July 30, 2015

Exemption No. 12227

Regulatory Docket No. FAA-2015-1572

Mr. Russell Hanson

Assistant Professor

Icahn School of Medicine at Mount Sinai

1425 Madison Avenue, Box 1498

New York, NY 10029

Dear Mr. Hanson:

This letter is to inform you that we have granted your request for exemption. It transmits our

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

By letter dated April 26, 2015, you petitioned the Federal Aviation Administration (FAA) for 

an exemption. You requested to operate aerial video, photography, research, film production, 

inspections, and increase of public knowledge.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is a DJI Phantom 2 Vision+.

In accordance with the statutory criteria provided in Section 333 of Public Law 112-95 in 

reference to 49 U.S.C. § 44704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, the Secretary of Transportation 

has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA 
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finds that relief from 14 CFR part 21, Certification procedures for products and parts, 

Subpart H—Airworthiness Certificates, and any associated noise certification and testing 

requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection1. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA-2014-0352), 

11109 to Clayco, Inc. (see Docket No. FAA-2014-0507), 11112 to VDOS Global, LLC (see

Docket No. FAA-2014-0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA-2014-

0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) 

with the specifications described by the petitioner and carrying no passengers or crew, rather 

than a manned aircraft of significantly greater proportions, carrying crew in addition to 

flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this 

exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Mr. Russell Hanson is granted an exemption from 

14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 

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

the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. 

This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Russell Hanson is hereafter referred to as the operator.

 

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. 

Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF 

analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by 

instruments aboard the UA.
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Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 

Vision+ when weighing less than 55 pounds including payload. Proposed operations 

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

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

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

(AGL). Altitude must be reported in feet AGL.

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

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

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

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

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

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

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

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
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operator must also present updated and revised documents if it petitions for extension 

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

or revision would affect the basis upon which the FAA granted this exemption, then 

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

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

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

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

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

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

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

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
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(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

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

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

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

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

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
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23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

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

activities at all times. 

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

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

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 in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

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

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. 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.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

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

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

parts 45, 47, 61, and 91.

This exemption terminates on July 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service

Enclosures
UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

Russell Hanson

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 PHANTOM 2 VISION+ UNMANNED AIRCRAFT 

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on April 26, 2015

Russell Hanson

Assistant Professor

Institute for Genomics and Multiscale Biology

Department of Genetics and Genomic Sciences

Icahn School of Medicine at Mount Sinai

1425 Madison Avenue, Box 1498

14th Floor, Room 14-20B

New York, NY 10029

Email: russellhanson@gmail.com
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) Section 333

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

Russell Hanson 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 Russell Hanson to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, special events, film sets, 

and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Russell Hanson provides his clients with the highest quality digital content for use in their commercial, 

personal, and non-profit multimedia projects. Russell Hanson has established himself as a technological 

innovator in multimedia and is recognized as a provider of quality product. Russell Hanson has over 3.5 years 

recreational/hobby experience in all aspects of aerial video and photography. The objective of Russell Hanson’s

aerial video and photography operations is to provide high quality imaging for a variety of research, 

commercial, public, and residential uses, specifically targeting:

• Aerial event photography 

• Research

• Aerial event filming 

• Film production 

• Aerial location scouting and safety inspection 

• Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision UAS 
Russell Hanson seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI 

Phantom 2 Vision+ is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control 

Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ 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 Phantom 2 Vision+ UA is 

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

The DJI Phantom 2 Vision+ UA that will be operated by Russell Hanson 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, Russell Hanson, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) 

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

Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Phantom 2 

Vision UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R 

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

(b).

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

its operation, Russell Hanson operation of DJI Phantom 2 Vision+ UAS meets the conditions of FMRA Section 

333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, Russell Hanson 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.

Russell Hanson submits that the requested relief is proper since an equivalent level of safety will be ensured. 

Russell Hanson 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 2 Vision+ Instruction Manual). Furthermore, Russell Hanson

will document and maintain all maintenance records for the DJI Phantom 2 Vision+ UAS.

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

Pilot in command, is requested by Russell Hanson 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 2 Vision+ UAS in a manner consistent with this exemption, including evasive and 

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

Russell Hanson seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the DJI Phantom 

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

such, Russell Hanson submits that it will ensure that the DJI Phantom 2 Vision+ UAS 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 2 Vision+ Instruction Manual), and that the aircraft are in a 

condition for safe flight.

Russell Hanson also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as 

the DJI Phantom 2 Vision+ UA will not have a typical barometric altimeter onboard. However, altitude 

information of the DJI Phantom 2 Vision+ UA will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for 
active monitoring of the flight path. This altitude information, combined with Russell Hanson’s operation of the 

DJI Phantom 2 Vision+ UAS within visual line of sight, at or below 500 feet AGL, will ensure a level of safety 

equivalent to Section 91.121.

Additionally, Russell Hanson seeks an exemption from the requirements of Section 91.151(b), entitled Fuel 

requirements for flight in VFR conditions. Russell Hanson submits that safety will not be affected by operation 

of the DJI Phantom 2 Vision+ UA during daylight hours in visual meteorological conditions (VMC) under 

visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 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, Russell Hanson 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:

Russell Hanson

Assistant Professor

Institute for Genomics and Multiscale Biology

Department of Genetics and Genomic Sciences

Icahn School of Medicine at Mount Sinai

1425 Madison Avenue, Box 1498

14th Floor, Room 14-20B

New York, NY 10029

Email: russellhanson@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which Russell Hanson Seeks Exemption.

1. Russell Hanson 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. Russell Hanson 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. Russell Hanson Exemption From The Requirements Of Section 91.121.

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

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(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. Russell Hanson 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. Russell Hanson 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. Russell Hanson 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. Russell Hanson 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. Russell Hanson 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 Russell Hanson Seeks And The Reason Russell Hanson Seeks The Relief.

1. Extent Of Relief Russell Hanson Seeks And The Reason Russell Hanson 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, Russell Hanson submits that an equivalent level of safety will be maintained 

because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS UA unless that PIC has met certain 

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

Phantom 2 Vision+ UAS in a manner consistent with the operations specifications as described in this 

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

people, vessels, vehicles and structures.

Further, Russell Hanson submits that all flights of the DJI Phantom 2 Vision+ UAS, conducted by the PIC 

pursuant to the grant of this Petition: (1) will be incidental to Russell Hanson business; and (2) will not carry 

passengers or property for compensation or hire.

2. Extent Of Relief Russell Hanson Seeks And The Russell Hanson 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 

Russell Hanson to determine that the DJI Phantom 2 Vision+ UAS are in airworthy condition prior to every 

flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual).
Russell Hanson seeks the requested relief because the DJI Phantom 2 Vision+ UAS do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Russell Hanson will 

ensure that the DJI Phantom 2 Vision+ UAS are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ 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.

3. Extent Of Relief Russell Hanson Seeks And The Reason Russell Hanson Seeks Relief From Section 

91.121.

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI 

Phantom 2 Vision+ UAS, which utilize a barometric pressure sensor, GPS equipment, and a radio 

communications telemetry data link to downlink altitude information from the UA to the PIC at the ground 

control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be 

reported to air traffic control (ATC) in feet above ground level (AGL), Russell Hanson seeks the requested 

relief because the DJI Phantom 2 Vision+ UA’s altimeter may be set on the ground to zero feet AGL, rather 

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

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

necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, 

an equivalent level of safety will be maintained since the DJI Phantom 2 Vision+ UAs are equipped with a 

barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure 

setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the 

heads-up display of the GCS.

4. Extent Of Relief Russell Hanson Seeks And The Russell Hanson Relief From Section 91.151(b).

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

required to allow flights of the battery powered DJI Phantom 2 Vision+ UAs during daylight hours in visual 

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

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

duration of the battery powered DJI Phantom 2 Vision+ UA will severely constrain the practicality of any aerial 

video or still photo flight operations that Russell Hanson proposes to conduct pursuant to this Petition.

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

Phantom 2 Vision+ operating documents, and Russell Hanson’s proposed operating limitations, ensure that 

Russell Hanson will safely operate the battery powered DJI Phantom 2 Vision+ UAs during daylight hours in 

visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a 

total duration of 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 Russell Hanson Seeks And The Reason Russell Hanson 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, Russell Hanson requests relief from these Sections because the DJI Phantom 2 

Vision+ UAS does not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 

Vision+ UAS meets the conditions of FMRA Section 333 for operation without an airworthiness certificate. 

Accordingly, Russell Hanson 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 Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+

Instruction Manual). Furthermore, Russell Hanson will document and maintain all maintenance records for the 

DJI Phantom 2 Vision+ UAS.

D. The Reasons Why Granting Russell Hanson 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 Russell Hanson to safely, efficiently, 

and economically perform aerial video and photography of special events, film sets, and landscape over certain 

areas of the United States.

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

and provide significant benefits to the economy. Notably, the benefits of Russell Hanson’s proposed operation 

of the DJI Phantom 2 Vision+ UAS will be realized without implicating any privacy issues.

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

The DJI Phantom 2 Vision+ UA 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 2 Vision+ UAS would 

reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety 

of life and property in the air and on the ground.

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

caused by arriving and departing aircraft will be reduced. The DJI Phantom 2 Vision+ UA do not require an 

airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography 

missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, 

departure, arrival, and landing phases of flight operations.

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

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial 

video and still photography flight operations. By using battery power and electric motors, the DJI Phantom 2 

Vision+ UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin 

class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and 

photography, while burning approximately 20-30 gallons per hour of leaded aviation fuel. The DJI Phantom 2 

Vision+ UA, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the 

UAs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 Vision+ UAS to perform aerial acquisitions, the substantial risk to life and property 

in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will 

be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard 

the aircraft, the DJI Phantom 2 Vision+ UA (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 2 Vision+ UAS Will 

Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ is also an economical alternative to using 

manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 Vision+ UAS will 

allow United States based companies, like Russell Hanson, to remain competitive and contribute to growth of 

the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency 
(“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt 

new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 2 

Vision+ UAS is one such technology that not only allows companies greater operational flexibility compared to

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

By operating the DJI Phantom 2 Vision+ UAS, companies such as Russell Hanson, can remain competitive and 

profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through 

commercial use of the DJI Phantom 2 Vision+ UAS, provides a stable workforce that increases consumer 

spending; improves local, state, and federal tax revenues; and allows companies to invest in research and 

development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

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

proposed operation of the DJI Phantom 2 Vision+ UAS will not implicate any privacy issues. Specifically, the 

DJI Phantom 2 Vision+ UAS will be operated only in compliance with operating documents (i.e., the Russell 

Hanson Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ 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 Russell Hanson Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ UA 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, Russell Hanson operation of the DJI Phantom 2 Vision+ UAS meet the conditions of FMRA 

Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

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

requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise 

pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 days 

after the date of enactment of this Act, the Secretary of Transportation shall determine if certain 

unmanned aircraft systems may operate safely in the national airspace system before completion of the 

plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this 

Act.

(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, Russell Hanson submits that the DJI Phantom 2 Vision+ UAS can operate safely in 

the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 

Vision+ UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.
a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ UAS does not create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specifications Of The DJI Phantom 2 Vision+ UAS.

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

Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And Navigation Modes Enable The UAS 

To Remain Within A Defined Operational Area.

The DJI Phantom 2 Vision+ UAS may be operated in both manual and fully autonomous flight modes. A 

complete description of the flight and navigational modes of the DJI Phantom 2 Vision+ UAS is provided at 

pages 25-35 of the DJI Phantom 2 Vision+ User Manual, attached hereto as Exhibit B.

iii. The DJI Phantom 2 Vision+ UAS Are Designed For Automatic Return To Home Point Or 

Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ UA will remain stationary, in flight, for 3 seconds or 

more. If, after 3 seconds, the DJI Phantom 2 Vision+ UA does not reacquire control link data from the GCS, the 

UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+ UAS are set forth at pages 27 

through 29 of the DJI Phantom 2 Vision+ User Manual, attached hereto as B.

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

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

control software is provided at pages 32 through 43 of the DJI Phantom 2 Vision+ User Manual. DJI Phantom 2 

Vision+ User Manual is attached hereto as Exhibit B.

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

Certificated Pilot in Command With A Safety Observer.

Russell Hanson 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 2 Vision+ UAS. Additionally, a safety observer will assist 

all pilots during flight time.

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

Limitations.

In seeking this exemption, proposes to commercially operate DJI Phantom 2 Vision+ UAS for the special 

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

following specific operating limitations:

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

operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 

Vision+ Unmanned Aircraft System. 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 FAAissued 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.
Russell Hanson submits that the equivalent level of safety established by Section 61.113(a) and (b) will be 

maintained because no PIC will be allowed to operate the DJI Phantom 2 Vision+ UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate 

the DJI Phantom 2 Vision+ UAS in a manner consistent with the exemption, including evasive and emergency 

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

Considering Russell Hanson proposed area of operations, and the operating limitations set forth-above; the 

parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements 

(See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ 

UAS, Russell Hanson submits that the additional manned airmanship experience of a commercially certificated 

pilot would not correlate to the airmanship skills necessary for Russell Hanson 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).

Russell Hanson will not allow any PIC to operate the DJI Phantom 2 Vision+ UAS unless that PIC has 

demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 2 Vision+ UAS training and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ UAS in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 

hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those 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 Russell Hanson

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 experiencebuilding 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, Russell Hanson will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ UAS in a 

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

appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not Adversely Affect 

Safety.

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

Russell Hanson will ensure that the DJI Phantom 2 Vision+ UAS is in an airworthy condition based upon the 

UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 

11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect 

Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information 

of the DJI Phantom 2 Vision+ UA will be provided to the PIC via GPS equipment and a radio communications 

telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and 

altitude. This altitude information, combined with Russell Hanson’s operation of the DJI Phantom 2 Vision+ 

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

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

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

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

material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 

11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

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

Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) 

as a result of (1) the technical specifications of the DJI Phantom 2 Vision+ UAs; (2) the limitations on the 

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

will ensure that it will safely operate the battery powered DJI Phantom 2 Vision+ UA 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 2 Vision+ UAS; the 

limitations on the proposed flight operations; and the location of the proposed operations, will ensure an 

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

DJI Phantom 2 Vision+ UAS provide audible and visual warnings to the PIC at the GCS when the UAs 

experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and 

again at approximately 10% remaining battery power. At the critically low battery level, the DJI Phantom 

Vision+ UAS will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not 

adversely affected when the technical characteristics and operating limitations of the UAS are considered. 

Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, 
including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from 

Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. 

Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

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

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, Russell Hanson submits that the equivalent level of safety with regard to the 

regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Russell Hanson will use trained technicians to 

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

practices prescribed in the operating documents (i.e., the Russell Hanson Aerial Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, Russell Hanson will 

document and maintain all maintenance records for the DJI Phantom 2 Vision+ UAS.

Since the DJI Phantom 2 Vision+ UAS will be inspected as prescribed by the operating documents, Russell 

Hanson will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the DJI Phantom 2 Vision+ User Manuals are attached hereto as Exhibit B; a copy of 

the DJI Phantom 2 Vision+ UAS Maintenance LOG is attached hereto as Exhibit C.

Likewise, the exemption sought will not adversely affect safety because Russell Hanson will use trained 

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

techniques, and practices prescribed by the operating documents.

Furthermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 

91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 Vision+ UAS will be performed by 

trained technicians. 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 Russell Hanson proposed operating limitations, the operating documents, and the technical 

aspects of the DJI Phantom 2 Vision+ UAS, Russell Hanson 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, Russell Hanson requests that the FAA prescribe special conditions for the 

intended operation of the DJI Phantom 2 Vision+ UAS, which contain such safety standards that the 

Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, 

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) 

& (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited 

purpose of conducting aerial video and photography over certain areas of the United States for compensation or 

hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users 

of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS.
Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the 

DJI Phantom 2 Vision+ UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate 

or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, 

entitled Special Conditions, states the following:

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

safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the 

aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. 

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

for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent 

to that established in the regulations.

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

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

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

that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 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).

F. A Summary That Can Be Published In The Federal Register, stating: The Rules From Which Russell 

Hanson Seeks Exemption:

Russell Hanson 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 Russell Hanson Seeks:

This exemption will permit Russell Hanson to commercially operate an Unmanned Aircraft System 

(UAS) for the purpose of conducting aerial video and photography over certain areas of the United 

States.

G. Any Additional Information, Views, Or Arguments Available To Support Russell Hanson 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, 

Russell Hanson 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, Russell Hanson will operate the DJI Phantom 2 Vision+ 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, Russell Hanson seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the 

FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 

Vision+ UAS commercially, without an airworthiness certificate, for the limited purpose of conducting aerial 

video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator 

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

advancing the interests of the public, by allowing Russell Hanson to safely, efficiently, and economically 

operate the DJI Phantom 2 Vision+ UAS commercially within the NAS.

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

Act of 2012, Section 333, Russell Hanson 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 Russell Hanson to operate the DJI 

Phantom 2 Vision+ UAS commercially for the purpose of conducting aerial video and photography over certain 

areas of the United States.

Dated: April 26, 2015

Respectfully submitted,

Russell Hanson

_________________________

Russell Hanson

Assistant Professor

Institute for Genomics and Multiscale Biology

Department of Genetics and Genomic Sciences

Icahn School of Medicine at Mount Sinai

1425 Madison Avenue, Box 1498

14th Floor, Room 14-20B

New York, NY 10029

Email: russellhanson@gmail.com

Appendices:

A – DJI Phantom 2 Vision+ Specifications Data Sheet 

B – DJI Phantom 2 Vision+ Manufacturer’s User Manual 

C – Monthly Maintenance Log

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

Russell Hanson 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 2 Vision+
. 1.1.1 Aircraft 

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery 

1.1.1.2 Weight (Battery & Propellers Included) – 2lbs 11.810oz (1242g) 

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 

1.1.3.5 HD Video Recording – 1080p30 & 720p 

1.1.3.6 Recording Field of View – 110°/85°

. 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 Phantom 2 Vision+ Manufacturer’s User Manual

APPENDIX – C
Russell Hanson

Assistant Professor

Institute for Genomics and Multiscale Biology

Department of Genetics and Genomic Sciences

Icahn School of Medicine at Mount Sinai

1425 Madison Avenue, Box 1498

14th Floor, Room 14-20B

New York, NY 10029

Email: russellhanson@gmail.com