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UNITED STATES OF AMERICA DEPARTMENT 

OF TRANSPORTATION FEDERAL AVIATION 

ADMINISTRATION WASHINGTON, D.C.

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

JAMES J. HARKINS

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, DJI PHANTOM 3, DJI INSPIRE 1 AND 

DJI SPREADING WINGS S900 & S1000+ (W/ A2 FC)

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on Feb 12th, 2016

James J. Harkins

PO Box 2217

Gearhart, OR 97138

Email: jim.deployed@gmail.com
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Table of Contents 

GLOSSARY OF ABBREVIATIONS .............................................................................................3

SUMMARY.....................................................................................................................................4

INTRODUCTION AND INTERESTS OF PETITIONER .............................................................4

BACKGROUND .............................................................................................................................4

BASIS FOR PETITION ..................................................................................................................5

NAME AND ADDRESS OF PETITIONER ...........................................................................6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH JAMES J. HARKINS SEEKS

EXEMPTION...........................................................................................................................7

THE EXTENT OF WHICH JAMES J. HARKINS SEEKS THE RELIEF............................9

THE REASONS WHY GRANTING JAMES J. HARKINS REQUEST WOULD BE IN 

THE PUBLIC INTEREST .....................................................................................................12

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY 

AFFECT SAFETY .................................................................................................................14

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER....................25

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO 

SUPPORT JAMES J. HARKINS’S REQUEST...................................................................25

CONCLUSION..............................................................................................................................26

APPENDICES ...............................................................................................................................27
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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

FC Flight Controller

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

RC Remote Control

Section 333 FAA Modernization & 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
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SUMMARY

JAMES J. HARKINS 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 JAMES J. 

HARKINS, to operate an Unmanned Aircraft System (UAS) for the commercial purpose of 

conducting aerial photography, videography, and cinematography for weddings, real estate,

construction site inspections, special events, film sets, television, public events, 

newsgathering, land, building and agricultural surveying and inspections, aerial data collection

as well as create company photography and videography for promotional videos and training 

for UAS operations over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

JAMES J. HARKINS provides his clients with expertise and knowledge in production 

and cinematography technologies as well provide audio/video solutions to present, produce, 

and educate. JAMES J. HARKINS also provides its clients with the highest quality digital 

equipment for use in their commercial, personal, and non-profit multimedia projects. 

JAMES J. HARKINS is an FAA certified Helicopter Air Transport Pilot and active duty Coast 

Guard Flight Examiner with over 26 years of military rotary-wing aviation experience. 

Additionally, JAMES J. HARKINS is an FAA certified Airframe & Power Plant Mechanic.

JAMES J. HARKINS also has over 3 years of aerial RC recreational/hobby experience. The 

objective of JAMES J. HARKINS’s aerial video and photography operations is to provide

high quality imaging for a variety of promotional, wedding, commercial, public, and 

residential uses, specifically targeting:

 Production and Motion Picture Filming

 Television/Film

 Wedding Videography and Photography

 Real Estate Videography and Photography

 Land, Building, and Construction Surveying

 Increase public knowledge of UAS

 Provide training and promote safe UAS operations for resale of DJI products by 

doing promotional and training videos and flight demonstrations.
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BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI S900 & S1000+ 

UASs

JAMES J. HARKINS seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a 

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

Phantom 2 has a maximum gross weight of approximately 2 pounds 13 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 3 has a maximum gross weight of approximately 3 

pounds, while having a length of 16 inches, width of 16 inches, height of 8 inches, and a 

maximum speed of approximately 31 knots. The DJI Inspire 1 has a maximum gross weight of 6 

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

maximum speed of approximately 42 knots. The DJI S900 has a maximum gross weight of 18 

pounds, a length of approx. 50 inches, width of 50 inches, height of approx. 15 inches, and a 

maximum speed of approximately 42 knots. The DJI S1000+ has a maximum gross weight of 24 

pounds 4 ounces, a length of approx. 53 inches, width of 53 inches, height of approx. 16 inches, 

and a maximum speed of approximately 45 knots.

The DJI Phantom 2, DJI Phantom 3, and DJI Inspire 1UA’s are equipped with four main 

rotors; driven by Lithium Polymer battery powered electric motors.

The DJI S900 UA is equipped with 6 main rotors; driven by Lithium Polymer battery 

powered electric motors.

The DJI S1000+ UA is equipped with 8 main rotors; driven by Lithium Polymer battery 

powered electric motors

BASIS FOR PETITION

Petitioner, JAMES J. HARKINS, 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, DJI Phantom 3, DJI Inspire 1, DJI 

Spreading Wings S900 & S1000+ UAS’s 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, JAMES J. HARKINS’s operation of DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s 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, JAMES J. HARKINS 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.

JAMES J. HARKINS submits that the requested relief is proper since an equivalent level 

of safety will be ensured. JAMES J. HARKINS will perform maintenance, alterations, or 
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preventive maintenance on the UAS’s using the methods, techniques, and practices prescribed in 

the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3, 

DJI Inspire 1, DJI Spreading Wings S900 & S1000+ Instruction Manuals). Furthermore, JAMES 

J. HARKINS will document and maintain all maintenance records for the DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s.

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

privileges and limitations: Pilot in command, is requested by JAMES J. HARKINS 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 flighthour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ UAS’s in a manner consistent 

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

distances from people, vessels, vehicles and structures.

JAMES J. HARKINS seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings 

S900 & S1000+ UAS’s do not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. As such, JAMES J. HARKINS submits that he will ensure that the DJI 

Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ UAS’s 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, DJI Phantom 

3, DJI Inspire 1, DJI Spreading Wings S900 & S1000+ Instruction Manuals), and that the aircraft 

are in a condition for safe flight.

JAMES J. HARKINS also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI Spreading 

Wings S900 & S1000+ UA’s will not have a typical barometric altimeter onboard. However, 

altitude information of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings 

S900 & S1000+ UA’s 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 JAMES J. 

HARKINS’s operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI Spreading 

Wings S900 & S1000+ UAS’s within visual line of sight, at or below 500 feet AGL, will ensure 

a level of safety equivalent to Section 91.121.

Additionally, JAMES J. HARKINS seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. JAMES J. HARKINS submits 

that safety will not be affected by operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, 

DJI Spreading Wings S900 & S1000+ UAs during daylight hours in visual meteorological 

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

duration of approximately 13 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, JAMES J. HARKINS provides the following 

information in support of its petition for exemption:
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A. Name And Address Of The Petitioner:

The name and address of the Petitioner and point of contact is:

JAMES J. HARKINS

PO Box 2217

Gearhart, OR 97138

Email: jim.deployed@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which JAMES J. HARKINS seeks 

Exemption.

1. JAMES J. HARKINS 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. JAMES J. HARKINS 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. JAMES J. HARKINS Seeks Exemption From The Requirements Of Section 

91.121.

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

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of

that aircraft, as the case may be, by reference to an altimeter that is set, when 

operating--

(1) Below 18,000 feet MSL, to--

(i) The current reported altimeter setting of a station along the route and within 

100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this 

section, the current reported altimeter setting of an appropriate available station; 

or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the 

departure airport or an appropriate altimeter setting available before departure.
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4. JAMES J. HARKINS Seeks Exemption From The Requirements Of Section 

91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection

(b), states the following:

(b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to 

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

that for at least 20 minutes.

5. JAMES J. HARKINS Seeks Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: Each 

owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this section, 

have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. JAMES J. HARKINS Seeks Exemption From The Requirements Of Section 

91.407(a)(1) 

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventive

maintenance, rebuilding, or alteration unless--

(1) It has been approved for return to service by a person authorized under §43.7 of

this chapter[.]

7. JAMES J. HARKINS 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
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(2) An inspection for the issuance of an airworthiness certificate in accordance with 

part 21 of this chapter.

8. JAMES J. HARKINS Seeks Exemption From The Requirements Of Sections 

91.417(a) And

91.417(b).

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the

following:

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each 

registered owner or operator shall keep the following records for the periods 

specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records 

of the 100-hour, annual, progressive, and other required or approved 

inspections, as appropriate, for each aircraft (including the airframe) and each 

engine, propeller, rotor, and appliance of an aircraft. The records must include--

(i) A description (or reference to data acceptable to the Administrator) of the 

work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft 

for return to service. 

(2) Records containing the following information:

(i) The total time in service of the airframe, each engine, each propeller, and 

each rotor.

(ii) The current status of life-limited parts of each airframe, engine, propeller, 

rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are 

required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the 

last inspection required by the inspection program under which the aircraft 

and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or safety 

directive number and revision date. If the AD or safety directive involves 

recurring action, the time and date when the next action is required.
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(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 JAMES J. HARKINS Seeks And The Reason JAMES J. 

HARKINS Seeks The Relief.

1. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J. 

HARKINS 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, JAMES J. HARKINS submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s 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 DJI Phantom 2, DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs 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, JAMES J. HARKINS submits that all flights of the DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+UASs, conducted by 
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the PIC pursuant to the grant of this Petition: (1) will be incidental to JAMES J. 

HARKINS’s business; and (2) will not carry passengers or property for compensation or 

hire.

2. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J. 

HARKINS 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 JAMES J. HARKINS to determine that the DJI Phantom 2, DJI Phantom 3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s are in airworthy condition prior 

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

JAMES J. HARKINS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 

2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ Instruction 

Manuals).

JAMES J. HARKINS seeks the requested relief because the DJI Phantom 2, DJI Phantom 

3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s do not require an 

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

HARKINS will ensure that the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UAS’s are in airworthy condition based upon its compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ Instruction Manuals) 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 JAMES J. HARKINS Seeks And The Reason JAMES J. 

HARKINS 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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 

& S1000+ UAS’s, 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), JAMES J. HARKINS seeks the requested relief because the DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s 

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.
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4. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J. 

HARKINS Seeks Relief From Section 91.151(b).

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

requested to the extent required to allow flights of the battery powered DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s during daylight hours 

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

of 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly 

after that for at least 5.5 minutes. JAMES J. HARKINS seeks the requested relief because 

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

DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s 

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

JAMES J. HARKINS proposes to conduct pursuant to this Petition.

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

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s, the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ operating documents, 

and JAMES J. HARKINS’s proposed operating limitations, ensure that JAMES J. HARKINS

will safely operate the battery powered DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UA’s during daylight hours in visual meteorological 

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

duration of 14.5 minutes to the first point of intended landing and, assuming normal cruising 

speed, to fly after that for at least 5.5 minutes.

5. Extent Of Relief JAMES J. HARKINS Seeks And The Reason JAMES J. 

HARKINS 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, JAMES J. HARKINS requests relief from 

these Sections because the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UAS’s do not require airworthiness certificates. As set forth more fully 

below, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & 

S1000+ UAS’s meet the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, JAMES J. HARKINS will perform maintenance, alterations, or 

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

the UAS operating documents (i.e., the JAMES J. HARKINS Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ Instruction Manuals). Furthermore, JAMES J. HARKINS will 

document and maintain all maintenance records for the DJI Phantom 2, DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs.

D. The Reasons Why Granting JAMES J. HARKINS’s Request Would Be In

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

Granting the present Petition will further the public interest by allowing JAMES J. 

HARKINS to utilize his 26 years of military rotary-wing aviation experience to demonstrate, 
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champion and support the safe operation of UAV’s in the national airspace. Additionally, JAMES J. 

HARKINS will showcase the safe, efficient, and economically performance of aerial video and 

photography collection for wedding films, real estate, special events, film sets, and landscape 

over certain areas of the United States.

Furthermore, the use of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UAS’s will decrease congestion of the NAS, reduce pollution, and 

provide significant benefits to the economy. Notably, the benefits of JAMES J. HARKINS’s 

proposed operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UAS’s will be realized without implicating any privacy issues.

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

The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 &

S1000+ UA’s 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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s

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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UA’s 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, 

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s.

Conducting aerial acquisitions with the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ UAS’s, 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, DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS’s 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, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAs, while reducing the 

carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled 

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

By using the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings 

S900 & S1000+ UASs to perform aerial acquisitions, the substantial risk to life and property in 

the air and on the ground, which is usually associated with traditional manned aircraft flight 
14

operations, will be substantially reduced or completely eliminated. Aside from the lack of flight 

crew members located onboard the aircraft, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ UAs (weighing approximately only 2 pounds 11 

ounces to 24 pounds respectively, at their maximum gross weights, with lengths of 16 inches to 

53 inches respectively, widths of 16 inches to 53 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, 

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs Will 

Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ UASs are also an economical alternative to using 

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

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs will allow 

United States based companies, like JAMES J. HARKINS, 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, DJI Phantom 3, DJI Inspire 

1, and DJI Spreading Wings S900 & S1000+ UASs is one such technology that not only allows 

companies greater operational flexibility compared to manned aircraft, but provides such 

flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings 

S900 & S1000+ UASs, companies such as JAMES J. HARKINS, 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, DJI Phantom 3, DJI Inspire 1, and 

DJI Spreading Wings S900 & S1000+ UASs, provides a stable workforce that increases 

consumer spending; improves local, state, and federal tax revenues; and allows companies to 

invest in research and development in order to remain competitive both in the United States and 

abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for 

decades, JAMES J. HARKINS’s proposed operation of the DJI Phantom 2, DJI Phantom 3, 

DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs will not implicate any privacy

issues. Specifically, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UASs will be operated only in compliance with operating documents 

(i.e.,the JAMES J. HARKINS Aerial Operations Manual, Monthly Maintenance Log, and DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

Instruction Manuals) which requires property owner involvement as well as local law 
15

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 JAMES J. HARKINS Seeks Exemption.

1. Reasons Why The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs 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, JAMES J. HARKINS’s operation of the DJI

Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs meet the conditions of FMRA Section 333, and will not require an airworthiness 

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

Section 333 provides authority for a UAS to operate without airworthiness

certification and sets forth requirements for considering whether a UAS will create a hazard

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

FMRA Section 333 states the following, in part:

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

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

 Transportation shall determine if certain unmanned aircraft systems may operate 

 safely in the national airspace system before completion of the plan and

 rulemaking required by section 332 of this Act or the guidance required by section

 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under 

 subsection (a), the Secretary shall determine, at a minimum--

(1) which types of unmanned aircraft systems, if any, as a result of their size, 

 weight, speed, operational capability, proximity to airports and populated

 areas, and operation within visual line of sight do not create a hazard to 

 users of the national airspace system or the public or pose a threat to

 national security; and

(2) whether a certificate of waiver, certificate of authorization, or

 airworthiness certification under section 44704 of title 49, United States

 Code, is required for the operation of unmanned aircraft systems identified

 under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section 

 that certain unmanned aircraft systems may operate safely in the national airspace 
16

 system, the Secretary shall establish requirements for the safe operation of such 

 aircraft systems in the national airspace system.

In seeking this exemption, JAMES J. HARKINS submits that the DJI Phantom 2 and DJI 

Inspire 1UASs can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom , DJI Phantom 3, DJI Inspire 

1, and DJI Spreading Wings S900 & S1000+ UASs; (b) the pilot certification requirement; 

and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and 

DJI Spreading Wings S900 & S1000+ UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 &

S1000+ UASs do not create a hazard to users of the NAS or the public, or otherwise pose a

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

i. Technical Specifications Of The DJI Phantom 2, DJI Phantom 3, DJI

Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs, and DJI A2 FC.

The technical specifications of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and

DJI Spreading Wings S900 & S1000+ UASs are set forth by the DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ Specifications and Data

Sheet, attached hereto as Appendices A, B, C, D, E and F.

ii. The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UASs Autonomous Flight And Navigation Modes Enable The 

UASs To Remain Within A Defined Operational Area.

The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 &

S1000+ UASs may be operated in both manual and fully autonomous flight modes. A

complete description of the flight and navigational modes of the DJI Phantom 2, DJI

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs is provided at

pages 25-35 of the DJI Phantom 2, page 11-14 of the DJI Phantom 3, pages 12-16 and 45-50

of the DJI Inspire 1, and pages 23, 30-31 and 33-37 of the A2 FC (used for the DJI Spreading

Wings S900 & S1000+ UAVs) User Manuals, attached hereto as Appendices G, H, I, J, K

and L.

iii. The DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading

Wings S900 & S1000+ UASs Are Designed For Automatic Return To Home Point Or

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

When the Control Link is lost, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and

DJI Spreading Wings S900 & S1000+ UAs will remain stationary, in flight, for 3 seconds or

more. If, after 3 seconds, the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI

Spreading Wings S900 & S1000+ UAs do not reacquire control link data from the GCS, the

UAs will assume that the Control Link is lost and the UAs will return to the home position
17

(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 UAS are set

forth at pages 27-29, pages 12-14 for the DJI Phantom 3, pages 13-15 for the DJI Inspire 1,

and pages 30-31 of the A2 FC (used for the DJI Spreading Wings S900 & S1000+ UAVs)

User Manuals, attached hereto as Appendices G, H, I, J, K and L.

b. Flight Operations Of DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and

DJI Spreading Wings S900 & S1000+ UASs Are Limited To The Line Of Sight Of A

Certificated PIC With A Safety Observer.

James Harkins currently holds a Helicopter Air Transport license (ATP) and 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, DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+UASs. Additionally, a safety observer will assist all 

pilots during flight time.

c. Flights Of DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading

Wings S900 & S1000+UASs Will Be Conducted Pursuant To Specific Operating

Limitations.

In seeking this exemption, JAMES J. HARKINS proposes to commercially operate 

DJI Phanton 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+

UASs for the special purpose of conducting aerial video and photography over certain 

areas of United States, pursuant to the following specific operating limitations:

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

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

55 pounds maximum gross weight: DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ UASs. 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, photography and cinematography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground 

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

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

ATC must be in feet AGL.

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

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

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

certificate.
18

6. 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.

7. 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.

8. 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.

9. 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. 

10. 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.

11. 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.

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

maintenance, overhaul, replacement, inspection, and life limit requirements.
19

13. 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.

14. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

16. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.

17. 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.

18. 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.

19. 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.

20. 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.
20

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

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 
21

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.

JAMES J. HARKINS 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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ UASs unless that PIC has demonstrated, by meeting 

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

operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI preading

Wings S900 & S1000+ UAS in a manner consistent with the exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. Considering JAMES J. HARKINS’s 

proposed area of operations, and the operating limitations set

forth-above; the parallel nature of private pilot aeronautical knowledge 

requirements to those of commercial pilot requirements (See Exemption 

No.11062); and the airmanship skills necessary to safely operate the DJI Phantom 

2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS, 

JAMES J. HARKINS submits that the additional manned

airmanship experience of a commercially certificated pilot would not correlate to 

the airmanship skills necessary for JAMES J. HARKINS’s specific proposed flight 

operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specific to

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

Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112,

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

JAMES J. HARKINS will not allow any PIC to operate the DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS unless that PIC 
22

has demonstrated, by meeting minimum flight-hour requirements or the DJI Phantom 2,

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UAS training 

and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI 

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

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

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

14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5

hours of those hours as a UAS pilot operating the same make and model of UAS to be used

for operations under the exemption). In addition to the hour requirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

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

that was obtained in compliance with applicable regulations will ensure an equivalent level of

safety during JAMES J. HARKINS’s proposed operations. The Administrator has held that 

prior documented flight experience that was obtained in compliance with applicable 

regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the

purpose of motion picture filming (or similar operations), the PIC must have

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot

with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the PIC

must also have accumulated and logged a minimum of 5 hours as a UAS pilot

operating the same make and model of UAS to be used for operations under the

exemption. For clarification, the FAA considers these minimum hour requirements to

be inclusive rather than additive; i.e. 5 hours make and model time may be included

in the 10 hours of multi-rotor time and the 10 hours may be included in the total 25

hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must

accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

The FAA finds that at a minimum, the flight-hour requirements in Exemption No.

11062 are appropriate to practice and build proficiency in the skills necessary to

safely conduct the petitioner’s proposed operations. The FAA also finds that prior

documented flight experience that was obtained in compliance with applicable

regulations would satisfy this requirement. Training, proficiency, and experience

building flights can also be conducted under the grant of exemption to accomplish the

required flight time. During training, proficiency, and experience-building flights the

PIC is required to operate the UA with appropriate distances in accordance with 14

C.F.R 91.119.

Exemption No. 11138 at page 15.

Accordingly, JAMES J. HARKINS will ensure safe operations by not allowing any 

PIC to operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading 

Wings S900 & S1000+ 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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+
23

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, JAMES J. HARKINS will ensure that the DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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, DJI Phantom 3, DJI Inspire 1, and DJI

Spreading Wings S900 & S1000+ UAs will be provided to the PIC via GPS equipment and a

radio communications telemetry data link, which downlinks from the UA to the GCS for

active monitoring of the flight path and altitude. This altitude information, combined with

JAMES J. HARKINS’s operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and 

DJI Spreading Wings S900 & S1000+ UAs within visual line of sight, at or below 500 feet 

AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will 

be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero

altitude initiation point is automatically established by the UASs at ground level.

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

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

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150,

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

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

Would Not Adversely Affect Safety.

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

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

2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs; (2) the

limitations on the proposed flight operations; and (3) the location of the proposed flight

operations. Accordingly, JAMES J. HARKINS will ensure that it will safely operate the 

battery powered DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings 

S900 & S1000+ UAs during daylight hours in VFR conditions, with enough battery power to 

fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming 
24

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,

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs; the 

limitations on the proposed flight operations; and the location of the proposed operations,

will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b).

Furthermore, safety will be ensured as the DJI Phantom 2 and DJI Inspire 1 UASs provide

audible and visual warnings to the PIC at the GCS when the UAs experiences low battery

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

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

DJI Phantom and DJI Inspire 1 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151

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

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

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

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

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

(e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066,

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

11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would

Not Adversely Affect Safety.

In seeking this exemption, JAMES J. HARKINS 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 JAMES J. HARKINS is a trained A&P licensed mechanic and will perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the operating documents (i.e., the JAMES J. 

HARKINS Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2, DJI 

Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ Instruction Manual). 

Furthermore, JAMES J. HARKINS will document and maintain all maintenance records for 

the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 

UASs.

Since the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings

S900 & S1000+ UASs will be inspected as prescribed by the operating documents, JAMES J. 

HARKINS 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, DJI Phantom 3, DJI Inspire 1, 

and DJI Spreading Wings S900 & S1000+ User Manuals are attached hereto as Appendices 

A, B, C, D, E and F; a copy of the DJI Phantom 2 and DJI Inspire 1 UAS Maintenance LOG 

is attached hereto as Appendix G.

Likewise, the exemption sought will not adversely affect safety because 

JAMES J. HARKINS is a trained A&P licensed mechanic and will perform maintenance, 
25

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, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs

will be performed in accordance with prescribed operating documents. 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 JAMES J. HARKINS’s proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2, DJI Phantom 3, DJI 

Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs, JAMES J. HARKINS 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, JAMES J. HARKINS requests 

that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2, 

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs, which 

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

safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 

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

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

limited purpose of conducting aerial video and photography over certain areas of the United 

States for compensation or hire.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a

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

further, provides the authority for such UAS to operate without airworthiness certification in

accordance with any requirements that must be established for the safe operation of the UAS

in the NAS.

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16, for operation of the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI

Spreading Wings S900 & S1000+ UASs, since the airworthiness regulations of 14 C.F.R.

Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual

design features of the aircraft. Section 21.16, entitled Special Conditions, states the

following:

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

adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller
26

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 JAMES J. HARKINS’ intended operation of the DJI 

Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs, 

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

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R

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

(a)(2), and 91.417(a) & (b).

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

From Which JAMES J. HARKINS Seeks Exemption:

JAMES J. HARKINS 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 JAMES J. HARKINS Seeks:

This exemption will permit JAMES J. HARKINS to commercially operate an Unmanned 

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

cinematography including photo and/or video for television, public events, newsgathering, 

real estate and land surveying over certain areas of the United States. As well as assist 

with company promotional videos and training demonstrations for UAS operations.

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

JAMES J. HARKINS’s Request.

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain

UAS may operate safely in the NAS. As such, JAMES J. HARKINS’s request for exemption 

may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set 

forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will

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

security; and further, provides the authority for such UAS to operate without airworthiness

certification.

As discussed in detail above, JAMES J. HARKINS will operate the DJI Phantom 2, 

DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ 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.
27
28

CONCLUSION

As set forth herein, JAMES J. HARKINS 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, DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs commercially, without an airworthiness certificate, 

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

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

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

advancing the interests of the public, by allowing JAMES J. HARKINS to safely, efficiently, 

and economically operate the DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI 

Spreading Wings S900 & S1000+ UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, JAMES J. HARKINS 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 James Harkins to operate the DJI 

Phantom 2, DJI Phantom 3, DJI Inspire 1, and DJI Spreading Wings S900 & S1000+ UASs 

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

of the United States.

Dated: Feb 12th, 2016

Respectfully submitted,

 

JAMES J. HARKINS

PO Box 2217

Gearhart, OR 97138

jim.deployed@gmail.com
29

Appendices:

A – DJI Phantom 2 Specifications Data Sheet

B – DJI Phantom 3 Specifications Data Sheet 

C – DJI Inspire 1 Specifications Data Sheet

D – DJI S900 Specifications Data Sheet

E – DJI S1000+ Specifications Data Sheet

F – DJI A2 Flight Controller Data Sheet

G – DJI Phantom 2 Manufacturer’s User Manual

H – DJI Phantom 3 Manufacturer’s User Manual

I – DJI Inspire 1 Manufacturer’s User Manual

J – DJI S900 Manufacturer’s User Manual

K – DJI S1000+ Manufacturer’s User Manual

L – DJI A2 FC Manufacturer’s User Manual

M – Monthly Maintenance Log
30

APPENDIX – A

DJI PHANTOM 2 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS 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

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
31
32

APPENDIX – B

DJI PHANTOM 3 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS 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)
33

2.2 DJI Phantom 3
34
35

APPENDIX – C

DJI INSPIRE 1 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS 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)
36

3.3 DJI Inspire 1
37
38
39
40

APPENDIX – D

DJI SPREADING WINGS S900 TECHNICAL SPECIFICATIONS

JAMES J. HARKINS 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)
41
42

APPENDIX – E

DJI SPREADING WINGS S1000+ TECHNICAL SPECIFICATIONS

JAMES J. HARKINS 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)
43
44

APPENDIX – F

DJI A2 FLIGHT CONTROLLER TECHNICAL SPECIFICATIONS

(USED AS THE FC FOR DJI SPREADING WINGS S900 & S1000+)

JAMES J. HARKINS 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)
45
46

APPENDIX – G

DJI Phantom 2 Manufacturer’s User Manual
47

APPENDIX – H

DJI Phantom 3 Manufacturer’s User Manual
48

APPENDIX – I

DJI Inspire 1 Manufacturer’s User Manual
49

APPENDIX – J

DJI Spreading Wings S900 Manufacturer’s User Manual
50

APPENDIX – K

DJI Spreading Wings S1000+ Manufacturer’s User Manual
51

APPENDIX – L

DJI A2 Flight Controller Manufacturer’s User Manual
52

APPENDIX – M

MONTHLY MAINTENANCE LOG

UAS:$

Date Issue

Discovered

Date Issue

Addressed

Issue Description & Maintenance Conducted

Maintenance Performed By:

(Print & Sign)

Software(Updates)

Airframe

Engines

Propellers

Camera (Gimbal)

Landing (Gear)

Vibration(Dampening)

Other: