PETITION OF: 

MIAMI DADE COLLEGE 

Eig-Watson School of Aviation 

Exemption Request Pursuant to 

Section 333 of the FAA Modernization 

and Reform Act of 2012 
INDEX 

I. Introduction 2 

II. Petitioner 3 

III. Proposed Operations 4 

IV. Program Activities 5 

V. Exemption Requested 5 

VI. DJI Phantom 2 UAS Vehicle Description 11 

VII. Airworthiness of DJI Phantom 2 UAS 13 

VIII. Training 13 

IX. Safety 13 

X. Operating Conditions 14 

XI. Pre-Flight Checklist 17 

XII. Post-Flight Checklist 17 

XIII. Public Interest 17 

XIV. Privacy 18 

1 
I. INTRODUCTION 

Miami Dade College (MDC) is an institution of higher education, accredited by the 

Southern Association of Colleges and Schools Commission on Colleges (SACSCOC). The 

MDC operates its flight programs through the Eig-Watson School of Aviation 

(School).Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 

("Reform Act") and 14 C.F.R. Part 11, MDC hereby applies for an exemption from the 

Federal Aviation Regulations (FARs) identified below to allow for the non-hobby 

operation of small unmanned aerial vehicles (UAS) as part of School's flight education 

programs. This exemption is based specifically on information outlined in this 

petition and such information contained in the Phantom 2 UAS Flight Operation 

Manual, and its manufacturer user manual, which includes the specifications of the 

UAS equipment, the Phantom 2 UAS Aircraft Flight Manual, the User Manual, the 

Smart Flight Battery Safety Guidelines, the Quick Start Guide, and Remote Training 

Control Manual. The new remote control unit to be utilized in these operations is 

compatible with the Phantom 2 Vision+, Phantom 2 Vision unite. 

MDC is proposing to offer educational courses that includes UAS ground and flight 

training as continuing education noncredit courses. These non-credit courses 

offerings may be expanded to such UAS, related subjects as aerodynamics, commercial 

uses, safety, and maintenance. 

MDC will further explore the possibility of enhancing their academic program by 

offering various courses in UAS ground and flight training for other commercial /nonmilitary industries to include video/photographic, agricultural, real estate, law 

enforcement/security, engineering, and architectural industries. The intent is to 

develop such educational training courses which would enable MDC to become an 

educational center for providing a formalized training program in UAS subjects, to 

both the public and private sector industries listed above. MDC also intends to deliver 

web-based online courses and deliver instructions in UAS ground and flight training 

to students within and outside the South Florida area. The School has the 

infrastructure to include the physical location of classrooms from its campuses 

serving the Miami-Dade County area, as well as, its academic network to include its 

faculty, adjunct faculties, administration, and the organization as part of its overall 

educational program. 

2 
II. Petitioner 

MDC has been in existence in the South Florida area since its initiation as a 

community college in 1960 and has provided college education while serving the 

community as a higher-level two-year educational institution. MDC has eight 

campuses and twenty-one outreach centers with over 165,000 students, making it the 

largest learning institution in the State of Florida. MDC has been recognized as one of 

the best community college in the United States. The School began in the 1960s and 

has a rich history in delivering aviation flight education to successful graduates who 

have served in both the public and private sector in aviation. The School has trained 

civilian pilots and aviation students by offering them various technical degrees 

in such credit programs as Professional Pilot, Maintenance, Aviation Administration, 

and Air Traffic Control. MDC has also been the forefront of training successful 

candidates that have continued their education in such institutions such as EmbryRiddle Aeronautical University and George T. Baker Maintenance School. MDC 

students have been employed with major airlines throughout the United States, and 

within numerous parts of governmental agencies having oversight over commercial 

aviation in the United States. MDC is dedicated to building a well developed 

educational program and it's visionary aviation and aerospace programs, that fosters 

aviation education in the South Florida area. 

In accordance with 14 C.F.R. 11.81 (a), the MDC the contact information for the 

Petitioner is: 

Thomas Jargiello 

Director 

Miami Dade College 

Eig-Watson School of Aviation 

500 College Terrace 

Homestead, Florida 33030-6009 

Phone# (305) 237-5080 

Fax# (305) 237-5956 

Web: www.mdc.edu 

Email: tjargiel@mdc.edu 

3 
III. Proposed Operations 

MDC is proposing to begin an educational VAS flight instruction program. This 

program will teach students the essential elements of VAS operations from a 

commercial and non-commercial perspective, and the overall aspect of operating 

an VAS within our current airspace. Our initial course would teach the history of VAS 

from its beginning stages of being used in military flight operations, to its transition 

into civilian use. This training will include an analysis of how these operations pertain 

to our National Airspace System (NAS). MDC is presently providing ground training 

under a Part 141 Certificate for its Professional Pilot Technology program. This 

program has been in existence for several years and offers educational accredited 

courses for Private, Instrument and Commercial ratings, all of which meet the 

regulatory standards of a Part 141 approval program. 

MDC proposes to formally develop a VAS training curriculum that meets the academic 

standards established for the all educational courses within our institutional system. 

The present proposal offers a VAS ground training course in Phase 1. The VAS flight 

portion training course will be offered in Phase 2 and would be conducted only upon 

receipt of this requested exemption. The MDC offering of a VAS educational training 

program is based on our current course outline that will meet safety considerations 

and regulatory compliance with our college level of academic standards. We would 

propose that our educational program can serve as a model for others to emulate and 

would serve as an invaluable FAA resource. The training will be conducted under 

strict operating requirements and conditions, to assured that the level of safety is 

maintained at the highest standard in authorizing operation ofUAS vehicles meeting 

FAA Section 333 standards. 

It is a fact that the sales of VAS vehicles has been on the rise and continues to grow 

with numerous different VAS models being offered by a variety of different 

manufacturing companies. The new owners have the accessibility, not only to 

purchase the UAS, without any regulatory constraint, but in most cases the 

manufacturing models do not provide the adequate training and instructions to 

operate such equipment. It is also more alarming that UAS operations, by these new 

owners in our current airspace system, do not have an educational safety training 

program for these new VAS operations. All this suggests that a well established 

educational training curriculum in the safe operation of the VAS in our current 

airspace system is required. MDC's regional educational program in offering VAS 

training would alleviate the current problem that new owners are facing, by offering 

an alternative program through an educational program, monitored and approved by 

the FAA. MDC intends to work under strict safety conditions coinciding with the 

FAA's responsibilities under Section 333 (c) of the Reform Act to establish 

requirements for the safe operation of such aircraft systems in the national airspace 

system. 

4 
IV. Program Activities 

The School's educational program for the use for UAS devices will include the 

following: 

(1) Training sessions during which School faculty will be trained in the 

operational and safety techniques for the use of the School's UAS devices. 

(2) Non-credit courses, addressing familiarization and safety subjects, dealing 

with the operation of UAS devices. These courses would include a ground 

school section and a live flight section. 

(3) These courses will be offered through the MDC School of Continuing Education. 

( 4) Additional non-credit UAS related courses dealing with such subjects as the 

aerodynamic operations of UAS devices, advanced safety principles, 

commercial uses of UAS devices, and maintenance of UAS devices. 

(5) It is the School's intent to further develop this program to include credit 

courses related to UAS subjects, as well as, a college credit certificate program 

dealing with the fundamentals of UAS operations, safety factors, flight 

aerodynamics, and commercial uses ofUAS equipment. 

Exemption Requested 

Miami Dade College requests exemptions from the following regulations: 

14 C.F.R. Part 21: (Aircraft certification requirements) 

14 C.F.R 45.23 (b); ("N" numbers and markings) 

14 C.F.R. 61.113 (a) & (b); (Private pilots operating for hire) 

14 C.F.R. 61.133; 

14 C.F.R. 91.7 (a) & (b); 

14 C.F.R. 91.9 (b); 

14 C.F.R. 91.103 

14 C.F.R. 91.109 (a); 

14 C.F.R. 91.119;14; 

14 C.F.R. 91.121; 

14 C.F.R. 91.151 (a); 

14 C.F.R. 91.203 (a) & (b) 

14 C.F.R. 91.405 (a); 

14 C.F.R 91.407 (a)(1); 

14 C.F.R. 91.409 (a)(2); 

14 C.F.R. 91.417 (a); 

(Commercial pilots as related to above) 

(Civil aircraft airworthiness) 

(Civil aircraft flight manual, marking and placard 

requirements) 

PreFlight Action 

(Dual controls for instruction) 

(Safe altitudes over obstacles) 

(Altimeter setting) 

(Fuel minimum) 

(Maintenance inspections) 

(Maintenance related) 

(Maintenance related) 

(Airworthy certificates) 

(Maintenance record keeping) 

5 
Additional information to support the requested exemption is as follows: 

(a) 14 C.F.R. Part 21, Subpart H. Airworthiness Certificates 14 C.F.R. 91.203 

(a) (1) 

Subpart H, Entitled Airworthiness Certificates, establishes the procedural 

requirements for the issuance of airworthiness certificates as required by FAR 91.203 

(a) (1). Given the size and limited operating area associated with the aircraft to be 

utilized by the Applicant, an exemption from Part 21 Subpart H meets the 

requirements of an equivalent level of safety under Part 11 and Section 333 of the 

Reform Act. The Federal Aviation Act (49 U.S.C. 44701 (f)) and Section 333 of the 

Reform Act both authorize the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed operational 

capability, and proximity to airports and populated areas of the particular UAS. In all 

cases, an analysis of these criteria demonstrates that the UAS operated without an 

airworthiness certificate, in the restricted environment and under the conditions 

proposed will be at least safe, or safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a 

pilot nor passenger, carries no explosive materials or flammable liquid fuels, and 

operates exclusively within a secured and designated area. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by both the 

operator and under the requirements and in compliance with local public safety 

requirements. The FAA will have advance notice of all operations. These safety 

enhancements provide a greater degree of safety to the public and property owners 

than conventional operations conducted with airworthiness certificates issued under 

14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates 

that there is no credible threat to national security posed by the UAS, due to its size, 

speed of operation, location of operation, lack of explosive materials of flammable 

liquid fuels, and inability to carry a substantial external load. 

(b) 14 C.F.R. 4 5.23 (b) Marking ofthe Aircraft 

The regulation requires that Aircraft marks include only the Roman capital letter "N" 

and the registration number is displayed on limited, restricted or light-sport category 

aircraft or experimental or provisionally certificated aircraft, the operator must also 

display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in 

letters no less than 2 inches nor more than 6 inches high, the words "limited," 

"restricted," "light sport", "experimental," or "provisional," as applicable. 

Even though the VAS will have no airworthiness certificate, an exemption may be 

needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which 

6 
the word "Experimental" can be placed. Given the size of the UAS, two-inch lettering 

will be impossible. The word "Experimental" will be placed on the fuselage in 

compliance with 45.29 (f). 

The equivalent level of safety will be provided by having the UAS marked on its 

fuselage as required by 45.29 (f) where the pilot, observer and others working with the 

UAS will see the identification of the UAS as "Experimental." Miami Dade College shall 

mark its UAS on the belly of its fuselage, placing the word "Experimental" and the "N" 

number as required by 14 C.F.R. 45.29 (f) so that the PIC (Pilot in Command) or and 

operator, or anyone assisting with the UAV including spectators will observe the 

markings. The FAA has previously issued exemptions to this regulation through 

Exemptions Nos 8738, 10167, 10167 A and 10700. 

(c)14 C.F.R. 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in 

Command. 

Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot license 

certificate may act as a pilot in command of an aircraft that is carrying passengers or 

property for compensation or hire. MDC may achieve an equivalent level of safety as 

achieved by current Regulations because the applicant's UAS do not carry any pilots or 

passengers nor property. The risks attendant to the operation of UAS is far Jess than 

the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of 

the UAS will have as a minimum a Private Pilot's License along with a current Third 

Class or higher Medical Certificate meeting or exceeding the current safety levels in 

relation to 14 CFR 61.113 (a) & (b). Further, a licensed private pilot will ensure 

regulations and piloting skills are maintained based on the operation of the UAS. 

MDC Full time faculty (s) and Adjunct Faculty(s) assigned to teach these courses will 

be employing person(s) with a minimum of a Private Pilot License to operate UAS, an 

exemption is also sought from 14 CFR 61.113, which restricts private pilot certificate 

holders from flying aircraft for compensation or hire, and which would also require a 

second class medical certificate. Most if not all MDC Full Time/ Adjunct instructors 

possesses Flight Instructor Certificate with current Medical Certificate of a third class 

or higher. 

(d)14 C.F.R. 91.7 (a): Civil Aircraft Airworthiness 

Section 91.7 (a) prohibits and individual from operating a civil aircraft unless it is in 

an airworthy condition. As there is no airworthiness certificate issued for the aircraft, 

should this exemption be granted, no FAA regulatory standard may apply for 

determining airworthiness. Given the size, weight and operational capability of the 

D}l Phantom 2 UAS vehicle, which weighs less than 3 pounds and would be flown at 

25 mph or less, an equivalent level of safety will be achieved by determining 

compliance with MDC in regards to UAS operation. 

7 
(e)14 C.F.R. 91.9 (b); Civil aircraft flight manual, marking and placard 

requirements 

This regulation depicts in Section 91.9 (b) (2) requires that no person may operate a 

U.S. registered civil aircraft (2) for which an Airplane or Rotorcraft Flight Manual is 

not required by 21.5 of this chapter, unless there is available in the aircraft a current 

approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, 

and placards, or any combination thereof. 

As there are no on board pilots or passengers, given the size of the UAS's, this 

regulation is inapplicable. An equivalent level of safety will be achieved by 

maintaining all safety /flight manuals delineating areas of where safety can be defined 

at the Pilot control station. The FAA has previously issued exemptions to this 

regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 

10167 A, 10602, 10700 and 32827. 14 C.F.R. 91.121 regarding altimeter settings is 

inapplicable insofar as my UAS utilizes electronic global positioning systems with a 

barometric sensor. 

(f)14 C.F.R. 91.103 PreFlight Action 

This regulation provides that each pilot in command is require to take certain actions 

before flight to ensure the safety of flight. As FAA approved rotorcraft flight manuals 

will not be provided for the aircraft an exemption will be needed. The PIC will take all 

actions as stated in the FOM (Flight Operating Manuals) in Section 4 under normal 

procedures including but not limited to reviewing weather, flight battery 

requirements, landing and takeoff distances and aircraft performance data before 

initiation of flight. 

(g) 14 C.F.R. 91.109 (a ); Dual controls for instruction 

This regulation section 91.103 provides that no person may operate a civil aircraft 

(except a manned free balloon) that is being used for flight instruction unless that 

aircraft has fully functioning dual controls. UAS aircraft and or remotely piloted 

aircraft by their design do not possess fully functioning dual controls since they are 

unmanned and the control functioning levers are simplified for one operator at a time. 

The flight control system of the DJI Phantom 2 is accomplished through the use of a 

control box that communicates with the aircraft via radio communications. The FAA 

has approved exemptions for flight training without fully functional dual controls for 

a number of aircraft and for flight instruction in experimental aircraft. The DJI 

Phantom 2 would be classified as experimental aircraft meeting the requirements for 

FAA approved exemption. Also, the equivalent level of safety provided by the fact that 

neither a pilot nor passengers will be carried in the aircraft and by the size and speed 

of the aircraft. 

8 
(h) 14 C.F.R. 91.119; Safe altitudes over obstacles 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, 

91.119 (c) limits aircraft flying over areas other than congested areas to an altitude of 

500 feet above the surface, except over open water or sparsely populated areas. In 

those cases, the aircraft may not be operated closer than 500 feet to any person, 

vessel, vehicle, or structure. As it relates to UAS aircraft, specifically the DJI Phantom 

will never be operated at higher than 200 feet AGL, with the exception that in certain 

circumstances where the UAS is used to survey or photograph a structure who height 

exceeds 200 feet AGL, the UAS will not be operated more than 100 feet above the 

highest point on the structure. For the safety of all persons near or around the 

structure, the UAS will be operated under strict security measures where the 

structure and people will not be exposed to operations without their pre-obtained 

consent. 

As it relates to flight operations with aircraft or rotorcraft weighting far more than the 

maximum 55 Lbs, proposed herein and the lack of flammable fuel, any risk associated 

with these operations is far less than those presently presented with conventional 

aircraft operating at or below 500 AGL. In addition to the low altitude operations of 

the UAS will ensure separation between these UAS operations and the operations of 

conventional aircraft that must comply with Section 91.119. In addition, every flight 

will be conducted over land owned or controlled by Miami Dade College unless 

permission is granted by the public or private organization in accordance with Miami 

Dade College policy and its mutual agreements between the parties involved. 

(i) 14 C.P.R. 91.121; Altimeter setting 

This petition requires each person operating an aircraft to maintain cruising altitude 

by reference to an altimeter that is set "to the elevation of the departure airport or an 

appropriate altimeter setting available before departure." As the petition requires a 

person operating an aircraft to maintain cruising altitude or flight level by reference 

to an altimeter that is set to the elevation of the departure airport or barometric 

pressure. As the UAS does not carry or possesses a barometric altimeter, but instead 

a GPS altitude read out, an exemption is required. An equivalent of safety will be 

enhanced pursuant to 14 C.F.R. 91.121 can be accomplished by (1) UAS operated at 

200 AGL or below, (2) within visual line of sight by the PIC (Pilot in Command), (3) 

where the GPS based altitude would indicate real time altitude indication to the PIC 

(Pilot in Command) at a ground based on screen display and ( 4) before each flight, a 

zero altitude initiation point is established for the PIC to verify exact altitude based on 

the accuracy of the on board GPS. 

9 
U) 14 C.F.R. 91.151 (a); Fuel minimum 

This regulation prohibits an individual from beginning "a flight in an airplane 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 (1) During the day, to fly after that for at least 30 minutes; or (2) at night, to fly 

for at least 45 minutes." 

Based on the DJI Phantom 2 UAS of maximum LiPo (Lithium Polymer) battery power 

of maximum 25 minutes, the technological limitations on the UAS battery means that 

no meaningful flight operations can be conducted while still maintaining a 30 minutes 

battery reserve. LiPo flight battery does have a battery level indicator, which 

indicates the percentage of battery power from 25% to 100%. An exemption from the 

fuel requirements of 14 C.F.R. 91.151 (a) is required. 

(k) 14 C.F.R. 91.203 (a) & (b) Maintenance inspections 

This regulation states: 

(a) except as provided in 91.715, no person may operate a civil aircraft unless it 

has the following: 

(1) An appropriate and current airworthiness certificate 

(b) No person may operate a civil aircraft unless the airworthiness certificate 

required by paragraph (a) of this section or a special flight authorization 

issued under 91.715 is displayed at the cabin or cockpit entrance so that it is 

legible to passengers or crew. 

As indicated in Exemption No. 11066, Regulatory Docket No. FAA 2014-0353, the 

original intent of these regulations was to display an aircraft's airworthiness 

certificate and registration documents so they would be easily available to inspectors 

and passengers. Since the DJI Phantom 2 UAS are small in nature, does not carry 

passengers, an equivalent level of safety will be accomplished by following the FAA's 

Memorandum subject "Interpretation regarding whether certain required documents 

may be kept at an unmanned aircraft's control station," dated August 8, 2014. It is 

ultimately decided that UAS documentation for flight will be stored at MDC Eig 

Watson School of Aviation location. 

(I) 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a): 

Section 91.405(a) requires that an aircraft operator or owner "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." Section 91.407 similarly makes 

reference to requirements in Part 43. Section 91.409 (a) (2) requires an annual 

inspection for the issuance of an airworthiness certificate. 

10 
Section 91.417 (a) requires the owner or operator to keep records showing certain 

maintenance work that has been accomplished by certificated mechanics, under Part 

43, or licensed pilots and records of approval of the aircraft for return to service. 

VI. DJI Phantom 2 UAS Vehicle Description: 

DJI Phantom 2 Vision and Drone Quadcopter has a gimbal stabilized 14 MP 

1080p Camera from DJI and is based on the same air frame as the Phantom 2 and 

Phantom 2 Vision. DJI Phantom 2 Vision and Drone Quadcopter weighs less than 3 

pounds, small and compact in size, and with speed limited to 23 mph and its vertical 

ascent limited to 5 to 10 mph. 

It features a 14 MP camera that is stabilized and controlled with an integrated 3-axis 

gimbal. Gimbal stabilization makes the Phantom 2 Vision+ ideal for shooting aerial 

footage and photos. The camera can take 14 MP, Adobe DNG RAW photos, and can 

record video in 1080p Full HD at 30 fps or 720p at 60 fps for creating slow motion 

effects. 

The Phantom 2 Vision has a radio control system often referred to as a transmitter. It 

features a 5,200 mAh battery that can sustain the quadcopter in the air for up to 25 

minutes. The transmitter features a line-of-sight range of up to 2625', depending on 

conditions. 

The camera is controlled via 2.4 GHz WI-Fi using an application available for iOS and 

Android devices. Using the supplied mount, the Phantom 2 can attach to a smartphone 

directly to the controller, giving the ability aside from the remote controller a "heads 

up" display directly from the camera's point-of-view. From the app you will also be 

able to start and stop video recording, take a snapshot and tilt the camera up or 

down. Also included in a 4GB MicroSD that can assist in conducting filming and 

photos. 

As with the other Phantom 2 models, the 5200 mAh battery system is simplified over 

the original version 1 Phantom. The battery slots in, and provides LED indicators on 

outside, tail-end of the aircraft so they can be seen in flight. Charging is also simplified, 

with all of the charging circuitry built into the battery itself. The recharge of the 

battery can be conducted by simply plugging it into the wall with the supplied 

universal AC adapter. 

The Phantom 2 Vision+ includes a Wi-Fi Range extender that will increase the 

wireless range of the smartphone used for FPV camera operation up to nearly 2300' 

feet line-of-sight. The range extender mounts on the transmitter (radio controller) 

along with the smartphone. 

11 
Features: 

Gimbal Stabilized 14 MP HD Camera 

Attitude and GPS Attitude Flight Modes 

Return to Home Failsafe 

Intelligent Orientation Control (IOC) 

DJI Vision iOS and Android App 

Assistant Software 

Slot-In Battery with LED Status Indicators 

Included 5.8 GHz Transmitter 

LED Status Indicator 

Self-Tightening Rotor 

DJI Phantom 2 Specifications: 

General Features 

Ready to Fly, Multifunctional Quad-rotor System 

Customized H3-2D and H3-3D Gimbal Support 

Precision Flight and Stable Hovering 

25min Flight Time & Smart Battery 

Auto Return-to-Home & Landing 

Advanced Power Management 

Intelligent Orientation Control (IOC) 

Easy Battery Replacement 

Self-tightening Propeller 

Video Downlink Support 

CAN-Bus Expansion Module 

Aircraft 

Weight (Battery & Propellers Included) 1000g 

Hover Accuracy (Ready To Fly) Vertical: 0.8m; 

Horizontal: 2.5m 

Max Yaw Angular Velocity 200° js 

Max Tilt Angle 35° 

Max Ascent I Descent Speed 

Ascent: 6mjs; Descent: 2m/s 

Max Flight Speed: 15mjs (Not Recommended) 

Diagonal Length: 350mm 

Flight Time: 25mins 

Take-Off Weight: $l300g 

Operating Temperature: -10°C ~ 50°C 

Supported Battery: DJI Smart Battery 

12 
D}I Smart Battery 

Type: 3S LiPo 

Capacity: 5200mAh, 11.1 V 

Charging Environment Range: 00 to 400 

Discharging Environment Range: -200 to SOD 

2.4GHz Remote Control 

Operating Frequency 

2.4GHz ISM 

Communication Distance (Open Area): 1000m 

Receiver Sensitivity (1 %PER): -97dBm 

Working Current/Voltage: 120 mA@3.7V 

Built-In LiPo Battery Working Current/Capacity: 3.7V, 2000mAh 

V. Airworthiness of the DJI Phantom 2 UAS 

Pursuant to 14 C.F.R Part 21, Subpart H, Airworthiness Certificates and 14 

C.F.R. 91.203 (a) (1), the FAA has indicated that there is no need for an exemption 

needed for this Section, due to the fact that under the Reform Act that the UAS 

selected in the DJI Phantom 2 Vision and Drone Quadcopter, provides an 

adequate level of safety. Such safety features include, the size, the weight and the 

operational capability of the UAS vehicle. The UAS weighs less than 3 pounds and 

would be flown at 23 mph or less, while being flown outside of controlled airspace. 

The UAS does not carry pilots or passengers and no materials and or flammable 

liquid, fuel, and explosive devices are to be carried by this device, as further outlined 

in the MDC operation specifications. 

VI. Training 

The School will mandate that all Instructors and Spotters, utilized in these educational 

programs, complete a mandatory 25 hour training program which will cover safety, 

UAS operations, regulatory issues, and emergency situations. Records will be 

appropriately maintained at the School concerning this training. Additionally, each 

instructor who will act as a pilot in command (PIC) will have a minimum of a private 

pilot rating and each PIC and Spotter, will have completed the following MDC aviation 

courses ATT 1100 Private Pilot Theory, ASC 1550 Aerodynamics, ASC 1610 Engines 

and Structures, and ASC 1210 Meteorology. 

13 
VII. Safety 

The School will develop a safety manual to be issued to all instructors. The safety 

manual will establish all pre-flight and post-flight checklist requirements, as well as, 

operational actions to be followed through the UAS operations. 

VIII. Operating Conditions: 

The DJI Phantom 2 Vision and Drone Quadcopter dimensions are 29 CM X 20 

CM, weighing 1000g. In still air conditions, the maximum air speed is 10 mph to 23 

MPH. The DJI Phantom has 4 motors powered by a 11.1 V, 5200 mAh3 SI Li-Po 

battery. 

Listed below are the MDC operating standards and limitations as proposed for this 

educational program utilizing the DJI Phantom 2 Vision and Drone Quadcopter: 

1. The UAS will weigh less than 3 pounds, including the fully mounted camera. 

UAS will have a maximum operating speed of approximately 23 mph. 

2. UAS flights will be operated within the line of sight of the Pilot in Command 

(PIC) and the visual observer (Spotter) who will maintain horizontal and 

vertical observation at all times. 

3. All UAS operations will occur between the hours of 9 AM and 3 PM. 

4. The maximum flight time for each operational flight will be limited to 20 

minutes from its 25 minutes of its maximum battery power. A reserve of 5 

minutes will ensure the ability to safely terminate the flight without undue 

incident or hazard to persons and or property. 

5. UAS flights will be operated at an altitude of no more than 200 feet above 

ground level (AGL) and no more than 100 feet above an elevated platform. 

6. UAS flights will operate at a lateral distance of no less than 100 feet from 

persons or property in order to avoid any interference with third parties 

during training or demonstration exercises. 

7. UAS flights will be conducted at a maximum lateral distance of 500 feet from 

any inhabited structure, vehicles or vessels. 

8. A minimum crew will consist of a UAS pilot (PIC)(holding a minimum of a 

Private Pilot License along with a Third or higher Class Medical Certificate) and 

a Spotter. The PIC will be required to act and perform as a visual observer and 

14 
8. A minimum crew will consist of a UAS pilot (PIC)(holding a minimum of a 

Private Pilot License along with a Third or higher Class Medical Certificate) and 

a Spotter. The PIC will be required to act and perform as a visual observer and 

maintain horizontal and vertical distance at all times when operating the UAS 

and its additional components to include cameras and or video equipment. 

The crew will also include a Spotter who will assist the PIC in the UAS 

operations. All Spotters will have completed a minimal educational 

requirement of ATT 1100 Private Pilot Theory, ASC 1550 Aerodynamics, ASC 

1610 Engines and Structures, and ASC 1210 Meteorology. 

9. All members of the flight crews for each operation will have been certified as 

educational trainers under the MDC certification program. 

10. A pre-flight briefing and post-flight briefing will be conducted after each UAS 

flight in order to evaluate all necessary information to maintain the highest 

safety of flight operation and that day's operations. 

11. The PIC (Pilot in Command) will obtain and document all persons involved 

with the planned operation and will maintain a ledger of all information for 

the particular type flight, which includes any and all vertical and horizontal 

distance from any persons and or property. 

12. Each UAS flight, regardless of whether it is conducted for training, testing, or 

evaluating the operational capability of the UAS, which includes maintenance, 

will be logged in by the PIC (Pilot in Command) or Spotter in an 

approve MDC UAS logbook. The flight will include the name of its PIC (Pilot in 

Command) and Spotter, pilot license information, date, duration of the flight, 

location, and the type of UAS flight, to include MDC training curriculum, testing 

and or maintenance, if required. 

13. The PIC and Spotter shall maintain communication with the VAS, at all times, 

either by voice, radio, remote control, or through the use of a smart phone or 

text. 

14. If the UAS loses communication with the PIC or Spotter, or loses GPS signal, the 

UAS shall have the capability to return the UAS to a pre-determined location 

away from any airport by a distance not to be less than 5 miles. 

15. All UAS flights will be conducted during the day and under visual flight rules 

and meteorological conditions. 

16. All UAS flights will be conducted at a distance exceeding 5 nautical miles away 

from any airport including towered or non-towered airports, to avoid any type 

of confrontation with arriving or departing aircrafts. 

15 
17. All flight operations will be conducted away from any congested or populated 

areas. 

18. The UAS will be operated and maintained in accordance with the requirements 

of the Manufacturer's Manuals and any manufacturer Safety Bulletins. 

19. Prior to the commencement of operations, all required operational 

permissions and permits will be obtained from state, county or city 

jurisdictions, including local law enforcement, fire or other appropriate 

governmental agencies to include the FAA 

20. A contingency plan will be in effect to safely terminate the UAS flight if there is 

a loss of communication between the PIC (Pilot in Command) or Spotter and 

the UAS. Also, a contingency plan will be put into effect to abort the flight in 

case of an unpredicted obstacle entering the operating airspace of the UAS or if 

an emergency occurs during the UAS flight. 

21. UAS flight operations will be conducted by the PIC (Pilot in Command) and 

Spotter, using the DJI Phantom 2 remote control system. The radio frequency 

spectrum used for the operation and control of the UAS shall be in compliance 

with Federal Communication Commission (FCC) or other acceptable 

governmental agency requirements. 

22. The DJI Phantom 2 has released an upgraded remote control (Models 

NPVt581, NDJ6 and NRC 900) to replace the previous models (PVTS81, DJ6 ad 

RC900). This upgraded remote control system comes with new features, 

including gimbal control dial, built in LiPo (Lithium Polymer) battery, and 

battery level LED indicators. This new remote control system is compatible 

with the Phantom 2 Vision, Phantom 2 Vision and Phantom 2 to operate the DJI 

Phantom 2. This upgraded remote control system will be inspected before any 

UAS flight for damages to the equipment, the control throttles, its locking 

mechanism, its dial buttons, and its battery level indicator lights. 

23. The LiPo (Lithium Polymer) batteries must be charged with a LiPo 

(Lithium Polymer) battery charger. The PIC (Pilot in Command) and Spotter 

will ensure that the batteries are fully charged and they are never overcharged 

before each flight. Both members of the crew will ensure that the battery is 

fully charged they are disconnected from the charger. Batteries will never be 

allowed to be charged below 3V per cell, while only using lithium polymer 

(LiPo) (Lithium Polymer) batteries. 

24. The PIC (Pilot in Command) and Spotter will ensure that when the DJI 

Phantom 2 is stored for an extended amount of time of more than a week, the 

batteries shall be removed from its remote control system and stored in a 

fireproof container for proper storage. 

16 
25. Transportation Security Administration (TSA) security and background checks 

will be completed for all MDC program participants (PIC, Spotters). 

XI. Pre-flight checklist 

Pre-flight checks will be performed by the PIC prior to each flight and at 

predefined intervals as part of the maintenance schedule. 

1. Visual inspections of the airframe; 

2. Visual inspections of the remote control system; 

3. Visual inspections of the four propellers, including attachment; 

4. Verify LiPo battery for level indicator; 

5. Verify GPS and Gimbal acquisition; 

6. Calibrate compass (rapidly switching fully upjdown)(verify LED lights); 

7. Verify remote controller for battery voltage and throttle check; 

8. Assembly of Video/Camera and verify for proper mounting on the airframe; 

9. Plan and up load mission 

10. Visual overall inspection before startup and first flight 

XII. Post flight checklist 

The Post-flight checks will be performed by the PIC after each flight and at 

predefined intervals as part of the maintenance schedule. 

1. Verify shut down procedure of both airframe and remote control system; 

2. Visual inspection of airframe for damages; 

3. Disassembly of LiPo and remote control batteries for proper storage; 

4. Disassembly of the four propellers (inspection for chips, cracks, etc); 

5. Disassembly ofvideojcamera component; 

6. Proper storage of all components in the DJI Phantom 2 enclosed suitcase. 

7. Logging of hours of flight/maintenance discrepancies; 

XIII. Public Interest 

The public interest will be satisfied by granting the MDC and the School this petition 

for exemption. Congress has established a national policy that promotes the early 

integration of UAS into the National Airspace System (NAS) in a controlled and safe 

working environment. This petition offered by MDC and the School promotes the 

highest level of safety by exceeding promulgated minimum safety standards. As an 

institution for higher education, MDC understands the level of collaborative effort in 

working with the FAA by proposing this petition in the public interest of the South 

Florida area. MDC feels we have an obligation to improve public safety by creating 

an educational program designed to teach the fundamentals of UAS flight operations. 

17 
The proposed UAS operations in this petition for exemption will benefit students, 

federat state, and local governments and the aviation industry in the South Florida 

area by allowing MDC to initiate formalize educational training with UAS systems. 

XIV. Privacy 

The MDC and the School will only conduct UAS flight operation over property it owns; 

or which it has received the consent of the owner or the organization in a mutual 

agreement between the parties. MDC will also not record and capture any videos, 

photographs, or images of any third party individuals or their property, unless prior 

permission has been granted to MDC. 

Approved and submitted by: 

(i(b.;)hfi 

Director 

Eig-Watson School of Aviation 

Miami Dade College 

2460 N.W. 66 Ave. Bldg. 701 Suite 204 

Miami, FL 33122 

Ph. (305) 237-5080 

Fax. (305) 237-5956 

www.mdc.edu/aviation 

e-mail: tjargiel@mdc.edu 

18