Chad Wiley (PIC)

13033 NW County Road 4002

Amoret, MO 64722

Request for exemption to fly UAS in business

Will be used within FAA requirements with regards to distance from airports elevations and daytime 

operation visual observance (VLOS) of UAS and all other FAA regulations.

A COA will be applied for on any flights that may be outside these requirements.

Will be flying UAS for:

Aerial surveying and mapping, videography, photography, agriculture and crop imaging, construction 

services, environmental management and analysis, real estate marketing and promotions, wildlife 

and forestry monitoring, and business marketing and promotions, search and rescue, inspections, 

news & events.

Will be flying Phantom 3 (UAS)

Drones are under 10 pounds and fly under 50 mile an hour

All specs are available online thru DJI at:

http://www.dji.com/product/phantom3/spec

PIC Has hands on flight experience with a Phantom 3, under the guidance of an experienced 

instructor. 

Preflight checklist below will be used:

Phantom 3 & R/C battery charged

Tablet/phone/monitor charged

Propellers installed and tightened

Remove gimbal lock

Gimbal not obstructed (grass)

Tablet/phone volume to MAX

Tablet/phone to R/C attached

R/C ON

R/C in PMode

Phantom ON

Launch DJI GO app

Check values :

Compass status

Gain values

Max height

RTH height (depends on flight location)

R/C EXP & Gain (0,50,40,5)

VPS ON (if indoor flight)

Satellite status

Format SD card

CHECK HOME POINT

CHECK BATTERY STATUS (Cells)

Takeoff

SUMMARY
CHAD WILEY seeks exemption from the requirements of 14 C.F.R §§ 91.7(a), 91.121,

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an

Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act

of 2012 (FMRA). This exemption will permit CHAD WILEY to operate an Unmanned Aircraft

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

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

INTRODUCTION AND INTERESTS OF THE PETITIONER

CHAD WILEY will provide his clients with expertise and knowledge in advanced technologies

and solutions to increase efficiency, productivity and effectiveness. The objective of CHAD 

WILEY and his aerial operations is to safely provide high quality imaging for a variety of 

commercial, public, and residential uses, specifically targeting:

• Agriculture

• General aerial still photos and video

• Wildlife population surveys

• Real Estate marketing

• Aerial inspections of public and private structures

• Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 UAS.

CHAD WILEY seeks an exemption to operate DJI systems for compensation or hire within the

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

with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI

Phantom 3 has a maximum gross weight of approximately 3 pounds while having a length of 16

inches, width of 16 inches, height of 8 inches, and a maximum speed of approximately 30 knots.

The DJI Phantom 3 is equipped with four main rotors, driven by Lithium Polymer battery

powered electric motors.

The UA that will be operated by CHAD WILEY will be registered in accordance with 49

U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and

marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, CHAD WILEY, 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 3 UA in the National Airspace System

(NAS), and for an exemption from the requirements of 14 C.F.R §§ 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, CHAD WILEY’s operation of the DJI Phantom 2 UA 

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, CHAD WILEY 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. CHAD WILEY submits that the requested

relief is proper since an equivalent level of safety will be ensured. CHAD WILEY will use

experienced personnel or technicians to perform maintenance, alterations, or preventive

maintenance on the UASs using the methods, techniques, and practices prescribed in the

operating documents (i.e., Monthly Maintenance Log, and DJI Instruction Manual). Furthermore,

CHAD WILEY will document and maintain all maintenance records for the DJI Phantom 3 UA.

Privileges and Limitations: Pilot in Command, is requested by CHAD WILEY to the extent

necessary to allow a Pilot in Command (PIC) who has demonstrated that the PIC is able to safely

operate the said DJI UA in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles, and 

structures.

CHAD WILEY seeks relief from Section 91.7(a), entitled Civil Aircraft Airworthiness, because

the DJI Phantom 3 UA does not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H. As such, CHAD WILEY submits that he will ensure that the

DJI Phantom 3 UA is in an airworthy condition, prior to every flight, by determining

that the UA is in compliance with the operating documents (i.e., Monthly Maintenance Log, and

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

CHAD WILEY also seeks an exemption from the requirements of Section 91.121, entitled

Altimeter Settings, as the DJI Phantom 3 UA will not have a typical barometric

altimeter onboard. However, altitude information of these said UA 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 CHAD WILEY’s operation of the DJI Phantom 3 UA

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

Section 91.121.

Additionally, CHAD WILEY seeks an exemption from the requirements of Section 91.151(b),

entitled Fuel Requirements for Flight in VFR Conditions. CHAD WILEY submits that safety

will not be affected by operation of the DJI Phantom 3 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 approximately 17.5 minutes to the first point of intended

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

In accordance with 14 C.F.R. § 11.81, CHAD WILEY provides the following information in

support of his petition for exemption

Name And Address Of The Petitioner.

CHAD WILEY

13033 NW County Road 4002

Amoret, MO 64722

cawt@ckt.net
The Specific Sections Of 14 C.F.R. From Which CHAD WILEY Seeks Exemption.

1. CHAD WILEY 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.

2. CHAD WILEY 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.

3. CHAD WILEY 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.

4. CHAD WILEY 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[.]

5. CHAD WILEY 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.

6. CHAD WILEY 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.

7. CHAD WILEY 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.

(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.
The Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY Seeks The

Relief.

1. Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY 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 CHAD WILEY to determine that the DJI Phantom 3 UA is in

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

operating documents (i.e., Monthly Maintenance Log and DJI Instruction Manual).

CHAD WILEY seeks the requested relief because the DJI Phantom 3 UA does not

require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore,

CHAD WILEY will ensure that the DJI Phantom 3 UA is in airworthy condition

based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and

DJI Instruction 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.

2. Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY 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 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), CHAD WILEY seeks the requested relief because the DJI Phantom 3

UA’s altimeter may be set on the ground to zero feet AGL, rather than the local

barometric pressure or field altitude, before each flight. 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 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.

3. Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY 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 3 UA 

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

(VFR), for a total duration of 17.5 minutes to the first point of intended landing and, assuming

normal cruising speed, to fly after that for at least 4.5 minutes. CHAD WILEY seeks the

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

of the battery powered DJI Phantom 3 UA will severely constrain the practicality of

any aerial video or still photo flight operations that CHAD WILEY proposes to conduct pursuant

to this Petition.

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

UA, the DJI Phantom 3 and CHAD WILEY’s proposed operating limitations, ensure
that CHAD WILEY will safely operate the battery powered DJI Phantom 3 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 17.5 minutes to the first point of

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

4. Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY 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, CHAD WILEY requests relief from these Sections

because the DJI Phantom 3 UA does not require airworthiness certificates. As set

forth more fully below, the DJI UAS meets the conditions of FMRA Section 333 for operation

without an airworthiness certificate. Accordingly, CHAD WILEY 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., the Monthly

Maintenance Log, and DJI Instruction Manual). Furthermore, CHAD WILEY will document and

maintain all maintenance records for the DJI Phantom 3 UAS.

The Reasons Why Granting CHAD WILEY’s Request Would Be In ThePublic Interest;

That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing CHAD WILEY to

safely, efficiently, and economically perform aerial video and photography of construction sites,

real estate, and landscape over certain areas of the United States. Additionally, use of the DJI

Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and provide

significant benefits to the economy. Notably, the benefits of CHAD WILEY’s proposed

operation of the DJI UAS will be realized without implicating any privacy issues.

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

The DJI Phantom 3 UA is battery powered and serves as a safe, efficient, and

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

exemption allowing the use of a DJI UAS would reduce the number of manned aircraft in the

NAS and 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 UA does not require an airport to takeoff or land. Likewise, a reduction of manned aircraft

conducting aerial video and photography missions would result in fewer aircraft that must be

handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of

flight operations.

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

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerial video and still photography flight operations. By using battery

power and electric motors, the DJI 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 3 UA, 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 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 UA (weighing approximately 3 & 15 pounds

and with a length of 16 & 20 inches and widths of 16 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 UAS Will Benefit

The Economy.

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

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

the DJI Phantom 3 UAS will allow United States based companies, like CHAD WILEY, 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 UAS is one such technology that not only allows companies greater operational

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

operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 UAS, companies such as CHAD WILEY, 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 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, CHAD WILEY’s proposed operation of the DJI UAS will not implicate any privacy

issues. Specifically, the DJI UAS will be operated only in compliance with operating documents

(i.e., The Monthly Maintenance Log, and DJI Instruction Manual) which requires property owner

involvement as well as local law enforcement notification, and in accordance with the Federal

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

Seeks And The Reason CHAD WILEY 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 CHAD WILEY to determine that the DJI Phantom 3 UA is in

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

operating documents (i.e., Monthly Maintenance Log and DJI Instruction Manual).
CHAD WILEY seeks the requested relief because the DJI UA does not require an airworthiness

certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, CHAD WILEY will

ensure that the DJI Phantom 3 UA is in airworthy condition based upon its

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Instruction

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.

1. Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY Seeks Relief

From Section 91.121.

Relief from Section 91.121, entitled Altimeter Settings, may be required to allow flight

operations of the DJI Phantom 3 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), CHAD WILEY seeks the requested relief because the DJI

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

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

2. Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY 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 UA during daylight

hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total

duration of 17.5 minutes to the first point of intended landing and, assuming normal cruising

speed, to fly after that for at least 4.5 minutes. CHAD WILEY seeks the requested relief because

without an exemption from Section 91.151(b), the flight time duration of the battery powered

DJI Phantom 3 UA will severely constrain the practicality of any aerial video or still

photo flight operations that CHAD WILEY proposes to conduct pursuant to this Petition.

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

UA, the DJI Phantom 3, and CHAD WILEY’s proposed operating limitations, ensure

that CHAD WILEY will safely operate the battery powered DJI Phantom 3 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 17.5 minutes to the first point of

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

3. Extent Of Relief CHAD WILEY Seeks And The Reason CHAD WILEY 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, CHAD WILEY requests relief from these Sections

because the DJI Phantom 3 UA does not require airworthiness certificates. As set
forth more fully below, the DJI UAS meets the conditions of FMRA Section 333 for operation

without an airworthiness certificate. Accordingly, CHAD WILEY 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., the Monthly

Maintenance Log, and DJI Instruction Manual). Furthermore, CHAD WILEY will document and

maintain all maintenance records for the DJI Phantom 3 UAS.

The Reasons Why Granting CHAD WILEY’s 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 CHAD WILEY to

safely, efficiently, and economically perform aerial video and photography of construction sites,

real estate, Farms and landscape over certain areas of the United States. Additionally, use of the

DJI Phantom 3 UAS will decrease congestion of the NAS, reduce pollution, and

provide significant benefits to the economy. Notably, the benefits of CHAD WILEY’s proposed

operation of the DJI UAS will be realized without implicating any privacy issues.

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

The DJI UA is battery powered and serves as a safe, efficient, and economical alternative to the

manned aircraft traditionally utilized to obtain aerial imagery. By reducing the number of

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

Phantom 3 UAS would reduce the number of manned aircraft in the NAS and reduce

noise and air pollution, as well as increase the safety of life and property in the air and on the

ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion

around airports caused by arriving and departing aircraft will be reduced. The DJI Phantom 3 

UA does not require an airport to takeoff or land. Likewise, a reduction of manned

aircraft conducting aerial video and photography missions would result in fewer aircraft that

must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing

phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 UAS.

Conducting aerial acquisitions with the DJI Phantom 3 UAS, instead of manned

aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution

generated during traditional aerial video and still photography flight operations. By using battery

power and electric motors, the DJI Phantom 3 UAS 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 3 UA, 

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 3 UAS to perform aerial

acquisitions, the substantial risk to life and property in the air and on the ground, which is

usually associated with traditional manned aircraft flight operations, will be substantially reduced

or completely eliminated. Aside from the lack of flight crew members located onboard the
aircraft, the DJI Phantom 3 UA (weighing approximately 3 & 15 pounds at its

maximum gross weight with a length of 16 & 20 inches and widths of 16 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 UAS Will Benefit

The Economy.

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

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

the DJI UAS will allow United States based companies, like CHAD WILEY 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 UAS is one such

technology that not only allows companies greater operational flexibility compared to manned

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

aircraft. By operating the DJI UAS, companies such as CHAD WILEY , 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 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,

CHAD WILEY’s proposed operation of the DJI UAS will not implicate any privacy issues.

Specifically, the DJI Phantom 3 UAS will be operated only in compliance with

operating documents (i.e., The Monthly Maintenance Log, and DJI Instruction Manual) which

requires property owner involvement as well as local law enforcement notification, and in

accordance with the Federal Aviation Regulations, including the minimum altitude requirements

of 14 C.F.R. § 91.119.

Rule From Which CHAD WILEY Seeks Exemption.

1. Reasons Why The DJI Phantom 3 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, CHAD WILEY’s operation of the DJI UAS meets the

conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance

with 14 C.F.R. Part 21, Subpart H.

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

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

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

following, in part:
(a) In General.--Notwithstanding any other requirement of this subtitle, and not later

than 180 days after the date of enactment of this Act, the Secretary of Transportation shall

determine if certain unmanned aircraft systems may operate safely in the national airspace

system before completion of the plan and rulemaking required by section 332 of this Act or the

guidance required by section 334 of this Act.

(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, CHAD WILEY submits that the DJI Phantom 3 UAS can

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

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

(c) the specific operating limitations.

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

GCS and flight control software is provided at DJI WEB SITE

1. 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 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 CHAD WILEY’s operation of the DJI Phantom 3 UA within visual line of

sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The

altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to

each flight, a zero altitude initiation point is automatically established by the UASs at ground

level.

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

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

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

11158, 11159, 11160, 11161).

2. 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 3 UAS; (2) 

the limitations on the proposed flight operations; and (3) the location of the proposed
flight operations. Accordingly, CHAD WILEY will ensure that it will safely operate the 

batterypowered DJI UA during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 17.5 minutes to the first point of intended landing and, assuming 

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

Here, as in Exemption No. 11109, the technical specifications of the DJI 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 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. At the critically low

battery level, the DJI Phantom 3 UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that

safety is not adversely affected when the technical characteristics and

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

operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689,

5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific

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

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080,

11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

3. 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, CHAD WILEY 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 CHAD WILEY

will use trained technicians to perform maintenance, alterations, or preventive maintenance on

the UASs using the methods, techniques, and practices prescribed in the operating documents

(i.e. The Monthly Maintenance Log and DJI Instruction Manual). Furthermore, CHAD WILEY

will document and maintain all maintenance records for the DJI UAS. Since the DJI UAS will be

inspected as prescribed by the operating documents, CHAD WILEY 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 User Manual is attached hereto as Appendix A; a copy of the DJI Phantom 3 

UAS Maintenance LOG is attached hereto as Appendix B.

Likewise, the exemption sought will not adversely affect safety because CHAD WILEY will use

trained technicians to perform maintenance, alterations or preventive maintenance on the UAS

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

Furthermore, the exemption sought would maintain an equivalent level of safety established by

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 3 UAS 

will be performed by trained technicians. Maintenance will be documented and

maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted

by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &

(b) establish that safety is not adversely affected when the technical characteristics and operating

limitations of the UAS are considered.

In consideration of CHAD WILEY’s proposed operating limitations, the operating documents,

and the technical aspects of the DJI Phantom 3 UAS, CHAD WILEY 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).

CONCLUSION

As set forth herein, CHAD WILEY seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe

operation of the DJI Phantom 3 UAS commercially, without an airworthiness

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

of the United States. By granting this Petition, the FAA Administrator will be fulfilling the

Congressional mandate of the FAA Modernization and Reform Act of 2012, while also

advancing the interests of the public, by allowing CHAD WILEY to safely, efficiently, and 

economically operate the DJI Phantom 3 UAS commercially within

the NAS.

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

Modernization and Reform Act of 2012, Section 333, CHAD WILEY respectfully requests that

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R

Sections 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 CHAD WILEY to operate the DJI Phantom 3 UAS

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

the United States.

Dated: February 18, 2016

Respectfully,

Chad Wiley