2 

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.........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH WELCH TENNIS COURTS, INC. 

SEEKS EXEMPTION............................................................................................................7

THE EXTENT OF RELIEF WELCH TENNIS COURTS, INC. SEEKS AND THE REASON

WELCH TENNIS COURTS, INC. SEEKS THE RELIEF..................................................10

THE REASONS WHY GRANTING WELCH TENNIS COURTS, INC.’S REQUEST WOULD

BE IN THE PUBLIC INTEREST ........................................................................................12

THE REASONS WHY GRANTING THE EXEMPTION TO WELCH TENNIS COURTS, INC.

WOULD NOT ADVERSELY AFFECT SAFETY..............................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER...................25 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT WELCH TENNIS COURTS, INC.’S REQUEST.............................................25

CONCLUSION.....................................................................................................................25 

APPENDICES......................................................................................... 26
3

GLOSSARY OF ABBREVIATIONS

AGL

AOI 

ATC

ATO 

AV

CFR 

COA 

FAA 

FAR 

GCS 

GPS 

LOL

NAS

NOTAM 

PIC 

Section 333 

SOP 

UA

UAS

VFR 

VLOS 

VMC 

VTOL 

Above Ground Level 

Area of Interest 

Air Traffic Control 

Air Traffic Organization 

Aerial Vehicle 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot In Command 

FAA Modernization and Reform Act of 2012 (FMRA) 

Standard Operating Procedures 

Unmanned Aircraft 

Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Site 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 
4

SUMMARY

Welch Tennis Courts, Inc. seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) &

(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & 

(b), to operate an Unmanned Aircraft System (DJI Phantom 2 Vision) pursuant to Section 333 of

the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit The 

WELCH TENNIS COURTS, INC. to operate an Unmanned Aircraft System (UAS) for the

commercial purpose of conducting aerial video and photography of construction sites, residential 

and commercial real estate, civil landscapes and events over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

The WELCH TENNIS COURTS, INC. has for forty-two years provided their clients, including

private sector businesses and non-profits, as well as local state and federal agencies, with

expertise and knowledge in tennis court design, construction, and repair. In the past we have

supplied our clients aerial video and photography using commercial aircraft. The objective of 

WELCH TENNIS COURTS, INC. and our Unmanned Aircraft System (DJI Phantom 2 Vision)

aerial operations is to provide a more affordable, high-quality production system for a variety of 

governmental, commercial, public, and residential uses, specifically targeting

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Economic development

• Civic landmarks

• Special event coverage

• Private and governmental training

My staff has safely flown small RC electric quadcopters recreationally for approximately 2 years 

without incident.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision, UAS

WELCH TENNIS COURTS, INC. seeks an exemption to operate DJI Phantom 2 Vision system

for compensation or hire within the NAS. The DJI Phantom 2 Vision is vertical takeoff and

landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The DJI Phantom 2 Vision has a maximum gross

weight of approximately 2.8 lb. while having a diagonal dimension of 13.8”, a maximum speed

of approximately 16.4’fps and a maximum flying height of 400'. The DJI Phantom 2 Vision is

equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. 
5 

BASIS FOR PETITION

Petitioner, WELCH TENNIS COURTS, 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 DJI Phantom 2 Vision, UAS in the National Airspace

System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

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

unmanned aircraft and its operation, WELCH TENNIS COURTS, INC. operation of DJI

Phantom 2 Vision UAS 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, WELCH TENNIS COURTS, 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.

WELCH TENNIS COURTS, INC. submits that the requested relief is proper since an equivalent

level of safety will be ensured. WELCH TENNIS COURTS, INC. will use experienced

personnel or technicians to perform maintenance, alterations, or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., 

DJI Phantom 2 Vision Instruction Manual).

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

and limitations: Pilot in command, is requested by WELCH TENNIS COURTS, INC. to the

extent necessary to allow a Pilot in Command (PIC) who has demonstrated, by meeting minimum 

flight- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 

Vision UAS in a manner consistent with this exemption, including evasive and emergency 

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

WELCH TENNIS COURTS, INC. seeks relief from Section 91.7(a), entitled Civil aircraft

airworthiness, because the DJI Phantom 2 Vision UAS do not require an airworthiness certificate

in accordance with 14 C.F.R. Part 21, Subpart H. As such, WELCH TENNIS COURTS, INC.

submits that they will ensure that the DJI Phantom 2 Vision UAS is in an airworthy condition,

prior to every flight, by determining that the UAS are in compliance with the operating 

documents (i.e., DJI Phantom 2 Vision Instruction Manual), and that the aircraft are in a

condition for safe flight. 
6 

WELCH TENNIS COURTS, INC. also seeks an exemption from the requirements of Section

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision UAS will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 2 Vision UAS

will be provided to the PIC via Global Positioning System (GPS) equipment and radio 

communications telemetry data link, which downlinks from the UA to the GCS for active 

monitoring of the flight path. This altitude information, combined with WELCH TENNIS 

COURTS, INC.’s operation of the DJI Phantom 2 Vision UAS within visual line of sight, at or

below 400 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, WELCH TENNIS COURTS, INC. seeks an exemption from the requirements of

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. WELCH TENNIS 

COURTS, INC. submits that safety will not be affected by operation of the DJI Phantom 2 

Vision 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 25 minutes.

Battery power indicators are also able to show exactly how much battery power is left, as well as 

how much time is needed to return safely back to point of take off.

In accordance with 14 C.F.R. § 11.81, WELCH TENNIS COURTS, 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:

George Todd III

Welch Tennis Courts, Inc. 

4501 US Hwy 41 S

PO Box 7770

Sun City, Fl 33586

813-641-7787 F-813-641-7795

G3@welchtennis.com
7 

B. The Specific Sections Of 14 C.F.R. From Which WELCH TENNIS COURTS, INC.

Seeks Exemption. 

1. WELCH TENNIS COURTS, INC. Seeks Exemption From The Requirements Of Section

61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part: 

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

(PIC) of an aircraft that is carrying passengers or property for compensation or hire; 

nor may that person, for compensation or hire, act as PIC of an aircraft. 

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

connection with any business or employment if—

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

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

2. WELCH TENNIS COURTS, 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. 

3. WELCH TENNIS COURTS, INC. Seeks Exemption From The Requirements Of Section

91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: 

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level 

of that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and 

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate available 

station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before 

departure. 
8 

4. WELCH TENNIS COURTS, INC. Seeks Exemption From The Requirements Of Section

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following: 

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

(considering wind and forecast weather conditions) there is enough fuel to fly to the 

first point of intended landing and, assuming normal cruising speed, to fly after that 

for at least 20 minutes. 

5. WELCH TENNIS COURTS, INC. Seeks Exemption From The Requirement Of Section

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. WELCH TENNIS COURTS, INC. Seeks Exemption From The Requirements Of Section

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following: 

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

maintenance, rebuilding, or alteration unless--

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

of this chapter[.] 

7. WELCH TENNIS COURTS, 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 

with part 21 of this chapter. 
9 

8. WELCH TENNIS COURTS, INC. Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b). 

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

following: 

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

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

in paragraph (b) of this section: 

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

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

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

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

(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. 
10 

(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 WELCH TENNIS COURTS, INC. Seeks And The Reason

WELCH TENNIS COURTS, INC. Seeks The Relief.

1. Extent Of Relief WELCH TENNIS COURTS, INC. Seeks And The Reason WELCH

TENNIS COURTS, 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, WELCH TENNIS COURTS, INC. submits that an equivalent

level of safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2 

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

demonstrating that the PIC is able to safely operate either the DJI Phantom 2 Vision 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, WELCH TENNIS COURTS, INC. submits that all flights of the DJI Phantom 2 Vision

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

WELCH TENNIS COURTS, INC. business; and (2) will not carry passengers or property for

compensation or hire. 
11 

2. Extent Of Relief WELCH TENNIS COURTS, INC. Seeks And The Reason WELCH

TENNIS COURTS, 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 WELCH TENNIS COURTS, INC. to determine that the DJI Phantom 2 Vision

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 2 Vision Instruction Manual).

WELCH TENNIS COURTS, INC. seeks the requested relief because the DJI Phantom 2 Vision

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

Therefore, WELCH TENNIS COURTS, INC. will ensure that the DJI Phantom 2 Vision UAS

are in airworthy condition based upon its compliance with the operating documents (i.e., DJI 

Phantom 2 Vision) prior to every flight, and further, determine that the aircraft are in condition

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

3. Extent Of Relief WELCH TENNIS COURTS, INC. Seeks And The Reason WELCH

TENNIS COURTS, 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 2 Vision 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), WELCH TENNIS COURTS, INC. seeks the requested relief because

the DJI Phantom 2 Vision 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 2 Vision 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. 

4. Extent Of Relief WELCH TENNIS COURTS, INC. Seeks And The Reason WELCH

TENNIS COURTS, INC. Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is 

requested to the extent required to allow flights of the battery powered DJI Phantom 2 Vision

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

(VFR), for a total duration of 25 minutes. WELCH TENNIS COURTS, INC. seeks the requested

relief because without an exemption from Section 91.151(b), the flight time duration of the 
12 

battery powered DJI Phantom 2 Vision UAS will severely constrain the practicality of any aerial

video or still photo flight operations that WELCH TENNIS COURTS, INC. proposes to conduct

pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 Vision UAS,

the DJI Phantom 2 Vision operating documents, and WELCH TENNIS COURTS, INC.’s

proposed operating limitations, ensure that WELCH TENNIS COURTS, INC. will safely operate

the battery powered DJI Phantom 2 Vision 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 25 minutes.

5. Extent Of Relief WELCH TENNIS COURTS, INC. Seeks And The Reason WELCH

TENNIS COURTS, 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, WELCH TENNIS COURTS, INC. requests relief from

these Sections because the DJI Phantom 2 Vision UAS do not require airworthiness certificates.

As set forth more fully below, the DJI Phantom 2 Vision UAS meet the conditions of FMRA

Section 333 for operation without an airworthiness certificate. Accordingly, WELCH TENNIS 

COURTS, INC. 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., DJI Phantom 2 Vision Instruction Manual).

D. The Reasons Why Granting WELCH TENNIS COURTS, 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 WELCH TENNIS 

COURTS, INC. to safely, efficiently, and economically perform aerial video and photography of

construction sites, real estate, events and civic landscape over certain areas of the United States. 

Additionally, use of the DJI Phantom 2 Vision UAS will decrease congestion of the NAS, reduce

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

TENNIS COURTS, INC.’s proposed operation of the DJI Phantom 2 Vision UAS will be

realized without implicating any privacy issues. 

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

The DJI Phantom 2 Vision UAS are battery powered and serve as a safe, efficient, and

economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By 

reducing the 
13 

amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use 

of a DJI Phantom 2 Vision 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 2 

Vision UAS do 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 2 Vision UAS.

Conducting aerial acquisitions with the DJI Phantom 2 Vision 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 2 Vision UAS produce 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 2 Vision

UAS, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, 

as the UAS are propelled by battery powered electric motors, rather than an internal combustion 

engine. 

By using the DJI Phantom 2 Vision 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 2 Vision

UAS (weighing approximately 2.8 pounds at their maximum gross weight with diagonal 

dimension of 13.8 inches, and with no fuel on board), has less physical potential for collateral

damage to life and property on the ground, and in the air, compared to the manned aircraft that 

typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 Vision UAS

Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 UAS are also an economical

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

the DJI Phantom 2 Vision UAS will allow United States based companies, like WELCH 

TENNIS COURTS, 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 2 Vision UAS is one such technology that not only allows

companies greater operational 
14 

flexibility compared to manned aircraft, but provides such flexibility without the high 

operational cost of a traditional manned aircraft. 

By operating the DJI Phantom 2 Vision UAS, companies such as WELCH TENNIS COURTS, 

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. 

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

2 Vision 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, 

WELCH TENNIS COURTS, INC.’s proposed operation of the DJI Phantom 2 Vision UAS will

not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision UAS will be operated

only in compliance with operating documents (i.e., DJI Phantom 2 Vision Instruction Manual)

which requires property owner involvement and in accordance with the Federal Aviation 

Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. 

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 WELCH TENNIS COURTS, INC. Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision 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, WELCH TENNIS COURTS, INC.’s operation of the DJI

Phantom 2 Vision UAS meet 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. 
15 

(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, WELCH TENNIS COURTS, INC. submits that the DJI Phantom 2 

Vision UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by:

(a) the characteristics of the DJI Phantom 2 Vision UAS; (b) the pilot certification requirement;

and (c) the specific operating limitations. 

a. The Specifications Of The DJI Phantom 2 Vision UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision 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 2 Vision UAS.

The technical specifications of the DJI Phantom 2 Vision UAS are set forth by the DJI Phantom

2 Vision User Manual, attached hereto as Appendix A.

ii. The DJI Phantom 2 Vision UAS Global Positioning Modes Enable The UAS To Remain

Within A Defined Operational Area. 

The DJI Phantom 2 Vision UAS may be operated in both manual and global positioning flight

modes. A complete description of the flight and navigational modes of the DJI Phantom 2 Vision

UAS is provided in the DJI Phantom 2 Vision User Manual attached hereto as Appendix A.

iii. The DJI Phantom 2 Vision UAS Are 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 2 Vision UAS will remain stationary, in flight,

for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision UAS does not reacquire

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

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

and shutdown. 
16 

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision UAS are set

forth in the DJI Phantom 2 Vision User Manual, attached hereto as Appendix A.

iv. The DJI Phantom 2 Vision GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 Vision GCS and

flight control software is provided in the DJI Phantom 2 Vision User Manual. DJI Phantom 2 

Vision User Manual is attached hereto as Appendix A.

b. Flight Operations Of DJI Phantom 2 Vision UAS Is Limited To The Line Of Sight Of A

Certificated Pilot in Command. 

WELCH TENNIS COURTS, INC. video production staff will be the only persons to act as a

pilot in command (PIC) of the DJI Phantom 2 Vision UAS.

c. Flights Of DJI Phantom 2 Vision UAS Will Be Conducted Pursuant To Specific Operating

Limitations. 

In seeking this exemption, WELCH TENNIS COURTS, INC. proposes to commercially

operate DJI Phantom 2 Vision 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 UAS weighing less than 55 

pounds maximum gross weight: DJI Phantom 2 Vision Unmanned Aircraft Systems.

Proposed operations of any other aircraft will require a new petition or a petition to 

amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for

the purpose of aerial video and photography.

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots.

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

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

special request is made and approved by ATC. All altitudes reported to ATC must be 

in feet AGL.

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. 

6. 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. 
17 

7. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition

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

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

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

Control Station must be included in the preflight inspection. 

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. 

9. 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. 

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

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

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. 

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

Safety Bulletins. 

12. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1.

All operations must be conducted under visual meteorological conditions (VMC). If 

flight at night is required, a special request will be made at the FAA office closest to 

proposed area of operations. Flights under special visual flight rules (SVFR) are not 

authorized. 

13. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of agreement 

with that airport’s management is obtained, and the operation is conducted in

accordance with a NOTAM as required by the operator’s COA. The letter of 

agreement with the airport management must be made available to the Administrator 

upon request.

14. 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.

15. 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.
18

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

in accordance with the operating documents.

17. 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.

18.

19.

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 (NNumber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must 

be as large as practicable.

20.

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.

21.

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.

22.

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

operations and activities at all times.

23.

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

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

persons (persons other than the PIC, 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;
19

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

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

25.

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.

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.

WELCH TENNIS COURTS, 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 2 Vision 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 2 Vision UAS in a 

manner consistent with the exemption, including evasive and emergency maneuvers and 

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

Considering WELCH TENNIS COURTS, INC.’s proposed area of operations, and the operating

limitations set forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption No. 11062); and the 

airmanship skills necessary to safely operate the DJI Phantom 2 Vision UAS, WELCH TENNIS 

COURTS, INC. submits that the additional manned airmanship experience of a commercially

certificated pilot would not correlate to the airmanship skills necessary for WELCH TENNIS 

COURTS, INC.’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in 

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161, 12820).

WELCH TENNIS COURTS, INC. will not allow any PIC to operate the DJI Phantom 2 Vision

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

Phantom 2 Vision UAS training and currency requirements, that the PIC is able to safely operate

the DJI Phantom 2 Vision 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 

24.
20

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 WELCH TENNIS COURTS, INC.’s 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, WELCH TENNIS COURTS, INC. will ensure safe operations by not allowing any

PIC to operate the DJI Phantom 2 Vision 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 2 Vision 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. 
21

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

every flight, WELCH TENNIS COURTS, INC. will ensure that the DJI Phantom 2 Vision 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, 12680).

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 2 Vision UAS 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 WELCH TENNIS COURTS, INC.’s operation of the DJI Phantom 2 Vision 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 

UAS 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, 12860).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not

Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 Vision

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

flight operations. Accordingly, WELCH TENNIS COURTS, INC. will ensure that it will safely

operate the battery powered DJI Phantom 2 Vision UAS during daylight hours in VFR

conditions, with enough battery power to fly for a total duration of 25 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 Vision 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 2 Vision UAS provide audible and

visual warnings to the PIC at the GCS when the UAS experiences low battery voltage, the first 

warning occurring at approximately 33% remaining battery power, and again at approximately 

10% remaining battery 
22

power. At the critically low battery level, the DJI Phantom 2 Vision 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, 12680).

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, WELCH TENNIS COURTS, 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 

WELCH TENNIS COURTS, 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., DJI Phantom 2 Vision Instruction Manual).

Furthermore, WELCH TENNIS COURTS, INC. will document and maintain all maintenance

records for the DJI Phantom 2 Vision UAS.

Since the DJI Phantom 2 Vision UAS will be inspected as prescribed by the operating

documents, WELCH TENNIS COURTS, 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 2 

Vision User Manuals are attached hereto as Appendix A.

Likewise, the exemption sought will not adversely affect safety because WELCH TENNIS 

COURTS, 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 2 Vision

UAS will be performed by trained technicians. 

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. 
23

In consideration of WELCH TENNIS COURTS, INC.’s proposed operating limitations, the

operating documents, and the technical aspects of the DJI Phantom 2 Vision UAS, WELCH 

TENNIS COURTS, 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, 12680).

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, WELCH TENNIS COURTS, INC. requests

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 Vision

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 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 2 Vision UAS, since the airworthiness regulations

of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or

unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the 

following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller 

because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, 

he prescribes special conditions and amendments thereto for the product. The special 

conditions are issued in accordance with Part 11 of this chapter and contain such safety 

standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to 

establish a level of safety equivalent to that established in the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 2 Vision

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 
24

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

91.417(a) & (b).

• A Summary That Can Be Published In The Federal Register, stating: The 

Rules From Which WELCH TENNIS COURTS, INC. Seeks Exemption:

WELCH TENNIS COURTS, INC. seeks exemption from the requirements of 14 C.F.R

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

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

A Brief Description Of The Nature Of The Exemption WELCH TENNIS COURTS, 

INC. Seeks:

This exemption will permit WELCH TENNIS COURTS, INC. to commercially operate an

Unmanned Aircraft System (UAS) for the purpose of conducting aerial video and 

photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support

WELCH TENNIS COURTS, 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, WELCH TENNIS COURTS, INC.’s request for

exemption may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 

11, as set forth above. 

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

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

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, WELCH TENNIS COURTS, INC. will operate the DJI Phantom 2 

Vision 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, WELCH TENNIS COURTS, 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 2 Vision 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 WELCH TENNIS COURTS, INC. to

safely, efficiently, and economically operate the DJI Phantom 2 Vision UAS commercially

within the NAS. 
25

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

Modernization and Reform Act of 2012, Section 333, WELCH TENNIS COURTS, INC.

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

requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit WELCH TENNIS 

COURTS, INC. to operate the DJI Phantom 2 Vision UAS commercially for the purpose of 

conducting aerial video and photography over certain areas of the United States. 

Dated: Jauary 6, 2016

Respectfully submitted,

George Todd III

Welch Tennis Courts, Inc. 

4501 US Hwy 41 S

PO Box 7770

Sun City, FL 33586

813-641-7787 F-813-641-7795

G3@welchtennis.com

Appendices:

A – Link to DJI Phantom 2 Vision Manual: Click on link below

http://dl.djicdn.com/downloads/phantom-2-vision/en/

Phantom_2_Vision_User_Manual_v1.8_en.pdf