U.S. Department of Transportation Docket Management System

1200 New Jersey Avenue, SE Washington, D.C. 20590 

Flame4Ensics Consulting and Investigations LLC.

William Tweedy, Owner

BASIS FOR PETITION 

Petitioner, Flame4Ensics Consulting & Investigations 

(hereinafter “Flame4Ensics”), 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+, in the National Airspace System 

(NAS), and for an exemption from the requirements of: 

14 C.F.R §§ 61.113(a) & (b) 14 CFR 45.23(b)

91.7(a),

91.109, 

91.119,

91.121,

91.151,

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

& (b) 
Name and Address of the Petitioner:

The name and address of the Petitioner and Point of Contact 

is: FLAME4ENSICS CONSULTING AND 

INVESTIGATIONS LLC

ATTN: William Tweedy

103 Los Santos Ct.

Vallejo, Ca. 94590-3521

CELL: 707-333-8433

EMAIL: tweedyvfdpio@aol.com 

PREFACE:

The Federal Aviation Act expressly grants the FAA the 

authority to issue exemptions. This statutory authority by its 

terms includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, that includes UAS, from the 

requirement that all civil aircraft must have a current 

airworthiness certificate. 

The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) 

or (b) of this section or any sections 44702 - 44716 of this 

title if the Administrator finds the exemption in the public 

interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 

USC §44704; 14 CFR §91.203 (a) (1). 
Flame4Ensics proposes to use one UAS: one (1) DJI 

PHANTOM 2+ for the following purposes: 

1. Aerial photography and/or videography for public 

and/or private use including real estate, architecture, 

land surveying, engineering and other related 

professional activities. 

2. Aerial photography, videography and/or providing 

live video feed for public and/or private use including 

television, public events, videography and news 

gathering. 

3. Aerial inspection/photography of residential/

commercial structures under contract with the owners or 

local government authority. 

4. Aerial video/photography or providing live video 

feed (so as long as all other parameters are met 

contained herein) to assist with search and rescue 

operations in cases of an emergency or natural disaster 

only when the local authorities or government has 

requested it by contract or donation. 

5. The ability to offer training to persons individually or 

belonging to both private and/or public organizations 

that have interests in the use and application of a UAS 
for the purpose of the safe operation of a UAS to 

enhance the safety of the National Airspace System 

(NAS) as well as for the protection of the persons and 

property. 

UAS is a quadcopter with four rotors and four motors 

and are only capable of vertical take-off and landing. 

These UAS weigh less than 55 pounds including 

payload. The Phantom 2+ can reach a maximum 

airspeed of 36 mph (16 meters/second) in non-GPS 

mode with similarly perfect flight conditions. NOTE: 

Flame4Ensics does not fly the UAS in non-GPS mode 

or anywhere near top speed. It can hover and move 

simultaneously in both the vertical and horizontal plane. 

The DJI Phantom 2+ also equipped with GPS and autoreturn function to the predetermined safe landing area as 

well as allowing reading of magnetic interference that 

can cause loss of GPS signal. 

Flame4Ensics will operate the UAS only in visual line of 

sight and in such a manner as to ensure the UAS will “not 

create a hazard to users of the national airspace system or the 

public.” (Reform Act Section 333 (b)). 

This exemption application is expressly submitted to fulfill 

Congress’ goal in passing Section 333(a) through (c) of the 

Reform Act. This law directs the Secretary of Transportation 

to consider whether certain unmanned aircraft systems may 

operate safely in the national airspace system (NAS) before 

completion of the rule making required under Section 333 of 
the Reform Act. In making this determination, the Secretary 

is required to determine which types of UAS do not create a 

hazard to users of the NAS or the public or pose a threat to 

national security in light of the following: 

• The UAS’s size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and 

populated areas; and

• Operation of the UAS within visual line of sight of the 

operator. 

Reform Act § 333 (a). Secretary determines that such 

vehicles “may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system.” Id. 

§333(c). 

The Federal Aviation Act expressly grants the FAA the 

authority to issue exemptions. This statutory authority by its 

terms includes exempting civil aircraft, as the term is defined 

under §40101 of the Act, that includes UAS, from the 

requirement that all civil aircraft must have a current 

airworthiness certificate. 

The Administrator may grant an exemption from a 

requirement of a regulation prescribed under subsection (a) 

or (b) of this section or any sections 44702 - 
44716 of this title if the Administrator finds the exemption in 

the public interest. 49 U.S.C. §44701(f) See also 49 USC 

§44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). 

RELIEF OVERVIEW:

Given the small size of the UAS involved and the restricted 

sterile environment within which they will operate, the 

applicant falls squarely within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that 

the FAA must, by exemption, allow commercial operations 

of UASs to commence immediately. Also due to the size of 

the UAS and the restricted areas in which the relevant UAS 

will operate, approval of the application presents no national 

security issue. 

Given the clear direction in Section 333 of the Reform Act, 

the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding 

the proposed operations, and the significant public benefit, 

including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with 

allowing UAS for aerial inspections, surveying and 

photography and videography, the grant of the requested 

exemptions is in the public interest. Accordingly, the 

applicant respectfully requests that the FAA grant the 

requested exemption without delay. 

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY:

Flame4Ensics proposes that the exemption requested herein 
apply to civil aircraft that have the characteristics and that 

operate with the limitations listed herein. These limitations 

provide for at least an equivalent or even higher level of 

safety to operations under the current regulatory structure 

because the proposed operations represent a safety 

enhancement to the already safe aerial inspections, surveying 

and photography and videography operations conducted with 

conventional aircraft. 

These limitations and conditions to which Flame4Ensics 

agrees to be bound when conducting commercial operations 

under an FAA issued exemption include: 

1. The UAS will weigh less than 55 lbs.

2. Flights will be operated within visual line of sight of a 

pilot and/or observer.

3. Maximum total flight time for each operational flight will 

be 20 minutes or less. 

Flights will be terminated at 25% battery power reserve 

should that occur prior to the 20 minute limit.

4. Flights will be operated at an altitude of no more than 400 

feet AGL.

5. Minimum crew for each operation will consist of the UAS 

Pilot and the Visual Observer. 

6. The UAS will only operate within a confined sterile 

closed-set area with a set safety perimeter, the boundaries of 

which will be determined by the UAS PIC based on the sitespecific activities and speed of the UAS required for the 
operation, and coordinated with the jurisdictional FAA 

FSDO and local government officials as applicable. 

7. Visual Observer and PIC will at all times be able to 

communicate by voice and/or 2-way hands-free radio or 

wireless communication system.

8. Written and/or oral permission from the relevant property 

holders will be obtained. 

9. If applicable, all required permissions and permits will be 

obtained from territorial, state, county or city jurisdictions, 

including local law enforcements, fire, or other appropriate 

governmental agencies.

10. If the UAS loses communications or loses its GPS signal, 

the UAS will have the capability to return to a predetermined safe location and land safely. 

11. The UAS will have the capability to abort flight in case 

of unpredicted obstacles or emergencies. 

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 as safe, or safer, than a conventional aircraft (fixed wing 

or rotorcraft) operating with an airworthiness certificate 

without the restrictions and conditions proposed. In 

consideration of the speed, weight, size, and limited 

operating area associated with the UAS and its operation, 

Flame4Ensics operation of the DJI Phantom 2+ 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, Flame4Ensics 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. Flame4Ensics submits that the requested relief is 

proper since an equivalent level of safety will be ensured. 

Flame4Ensics will use experienced personnel or technicians 

as needed to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and 

practices prescribed in the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2+ Instruction 
Manuals). Furthermore, Flame4Ensics will document and 

maintain all maintenance records for the DJI Phantom 2+ 

UAS. 

Relief from certain requirements of Section 61.113(a) and 

(b), entitled Private pilot privileges and limitations: Pilot in 

command, is requested by Flame4Ensics the extent necessary 

to allow a Pilot in Command (PIC) to meet or exceed the 

described requirements of operations set by manufacturer, 

and who has demonstrated, that the PIC is able to safely 

operate the DJI Phantom 2+ UAS in a manner consistent 

with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Flame4Ensics relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom 2+ UAS 

does not require an airworthiness certificate in accordance 

with 14 C.F.R. Part 21, Subpart H. As such, Flame4Ensics 

submits that the PIC will ensure that the DJI Phantom 2+ 

UAS is in an airworthy condition, prior to every flight, by 

determining that the UAS are in compliance with the 

operating documents (i.e., Monthly Maintenance Log, DJI 

Phantom 2+ Instruction Manuals), and that the aircraft are in 

a condition for safe flight. 

Flame4Ensics also seeks an exemption from the requirements 

of Section 91.109, titled Flight Instruction. This regulation 

provides that "No person may operate a civil aircraft that is 
being used for flight instruction unless that aircraft has fully 

functioning dual controls." The controls for a UAS do not 

currently have a set of fully functioning dual controls. If a 

UAS pilot is being trained, the pilot performing the training 

would be directly supervising and could take over the 

controls from the pilot in training if the need arose. This 

would be similar to the technique of a "throw-over type" 

control wheel in some fixed wing aircraft. This technique 

meets the intent 91.109 and provides an equivalent level of 

safety. In addition, any training would be performed in a 

designated RC aircraft flying area or similar area with no 

spectators or other people in the area and following all safety 

guidelines to ensure the safety of the pilot, observer and 

trainee(s). 

In addition, Flame4Ensics requests an exemption from the 

requirements of Section 91.119, titled Minimum safe 

altitudes. This regulation provides that over sparsely 

populated areas the aircraft cannot be operated closer than 

500 feet to any person, vessel, vehicle, or structure. Since the 

proposed uses would include flights involving photography, 

videography or survey of persons, vessels, vehicles or 

structures, it would be necessary to operate closer than 500 

feet to the items listed. Operations will only be flown over 

property or persons where permission has been obtained, and 

careful pre-planning has been performed including taking 

weather conditions and wind speeds into account, identifying 

potential obstacles or threats and aggressive use of the visual 
safety observer to maintain safe distances and flight paths. 

Further, UAS aircraft operate at a very slow airspeed, and a 

low mass, and do not need as much space to operate safely, 

as outlined in 91.119. Flame4Ensics asserts that the slower 

speed, smaller mass and careful pre- planning would provide 

an equivalent level of safety. Furthermore, Flame4Ensics can 

place warning signs, barriers and/or structures to sufficiently 

protect nonparticipating person from the UAS or debris in 

the event of an accident. 

Flame4Ensics also seeks an exemption from the requirements 

of Section 91.121, titled Altimeter Settings, as the DJI 

Phantom 2+ will not have a typical barometric altimeter 

onboard. However, altitude information of the DJI Phantom 

2+ will be provided to the PIC via Global Positioning System 

(GPS) equipment and radio communications telemetry data 

link, which downlinks from the UAS to the GCS for active 

monitoring of the flight path. This altitude information, 

combined with Flame4Ensics operation of the DJI Phantom 

2+ UAS within visual line of sight, at or below 400 feet 

AGL, will ensure a level of safety equivalent to Section 

91.121. 

Additionally, Flame4Ensics seeks an exemption from the 

requirements of Section 91.151, entitled Fuel requirements 

for flight in VFR conditions. This regulation provides that no 

person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly to the first point 

of intended landing and to fly after that for at least 30 
minutes, the intention of this paragraph being to provide a 

reasonable reserve of energy to plan for a safe landing should 

there be a delay in landing. Given the close proximity to the 

ground station, the ability for the UAS to land in a very small 

space and the built in energy level monitoring of the UAS 

there is a resulting equivalent level of safety if the flight is 

planned to be completed with 20% battery energy remaining. 

Flame4Ensics requests an exemption to the word "fuel" and 

ask for an equivalent interpretation with the word "energy". 

REASONS FOR RELIEF FROM THE LISTED SECTIONS 

ABOVE:

1. Section 61.113(a) & 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 meet all requirements as 

described in the DJI Phantom 2+ owner’s manual 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, Flame4Ensics submits that an 

equivalent level of safety will be maintained because no PIC 

will be allowed to operate the DJI Phantom 2+ UAS unless 
that PIC has demonstrated that the PIC is able to safely 

operate either the DJI Phantom 2+ 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. 

Furthermore, Flame4Ensics submits that all flights of the DJI 

Phantom 2+ UAS, conducted by the PIC pursuant to the 

grant of this Petition: (1) will be incidental to 

Flame4Ensics’s business; and (2) will not carry passengers or 

property for compensation or hire. 

2. 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft 

airworthiness, is requested to the extent required to allow 

Flame4Ensics to determine that the DJI Phantom 2+ UAS is 

in airworthy condition prior to every flight by ensuring that 

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

the Monthly Maintenance Log, and DJI Inspire 1 and DJI 

Phantom 3 Instruction Manuals). 

Flame4Ensics seeks the requested relief because the DJI 

Phantom 2+ UAS do not require an airworthiness certificate 

in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, 

Flame4Ensics will ensure that the DJI Phantom 2+ UAS are 

in airworthy condition based upon its compliance with the 

operating documents (i.e., the Monthly Maintenance Log, 

DJI Phantom 2+ Instruction Manuals) prior to every flight, 
and further, determine that the UAS are in condition for safe 

flight, as stated in the conditions and limitations below. 

3. 91.121.

Relief from Section 91.121, entitled Altimeter settings, may 

be required to allow flight operations of the DJI Inspire 1 and 

DJI Phantom 3 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), Flame4Ensics seeks the 

requested relief because the DJI Phantom 2+ UAS 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+ 

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 UAS on the heads-up display 

of the GCS. 
4. 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+ UAS 

during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for flights planned 

to be completed with 20% battery energy remaining. 

Flame4Ensics seeks the requested relief because without an 

exemption from Section 91.151(b), the flight time duration of 

the battery powered DJI Phantom 2+ UAS will severely 

constrain the practicality of any aerial video or still photo 

flight operations that Flame4Ensics proposes to conduct 

pursuant to this Petition. Significantly, as set forth below, the 

technical specifications of the DJI Phantom 2+ UAS, the DJI 

Phantom 2+ operating documents, and Flame4Ensics’s 

proposed operating limitations, ensure that Flame4Ensics 

will safely operate the battery powered DJI Phantom 2+ 

UAS during daylight hours in visual meteorological 

conditions (VMC), under visual flight rules (VFR), with 

flights planned to be completed with 20% battery energy 

remaining. 

14 CFR 45.23(b)

Marking of the Aircraft;

Applicable codes of Federal Regulation require aircraft to be 

marked according to certain specifications. Flame4Ensics 

UAS are, by definition, unmanned. They therefore do not 

have a cabin, cockpit or pilot station on which to mark 
certain words or phrases. Further, two inch lettering is 

difficult to place on such small aircraft. The FAA has 

previously issued exemptions to this regulation through 

Exemptions No 10167 and 10700. 

5. 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, Flame4Ensics requests relief from 

these Sections because the DJI Phantom 2+ UAS do not 

require airworthiness certificates. As set forth more fully 

below, the DJI Phantom 2+ UAS meet the conditions of 

FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly 

Flame4Ensics will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the 

UAS using the methods, techniques, and practices prescribed 

in the UAS operating documents (i.e., the Monthly 

Maintenance Log, and DJI Phantom 2+ Instruction 

Manuals). Furthermore, Flame4Ensics will document and 

maintain all maintenance records for the DJI Phantom 2+ 

UAS. 
PUBLIC BENEFIT TO GRANTING RELIEF UNDER 

PETITION:

Granting the present Petition will further the public interest 

by allowing Flame4Ensics to safely, efficiently, and 

economically perform aerial photography, videography, 

surveys and inspections of real estate, construction sites, 

undeveloped natural areas, and other locations where such 

work is appropriate and necessary, in support of Public 

Safety Agencies and other businesses attempts to develop 

and grow their opportunities for commerce. This exemption 

application is expressly submitted to fulfill Congress’ goal in 

passing Section 333(a) through (c) of the Reform Act. This 

law directs the Secretary of Transportation to consider 

whether certain unmanned aircraft systems may operate 

safely in the national airspace system (NAS) before 

completion of the rule making required under Section 332 of 

the Reform Act. In making this determination, the Secretary 

is required to determine which types of UAS do not create a 

hazard to users of the NAS or the public or pose a threat to 

national security in light of the following: 

• The UAS’s size, weight, speed and operational capability;

• Operation of the UAS in close proximity to airports and 

populated areas; and

• Operation of the UAS within visual line of sight of the 

operator.

Reform Act 
§ 333 (a). Lastly, if the Secretary determines that such 

vehicles “may operate safely in the national airspace system, 

the Secretary shall establish requirements for the safe 

operation of such aircraft in the national airspace system.” Id. 

§333(c). 

Given the small size of the UAS involved and the nature of 

their intended use, the applicant falls squarely within that 

zone of safety (an equivalent level of safety) in which 

Congress envisioned that the FAA must, by exemption, allow 

commercial operations of UASs to commence immediately. 

Also due to the size of the UAS and their intended use, 

approval of the application presents no national security 

issue. Given the clear direction in Section 333 of the Reform 

Act, the authority contained in the Federal Aviation Act, as 

amended; the strong equivalent level of safety surrounding 

the proposed operations, and the significant public benefit, 

including enhanced safety, reduction in environmental 

impacts, including reduced emissions associated with 

allowing UASs for aerial photography and videography, the 

grant of the requested exemptions is in the public interest. 

Accordingly, the applicant respectfully requests that the FAA 

grant the requested exemption without delay. 
REASONS FOR PUBLIC BENEFIT:

1. The Public Will Benefit From Decreased Congestion Of 

The NAS.

The DJI Phantom 2+ UAS are battery powered and serve as 

a safe, efficient, and economical alternative to the manned 

aircraft traditionally utilized to obtain aerial imagery. By 

reducing the amount of manned aircraft needed to perform 

such aerial photography and videography, an exemption 

allowing the use of a DJI Phantom 2+ 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+ UAS do not require an airport to takeoff or land. 

Likewise, a reduction of manned aircraft conducting aerial 

video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the 

ground, takeoff, departure, arrival, and landing phases of 

flight operations. 

2. The Public Will Benefit From The Safety And Efficiency 

Of The DJI Phantom 2+ UAS.

Conducting aerial photography and videography with the DJI 

Phantom 2+ UAS, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and 

noise pollution generated during traditional aerial 
photography and videography flight operations. By using 

battery power and electric motors, the DJI Phantom 2+ UAS 

produce no air pollution, and are 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+ UAS, while reducing the carbon 

footprint of aerial photography and videography, also 

eliminate noise pollution, as the UAS are propelled by 

battery powered electric motors, rather than an internal 

combustion engine. 

By using the DJI Phantom 2+ UAS to perform aerial 

photography and videography, the substantial risk to life and 

property in the air and on the ground usually associated with 

traditional manned aircraft flight operations will be 

substantially reduced or completely eliminated. Aside from 

the lack of flight crew members located on-board the aircraft, 

the DJI Phantom 2+ UAS (weighing respectively about 2.8 

pounds with diagonal lengths of about 23 inches and 

carrying no fuel or other combustibles 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 Photography, Videography, Surveys, 

Inspections, and Other Operations With The DJI Phantom 2+ 

UAS Will Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2+ 

UAS are also an economical alternative to using manned 

aircraft to conduct similar aerial operations. As such, 

operation of the DJI Phantom 2+ UAS will allow U.S.-based 

companies, like Flame4Ensics, 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+ 

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+ UAS, companies such as Flame4Ensics can 

remain competitive and profitable, and therefore, provide 

greater job stability to employees and contractors, which will 

ultimately contribute to growth of the U.S. economy. 

Improved financial performance of U.S. companies, through 

commercial use of the DJI Phantom 3 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, Flame4Ensics’s proposed 

operation of the DJI Phantom 2+ UAS will not implicate any 

privacy issues. Specifically, the DJI Phantom 2+ UAS will be 

operated only in compliance with operating documents (i.e., 

the Flame4Ensics Standard Operating Procedures, the 

Monthly Maintenance Log, and DJI Phantom 2+ Instruction 

Manuals) which require 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. 

REASONS WHY GRANTING THE EXEMPTION 

WOULD NOT ADVERSELY EFFECT SAFETY:

Reasons Why The DJI Phantom 2+ UAS Meet The 

Conditions Of The FAA Modernization and Reform Act of 

2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited 

operating area associated with the unmanned aircraft and its 

operation, Flame4Ensics operation of the DJI Phantom 2+ 

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. In seeking this exemption, 

Flame4Ensics submits that the DJI Phantom 2+ UAS can 

operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by the characteristics of the DJI Phantom 2+ 

UAS. Both UAS are designed to hover and/or return to a safe 
home point in the event of loss of the control link with the 

GCS. 

During all flights of either the DJI Phantom 2+ UAS, the PIC 

will be assisted by a visual safety observer to maintain safe 

visual line of sight tracking and control of the UAS. All 

flights will be conducted solely for the purpose of 

performing aerial photography, videography, surveys and 

inspections, not to carry passengers or cargo for hire.

Due to the design of the DJI Phantom 2+ UAS, neither UAS 

is able to exceed the maximum allowed airspeed under prior 

FAA exemptions. The UA may not be flown at an indicated 

airspeed exceeding 35 knots. The UAS does not reach the 55 

pound threshold since it weighs under 10 pounds including 

battery and camera payload. The maximum operating 

altitude is set at 400 feet in the navigation software for both 

UAS and the software provides both a visual and audio 

warning regarding the approaching maximum altitude. 

PERSONAL STATEMENTS AND BACKGROUND:

William Tweedy is operating Flame4Ensics Consulting and 

Investigations a limited liability company operating as 

Flame4Ensics Consulting and Investigations LLC. The 

owner is a retired Public Safety Officer, (Police and Fire) and 

has a great interest in photography, videography and RC 

aircraft. Located in the Northern California, Flame4Ensics 

operates mostly in rural and suburban areas and occasionally 

(if they are lucky) by the beach. 
As a company, Flame4Ensics has commercial liability 

Insurance. I am willing to take additional coursework and 

pay licensure fees to be able to operate their UAS 

commercially. My main focus is safety during flight 

operations, both for myself and others as well as their 

equipment and others’ property. I am very familiar with the 

DJI Operator Manuals for the DJI Phantom 2+ and work 

hard to stay on top of developments in the industry as well as 

how UAS are being used in the community.

I have already met with local police and Fire Departments 

and municipal code inspectors regarding how UAS could be 

valuable in promoting public safety and ensuring compliance 

with local conservation and land use ordinances. Obtaining 

this exemption will be a major step forward in making this 

dream a reality. 

Respectfully submitted, 

William Tweedy

Flame4Ensics Consulting and Investigations LLC.