UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

LOCKTON ENTERPRISES, INCORPORATED

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS,

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b)

CONCERNING COMMERCIALOPERATION OF A

DJI PHANTOM 3 PROFESSIONAL UNMANNED AIRCRAFT SYSTEM 

PURSUANT TO 

SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Dated December 21, 2015

Robert Hopson, Vice President

Aviation Specialist

Lockton Enterprises, Inc.

444 W. 47th Street #900

Kansas City, Missouri 64112

Direct (816) 960-9143 Mobile: (816) 260-8044

Email: rhopson@ lockton.com
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 2 of 24

SUMMARY 

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (FMRA), Subsection (f) of 49 USC Section 44701, and 14 CFR Part 11, Lockton Enterprises, Incorporated, the Petitioner (hereafter referred to as Lockton Enterprises), seeks 

exemption from the following listed Code of Federal Regulations (CFR): 14 CFR Sections 

61.113(a) and (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (a)(2), 

and 91.417(a) and (b).

This exemption will permit Lockton Enterprises to operate an unmanned aircraft system (UAS) 

for the commercial purpose of conducting aerial video, photography, and data collection of client 

properties over certain areas of the United States in the furtherance of our insurance and risk 

management services, including assessment and valuation, loss prevention, claims management 

and catastrophe response.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Lockton Enterprises provides its clients, in part, with a broad array of commercial insurance and 

other risk management services. Our objective is to safely provide high quality imaging and data 

collection in the furtherance of the services we offer our clients.

BACKGROUND 

The DJI Phantom 3 Professional is a vertical takeoff and landing (VTOL) unmanned aircraft 

(UA) with a ground control station (GCS) utilizing an electronic tablet or smart phone. The DJI 

Phantom 3 Professional is approximately 16 inches square, 8 inches high, with a maximum 

weight of less than 3 pounds and a maximum speed of approximately 31 knots. It is equipped 

with four main rotors, driven by lithium-polymer battery-powered electric motors. 

The DJI Phantom 3 Professional UA that will be operated by Lockton Enterprises will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 CFR Part 47, 

Aircraft Registration, and marked in accordance with 14 CFR Part 45, Identification and Registration Marking. 

BASIS FOR PETITION 

The Petitioner, Lockton Enterprises, pursuant to the provisions 14 CFR Section 11.61(b) and the 

FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain 

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI 

Phantom 3 Professional UA in the National Airspace System (NAS), and for an exemption from 

the requirements of 14 CFR Sections 61.113(a) and (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) and (a)(2), and 91.417(a) and (b). 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 3 of 24

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

the DJI Phantom 3 Professional UA, it meets the conditions of FMRA Section 333 and therefore 

requires no airworthiness certificate in accordance with 14 CFR Part 21, subpart H. 

In accordance with 14 CFR Section 11.81 (a) through (e), Lockton Enterprises provides the following information in support of his petition for exemption: 

NAME AND MAILING ADDRESS OF THE PETITIONER (14 CFR 11.81(a))

The name and address of the Petitioner and point of contact (POC) is: 

Lockton Enterprises, Inc.

POC: Robert Hopson, Vice President

444 W. 47th Street #900

Kansas City, MO 64112

Direct: (816) 960-9143

Mobile: (816) 260-8044

Email: rhopson@lockton.com

SPECIFIC SECTIONS FOR WHICH EXEMPION IS SOUGHT (14 CFR 11.81(b))

1. Section 61.113, Private pilot privileges and limitations: Pilot in command Subsections (a) 

and (b):

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of 

an aircraft that is carrying passengers or property for compensation or hire; nor may 

that person, for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection 

with any business or employment if—

(1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

2. Section 91.7, Civil Aircraft Airworthiness Subsection (a):

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

3. Section 91.121, Altimeter Settings Subsection (a):

(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; 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 4 of 24

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of 

this Section, the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure. 

4. Section 91.151, Fuel Requirements for Flight in VFR Conditions Subsection (b):

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

wind and forecast weather conditions) there is enough fuel to fly to the first point of intended 

landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 

5. Section 91.405, Maintenance required Subsection (a):

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in Subpart E of this Part and shall between required inspections, except as provided in paragraph (c) of this Section, have discrepancies repaired as prescribed in Part 43 of this chapter[.] 

6. Section 91.407, Operation after maintenance, preventive maintenance, rebuilding, or 

alteration, Subsection (a)(1):

(a) No person may operate any aircraft that has undergone maintenance, preventive 

maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under § 43.7 of 

this chapter. 

7. Section 91.409, Inspections, Subsection (a):

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

unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with Part 43 of this chapter and has been 

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

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

with Part 21 of this chapter. 

8. Section 91.417, Maintenance Records, Subsections (a) and (b):

(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: 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 5 of 24

(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 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. 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 6 of 24

EXTENT OF RELIEF SOUGHT AND REASONS (14 CFR 11.81(c))

1. Regulation and Extent of Relief Sought: 14 CFR Section 61.113(a) and (b)

Relief from Section 61.113(a) and (b), Private Pilot Privileges and Limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a sport pilot or higher level 

certificate, as well as a current and valid airman medical certificate or driver’s license, and 

who has met certain flight-hour and currency requirements, to conduct the proposed UAS 

flight operations. 

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, Lockton Enterprises submits that an equivalent level of safety will 

be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional UA unless that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC 

is able to safely operate either the DJI Phantom 3 Professional UA in a manner consistent with 

the specifications as described in this exemption and FAA-issued Conditions and Limitations, 

including evasive and emergency maneuvers, as well as maintaining appropriate distances from 

people, vessels, vehicles, and structures. 

Further, Lockton Enterprises submits that all flights of the DJI Phantom 3 Professional UA, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Lockton Enterprises’ business; (2) will not carry passengers or property for compensation or hire; and (3) will 

be operated over areas of controlled access.

2. Regulation and Extent of Relief Sought: 14 CFR Section 91.7(a)

Relief from Section 91.7(a), Civil aircraft airworthiness, is requested to allow Lockton Enterprises to determine that the DJI Phantom 3 Professional UA is in airworthy condition prior to 

every flight by ensuring that the UAS is in compliance with the operating documents (i.e., Exemption Conditions and Limitations and the DJI Phantom 3 Professional User Manual ). 

Lockton Enterprises seeks the relief because the DJI Phantom 3 Professional UA does not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. Therefore, 

Lockton Enterprises will ensure that the DJI Phantom 3 Professional UA is in airworthy condition based upon its compliance with the operating documents (i.e., Exemption Conditions and 

Limitations and the DJI Phantom 3 Professional User Manual) prior to every flight, and further, 

determine that the aircraft is in condition for safe flight, as stated in the conditions and limitations below. 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 7 of 24

3. Regulation and Extent of Relief Sought: 14 CFR Section 91.121 

Relief from Section 91.121, Altimeter settings, is required to allow flight operations of the DJI 

Phantom 3 Professional UA, which utilizes 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), Lockton Enterprises seeks relief because the DJI Phantom 3 Professional UA’s altimeter 

may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight. 

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

to the extent necessary to comply with the applicable conditions and limitations stated below. As 

more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 3 Professional UA is equipped with a barometric pressure sensor and GPS equipment, which

automatically ensures that a ground level pressure setting will be established prior to each flight, 

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

4. Regulation and Extent of Relief Sought: 14 CFR Section 91.151(b)

Relief from Section 91.151(b), Fuel Requirements for Flight in VFR Conditions, is requested to 

the extent required to allow flights of the battery-powered DJI Phantom 3 Professional UA during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), 

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

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

Lockton Enterprises seeks the relief because without an exemption from Section 91.151(b), the 

flight time duration of the battery-powered DJI Phantom 3 Professional UA will severely constrain the practicality of any aerial video, still photography, or data collection proposed here.

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

UA, and Lockton Enterprises’ proposed Conditions and Limitations, ensure that Lockton Enterprises will safely operate the battery powered DJI Phantom 3 Professional UA during daylight 

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

battery power to fly for a total duration of 19 minutes to the first point of intended landing and, 

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

5. Regulation and Extent of Relief Sought: 14 CFR Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) 

Since Sections 91.405(a), Maintenance required; 91.407(a)(1), Operation after maintenance; 

91.409(a)(1) & (a)(2), Inspections; and 91.417(a) & (b), Maintenance records, only apply to aircraft with an airworthiness certificate, Lockton Enterprises requests relief from these as the DJI 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 8 of 24

Phantom 3 Professional UA does not require an airworthiness certificate. As set forth more fully 

below, the DJI Phantom UAS meets the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, Lockton Enterprises will use trained technicians to 

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

techniques, and practices prescribed in the UAS operating documents (i.e., exemption Conditions and Limitations and the DJI Phantom 3 Professional User Manual). Furthermore, Lockton 

Enterprises will document and maintain all maintenance records for the DJI Phantom 3 Professional UAS. 

REASONS WHY GRANTING THIS REQUEST WOULD BE IN THE PUBLIC 

INTEREST (14 CFR 11.81(d))

Granting this Petition will further the public interest by allowing Lockton Enterprises to 

safely, efficiently, and economically perform aerial video, photography, and data collection of client properties over certain areas of the United States.

Use of the DJI Phantom 3 Professional UAS in lieu of an aircraft will 1) decrease congestion 

of the NAS; 2) reduce pollution and noise; 3) provide significant benefits to the public; 4) allow Lockton Enterprises to remain competitive; and 5) avoid privacy issues. 

1. The public will benefit from decreased congestion of the NAS 

The DJI Phantom 3 Professional UA is battery powered and serves as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery and data 

collection. An exemption allowing the use of a DJI Phantom 3 Professional UAS would reduce 

the number of manned aircraft in the NAS, particularly those loitering at a work site while taking 

photographs or collecting data.

2. The public will benefit from reduced pollution and noise

Reducing the number of manned aircraft operating in the NAS reduces congestion around airports caused by arriving and departing aircraft, and increase the safety of life and property in the 

air and on the ground. The DJI Phantom 3 Professional UA does not require an airport to takeoff 

or land, and, in fact, will not be operated near airports. 

3. The public will benefit from the safety and efficiency of the DJI Phantom 3 Professional 

UAS 

Conducting aerial video, photography, and data collection with the DJI Phantom 3 Professional 

UAS, instead of manned aircraft, will benefit the public by substantially reducing the levels of 

air and noise pollution generated. Using battery power and electric motors, the DJI Phantom 3 

Professional UAS produce no end-user air pollution, and is the most viable environmentally 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 9 of 24

conscious alternative to the internal combustion or turbine engine aircraft that are typically utilized for aerial video and photography. Those non-emission controlled engines typically burn

approximately 10 to 25 gallons of leaded aviation gasoline or jet fuel per hour. 

The DJI Phantom 3 Professional UA, while reducing the carbon footprint of aerial operations, 

also virtually eliminates noise pollution. Manned aircraft are powered by an engine that drives 

a rotor system or propeller that produces considerable noise.

Using the DJI Phantom 3 Professional UAS to perform photography and data collection, any

risk to life and property in the air and on the ground associated with traditional manned aircraft 

flight operations will be virtually eliminated. Aside from not having flight crew members, the 

DJI Phantom 3 Professional UA weighs less than three pounds and carries no flammable fuel. 

Its very low weight inherently has less physical potential for collateral damage to life and property compared to the manned aircraft weighing the thousands of pounds that it replaces.

Using the DJI Phantom 3 Professional UAS also eliminates the need for direct human access 

and proximity to points of interest, which can now be accomplished remotely. There will be no 

need for personnel to scale buildings, towers, structures, etc. under precarious conditions when 

the same observation and evaluation can be conducted in utter safety from the ground.

4. The public will benefit by allowing Lockton Enterprises to remain a competitive in 

the use of emerging technologies

In addition to being safe and efficient, the DJI Phantom 3 Professional UA is also an economical 

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

the DJI Phantom 3 Professional UAS will allow United States based companies, like Lockton 

Enterprises, to remain innovative and 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 Professional UAS is one such technology that 

not only allows companies greater operational flexibility compared to manned aircraft, but 

provides such flexibility without the high operating cost of a traditional manned aircraft. 

5. The public will benefit as there are no privacy issues

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

Lockton Enterprises’ proposed operation of the DJI Phantom 3 Professional UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Professional UAS will be operated only 

in compliance with operating documents which require property owner involvement as well as 

occasional law enforcement cooperation, ATC notification, and in accordance with the Federal 

Aviation Regulations, including the minimum altitude requirements of 14 CFR § 91.119.
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 10 of 24

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY, AND HOW THE EXEMPTION WOULD PROVIDE A LEVEL OF 

SAFETY AT LEAST EQUAL TO THAT PROVIDED BY THE RULE FROM WHICH 

LOCKTON ENTERPRISES SEEKS EXEMPTION (14 CFR 11.81(e))

1. Reasons why the DJI Phantom 3 Professional UA meets the conditions of the FAA 

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

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Lockton Enterprises’ operation of the DJI Phantom 3 Professional UAS meets the conditions of FMRA Section 333, and will not require an airworthiness 

certificate in accordance with 14 CFR Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the 

following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not 

later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by Section

332 of this Act or the guidance required by Section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their 

size, weight, speed, operational capability, proximity to airports and populated 

areas, and operation within visual line of sight do not create a hazard to users 

of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under Section 44704 of title 49, United States Code, is 

required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.--If the Secretary determines under this Section that certain unmanned aircraft systems may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft 

systems in the national airspace system.
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 11 of 24

In seeking this exemption, Lockton Enterprises submits that the DJI Phantom 3 Professional UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated 

by a) the characteristics of the DJI Phantom 3 Professional UA; b) the pilot certification 

requirement; and c) the specific operating limitations. 

a. The specifications of the DJI Phantom 3 Professional UAS demonstrate its 

safe characteristics 

The DJI Phantom 3 Professional UAS does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its modest size, weight, speed, limited 

operational range and endurance, and designed-in safety features.

i. Technical specifications Of The DJI Phantom 3 Professional UAS 

The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the DJI 

Phantom 3 Professional User Manual, attached as a link in Appendix A. 

ii. The DJI Phantom 3 Professional UAS autonomous flight and navigation 

modes enable the UAS to remain within a defined operational area 

The DJI Phantom 3 Professional UAS may be operated in both manual and fully autonomous 

flight modes. A complete description of the flight and navigational modes of the DJI Phantom 3 

Professional UAS is provided at pages 11 through 15 of the DJI Phantom 3 Professional User 

Manual, attached as a link in Appendix A. 

iii. The DJI Phantom 3 Professional UAS are designed for automatic return 

to home (RTH) point or hover in the event of loss of the control link or navigation

When the control link is lost, the DJI Phantom 3 Professional UA remains stationary, in flight, 

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Professional UA 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 location and shutdown. 

A complete description of the failsafe RTH function of the DJI Phantom 3 Professional UAS is 

set forth at page 14 of the DJI Phantom 3 Professional User Manual, attached as a link in Appendix A. 

iv. The DJI Phantom 3 Professional GCS and its operation

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

GCS is provided at pages 23 through 29 of the DJI Phantom 3 Professional User Manual. A link 

to the DJI Phantom 3 Professional User Manuals are attached as a link in Appendix A. 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 12 of 24

b. Flight operations of DJI Phantom 3 Professional UAS are limited to the line 

of sight of a certificated Pilot in Command (PIC) with a Visual Observer (VO)

A certificated pilot will be the only person to act as a PIC of the DJI Phantom 3 Professional 

UAS. Additionally, a qualified Visual Observer will assist during flight time. 

c. Flights of DJI Phantom 3 Professional UAS will be conducted pursuant to 

specific Conditions and Limitations

In seeking this exemption, Lockton Enterprises proposes to commercially operate DJI Phantom 3 

Professional UAS for the special purpose of conducting aerial video, photography, and data collection over certain areas of the United States, pursuant to the following Conditions and Limitations (or other such similar Conditions and Limitations as the FAA may issue): 

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 3 Professional UA when weighing less than 55 pounds including payload. Proposed operations 

of any other aircraft will require a new petition or a petition to amend this exemption.

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 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 13 of 24

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 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 document.

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.
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 14 of 24

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.

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 UA 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.
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 15 of 24

18. For tethered UAS operations, the tether line must have colored pennants or streamers attached at not more than 50 foot intervals beginning at 150 feet above the surface of the 

earth and visible from at least one mile. This requirement for pennants or streamers is not 

applicable when operating exclusively below the top of and within 250 feet of any structure, so long as the UA operation does not obscure the lighting of the structure.

19. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property.

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

21. 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.

22. 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.

23. 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.

24. 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.

25. The UA must remain clear and give way to all manned aviation operations and activities 

at all times.

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

27. All flight operations must be conducted at least 500feet from all nonparticipating persons, vessels, vehicles, and structures unless:
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 16 of 24

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.

28. 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.

29. 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 Website: www.ntsb.gov.

Unless otherwise specified in granting this grant of exemption, the UAS, the UAS PIC, and the 

UAS operations will comply with all applicable parts of 14 CFR including, but not limited to, 

Parts 45, 47, 61, and 91.

2. Reasons why an exemption from the requirements of Section 61.113(a) & (b) would 

not adversely affect safety

Lockton Enterprises submits that the equivalent level of safety established by Section 61.113(a) 

& (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Professional 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 Professional UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles, and structures. 

Considering Lockton Enterprises’ 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 with regards to airspace, and the airmanship skills necessary to 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 17 of 24

safely operate the DJI Phantom 3 Professional UAS, Lockton Enterprises submits that the additional manned aeronautical experience of a commercially certificated pilot would not correlate to 

the airmanship skills necessary for Lockton Enterprises’ specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) & (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, 12645). 

Lockton Enterprises will not allow any PIC to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 3 Professional UAS training and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional UAS in a manner consistent with this exemption, including 

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

vehicles, and structures. 

Specifically, 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 (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 experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during Lockton Enterprises’ 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 multirotor 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 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 18 of 24

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 CFR 91.119. 

3. Reasons why an exemption from the requirements of Section 91.7(a) would not adversely 

affect safety

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to 

every flight, Lockton Enterprises will ensure that the DJI Phantom 3 Professional UAS is in an 

airworthy condition based upon 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, 12645). 

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 Professional UA will be provided to the PIC via GPS 

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

the GCS for active monitoring of the flight path and altitude. 

This altitude information, combined with Lockton Enterprises’ operation of the DJI Phantom 3 

Professional UA within visual line of sight, at or below 400 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point is automatically established by the UASs at ground level. 

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

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161, 12645). 

5. Reasons why an exemption from the requirements of Section 91.151(b) would not 

adversely affect safety
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 19 of 24

A grant of this exemption would ensure an equivalent level of safety established by 14 CFR Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 3 Professional 

UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed 

flight operations. Accordingly, Lockton Enterprises will ensure that it will safely operate the battery-powered DJI Phantom 3 Professional UA during daylight hours in VFR conditions, with 

enough battery power to fly for a total duration of approximately 18 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 Professional UAS, the Conditions and Limitations on the proposed flight operations, and the location 

of the proposed operations, will ensure an equivalent level of safety established by 14 CFR

Section 91.151(b). 

The DJI Phantom 3 Professional UAS provides audible and visual warnings to the PIC at the 

GCS when the UA experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery 

power (warning thresholds are user programmable). At the critically low battery level, the DJI 

Phantom 3 Professional 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, 12645). 

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, Lockton Enterprises 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 Lockton 

Enterprises will use technicians to perform maintenance, preventive maintenance, or alterations

on the UAS using the methods, techniques, and practices prescribed in the operating documents 

(i.e. the exemption Conditions and Limitations and the DJI Phantom 3 Professional User Manual 

). Furthermore, Lockton Enterprises will document and maintain all maintenance records for the 

DJI Phantom 3 Professional UAS. 

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

documents, Lockton Enterprises will maintain the equivalent level of safety established by 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 20 of 24

Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A link to the DJI Phantom 3 Professional 

User Manual is attached in Appendix A; a copy of Lockton Enterprises’ DJI Phantom 3 Professional UAS Maintenance Log is attached hereto as Appendix B. 

Likewise, the exemption sought will not adversely affect safety because Lockton Enterprises will use technicians to perform maintenance, alterations or preventive maintenance 

on the UAS using the methods, techniques, and practices prescribed by the operating documents. 

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 Lockton Enterprises’ proposed Conditions and Limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 Professional UAS, Lockton Enterprises submits that safety will not be adversely affected by granting exemption from 14 CFR

Sections 91.405(a), 91.407(a)(1) & (a)(2), 91.409(a)(2), and 91.417(a) & (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, 

12645). 

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 CFR § 21.16, Special Conditions, Lockton Enterprises requests that the FAA prescribe 

special conditions for the intended operation of the DJI Phantom 3 Professional UAS, which 

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

equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CFR §§ 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 UA for the limited purpose of conducting aerial video, photography, and data collection over certain areas of the United States in the 

furtherance of our business. FMRA Section 333 sets forth the requirements for considering 

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat 

to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the 

safe operation of the UAS in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 CFR

§ 21.16, for operation of the DJI Phantom 3 Professional UAS, since the airworthiness 

regulations of 14 CFR Part 21 do not contain adequate or appropriate safety standards, due 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 21 of 24

to the novel or unusual design features of the aircraft. Section 21.16, 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. 

Therefore, in accordance with FMRA Section 333 and 14 CFR § 21.16, the FAA may prescribe 

special conditions for Lockton Enterprises’ intended operation of the DJI Phantom 3 Professional UAS, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CFR 

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). 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

(14 CFR 11.81(f))

Lockton Enterprises, Inc., Kansas City, Missouri, seeks exemption from the requirements of 

14 CFR 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). This exemption will permit Lockton Enterprises, 

Inc. to commercially operate an unmanned aircraft system (UAS) for the purpose of conducting aerial video, photography and data collection over certain areas of the United States.

ADDITIONAL INFORMATION, VIEWS OR ARGUMENTS TO SUPPORT THIS 

REQUEST (14 CFR 11.81(g))

The FAA has set precedence by previously granted exemptions in circumstances similar, in all

material respects, to those presented herein.

USE OF THIS EXEMPTION OUTSIDE THE UNITED STATES; REASONS WHY

(14 CFR 11.81(h))

No operations outside of the United States are sought.

CONCLUSION 

As set forth herein, Lockton Enterprises seeks an exemption pursuant to 14 CFR § 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 Professional UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video, photography, and data collection over 
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 22 of 24

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 Lockton Enterprises to safely, efficiently, 

and economically operate the DJI Phantom 3 Professional UAS commercially within the NAS. 

WHEREFORE, in accordance with the Title 49 of the United States Code, Title 14 Federal 

Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Lockton Enterprises respectfully requests that the Administrator grant this Petition for an exemption 

from the requirements of 14 CF R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Lockton Enterprises to operate the DJI Phantom 3 Professional UAS commercially for the purpose of conducting aerial video, photography, and data collection over certain areas of the United States. 

Respectfully submitted, 

Robert Hopson

Lockton Enterprises, Inc.

Dated: December 21, 2015
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 23 of 24

APPENDIX A

DJI Phantom 3 Professional In the Box:

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_In_the_Box_en_0901.pdf

DJI Phantom 3 Professional Quick Start Guide: 

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide_en_v1.2.pdf

DJI Phantom 3 Professional User Manual:

http://download.dji-innovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.6_en.pdf

DJI Phantom 3 Professional Intelligent Flight Battery Safety Guidelines:

http://download.dji-innovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_en.pdf

DJI Phantom 3 Professional Safety Guidelines and Disclaimer:

http://download.dji-innovations.com/downloads/phantom_3/en/Safety_Guidelines_Disclaimer_en_201509.pdf
Lockton Enterprises, Inc. FMRA Section 333 Exemption Petition Page 24 of 24

APPENDIX B

Lockton Enterprises DJI Phantom 3 Professional UAS Aircraft Log

N number_________ Serial number______________

NOTE: All inspections, maintenance, preventive maintenance, or alterations must be accomplished 

using the methods, techniques, and practices prescribed by the operating documents, manufacturer’s 

manuals, and any FAA-issued Conditions and Limitations. Following any maintenance or alterations 

that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, 

the aircraft must undergo a functional test flight prior to conducting further operations under this 

exemption. See exemption Conditions and Limitations regarding functional test flights. 

Firmware updates and DJI GO app iOS/Android version updates will be considered alterations. 

Aircraft Logbook page sample:

Date

Cumulative 

Hours

Discrepancy

or Event

Description of Inspection,

Maintenance, or Alteration Performed

Returned to 

Service by

Safety Bulletin and Notice Compliance page sample:

Date

Cumulative 

Hours

Safety Bulletin

or Notice

Description of Inspection,

Maintenance, or Alteration Performed

Returned to 

Service by

Remote Controller and iOS/Android Version Logbook page sample:

Date Device Discrepancy

or Event

Description of Inspection,

Maintenance, or Alteration Performed

Returned to 

Service by

(Above samples are representative of content only. Actual logbook pages will be maintained in a 

landscape format on page widths of at least 11 inches and will have data blocks of sufficient size so 

as to accommodate legible entries.)