UNITED STATES OF AMERICA DEPARTMENT OF 

TRANSPORTATION FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

William Gardner Dodd, d.b.a eyeDyllic Photography 

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 

14 OF THE CODE OF FEDERAL REGULATIONS

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

& (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI 

INSPIRE 1 UNMANNED AIRCRAFT SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95) 

Submitted on June 17, 2015 

William G Dodd d.b.a eyeDyllic Photography

7225 Blakeley Forest Blvd

Spanish Fort, Alabama 36527

251-228-0169 
TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS

 ..................................................................................3 

SUMMARY

 ..................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER

 ..................................................................................4 

BACKGROUND

 ..................................................................................5 

BASIS FOR PETITION

 ..................................................................................5 

NAME AND ADDRESS OF PETITIONER

 ..................................................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH William G Dodd SEEKS 

EXEMPTION

 ..................................................................................8 

 THE EXTENT OF RELIEF William G Dodd SEEKS AND THE REASON William G Dodd 

SEEKS THE RELIEF

 ..................................................................................11 

 THE REASONS WHY GRANTING William G Dodd’s REQUEST WOULD BE IN THE 

PUBLIC INTEREST

 ..................................................................................14

 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY

 ..................................................................................17 

CONCLUSION

 ..................................................................................32 
GLOSSARY OF ABBREVIATIONS 

AGL

Above Ground Level

AOI

Area of Interest

ATC

Air Traffic Control

ATO

Air Traffic Organization

AV

Aerial Vehicle

CFR

Code of Federal Regulations

COA

Certificate of Authorization

FAA

Federal Aviation Administration

FAR

Federal Aviation Regulation

GCS

Ground Control Station

GPS
Global Positioning System

LOL

Loss of Link

NAS

National Airspace System

NOTAM

Notice to Airman

PIC

Pilot In Command 

Section 333

FAA Modernization and Reform Act of 2012 (FMRA)

SO

Safety Observer 

SOP

Standard Operating Procedures

UA

Unmanned Aircraft

UAS

Unmanned Aircraft System 

VFR

Visual Flight Rules 

VLOS

Visual Line of Site 

VMC

Visual Meteorological Conditions 
VTOL

Vertical Takeoff and Landing
SUMMARY 

William G Dodd 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 pursuant to Section 

333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption 

will permit William G Dodd to operate an Unmanned Aircraft System (UAS) for 

the commercial purpose of conducting aerial video and photography over certain 

areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

My name is William G Dodd, I am 36 years old. I am a professional photographer 

and videographer.

The objective of William G Dodd is to provide high quality aerial imaging for a 

variety of commercial and public uses, specifically: 

aerial photography and videography for commercial use, including aerial 

cinematography on controlled sets

• • 

BACKGROUND 

Unmanned Aircraft Systems: DJI Phantom 3, DJI Inspire 1 UASs 

William G Dodd seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Phantom 3 and DJI Inspire 1 are 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 2 pounds 11 ounces, while having a 

length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed 

of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 

pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11.8 

inches, and a maximum speed of approximately 42 knots. The DJI Phantom 3 and 

DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer 

battery powered electric motors. 

The DJI Phantom 3 and DJI Inspire 1 UAs that will be operated by William G 

Dodd 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, William G Dodd, 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, DJI 

Inspire 1 UASs 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, William G Dodd’s operation of DJI 

Phantom 3 and DJI Inspire 1 UASs 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, William G Dodd 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. 

William G Dodd submits that the requested relief is proper since an equivalent 

level of safety will be ensured. William G Dodd 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 Phantom 3 and DJI Inspire 1 

Instruction Manual). Furthermore, William G Dodd will document and maintain all 

maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs. 

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

privileges and limitations: Pilot in command, is requested by William G Dodd to 

the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or 

higher level certificate, as well as an airman medical certificate, and who has 

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

the PIC is able to safely operate the DJI Phantom 3 and DJI Inspire 1 UASs in a 
manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles 

and structures. 

William G Dodd seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 3 and DJI Inspire 1 UASs do not require 

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

such, 

William G Dodd submits that he will ensure that the DJI Phantom 3 and DJI 

Inspire 1UASs are in an airworthy condition, prior to every flight, by determining 

that the UASs are in compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual), and 

that the aircraft are in a condition for safe flight. 

William G Dodd also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3 and DJI Inspire 1 UAs will not 

have a typical barometric altimeter onboard. However, altitude information of the 

DJI Phantom 3 and DJI Inspire 1UAs 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 William G Dodd’s operation of the 

DJI Phantom 3 and DJI Inspire 1 UASs within visual line of sight, at or below 400 

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

Additionally, William G Dodd seeks an exemption from the requirements of 

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

G Dodd submits that safety will not be affected by operation of the DJI Phantom 3 

and DJI Inspire 1 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 13.5 minutes to the first point of intended landing and, 

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

In accordance with 14 C.F.R. § 11.81, William G Dodd 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: 
William G Dodd 

d.b.a eyeDyllic Photography

7225 Blakeley Forest Blvd

Spanish Fort, Alabama 36527

251-228-0169

email: bill.dodd@eyedyllic.com 

B. The Specific Sections Of 14 C.F.R. From Which William G Dodd Seeks 

Exemption. 

1. William G Dodd 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. William G Dodd 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. William G Dodd 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. 

4. William G Dodd 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. William G Dodd 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. William G Dodd 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. William G Dodd 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. 

8. William G Dodd 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. 

C. The Extent Of Relief William G Dodd Seeks And The Reason William G 

Dodd Seeks The Relief. 

1. Extent Of Relief William G Dodd Seeks And The Reason William G Dodd 

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, William G Dodd submits that an equivalent level of 

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

Phantom 3 UAS or DJI Inspire 1 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 3 or DJI Inspire 1 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, William G Dodd submits that all flights of the DJI Phantom 3 

and DJI Inspire 1 UASs, conducted by the PIC pursuant to the grant of this 

Petition: (1) 

will be incidental to William G Dodd’s business; and (2) will not carry passengers 

or 

property for compensation or hire. 

2. Extent Of Relief William G Dodd Seeks And The Reason William G Dodd 

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 William G Dodd to determine that the DJI Phantom 3 

and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring 

that the UAS is in compliance with the operating documents (i.e., the William G 

Dodd Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 

and DJI Inspire 1 Instruction Manual). 
William G Dodd seeks the requested relief because the DJI Phantom 3 

and DJI Inspire 1 UASs do not require an airworthiness certificate in accordance 

with 14 

C.F.R. Part 21, Subpart H. Therefore, William G Dodd will ensure that the DJI 

Phantom 3 and DJI Inspire 1 UASs are in airworthy condition based upon its 

compliance 

with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 

and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine 

that 

the aircraft are in condition for safe flight, as stated in the conditions and 

limitations 

below. 

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

flight operations of the DJI Phantom 3 and DJI Inspire 1 UASs, 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), William G Dodd seeks the requested relief because the DJI 

Phantom 3 and DJI Inspire 1 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 

3. Extent Of Relief William G Dodd Seeks And The Reason William G Dodd 

Seeks Relief From Section 91.121. 

be maintained since the DJI Phantom 3 and DJI Inspire 1 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 William G Dodd Seeks And The Reason William G Dodd 

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 and DJI Inspire 1 UAs during daylight hours in visual 

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

duration of 13.5 minutes to the first point of intended landing and, assuming 

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

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

the flight time duration of the battery powered DJI Phantom 3 and DJI Inspire 1 

UAs will severely constrain the practicality of any aerial video or still photo flight 

operations that William G Dodd proposes to conduct pursuant to this Petition. 

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

and DJI Inspire 1 UASs, the DJI Phantom 3 and DJI Inspire 1 operating 

documents, and William G Dodd’s proposed operating limitations, ensure that 

William G Dodd will safely operate the battery powered DJI Phantom 3 and DJI 

Inspire 

1 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 13.5 

minutes 

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

after that 

for at least 4.5 minutes. 

5. Extent Of Relief William G Dodd Seeks And The Reason William G Dodd 

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, William G Dodd 

requests relief from these Sections because the DJI Phantom 3 and DJI Inspire 1 

UASs do not require airworthiness certificates. As set forth more fully below, the 

DJI Phantom 3 and DJI Inspire 1 UASs meet the conditions of FMRA Section 333 

for operation without an airworthiness certificate. Accordingly, William G Dodd 

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

maintenance on the UASs using the methods, techniques, and practices prescribed 
in the UAS operating documents (i.e., the William G Dodd Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 

Instruction Manual). Furthermore, William G Dodd will document and maintain all 

maintenance records for the DJI Phantom 3 and DJI Inspire 1 UASs. 

D. The Reasons Why Granting William G Dodd 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 William G 

Dodd 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 and DJI Inspire 1 UASs will decrease 

congestion of the NAS, reduce pollution, and provide significant benefits to the 

economy. Notably, the benefits of William G Dodd’s proposed operation of the DJI 

Phantom 3 and DJI Inspire 1 UASs will be realized without implicating any 

privacy issues. 

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

The DJI Phantom 3 and DJI Inspire 1 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 amount of manned aircraft needed to 

perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 3 or 

DJI 

Inspire 1 UAS would reduce the amount of manned aircraft in the NAS, reduce 

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

and on the ground. 

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

congestion around airports caused by arriving and departing aircraft will be 

reduced. The 

DJI Phantom 3 and DJI Inspire 1 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 3 and DJI Inspire 1 UASs. 

Conducting aerial acquisitions with the DJI Phantom 3 and DJI Inspire 1 UASs, 

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 and DJI Inspire 1 UASs 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 and DJI Inspire 1 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 3 and DJI Inspire 1 UASs 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 and DJI Inspire 1 UAs 

(weighing 

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their 

maximum gross weights with lengths of 16 inches and 17.3 inches respectively, 

widths of 

16 inches and 17.7 inches respectively, 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 3 and DJI Inspire 1 UASs Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 3 and DJI Inspire 1 UASs 

are also an economical alternative to using manned aircraft to conduct similar 

aerial operations. As such, operation of the DJI Phantom 3 and DJI Inspire 1 UASs 

will allow United States based companies, like William G Dodd, to remain 

competitive and contribute to growth of the U.S. economy. Specifically, with the 

rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) 

regulatory actions phasing out leaded aviation fuels, U.S. owned and operated 

companies must adopt new and alternative technology in order to remain 

competitive. Operating the battery powered DJI Phantom 3 and DJI Inspire 1 

UASs 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 and DJI Inspire 1 UASs, companies such as 

William G Dodd, 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 3 and DJI Inspire 1 UASs, 

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, William G Dodd’s proposed operation of the DJI Phantom 3 and DJI 

Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI 

Phantom 3 and DJI Inspire 1 UASs will be operated only in compliance with 

operating documents (i.e., the William G Dodd Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 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. 

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 William G Dodd Seeks 

Exemption. 

1. Reasons Why The DJI Phantom 3 and DJI Inspire 1 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, William G Dodd’s operation of the 

DJI Phantom 3 and DJI Inspire 1 UASs 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. 

(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, William G Dodd submits that the DJI Phantom 3 and 

DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA 

Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 3 and 

DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific 

operating 

limitations. 

a. The Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs 

Demonstrate Its Safe Characteristics. 

The DJI Phantom 3 and DJI Inspire 1 UASs do not create a hazard to 

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

considering 

its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 3 and DJI Inspire 1 UASs. 

The technical specifications of the DJI Phantom 3 and DJI Inspire 1 

UASs are set forth by the DJI Phantom 3 and DJI Inspire 1 Specifications and 

Data Sheet, attached hereto as Exhibit A and B. 

ii. The DJI Phantom 3 and DJI Inspire 1 UASs Autonomous Flight And 

Navigation Modes Enable The UASs To Remain Within A Defined 

Operational Area. 

 

The DJI Phantom 3 and DJI Inspire 1 UASs may be operated in both 

manual and fully autonomous flight modes. A complete description of the flight 

and 

navigational modes of the DJI Phantom 3 and DJI Inspire 1 UASs is provided at 
pages 25-35 of the DJI Phantom 3 and pages 12-16 and 45-50 of the DJI Inspire 

1 User Manuals, attached hereto as Exhibit C and D. 

iii. The DJI Phantom 3 and DJI Inspire 1 UASs 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 3 and DJI Inspire 1 UAs will 

remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI 

Phantom 3 and DJI Inspire 1 UAs do not reacquire control link data from the GCS, 

the UAs will assume that the Control Link is lost and the UAs will return to the 

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

position and shutdown. 

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

forth at pages 27 through 29 and for the DJI Inspire 1 at pages 13 through 15 of the 

DJI Phantom 3 and DJI Inspire 1 User Manuals, attached hereto as Exhibit C and 

D. 

iv. The DJI Phantom 3 and DJI Inspire 1 GCS And Its Operation. 

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

and DJI Inspire 1 GCS and flight control software is provided at pages 32 

through 43 of the DJI Phantom 3 User Manual and pages 40 through 47 of the 

DJI Inspire 1 User Manual. DJI Phantom 3 and DJI Inspire 1 User Manuals are 

attached hereto as Exhibits C and D. 

b. Flight Operations Of DJI Phantom 3 and DJI Inspire 1 UASs Are Limited 

To The Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

William G Dodd will only utilize certificated pilots who possess a current and 

 

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

Phantom 3 and DJI Inspire 1 UASs. Additionally, a safety observer will assist all 

pilots during flight time. 
c. Flights Of DJI Phantom 3 and DJI Inspire 1 UASs Will Be Conducted 

Pursuant To Specific Operating Limitations. 

In seeking this exemption, William G Dodd proposes to commercially operate 

DJI Phantom 3 and DJI Inspire 1 UASs for the special purpose of conducting 

aerial video and photography over certain areas of United States, pursuant to the 

following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following 

aircraft described in the operating documents, rotorcraft UASs weighing less than 

55 pounds maximum gross weight: DJI Phantom 3 and DJI Inspire 1 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 500 feet above ground 

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

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

ATC must be in feet AGL. 

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

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

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

certificate. 

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

permitted. 

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

satisfy the VLOS requirement as long as the PIC always maintains VLOS 

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

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

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

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

functions prescribed in the operating documents. 
8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and is 

not permitted to operate the camera or other instruments. 

 

9. The operating documents and the grant of exemption must be accessible during 

UAS operations and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations contained in the grant of 

exemption and the procedures outlined in the operating documents, the conditions 

and limitations contained in the grant of exemption take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its 

operating documents. The operator may update or revise its operating documents. 

It is the operator’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. The operator must also 

present updated and revised documents if it petitions for extension or amendment 

to the grant of exemption. If the operator determines that any update or revision 

would affect the basis upon which the FAA granted the exemption, then the 

operator must petition for amendment to its grant of exemption. The FAA’s UAS 

Integration Office (AFS-80) may be contacted if questions arise regarding updates 

or revisions to the operating documents. 

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

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

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

maintenance has been performed and the UAS is found to be in a condition for safe 

flight. The Ground Control Station must be included in the preflight inspection. All 

maintenance and alterations must be properly documented in the aircraft records. 

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

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

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

flight must make an entry in the aircraft records. 

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

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

relevant sections of the operating documents. 

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

maintenance, overhaul, replacement, inspection, and life limit requirements. 
 14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

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

must be noted in the aircraft records, including total time in service, 

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

returning the UAS to service. 

 15. Each UASs operated under this exemption must comply with all 

manufacturer Safety Bulletins. 

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

corrective action taken against discrepancies discovered between 

inspections. 

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

third- class medical certificate. 

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

 

operator’s qualification criteria and demonstrates the ability to safely operate the 

UAS in a manner consistent with how the UAS will be operated under the 

exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 

61.51(b). Flights for the purposes of training the operator’s PICs are permitted 

under the terms of the exemption. However, training operations may only be 

conducted during dedicated training sessions. During training, proficiency, and 

experience-building flights, all persons not essential for flight operations are 

considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

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

§ 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. 

 20. 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. 

 21. 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. 

 22. If the UA loses communications or loses its GPS signal, it must return to a 

pre- determined location within the planned operating area and land or be 

recovered in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

 24. The PIC is prohibited from beginning a flight unless (considering wind and 

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining. 

 25. The operator must obtain an Air Traffic Organization (ATO) issued 

Certificate of Waiver or Authorization (COA) prior to conducting any 

operations under the grant of exemption. This COA will also require the 

operator to request a Notice to Airman (NOTAM) not more than 72 hours in 

advance, but not less than 48 hours prior to the operation. All operations 

shall be conducted in accordance with airspace requirements in the ATO 

issued COA including class of airspace, altitude level and potential 
transponder requirements. 

26. All aircraft operated in accordance with the exemption must be identified by 

serial number, registered in accordance with 14 C.F.R. part 47, and have 

identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart 

C. Markings must be as large as practicable. 

 27. Before conducting operations, the radio frequency spectrum used for 

operation and control of the UA must comply with the Federal 

Communications Commission (FCC) or other appropriate government 

oversight agency requirements. 

 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be 

available to the PIC at the Ground Control Station of the UAS any time the 

UAS is operating. These documents must be made available to the 

Administrator or any law enforcement official upon request. 

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

operations and activities at all times. 

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

vehicle. 

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

nonparticipating persons (persons other than the PIC, SO, operator trainees 

or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

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

must ensure that nonparticipating persons remain under such protection. If a 

situation arises where nonparticipating persons leave such protection and are 

within 500 feet of the UA, flight operations must cease immediately and/or; 

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

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

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

closer to those objects and determined that it does not present an undue 
hazard, and; 

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

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

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

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

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted. 

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

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

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

Accidents must be reported to the National Transportation Safety Board (NTSB) 

per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety. 

William G Dodd submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate 

 

the DJI Phantom 3 and DJI Inspire 1 UASs unless that PIC has demonstrated, by 

meeting minimum flight-hour and currency requirements, that the PIC is able to 

safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner consistent with 

the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Considering William G Dodd’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 3 or DJI Inspire 1 UAS, William G Dodd submits that the additional 

manned airmanship experience of a commercially certificated pilot would not 

correlate to the airmanship skills necessary for William G Dodd’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). 
William G Dodd will not allow any PIC to operate the DJI Phantom 3 or DJI 

Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 3 or DJI Inspire 1 UAS training and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 3 or DJI 

Inspire 1 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

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

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

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

model of UAS to be used for operations under the exemption). In addition to the 

hour 

requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 

days (for currency purposes). 

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

experience that was obtained in compliance with applicable regulations will ensure 

an 

equivalent level of safety during William G Dodd’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, William G Dodd will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 3 or DJI Inspire 1 UAS unless that PIC has 

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

the PIC 

is able to safely operate the DJI Phantom 3 or DJI Inspire 1 UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

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

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) 

Would Not Adversely Affect Safety. 

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

because prior to every flight, William G Dodd will ensure that the DJI Phantom 3 

or DJI Inspire 1 UAS is in an airworthy condition based upon the UAS’s 

compliance with its operating documents and as stated in the conditions and 

limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

to UAS, in circumstances similar, in all material respects, to those presented herein 

(e.g. 

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 
4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Phantom 3 and DJI Inspire 1 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 William G 

Dodd’s operation of the DJI Phantom 3 and DJI Inspire 1 UAs within visual line of 

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

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

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

automatically established by the UASs at ground level. 

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

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

Exemption 

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

11138, 

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

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

Would Not Adversely Affect Safety. 

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

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

 

Phantom 3 and DJI Inspire 1 UASs; (2) the limitations on the proposed flight 

operations; and (3) the location of the proposed flight operations. Accordingly, 

William G Dodd will ensure that it will safely operate the battery powered DJI 

Phantom 3 and DJI Inspire 1 UAs during daylight hours in VFR conditions, with 

enough battery power to fly for a total duration of 13.5 minutes to the first point of 

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

4.5 minutes. 

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

3 and DJI Inspire 1 UASs; the limitations on the proposed flight operations; and 

the location of the proposed operations, will ensure an equivalent level of safety 
established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as 

the DJI Phantom 3 and DJI Inspire 1 UASs 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 power. At the critically low battery level, the 

DJI Phantom Vision + and DJI Inspire 1 UASs 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). 

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, William G Dodd submits that the William G Dodd 

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 William G Dodd 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 William G Dodd Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 and DJI Inspire 1 Instruction Manual). 

Furthermore, William G Dodd will document and maintain all maintenance records 

for the DJI Phantom 3 and DJI Inspire 1 UASs. 

Since the DJI Phantom 3 and DJI Inspire 1 UASs will be inspected as prescribed 

by the operating documents, William G Dodd will maintain the equivalent level of 

safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of 

the DJI Phantom 3 and DJI Inspire 1 User Manuals are attached hereto as Exhibit 

C and D; a copy of the DJI Phantom 3 and DJI Inspire 1 UAS Maintenance LOG is 

attached hereto as Exhibit E. 
Likewise, the exemption sought will not adversely affect safety because William G 

Dodd 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 and DJI Inspire 1 UASs 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 William G Dodd’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 3 and DJI 

Inspire 1 UASs, William G Dodd submits that safety will not be adversely affected 

by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 

91.409(a) (2), and 91.417(a) and (b). The FAA has previously granted relief 

specific to UAS in circumstances similar, in all material respects, to those 

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 

11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, William G Dodd 

requests that the FAA prescribe special conditions for the intended operation of the 

DJI Phantom 3 and DJI Inspire 1 UASs, 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 3 and DJI Inspire 1 UASs, 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 3 and DJI Inspire 1 UASs, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that 

established 

by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 

91.121, 

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

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

Rules From Which William G Dodd Seeks Exemption: 

William G Dodd 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 William G Dodd Seeks: 
This exemption will permit William G Dodd 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 

William G Dodd’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, William G Dodd’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, William G Dodd will operate the DJI Phantom 3 and 

DJI Inspire 1 UASs 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, William G Dodd 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 and DJI Inspire 1 

UASs 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 William G Dodd to safely, 

efficiently, and economically operate the DJI Phantom 3 and DJI Inspire 1 UASs 

commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, William G Dodd 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 

William G Dodd to operate the DJI Phantom 3 and DJI Inspire 1 UASs 

commercially for the purpose of conducting aerial video and photography over 

certain areas of the United States.

June 17, 2015 

Respectfully submitted, 

William G Dodd 

 

_________________________ 

William G Dodd 

William G Dodd

7225 Blakeley Forest Blvd, Spanish Fort, Alabama 36527 

Appendices: 

A – DJI Phantom 3 Specifications Data Sheet 

B – DJI Inspire 1 Specifications Data Sheet 
APPENDIX – A 

DJI Phantom 3 TECHNICAL SPECIFICATIONS 

William G Dodd only utilizes safe and reliable UASs. DJI is an industry leader in 

small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled 

airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set 

distance. In addition, DJI software provides real-time altitude and location 

information to the PIC via the linked monitor (smart phone/tablet devices) 

1.1 DJI Phantom 3 

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 6000mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) –12802g) 

1.1.1.3 Hover Accuracy (Ready to Fly) – Vertical: .8m; Horizontal: 2.5m 

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

1.1.1.8 Max Flight Speed – 15m/s (NOT RECOMMENDED) 

 . 1.1.2 Gimbal 

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA 1.1.2.2 Control 
Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s 

 . 1.1.3 Camera 

1.1.3.1 Operating Temperature Range - 320F - 1040F (00C - 400C) 

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850 

 . 1.1.4 Transmitter 

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

1.1.4.2 Communication Distance (unobstructed) – FCC Compliance: 800m 

1.1.4.3 Receiver Sensitivity (1%PER) - -93dBm

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V 

 

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m 1.1.5.3 Transmitter 

Power – 20dBm

1.1.5.4 Power Consumption – 2W 
APPENDIX – B 

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS 

William G Dodd only utilizes safe and reliable UASs. DJI is an industry leader in 

small UAS production. DJI UASs are loaded with ground breaking software 

enabling the user to set parameters which will not allow flight into controlled 

airspace. Parameters can also be set to limit flight to no higher than a 

predetermined and set altitude as well as limit flight to a predetermined and set 

distance. In addition, DJI software provides real-time altitude and location 

information to the PIC via the linked monitor (smart phone/tablet devices) 

2.2 DJI Inspire 1 

2.2.1 Aircraft

2.2.1.1 Model – T600

2.2.1.2 Weight (Battery Included) – 6lbs 7.5291oz (2935g)

2.2.1.3 Hovering Accuracy (GPS Mode) – Vertical: 0.5m; Horizontal: 

2.5m

2.2.1.4 Max Angular Velocity – Pitch: 3000/s; Yaw: 1500/s 2.2.1.5 Max Tilt Angle 

- 350

2.2.1.6 Max Ascent Speed – 5m/s

2.2.1.7 Max Descent Speed – 4m/s

2.2.1.8 Max Speed – 22m/s (ATTI mode, no wind – NOT 

RECOMMENDED)

2.2.1.9 Max Flight Altitude – 4500m

2.2.1.10 Max Wind Resistance – 10m/s

2.2.1.11 Max Flight Time – Approximately 18 minutes

2.2.1.12 Motor Model – DJI 3510

2.2.1.13 Propeller Model – DJI 1345

2.2.1.14 Operating Temperature Range – 140F to 1040F (-100C to 

400C)

2.2.1.15 Dimensions – 17 1⁄4” x 17 3⁄4” x 12” 

2.2.2 Gimbal

2.2.2.1 Model – ZENMUSE X3

2.2.2.2 Output Power (with camera) – Static: 9W; In Motion: 11W 2.2.2.3 
Operating Current – Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration 

Range - ±0.030

2.2.2.5 Mounting – Detachable

2.2.2.6 Controllable Range – Pitch: -900 to +300; Pan: ±3200 2.2.2.7 Mechanical 

Range – Pitch: -1250 to 450; Pan: ±3300 2.2.2.8 Max Controllable Speed – Pitch: 

1200/s; Pan: 1800/s 

2.2.3 Camera

2.2.3.1 Name – X3 

2.2.3.2 Model – FC350

2.2.3.3 Total Pixels – 12.76M

2.2.3.4 Effective Pixels – 12.4M

2.2.3.5 Image Max Size – 4000x3000

2.2.3.6 ISO Range – 100-3200

2.2.3.7 Field of View - 940

2.2.3.8 CMOS – Sony EXMOR 1/2.3”

2.2.3.9 HD Video Recording – UHD(4K): 4096x2160p24/25, 

3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; 

HD: 1280x720p24/25/30/48/50/60

2.2.3.10 Operating Temperature Range - 320F - 1040F (00C - 400C) 

2.2.4 Transmitter 2.2.4.1 Name – C1 

2.2.4.2 Operating Frequency – 5.728-5.850GHz; 2.400-2.483GHz 2.2.4.3 

Communicating Distance (unobstructed) – 2000m 2.2.4.4 Output Power – 9W

2.2.4.5 Operating Temperature Range - 140F to 1040F (-100C to 

400C)

2.2.4.6 Battery – 600mAh LiPo 2S