UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

THAYER ENTERTAINMENT

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL 

OPERATION OF DJI PHANTOM 2 VISION+ UNMANNED AIRCRAFT 

SYSTEM

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on May 24, 2015 

Robert Thayer

Thayer Entertainment

25290 Calvert Dr

Greensboro, MD 21639

(443) 253-1716
2

TABLE OF CONTENTS

Page 

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

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

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

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

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

NAME AND ADDRESS OF PETITIONER.............................................................7 

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH THAYER

ENTERTAINMENT SEEKS EXEMPTION.................................................................8 

THE EXTENT OF RELIEF THAYER ENTERTAINMENT SEEKS AND THE 

REASON THAYER ENTERTAINMENT SEEKS THE RELIEF.........................11 

THE REASONS WHY GRANTING THAYER ENTERTAINMENT's REQUEST 

WOULD BE IN THE PUBLIC INTEREST .........................................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..........................................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT THAYER ENTERTAINMENT's REQUEST.........34 

CONCLUSION....................................................................................................................35

APPENDICES........................................................................................37
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

THAYER ENTERTAINMENT 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 THAYER ENTERTAINMENT to operate an Unmanned Aircraft System 

(UAS) for the commercial purpose of conducting aerial video and photography of 

construction sites, real estate, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

THAYER ENTERTAINMENT provides its clients with expertise and knowledge 

in advanced technologies and solutions to increase efficiency, productivity and 

effectiveness. THAYER ENTERTAINMENT is experienced in all aspects of aerial video 

and photography. The objective of THAYER ENTERTAINMENT's aerial video and 

photography operations is to provide low cost, high quality imaging for a variety of 

commercial and residential customers.

BACKGROUND

Unmanned Aircraft System: DJI Phantom 2 Vision+ UAS

THAYER ENTERTAINMENT seeks an exemption to operate a DJI Phantom 

2 Vision+ unmanned aircraft system (UAS) for compensation or hire within the NAS. 

The DJI Phantom 2 Vision+ is a vertical takeoff and landing (VTOL) Unmanned 

Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart 

phone systems. The DJI Phantom 2 Vision+ has a maximum gross weight of 

approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 

inches, height of 8 inches, and a maximum speed of 
5

approximately 29 knots. The DJI Phantom 2 Vision+ UA is equipped with four main 

rotors; driven by Lithium Polymer battery powered electric motors. 

The DJI Phantom 2 Vision+ UA that will be operated by THAYER 

ENTERTAINMENT will be registered in accordance with 49 U.S.C. 44103, Registration 

of Aircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance 

with 14 C.F.R. Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, THAYER ENTERTAINMENT, pursuant to the provisions of the 

Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and 

Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft 

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

Vision+ UAS in the National Airspace System (NAS), and for an exemption from the 

requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 

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

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

with the unmanned aircraft and its operation, THAYER ENTERTAINMENT's

operation of DJI Phantom 2 Vision+ UAS meets the conditions of FMRA Section 333 

and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. 

Part 21, Subpart H. 
6

Accordingly, THAYER ENTERTAINMENT 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 THAYER ENTERTAINMENT submits that the requested relief is proper 

since an equivalent level of safety will be ensured. THAYER ENTERTAINMENT will 

use experienced personnel or technicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed in the operating documents (i.e., the THAYER ENTERTAINMENT Aerial 

Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction 

Manual). Furthermore, THAYER ENTERTAINMENT will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ UAS. 

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

privileges and limitations: Pilot in command, is requested by THAYER 

ENTERTAINMENT to the extent necessary to allow a Pilot in Command (PIC) holding a 

private pilot or higher level certificate, as well as an airman medical certificate, and who 

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

PIC is able to safely operate the DJI Phantom 2 Vision+ UAS in a manner consistent with 

this exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

THAYER ENTERTAINMENT seeks relief from Section 91.7(a), entitled Civil 

aircraft airworthiness, because the DJI Phantom 2 Vision+ UAS do not require an 

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

THAYER ENTERTAINMENT submits that it will ensure that the DJI Phantom 2 
7

Vision+ UAS are in an airworthy condition, prior to every flight, by determining that 

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

ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 Vision+ Instruction Manual), and that the aircraft are in a condition for 

safe flight. 

THAYER ENTERTAINMENT also seeks an exemption from the requirements of 

Section 91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ UA will not 

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

Phantom 2 Vision+ UA will be provided to the PIC via Global Positioning System (GPS) 

equipment and radio communications telemetry data link, which downlinks from the UA to 

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

THAYER ENTERTAINMENT's operation of the DJI Phantom 2 Vision+ UAS within 

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

Section 91.121. 

Additionally, THAYER ENTERTAINMENT seeks an exemption from the 

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

THAYER ENTERTAINMENT submits that safety will not be affected by operation of the 

DJI Phantom 2 Vision+ UA during daylight hours in visual meteorological conditions 

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

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

assuming normal cruising speed, to fly after that for at least 4.5 minutes. 
8

In accordance with 14 C.F.R. § 11.81, THAYER ENTERTAINMENT provides the 

following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

Robert Thayer

D.B.A. THAYER ENTERTAINMENT 

25290 Calvert Dr

Greensboro, MD 21639

Tel: (443) 253-1716

Email: rcthayer@comcast.net

B. The Specific Sections Of 14 C.F.R. From Which THAYER ENTERTAINMENT Seeks 

Exemption. 

1. THAYER ENTERTAINMENT 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. THAYER ENTERTAINMENT 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. 
9

3. THAYER ENTERTAINMENT Seeks Exemption From The 

Requirements Of Section 91.121.

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

part: 

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

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

when operating--

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

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

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. THAYER ENTERTAINMENT 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. THAYER ENTERTAINMENT 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[.] 
10

6. THAYER ENTERTAINMENT 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. THAYER ENTERTAINMENT Seeks Exemption From The 

Requirements Of Sections 91.409(a)(1) And 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had --

(1) An annual inspection in accordance with part 43 of this chapter and has 

been approved for return to service by a person authorized by § 43.7 of this 

chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance 

with part 21 of this chapter. 

8. THAYER ENTERTAINMENT 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--
11

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

the work performed; and 

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

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

aircraft for return to service. 

(2) Records containing the following information: 

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

each rotor. 

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

propeller, rotor, and appliance. 

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

are required to be overhauled on a specified time basis. 

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

last inspection required by the inspection program under which the 

aircraft and its appliances are maintained. 

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

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

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

involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each 

major alteration to the airframe and currently installed engines, rotors, 

propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods 

prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained 

until the work is repeated or superseded by other work or for 1 year after the 

work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained 

and transferred with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of 

this chapter shall be retained until the defects are repaired and the aircraft is 

approved for return to service. 
12

C. The Extent Of Relief THAYER ENTERTAINMENT Seeks And The Reason THAYER

ENTERTAINMENT Seeks The Relief. 

1. Extent Of Relief THAYER ENTERTAINMENT Seeks And The Reason

THAYER ENTERTAINMENT 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, THAYER ENTERTAINMENT submits that an 

equivalent level of safety will be maintained because no PIC will be allowed to operate the

DJI Phantom 2 Vision+ UAS unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 

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

this exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.Further, THAYER 

ENTERTAINMENT submits that all flights of the DJI Phantom 2 Vision+ UAS, 

conducted by the PIC pursuant to the grant of this 
13

Petition: (1) will be incidental to THAYER ENTERTAINMENT's business; and (2) will 

not carry passengers or property for compensation or hire. 

2. Extent Of Relief THAYER ENTERTAINMENT Seeks And The Reason

THAYER ENTERTAINMENT 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 THAYER ENTERTAINMENT to determine that the DJI 

Phantom 2 Vision+ UAS are in airworthy condition prior to every flight by ensuring that 

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

ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 Vision+ Instruction Manual). 

THAYER ENTERTAINMENT seeks the requested relief because the DJI

Phantom 2 Vision+ UAS do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, THAYER ENTERTAINMENT will ensure that the 

DJI Phantom 2 Vision+ UAS is in n airworthy condition based upon its compliance with 

the operating documents (i.e., the THAYER ENTERTAINMENT Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual) 

prior to every flight, and further, determine that the aircraft are in condition for safe flight, 

as stated in the 3. Extconditions and limitations below.ent Of Relief THAYER 

ENTERTAINMENT Seeks And The Reason THAYER 

ENTERTAINMENT Seeks Relief From Section 91.121.

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

flight operations of the DJI Phantom 2 Vision+ UAS, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UA to the PIC at the ground control station (GCS). Since 

the FAA requires that any altitude information concerning UAS operations 
14

be reported to air traffic control (ATC) in feet above ground level (AGL), THAYER 

ENTERTAINMENT seeks the requested relief because the DJI Phantom 2 Vision+ 

UA’s altimeter may be set on the ground to zero feet AGL, rather than the local 

barometric pressure or field altitude, before each flight. 

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Phantom 2 Vision+ UA is equipped with a barometric 

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

pressure setting will be established prior to each flight, and provides the PIC with altitude 

information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief THAYER ENTERTAINMENT Seeks And The Reason

THAYER ENTERTAINMENT 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 Vision+ UA during daylight hours in visual meteorological conditions 

(VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first 

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

4.5 minutes. THAYER ENTERTAINMENT seeks the requested relief because without an 

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

Phantom 2 Vision+ UA will severely constrain the practicality of any aerial video or still 

photo flight operations that THAYER ENTERTAINMENT proposes to conduct pursuant 

to this Petition. 
15

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

Vision+ UAS, the DJI Phantom 2 Vision+ operating documents, and THAYER 

ENTERTAINMENT's proposed operating limitations, ensure that THAYER 

ENTERTAINMENT will safely operate the battery powered DJI Phantom 2 Vision+ 

UAsduring daylight hours in visual meteorological conditions (VMC), under visual flight 

rules (VFR), with enough battery power to fly for a total duration of 13.5 minutes to the 

first point of intended landing and, assuming normal cruising speed, to fly after that for at 

least 4.5 minutes.

5. Extent Of Relief THAYER ENTERTAINMENT Seeks And The Reason

THAYER ENTERTAINMENT 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, THAYER ENTERTAINMENT 

requests relief from these Sections because the DJI Phantom 2 Vision+ 

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

Phantom 2 Vision+ UAS meet the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, THAYER ENTERTAINMENT will use trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs

using the methods, techniques, and practices prescribed in the UAS operating documents 

(i.e., the THAYER ENTERTAINMENT Aerial Operations Manual, Monthly 

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

THAYER ENTERTAINMENT will document and maintain all maintenance records for 

the DJI Phantom 2 Vision+ UAS. 

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

D. The Reasons Why Granting THAYER ENTERTAINMENT's Request Would Be 

In The 
16

Granting the present Petition will further the public interest by allowing THAYER 

ENTERTAINMENT to safely, efficiently, and economically perform aerial video and 

photography of construction sites, real estate, and landscape over certain areas of the 

United States. Additionally, use of the DJI Phantom 2 Vision+ UAS will decrease 

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

Notably, the benefits of THAYER ENTERTAINMENT's proposed operation of the DJI 

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

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

The DJI Phantom 2 Vision+ UA is battery powered and serve as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, 

an exemption allowing the use of a DJI Phantom 2 Vision+ UA would reduce the amount 

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

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

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

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom 2 Vision+ UA does not require an airport to takeoff or land. Likewise, a 

reduction of manned aircraft conducting aerial video and photography missions would 

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

takeoff, departure, arrival, and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI

Phantom 2 Vision+ UAS.
17

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ UAS, instead of 

manned aircraft, will greatly benefit the public by drastically reducing the levels of air and 

noise pollution generated during traditional aerial video and still photography flight 

operations. By using battery power and electric motors, the DJI Phantom 2 Vision+ UAS 

produce no air pollution, and is the most viable environmentally conscious alternative to 

the cabin class, six cylinder internal combustion engine aircraft that are typically utilized 

for aerial video and photography, while burning approximately 20-30 gallons per hour of 

leaded aviation fuel. The DJI Phantom 2 Vision+ UA, while reducing the carbon footprint 

of aerial acquisitions, also eliminates noise pollution, as the UA ispropelled by battery 

powered electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 2 Vision+ a UAS to perform aerial acquisitions, the 

substantial risk to life and property in the air and on the ground, which is usually 

associated with traditional manned aircraft flight operations, will be substantially reduced 

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

aircraft, the DJI Phantom 2 Vision+ UA(weighing approximately 2 pounds 11 ounces , at 

its maximum gross weights with length of 16 inches , width of 16 inches , 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). 
18

3. Performing Aerial Video and Photography Operations With The DJI

Phantom 2 Vision+ UASsWill Benefit The Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ UAS are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As 

such, operation of the DJI Phantom 2 Vision+ aUAS will allow United States based 

companies, like THAYER ENTERTAINMENT, to remain competitive and contribute to 

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the 

Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation 

fuels, U.S. owned and operated companies must adopt new and alternative technology in 

order to remain competitive. Operating the battery powered DJI Phantom 2 Vision+ UAS is 

one such technology that not only allows companies greater operational flexibility 

compared to manned aircraft, but provides such flexibility without the high operational cost 

of a traditional manned aircraft. 

By operating the DJI Phantom 2 Vision+ UAS, companies such as THAYER 

ENTERTAINMENT, can remain competitive and profitable, and therefore, provide 

greater job stability to employees and contractors, which will ultimately contribute to 

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

through commercial use of the DJI Phantom 2 Vision+ UAS, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax revenues; and 

allows companies to invest in research and development in order to remain competitive 

both in the United States and abroad. 

4. There Are No Privacy Issues.

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

decades, THAYER ENTERTAINMENT's proposed operation of the DJI Phantom 2 

Vision+ UAS will not implicate any privacy issues. 
19

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

THAYER ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 

2 Vision+ Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, including the 

minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which THAYER ENTERTAINMENT Seeks 

Exemption. 

1. Reasons Why The DJI Phantom 2 Vision+ UA Meets 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, THAYER ENTERTAINMENT's operation of the 

DJI Phantom 2 Vision+ aUAS meet sthe 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.
20

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

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

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

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

populated areas, and operation within visual line of sight do not create 

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

threat to national security; and

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

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

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

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, THAYER ENTERTAINMENT submits that the DJI Phantom 2 

Vision+UAS can operate safely in the NAS pursuant to FMRA Section 

333, as demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ 

UAS; (b) the pilot certification requirement; and (c) the specific operating 

limitations. 

a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate

Its Safe Characteristics.

The DJI Phantom 2 Vision+ UAS 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 Vision+ UAS.

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

DJI Phantom 2 Vision+ Specifications and Data Sheet, attached hereto as Exhibit A. 
21

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

Navigation Modes Enable The UASs To Remain Within A Defined 

Operational Area.

The DJI Phantom 2 Vision+ UAS may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and navigational modes of 

the DJI Phantom 2 Vision+ UAS is provided at pages 25-35 of the DJI Phantom 2 Vision+ 

and pages 12-16, attached hereto as Exhibit B.

iii. The DJI Phantom 2 Vision+ UAS is Designed For Automatic 

Return To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ UA will remain 

stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 2 Vision+ 

UAs do not reacquire control link data from the GCS, the UA will assume that the Control 

Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and 

will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+

UAS are set forth at pages 27 through 29 of the DJI Phantom 2 Vision + User Manual, 

attached hereto as Exhibit B in a Seperately Attached PDF. 

iv. The DJI Phantom 2 Vision+ GCS And Its

Operation.

A complete description of the operation and specifications of the DJI Phantom 2 

Vision+ GCS and flight control software is provided at pages 32 through 43 of the DJI 

Phantom 2 Vision+ User Manual attached hereto as Exhibits B.
22

b. Flight Operations Of DJI Phantom 2 Vision+ UAS is Limited To The 

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

Observer.

THAYER ENTERTAINMENT will only utilize certificated pilots who possess a 

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

Phantom 2 Vision+ UAS. Additionally, a safety observer will assist all pilots during 

flight time. 

c. Flights Of DJI Phantom 2 Vision+ UAS Will Be Conducted 

Pursuant To Specific Operating Limitations.

In seeking this exemption, THAYER ENTERTAINMENT proposes to 

commercially operate DJI Phantom 2 Vision+UAS for the special purpose of 

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

to the following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less

than 55 pounds maximum gross weight: DJI Phantom 2 Vision+ Unmanned 

Aircraft System. Proposed operations of any other aircraft will require a new 

petition or a petition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations

for the purpose of aerial video and photography.

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

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

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

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

reported to ATC must be in feet AGL.

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

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

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

medical certificate.
23

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

permitted.

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

the VLOS requirement as long as the PIC always maintains VLOS capability.

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

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

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

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

functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing

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

is not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in the grant

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

conditions and limitations contained in the grant of exemption take precedence

and must be followed. Otherwise, the operator must follow the procedures as

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

operating documents. It is the operator’s responsibility to track such revisions

and present updated and revised documents to the Administrator upon request.

The operator must also present updated and revised documents if it petitions for

extension or amendment to the grant of exemption. If the operator determines

that any update or revision would affect the basis upon which the FAA granted

the exemption, then the operator must petition for amendment to its grant of

exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if

questions arise regarding updates or revisions to the operating documents.

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

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

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

necessary maintenance has been performed and the UAS is found to be in a

condition for safe flight. The Ground Control Station must be included in the

preflight inspection. All maintenance and alterations must be properly

documented in the aircraft records.

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

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

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

functional test flight must make an entry in the aircraft records.

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

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

relevant sections of the operating documents.
24

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

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

14. The operator must carry out its maintenance, inspections, and record keeping

requirements, in accordance with the operating documents. Maintenance,

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

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

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

UAS to service.

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

Safety Bulletins.

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

corrective action taken against discrepancies discovered between inspections.

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

third- class medical certificate.

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

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

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

exemption, including evasive and emergency maneuvers and maintaining

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

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

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

permitted under the terms of the exemption. However, training operations may

only be conducted during dedicated training sessions. During training,

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

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

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

91.119. 

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

1.1. All operations must be conducted under visual meteorological conditions

(VMC). If flight at night is required, a special request will be made at the FAA

office closest to proposed area of operations. Flights under special visual flight

rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as

denoted on a current FAA-published aeronautical chart unless a letter of

agreement with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s COA.

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

the Administrator upon request.
25

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

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

PIC.

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

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

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

Subpart C. Markings must be as large as practicable.

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

and control of the UA must comply with the Federal Communications

Commission (FCC) or other appropriate government oversight agency

requirements.

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

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

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

Administrator or any law enforcement official upon request.

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

operations and activities at all times.

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

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

persons (persons other than the PIC, SO, operator trainees or essential persons),

vessels, vehicles, and structures unless:
26

a. Barriers or structures are present that sufficiently protect nonparticipating

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

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UA, flight operations must cease

immediately and/or;

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

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

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

operating closer to those objects and determined that it does not present

an undue hazard, and;

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

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

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

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

Permission from land owner/controller or authorized representative will be

obtained for each flight to be conducted.

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

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

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

hours. Accidents must be reported to the National Transportation Safety Board

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

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

And (b) Would Not Adversely Affect Safety.

THAYER ENTERTAINMENT submits that the equivalent level of safety

established by Section 61.113(a) and (b) will be maintained because no PIC will be 

allowed to operate the DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated, by 

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

operate the DJI Phantom 2 Vision+ UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. 

Considering THAYER ENTERTAINMENT's proposed area of operations, 

and the operating limitations set forth-above; the parallel nature of private pilot 

aeronautical 
27

knowledge requirements to those of commercial pilot requirements (See Exemption No. 

11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ 

UAS, THAYER ENTERTAINMENT submits that the additional manned airmanship 

experience of a commercially certificated pilot would not correlate to the airmanship 

skills necessary for THAYER ENTERTAINMENT'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). 

THAYER ENTERTAINMENT will not allow any PIC to operate the DJI Phantom 

2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 2 Vision+ UAS training and currency requirements, that 

the PIC is able to safely operate the DJI Phantom 2 Vision+ UAS in a manner consistent 

with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

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

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

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

UAS to be used for operations under the exemption). In addition to the hour requirements, 

the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency

purposes). 
28

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 THAYER ENTERTAINMENT'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, THAYER ENTERTAINMENT will ensure safe operations by not allowing 

any PIC to operate the DJI Phantom 2 Vision+ UAS unless that PIC has 

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

able to safely operate the DJI Phantom 2 Vision+ UAS in a manner 

consistent with the exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from people, vessels, vehicles and structures. 
29

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, THAYER ENTERTAINMENT will ensure that the DJI 

Phantom 2 Vision+ UAS is in an airworthy condition based upon the UAS’s 

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

limitations herein. 

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

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

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

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

4. Reasons Why An Exemption From The Requirements Of Section 91.121

Would Not Adversely Affect Safety.

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

because the altitude information of the DJI Phantom 2 Vision+ UA will be provided to the 

PIC via GPS equipment and a radio communications telemetry data link, which downlinks 

from the UA to the GCS for active monitoring of the flight path and altitude. This altitude 

information, combined with THAYER ENTERTAINMENT's operation of the DJI Phanto

m 2 Vision+ UA within visual line of sight, at or below 500 feet AGL, will ensure a level 

of safety equivalent to Section 91.121. The altitude information will be generated by GPS 

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

is automatically established by the UASs at ground level. 

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

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 
30

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

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

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

Would Not Adversely Affect Safety.

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

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

Phantom 2 Vision+ UAS; (2) the limitations on the proposed flight operations; and (3) the 

location of the proposed flight operations. Accordingly, THAYER ENTERTAINMENT 

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

during daylight hours in VFR conditions, with enough battery power to fly for a total 

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

cruising speed, to fly after that for at least 4.5 minutes. Here, as in Exemption No. 11109, 

the technical specifications of the DJI Phantom 2 Vision+ UAS; the limitations on the 

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

equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety 

will be ensured as the DJI Phantom 2 Vision+ UAS provide audible and visual warnings to 

the PIC at the GCS when the UAs experiences low battery voltage, the first warning 

occurring at approximately 33% remaining battery power, and again at approximately 10% 

remaining battery power. At the critically low battery level, the DJI Phantom Vision+ UAS 

will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

operating limitations of the UAS are considered. Relief has been granted for manned 
31

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, THAYER ENTERTAINMENT 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 THAYER ENTERTAINMENT will use trained 

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

using the methods, techniques, and practices prescribed in the operating documents (i.e., 

the THAYER ENTERTAINMENT Aerial Operations Manual, Monthly Maintenance Log, 

and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, THAYER 

ENTERTAINMENT will document and maintain all maintenance records for the DJI 

Phantom 2 Vision+ UAS. 

Since the DJI Phantom 2 Vision+ UAS will be inspected as prescribed by the 

operating documents, THAYER ENTERTAINMENT will maintain the equivalent level of 

safety established by Sections 91.405(a), 91.409(a)(1), and 

91.409(a)(2). A copy of the DJI Phantom 2 Vision+ User Manual are attached hereto as 

Exhibit B ; a copy of the DJI Phantom 2 Vision+ UAS Maintenance LOG is attached 

hereto as Exhibit C. 
32

Likewise, the exemption sought will not adversely affect safety because THAYER 

ENTERTAINMENT will use trained technicians to perform maintenance, alterations or 

preventive maintenance on the UAS using the methods, techniques, and practices 

prescribed by the operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Phantom 2 Vision+ UAS will be performed by trained technicians. Maintenance will 

be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of THAYER ENTERTAINMENT's proposed operating 

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

Vision+ UAS, THAYER ENTERTAINMENT 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, THAYER 

ENTERTAINMENT
33

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

Phantom 2 Vision+ UAS, which contain such safety standards that the Administrator finds 

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

Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 

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

special conditions will permit safe operation of the UAs for the limited purpose of 

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

compensation or hire. FMRA Section 333 sets forth the requirements for considering

whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a 

threat to national security; and further, provides the authority for such UAS to operate 

without airworthiness certification in accordance with any requirements that must be 

established for the safe operation of the UAS in the NAS. 

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

§ 21.16, for operation of the DJI Phantom 2 Vision+ UAS, since the

airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate 

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

entitled Special Conditions, states the following: 

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

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

because of a novel or unusual design feature of the aircraft, aircraft engine or 

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

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.
34

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

may prescribe special conditions for THAYER ENTERTAINMENT’s intended operation 

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

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

14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 

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

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

From Which THAYER ENTERTAINMENT Seeks Exemption: 

THAYER ENTERTAINMENT 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 THAYER 

ENTERTAINMENT Seeks: 

This exemption will permit THAYER ENTERTAINMENT to commercially 

operate an Unmanned Aircraft System (UAS) for the purpose of conducting 

aerial video and photography over certain areas of the United States.

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

THAYER ENTERTAINMENT'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, THAYER ENTERTAINMENT'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. 
35

As discussed in detail above, THAYER ENTERTAINMENT will operate the DJI 

Phantom 2 Vision+ UAS safely in the NAS, without creating a hazard to users of the NAS, 

or the public, or otherwise pose a threat to national security. 

CONCLUSION

As set forth herein, THAYER ENTERTAINMENT seeks an exemption 

C.F.R. pursuant to 14 § 11.61 and Section 333 of the FAA Modernization and Reform 

Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 Vision+ UAS 

commercially, without an airworthiness certificate, for the limited purpose of conducting 

aerial video and photography over certain areas of the United States. By granting this 

Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA 

Modernization and Reform Act of 2012, while also advancing the interests of the public, by 

allowing THAYER ENTERTAINMENT to safely, efficiently, and economically operate 

the DJI Phantom 2 Vision+ UAS commercially within the NAS. WHEREFORE, in 

accordance with the Federal Aviation Regulations and the FAA Modernization and Reform 

Act of 2012, Section 333, THAYER ENTERTAINMENT 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 Leading Edge to operate the DJI Phantom 2 

Vision+ UAS commercially for the purpose of conducting aerial video and photography

over certain areas of the United States. Dated: May 24, 2015
36

Respectfully submitted,

THAYER ENTERTAINMENT

/s/ Robert G. Thayer

_________________________

Robert Thayer

25290 Calvert Dr 

Greensboro, MD 21639

Tel: (443) 253-1716

Appendices:

A – DJI Phantom 2 Vision+ Specifications Data Sheet

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

C – Monthly Maintenance Log
37

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

THAYER ENTERTAINMENT 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. 

also be set to limit flight to no higher than a predetermined and set altitude as well as limit Parameters can 

flight to a predetermined and set distance. In addition, DJI software provides real-time 

altitude and location information to the PIC via the linked monitor (smart phone/tablet 

devices)

1.1 DJI Phantom 2 Vision+ 

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

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

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

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

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

1.1.2 Gimbal

1.1.2.1 Working Current – Static: 750mA; Dynamic: 900mA

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender
38

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W
41

APPENDIX – B

DJI Phantom 2 Vision+ Manufacturer’s User Manual

See Seperate Attached PDF
43

APPENDIX – C

month:_________(year:________

UAS$#:$___________ Date(Issue(

Discovered

Date(Issue(

Addressed

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other:

MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted

Maintenance(Performed(By:(((

Print(&(Sign