinks from the UAS to the GCS for active monitoring of 

the flight path. This altitude information, combined with Aladtec, Inc.’s skilled operation 

of the DJI Phantom 3 UAS within visual line of sight, at or below 400 feet AGL, will 

ensure a level of safety equivalent to Section 91.121. 

Aladtec, Inc. also seeks an exemption from the requirements of Section 91.151(b), 

entitled Fuel requirements for flight in VFR conditions. Aladtec, Inc. submits that safety 

will not be affected by operation of the DJI Phantom 3 UAS during daylight hours in 

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

battery power to fly for a total duration of approximately 15 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5

minutes. 

7 
In accordance with 14 C.F.R. § 11.81, Aladtec, Inc. 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: 

Jesse Feyereisen 

Aladtec, Inc.

906 Dominion Dr.

Hudson, WI 54016 

Tel: (888) 749-5550

Email: jesse@aladtec.com

B. The Specific Sections Of 14 C.F.R. From Which Aladtec, Inc. Seeks

Exemption.

1. Aladtec, Inc. Seeks Exemption From The Requirements Of Section

61.101(e)(4) and (5).

Section 61.101, entitled Recreational pilot privileges and limitations: Pilot in

command, subsection (e)(4) and (5) prescribe the following, in relevant part:

(e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot

may not act as pilot in command of an aircraft--

(4) For compensation or hire;

(5) In furtherance of a business;

(f) Aladtec, Inc. Seeks Exemption From The Requirements Of Section

61.23(a).

Section 61.23(a), entitled Operations requiring a medical certificate: Requirements 

and duration, subsection (a) prescribe the following, in relevant part:

(f) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot

may not act as pilot in command of an aircraft--

8 
3. Aladtec, Inc. Seeks Exemption From The Requirements Of

Section 61.315(a).

Section 61.315(a), entitled What are the privileges and limits of my sport pilot 

certificate, subsection (a) prescribe the following, in relevant part: 

(c) You may not act as pilot in command of a light-sport aircraft:

(2) For compensation or hire.

(3) In furtherance of a business.--

(ci) Aladtec, Inc. Seeks Exemption From The Requirements Of

Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the

following: 

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

5. Aladtec, Inc. 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.

9 
6. Aladtec, Inc. 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.

7. Aladtec, Inc. 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[.]

8. Aladtec, Inc. 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[.]

(b) Aladtec, Inc. 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

10
with part 21 of this chapter.

10. Aladtec, Inc. Exemption From The Requirements Of

Sections 91.417(a) and 91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each

registered owner or operator shall keep the following records for the periods

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and

records of the 100-hour, annual, progressive, and other required or approved

inspections, as appropriate, for each aircraft (including the airframe) and each

engine, propeller, rotor, and appliance of an aircraft. The records must

include--

(i) A description (or reference to data acceptable to the Administrator) of

the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the

aircraft for return to service.

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and

each rotor.

(ii) The current status of life-limited parts of each airframe, engine,

propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which

are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety

directives including, for each, the method of compliance, the AD or

safety directive number and revision date. If the AD or safety directive

involves recurring action, the time and date when the next action is

required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each

11
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 Aladtec, Inc. Seeks And The Reason Aladtec, Inc. Seeks

The Relief.

1. Extent Of Relief Aladtec, Inc. Seeks And The Reason Aladtec, Inc. 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, Aladtec, Inc. submits that an equivalent level of 

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

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

12
demonstrating that the PIC is able to safely operate either the DJI Phantom 3 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, Aladtec, Inc. submits that all flights of the DJI Phantom 3 UAS, 

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

incidental to Aladtec, Inc. business; and (2) will not carry passengers or 

property for compensation or hire. 

2.Extent Of Relief Aladtec, Inc. Seeks And The Reason

Aladtec, Inc. Seeks Relief From Section 61.23(a).

Relief from Section 61.23(a), entitled Operations requiring a medical certificate:

Requirements and duration, is requested to the extent required to necessary to allow a PIC

holding a sport pilot certificate or higher level certificate, as well as a current and valid

driver’s license, to conduct the proposed UAS flight operations for compensation or hire. 

This relief is requested since the limitations set forth in Section 61.23(a) otherwise 

require the PIC of any flight for compensation or hire to hold a comprehensive FAA issued

medical certificate. In Exemption No. 11213 to Aeryon Labs, Inc., the FAA “finds that, 

because of the risk mitigations established in the conditions and limitations of this

exemption, a person that holds a U.S. issued driver’s license who is operating a UAS will

not adversely affect safety. The FAA is granting relief from § 61.23(a) to allow any pilot

that holds one of the pilot’s certificates discussed above to operate a UAS under this

exemption with a U.S. issued driver’s license, in lieu of an FAA-issued medical certificate.

The FAA is also granting relief from § 61.23(c) to allow sport pilot certificate holders to

operate aircraft other than LSA with a U.S. issued driver’s license under this exemption.” 

13
3.Extent Of Relief Aladtec, Inc. Seeks And The

Reason Aladtec, Inc. Seeks Relief From Section 61.315(a).

Relief from Section 61.315(a) entitled What are the privileges and limits of my 

sport pilot certificate, is requested to the extent necessary to allow a PIC holding a sport 

pilot or higher level certificate to conduct the proposed UAS flight operations for 

compensation or hire. 

This relief is requested since the limitations set forth in Section 61.315(a) restrict a

sport pilot from acting as the PIC of any flight for compensation or hire, or for the 

furtherance of any business. 

In Exemption No. 11213 to Aeryon Labs, Inc., the FAA re-assessed the level of

pilot certificate that would be appropriate for the petitioner’s operations. In evaluating this

petition, similar to the evaluation of the private and commercial pilot certificates in

Exemption No. 11062, the agency compared the aeronautical knowledge requirements of 

the recreational and sport pilot certificates to those of the private pilot certificate. They

found that the aeronautical knowledge requirements that would be applicable to a UAS

operation for a recreational pilot and sport pilot certificate are substantially similar as those 

for a private pilot certificate.

Additionally, similar to the private and commercial pilot certificates, holders of

recreational and sport pilot certificates are subject to security screening by the Department

of Homeland Security (DHS). 

Therefore, because they must demonstrate aeronautical knowledge relevant to UAS

operations and are subject to DHS screening, factors that were considered by the FAA in

allowing private pilot operations under previous exemptions, the FAA now determines that

holders of recreational and sport pilot certificates may serve as the PIC for UAS 

operations. 

14
4.Extent Of Relief Aladtec, Inc. Seeks And Aladtec, Inc. 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 Aladtec, Inc. to determine that the DJI Phantom 3 UAS are in airworthy 

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

operating documents (i.e., DJI Phantom 3 Instruction Manual). 

Aladtec, Inc. seeks the requested relief because the DJI Phantom 3 UAS does 

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

Therefore, Aladtec, Inc. will ensure that the DJI Phantom 3 UAS are in airworthy 

condition based upon its compliance with the operating documents (i.e., DJI Phantom 3 

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

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

5.Extent Of Relief Aladtec, Inc. Seeks And The Reason

Aladtec, Inc. 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 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), Aladtec, Inc. seeks the requested relief 

because the DJI Phantom 3 UA’s altimeter may be set on the ground to zero feet AGL, 

rather than the local barometric pressure or field altitude, before each flight. 

15
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 UAs are equipped with a barometric pressure 

sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude

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

6. Extent Of Relief Aladtec, Inc. Seeks And Aladtec, Inc. 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 

UAS during daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), for a total duration of 15 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 5 minutes. Aladtec, Inc. seeks 

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

duration of the battery powered DJI Phantom 3 UAS will severely constrain the 

practicality of any aerial video or still photo flight operations that Aladtec, Inc. proposes 

to conduct pursuant to this Petition. 

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

UAS, the DJI Phantom 3 operating documents, and Aladtec, Inc.'s proposed operating 

limitations, ensure that Aladtec, Inc. will safely operate the battery powered DJI Phantom 

3 UAS during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), with enough battery power to fly for a total 

duration of 15 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 5 minutes. 

16
7.Extent Of Relief Aladtec, Inc. Seeks And The Reason

Aladtec, Inc. 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, Aladtec, Inc. requests relief from 

these Sections because the DJI Phantom 3 UAS does not require airworthiness certificates. 

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

Section 333 for operation without an airworthiness certificate. Accordingly, Aladtec, Inc.

will use highly 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., the DJI Phantom 3 Instruction Manual). Furthermore, 

Aladtec, Inc. will document and maintain all maintenance records for the DJI Phantom 3 

UAS. 

D.The Reasons Why Granting Aladtec, Inc. 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 Aladtec, 

Inc. to safely, efficiently, and economically conduct aerial video and photography of Public 

Safety service facilities, in the United States. 

Additionally, use of the DJI Phantom 3 UAS will decrease congestion of the NAS, 

increase perception and publicity of local Public Safety departments, and provide 

significant benefits to the economy. Notably, the benefits of Aladtec, Inc.’s proposed 

operation of the DJI Phantom 3 UAS will be realized without implicating any privacy 

issues. 

17
1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 UAS 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 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 UAS does not require an airport to takeoff or land. Likewise, a reduction 

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

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

departure, arrival, and landing phases of flight operations. 

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

Phantom 3 UAS.

Conducting aerial acquisitions with the DJI Phantom 3 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 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 UAS, while reducing the carbon 

footprint of aerial acquisitions, also eliminates noise pollution, as the UAS is propelled 

by battery powered electric motors, rather than an internal combustion engine.

 

18
By using the DJI Phantom 3 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 UAS (Phantom 3 weighing approximately 2.82 pounds maximum gross 

weights with a length of 23.2 inches, width of 23.2 inches, has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared tothe 

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 UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 3 are economical alternatives to 

using manned aircraft to conduct similar aerial operations. As such, operation of the DJI 

Phantom 3 UAS will allow United States based companies, like Aladtec, Inc., 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 UAS allows companies greater operational flexibility compared to manned 

aircraft, and provides such flexibility without the high operational cost of a traditional 

manned aircraft. 

By operating the DJI Phantom 3 UAS, companies such as Aladtec, Inc., 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. 

19
Improved financial performance of U.S. companies, through commercial use of the DJI 

Phantom 3 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, Aladtec, Inc. proposed operation of the DJI Phantom 3 UAS will not implicate 

any privacy issues. Specifically, the DJI Phantom 3 UAS will be operated only in 

compliance with the conditions set forth in any exemption granted under this petition. 

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 Aladtec, Inc. Seeks Exemption.

1. Reasons Why The DJI Phantom 3 UAS Meet The Conditions Of The FAA

Modernization and Reform Act of 2012 (FMRA) Section 333.

In consideration of the size, weight, speed, and limited operating area 

associated with the unmanned aircraft and its operation, Aladtec, Inc. operation of the 

DJI Phantom 3 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.

20
(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, Aladtec, Inc. submits that the DJI Phantom 3 UAS can 

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

characteristics of the DJI Phantom 3 UAS; (b) the pilot certification requirement; and

(c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 3 UAS Demonstrate

Its Safe Characteristics.

The DJI Phantom 3 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 UAS. The technical

specifications of the DJI Phantom 3 UAS are set forth by the DJI Phantom 3 

Specifications and Data Sheet, attached hereto as Exhibit A. 

21
ii. The DJI Phantom 3 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, the UAs will remain stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 does not reacquire control 

link data from the GCS, the UA will assume that the Control Link is lost and the UA will 

return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff 

position and shutdown. 

A complete description of the Failsafe Functions of the DJI Phantom 3 UAS are 

set forth in the attached Phantom 3 User Manual, attached hereto as B.1

iii. The DJI Phantom 3 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 GCS and 

flight control software is provided in the DJI Phantom 3 User Manual. DJI Phantom 3 User 

Manual is attached hereto as Exhibit B. 

b. Flight Operations Of DJI Phantom 3 UAS Are Limited To The Line Of

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

Aladtec, Inc. will only utilize certificated pilots who possess a current 

and valid airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 3 

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

c. Flights Of DJI Phantom 3 UAS Will Be Conducted Pursuant To Specific

Operating Limitations.

In seeking this exemption, proposes to commercially operate DJI Phantom 3 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 Unmanned Aircraft System.

22
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 30 knots. 

4. The UAS must be operated at an altitude of no more than 400 feet above ground

level (AGL), as indicated by the procedures specified in the operating documents

unless a special request is made and approved by ATC. All altitudes reported to

ATC must be in feet AGL.

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all

times. This requires the PIC to be able to use human vision unaided by any device

other than corrective lenses, as specified on the PIC’s FAA-issued airman medical

certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not

permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy

the VLOS requirement as long as the PIC always maintains VLOS capability. The

SO and PIC must be able to communicate verbally at all times. Electronic

messaging or texting is not permitted during flight operations. The PIC must be

designated before the flight and cannot transfer his or her designation for the

duration of the flight. The PIC must ensure that the SO can perform 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 

23
condition for safe flight. If the inspection reveals a condition that affects the

safe operation of the UAS, the aircraft is prohibited from operating until the

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS

operation or flight characteristics, e.g. replacement of a flight critical

component, must undergo a functional test flight. The PIC who conducts the

functional test flight must make an entry in the aircraft records.

12. The pre-flight inspection must account for all potential discrepancies, e.g.

inoperable components, items, or equipment, not already covered in the relevant 

sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

inspection, alterations, and status of replacement/overhaul component parts must

be noted in the aircraft records, including total time in service, description of

work accomplished, and the signature of the authorized person returning the

UAS to service.

15. Each UAS operated under this exemption must comply with all manufacturer

Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective 

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current

third- class medical certificate.

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

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. § 

19.1. All operations must be conducted under visual meteorological

24
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 UAS 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 UAS 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. 

25
29. The UA must remain clear and yield the right of way to all manned aviation

operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

persons from the UA and/or debris in the event of an accident. The

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the

owner/controller of such vessels, vehicles or structures has granted

permission and the PIC has made a safety assessment of the risk of

operating closer to those objects and determined that it does not present

an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons

do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled-access property

with permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Integration Office (AFS-80) within 24

hours. Accidents must be reported 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.

Aladtec, Inc. 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

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 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 Aladtec, Inc. proposed area of operations, and the operating limitations 

set forth-above; the parallel nature of sport 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 UAS, Aladtec, Inc. submits that the 

additional manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for Aladtec, Inc. 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).

Aladtec, Inc. will not allow any PIC to operate the DJI Phantom 3 UAS unless that 

PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 

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

Phantom 3 UAS in a manner consistent with this exemption, including evasive and

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency 

purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight

27
experience that was obtained in compliance with applicable regulations will ensure an 

equivalent level of safety during Aladtec, Inc. proposed operations. The Administrator 

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

with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as 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, Aladtec, Inc. will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 3 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 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 

28
because prior to every flight, Aladtec, Inc. will ensure that the DJI Phantom 3 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 UAS will be provided to the PIC via GPS 

equipment and a radio communications telemetry data link, which downlinks from the 

UAS to the GCS for active monitoring of the flight path and altitude. This altitude

information, combined with Aladtec, Inc.'s operation of the DJI Phantom 3 UAS within 

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

Section 91.121. The altitude information will be generated by GPS equipment installed 

onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in 

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 

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

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b)

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 

29
14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI 

Phantom 3 UAs; (2) the limitations on the proposed flight operations; and (3) the location 

of the proposed flight operations. Accordingly, Aladtec, Inc. will ensure that it will safely 

operate the battery powered DJI Phantom 3 UAs during daylight hours in VFR conditions, 

with enough battery power to fly for a total duration of 15 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 5 

minutes. 

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

3 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 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 30% remaining battery power, and again at 

approximately 15% remaining battery power. At the critically low battery level, the DJI 

Phantom 3 UAS will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

establish that safety is not adversely affected when the technical characteristics and 

operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, 

to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 

11157, 11158, 11159, 11160, 11161).

30
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, Aladtec, Inc. 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 Aladtec, Inc. 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., the Monthly Maintenance Log, and DJI

Phantom 3 Instruction Manual). Furthermore, Aladtec, Inc. will document and maintain all 

maintenance records for the DJI Phantom 3 UAS. 

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

documents, Aladtec, Inc. 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 User 

Manuals are attached hereto as Exhibit B; a copy of the DJI Phantom 3 UAS Monthly 

Maintenance LOG is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Aladtec, 

Inc. 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 UAS will be performed by trained technicians. Maintenance 

31 

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 Aladtec, Inc. proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 UAS, Aladtec, Inc. 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, Aladtec, Inc. requests that the 

FAA prescribe special conditions for the intended operation of the DJI Phantom 3 UAS, 

which contain such safety standards that the Administrator finds necessary to establish a 

level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R 

§§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs 

for the limited purpose of conducting aerial video and photography over certain areas of 

the United States for compensation or hire. FMRA Section 333 sets forth the requirements 

for considering whether a UAS will create a hazard to users of the NAS or the public, or 

otherwise pose a threat to national security; and further, provides the 

32
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 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 Aladtec, Inc.'s intended operation of the 

Phantom 3 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 Aladtec, Inc. Seeks Exemption:

Aladtec, Inc. seeks exemption from the requirements of 14 C.F.R Sections 

61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Aladtec, Inc. Seeks:

This exemption will permit Aladtec, Inc. to commercially operate an 

33
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

Aladtec, Inc.'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, Aladtec, Inc. 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.

As discussed in detail above, Aladtec, Inc. will operate the DJI Phantom 3 

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, Aladtec, Inc. 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 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 Aladtec, 

Inc. to safely, efficiently, and economically operate the DJI Phantom 3 UAS 

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commercially within the NAS.

WHEREFORE, in accordance with the Federal Aviation Regulations and the 

FAA Modernization and Reform Act of 2012, Section 333, Aladtec, Inc. respectfully 

requests that the Administrator grant this Petition for an exemption from the requirements 

of 14 C.F.R Sections 61.101(e)(4) and (5), 61.315(a), 61.23(a), 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 Aladtec, Inc.

to operate the DJI Phantom 3 UAS commercially for the purpose of conducting aerial 

video and photography over areas of the United States. Dated: June 8, 2015 

Respectfully submitted, 

Jesse Feyereisen

Jesse Feyereisen

Aladtec, Inc. 

906 Dominion Dr.

Hudson, WI 54016

Tel: (888) 749-5550

Email: jesse@aladtec.com

35
Exhibits: 

Exhibits: 

A – DJI Phantom 3 Specifications Data Sheet 

B– DJI Phantom 3 Manufacturer’s User Manual 

C – Monthly Maintenance Log 

EXHIBIT – A 

DJI Phantom 3 Specifications Data Sheet 

36
DJI Phantom 3 Professional TECHNICAL SPECIFICATIONS

Aircraft Weight (Including Battery And Propellers): 1280 g

Diagonal Size (Including Propellers): 590 mm

Max Ascent Speed: 5 m/s

Max Descent Speed: 3 m/s

Hover Accuracy:

Vertical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m

Horizontal: +/- 1.5 m

Max Speed: 16 m/s (ATTI mode, no wind)

Max Altitude Above Sea Level: 6000 m

Operating Temperature: 0°C to 40°C

GPS Mode: GPS/GLONASS

Dimensions: 438x451x301 mm

Gimbal 

Controllable Range: Pitch -90° to +30°

Stabilization: 3-axis (pitch, roll, yaw)

37
Camera Sensor: Sony EXMOR 1/2.3” Effective pixels: 12.4 M (total pixels: 

12.76 M)

Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at ∞

ISO Range: 100-3200 (video) 100-1600 (photo)

Shutter Speed: 8s -1/8000s

Image Max Size: 4000 x 3000

Still Photography Modes:

Single Shot

Burst Shooting: 3/5/7 shots

Auto Exposure Bracketing (AEB): 3/5

Bracketed Frames at 0.7EV Bias

Time-lapse

Video Recording Modes:

Phantom 3 Professional

UHD: 4096x2160p 24/25, 3840x2160p 24/25/30

FHD: 1920x1080p 24/25/30/48/50/60

HD: 1280x720p 24/25/30/48/50/60

Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required

Max Bitrate Of Video Storage: 60 Mbps

Supported File Formats: FAT32/exFAT

Photo: JPEG, DNG

Video: MP4, MOV (MPEG-4 AVC/H.264)

Operating Temperature: 0°C to 40°C

38
Remote 

Controller 

Operating Frequency: 2.400 GHz-2.483 GHz

Max Distance: 2000m (outdoors and unobstructed)

Video Output Port: USB

Operating Temperature: 0°C- 40°C

Battery: 6000 mAh LiPo 2S

Mobile Device Holder: For tablet or phone

Receiver Sensitivity (1%PER): -101 dBm ±2 dBm

Transmitter Power (EIRP): FCC: 20 dBm

CE: 16 dBm

Working Voltage: 1.2 A @7.4 V

Charger Voltage: 17.4 V

Rated Power: 100 W

Intelligent

Flight

Battery 

Capacity: 4480 mAh

Voltage: 15.2 V

Battery Type: LiPo 4S

Energy: 68 Wh

Net Weight: 365 g

Max Flight Time: Approximately 23 minutes

Operating Temperature: -10°C to 40°C

Max Charging Power: 100 W

39
Vision 

Positioning 

Max Velocity: Less than 8 m/s (when 2 m above ground)

Altitude Range: 30 cm-300 cm

Operating Range: 30 cm-300 cm

Operating Environment: Surface with clear pattern and adequate lighting (Lux > 15)

40
Exhibits: 

A – DJI Phantom 3 Specifications Data Sheet

B – DJI Phantom 3 Manufacturer’s User Manual

C – Monthly Maintenance Log

EXHIBIT – B

DJI Phantom 3 Manufacturer’s User Manual 

41
EXHIBIT – C

MONTHLY MAINTENANCE LOG

month: year:

UAS #: Date Issue 

Discovered

Date Issue 

Addressed Issue Description & Maintenance Conducted Maintenance Performed By:

Print & Sign

Software Updates

Airframe

Engines

Propellers

Camera Gimbal

Landing Gear

Vibration Dampening

Other:

Jesse Feyereisen 

ALADTEC, INC. 

906 Dominion Dr.

Hudson WI, 54016 

Tel: (888) 749-5550 Email: 

jesse@aladtec.com 

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