UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

CHAD BROWN

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)(l),

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

OPERATION OF DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1 UNMANNED

AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on July 10, 2015

CHAD BROWN 

2354 Fairview Lane 

Mound, MN 55364
OAP Petition for Exemption Page 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. ............................................................... 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CHAD BROWN 

SEEKS EXEMPTION ................................................................................................... 6

THE EXTENT OF RELIEF CHAD BROWN SEEKS AND THE REASONS FOR 

THAT RELIEF ............................................................................................................ 15

THE REASONS WHY GRANTING CHAD BROWN’S REQUEST WOULD BE 

IN THE PUBLIC INTEREST ................................................................................... 17

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER ....... 30

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT CHAD BROWN’S QUEST .................................. 34

CONCLUSION ........................................................................................................................ 30

APPENDICES ............................................................................................................................... 31
GLOSSARY OF ABBREVIATIONS

AGL

AOI

ATC

ATO

AV

CFR

COA

FAA

FAR

GCS

GPS

LOL 

NAS

NOTAM

PIC

Section 333

so

SOP

UA 

UAS

VFR

VLOS

VMC

VTOL

Above Ground Level

Area of Interest

Air Traffic Control

Air Traffic Organization 

Aerial Vehicle

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration

Federal Aviation Regulation

Ground Control Station

Global Positioning System

Loss of Link

National Airspace System 

Notice to Airman

Pilot In Command

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

Safety Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft System

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Takeoff and Landing

CHAD BROWN Petition for Exemption Page 3
CHAD BROWN Petition for Page 4

SUMMARY

CHAD BROWN doing business as CHAD BROWN ("CHAD BROWN") seeks 

exemption from the requirements of 14 C.F.R §§ 61.113(a) & or alternatively an 

exemption from C.F.R §§ 61.113, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 

91.409(a)(l) & (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 CHAD BROWN 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 PETITIONERs

Chad Brown has over 5 years recreational/hobby experience in all aspects of 

aerial flight and 2 years of aerial video and photography. The objective of CHAD 

BROWN's aerial video and photography operations is to provide high quality imaging 

for a variety of commercial, public, and residential uses, specifically targeting:

• Construction sites before and after

• Appraisals

• Real-estate marketing

• Motion Picture Filming

• Aerial acquisitions used for inspections of public and private structures.

• Search and Rescue operations

• Public events and news gathering

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Inspire 1 UASs

CHAD BROWN seeks an exemption to operate DJI systems for compensation or 

hire within the NAS. The DJI Phantom 2 Vision+ and DJI Inspire 1 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 Vision+ has a maximum 

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

width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. 

The DJI 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 Phantom 2 Vision+ and DJI Inspire 1UAs are equipped 

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

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs that will be operated by 

CHAD BROWN 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.
CHAD BROWN Petition for Page 5

BASIS FOR PETITION

Petitioner, CHAD BROWN, 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 Rulesfor Certain Unmanned Aircraft Systems, hereby petitions the Administrator to

commercially operate the DJI Phantom 2 Vision+, DJI Inspire 1 UASs 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, 91.15l(b), 91.405(a), 91.407(a)(l ), 91.409(a)(l) & (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, CHAD BROWN’s operation of DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs 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, CHAD BROWN requests relief from Sections 91.405(a), 

91.407(a)(l ), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), as these sections set forth 

requirements for maintenance that only apply to aircraft with an airworthiness certificate.

CHAD BROWN submits that the requested relief is proper since an equivalent 

level of safety will be ensured. CHAD BROWN will use experienced personnel or 

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

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

Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction 

Manual). Furthermore, CHAD BROWN will document and maintain all maintenance 

records for the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs.

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

privileges and limitations: Pilot in command, is requested by CHAD BROWN to the 

extent necessary to allow a Pilot in Command (PIC) is able to safely operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs in a manner consistent with this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures. Alternatively, CHAD BROWN request that the 

requirement of private pilot licensing for commercial UA use required of previous 

exemptions be lifted in this particular request pursuant to CHAD BROWN’S argument 

herein.

CHAD BROWN seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not 

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

such, CHAD BROWN submits that he will ensure that the DJI Phantom 2 Vision+ and 

DJI Inspire 1UASs are in an airworthy condition, prior to every flight, by determining 

that the UASs are in compliance with the operating documents (i.e., Monthly 
CHAD BROWN Petition for Page 6

Maintenance Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual), and 

that the aircraft are in a condition for safe flight.

CHAD BROWN also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ and DJI Inspire 1 UAs 

will not have a typical barometric altimeter onboard. However, altitude information of the 

DJI Phantom 2 Vision+ and DJI Inspire 1UAs 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 CHAD BROWN’S operation of the DJI Phantom 2 Vision+ 

and DJI Inspire 1 UASs within visual line of sight, at or below 400 feet AGL, will ensure 

a level of safety equivalent to Section 91.121.

Additionally, CHAD BROWN seeks an exemption from the requirements of 

Section 91.15l(b), entitled Fuel requirements for flight in VFR conditions. CHAD 

BROWN submits that safety will not be affected by operation of the DJI Phantom 2 

Vision+ and DJI Inspire 1UAs during daylight hours in visual meteorological conditions 

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

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

assuming normal cruising speed, to fly after that for at least

4.5 minutes.

In accordance with 14 C.F.R. § 11.81, CHAD BROWN provides the following 

information in support of his petition for exemption:

A.NAME AND ADDRESS OF THE PETITIONER.

The name and address of the Petitioners and point of contact are:

CHAD BROWN

2354 Fairview Lane

Mound, MN 55364

Email: cb4email@yahoo.com

B. THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH CHAD 

BROWN SEEKS EXEMPTION.

1. CHAD BROWN SEEKS EXEMPTION FROM THE 

REQUIREMENTS OF SECTION 61.113.

CHAD BROWN’S ARGUMENT FOR EXEMPTION FROM 14 C.F.R. 

§61.113: PRIVATE PILOT PRIVILEGES AND LIMITATIONS: PIC.

CHAD BROWN requests an exemption from 14 C.F.R. §61.113 so that the PIC of 

the UA will not be required to possess a private or commercial pilot's license. As the FAA 

and numerous other national airspace regulators have recognized, UA operations conducted 

by persons who do not hold a pilot's license can still achieve the equivalent level of 

safety of current operations by manned aircraft with pilots holding a private or commercial 

pilot's license.
CHAD BROWN Petition for Page 7

Although it recognizes that a pilot's license is unnecessary for safe UA operation, the

FAA has to date declined to allow grant exemptions under Section 333 that would permit 

individuals who possess neither a private nor a commercial pilot's certificate to conduct 

commercial UA operations. It has specified two reasons for declining to do so. First, it 

has stated that it does not possess the authority under Section 333 to exempt 

individuals from the requirement under 49 U.S.C. §44711 to hold an airman certificate 

authorizing the airman to serve in the capacity for which the certificate was issued. 

Exemption No. 11110 at 14. Second, the FAA has concluded that the Department of 

Homeland Security (DRS) security screening required of all certified airmen meets the 

statutory requirement in Section 333 that operations not pose a threat to national 

security. Exemption No. 11110 at 15.

CHAD BROWN respectfully requests that the FAA reconsider its position. There 

is no dispute that it is unnecessary for an operator of a UA to go through the rigorous process 

of becoming a certified pilot in order to safely operate a UA. In addition, the FAA does have 

the authority to exempt UA operators from the requirement in 49 U.S.C. §4471l to 

hold an airman certificate for "serv[ing] in the capacity for which the certificate was 

issued." Indeed, it has exercised that authority repeatedly in the Section 333 process. 

Finally, the FAA's security concerns can be addressed by a variety of methods involving 

operator background checks to be conducted by government agencies.

2. THE FAA AND FOREIGN REGULATORS RECOGNIZE THAT

OBTAINING A MANNED AIRCRAFT PILOT LICENSE IS

UNNECESSARY FOR SAFE OPERATION OF A UA

The FAA, like the other national airspace regulators that have considered the issue,

has concluded that UA operations conducted by persons who do not hold a pilot's license

can still achieve the equivalent level of safety of current operations by manned aircraft with

pilots holding a private or commercial pilot's license. In its recent UAS NPRM, the FAA

stated:

"While these airman certification requirements are necessary for manned

aircraft operations, they impose an unnecessary burden for many small UAS

operations. This is because a person typically obtains a private or commercial

pilot certificate by learning how to operate a manned aircraft. Much of that

knowledge would not be applicable to small UAS operations because a small

UAS is operated differently than manned aircraft. n addition, the knowledge

currently necessary to obtain a private or commercial pilot certificate would

not equip the certificate holder with the tools necessary to safely operate a

small UAS... Thus, requiring persons wishing to operate a small UAS to

obtain a private or commercial pilot certificate imposes the cost of

certification on those persons, but does not result in a significant safety

benefit because the process of obtaining the certificate does not equip those

persons with the tools necessary to mitigate the public risk posed by small

UAS operations." Operation and Certification of Small Unmanned Aircraft,

80 Fed. Reg. 9543 at 9550 (proposed Feb. 23, 2015 (to be codified at 14

C.F.R. Parts 21, 43, 45, et al.)).
CHAD BROWN Petition for Page 8

The FAA's conclusion that manned aircraft flying experience is unnecessary for the

operation of a UA is supported by research by the FAA and the Army Research Laboratory.

They demonstrate that UAs, even those much larger than the sUAS proposed by CHAD 

BROWN, can be safely flown by non-certificated pilots with a small amount of training. For 

example, one Army Research Laboratory study concluded:

"[T]he specific motor skills needed to control the radio-controlled UAV

would have to be learned by aviators independently of the motor skills 

learned in flying an aircraft. In particular, the somatic and visual cues that

pilots use during aircraft landings would not be useful (and perhaps even

counter-productive) for the different skill sets and perceptual viewpoint

necessary for radio-controlled landings."1

Additional research reports lend further support for the exclusion requested. For

example, a report sponsored by the FAA concluded that "We know that certain systems, like

the U.S. Army Hunter and Shadow systems, are successfully flown by pilots with no manned

aircraft experience.”2

In addition, foreign government airspace regulators that have examined the issue

have consistently recognized that the skills required to fly a manned aircraft are irrelevant to

operating a UA. For that reason, they have concluded that UA operators do not need to have

a private or commercial pilot's license. Canada, for example, does not require a pilot's

license to operate a UA. Transport Canada requires training of UA operators, but that training

is limited to pilot ground school and flight operation training on UAs, not manned aircraft.3

Moreover, Canada allows this training to be "provided by other pilots, manufacturers, [UA]

flight training organizations or .. . self-taught." 4

1 Michael J. Barnes, Beverly G. Knapp, Barry W. Tillman, Brett A. Walters & Darlene

Veliki,

Crew systems analysis of unmanned aerial vehicle (UAV) future job and tasldng

environments, Technical Report ARL-TR-2081, Aberdeen Proving Ground, MD: Army

Research Laboratory, page 12 (2000), available at

http://www.dtic.mil/dtic/tr/fulltext/u2/a374230.pdf.

2 Kevin W. Williams, Unmanned Aircraft Pilot Medical Certification Requirements, Report

DOT/FAA/AM-07/3, FAA Civil Aerospace Medical Institute, page 2, (2007), available at

http://fas.org/iro/program /collect /ua-pilot.pd f. While the authors speculated that UAS use in

populated areas may change this assessment, indicating further research was needed to

address this concern, this concern is inapplicable as Helios's flights will not be in congested

areas. See also Jason S. McCarley & Christopher D. Wickens, Human Factors Implications

of UAVs in the National Airspac e, Institute of Aviation, Aviation Human Factors Division,

University of Illinois at Urbana-Champaign, 13 (2004), available at

http://www .tc.faa.gov/logistics/grants/pdf/2004/04-G-032.pdf

3 See Civil Aviation, Standards, Transport Canada, Advisory Circular: Guidance Material

for Operating Unmanned Air Vehicle Systems under an Exemption at 14 and 18-22, (Nov.

27, 2014) available at http://www.tc.gc.ca/media/documents /ca-opssvs/ac-600-004.pdf.

4 Id. at 14.
CHAD BROWN Petition for Exemption Page 9

Similarly, the United Kingdom's Civil Aviation Authority (CAA) recognized that

determining "Remote Pilot qualification requirements on the same basis as manned aircraft

may yield requirements that are too inflexible, too onerous and inappropriate for UAS

operations."5 As a result, the CAA only requires UA operators to demonstrate UA operator

competence. 6 While there are a variety of ways to demonstrate competence, the most

common is to complete a course that will lead to a ground exam and flight test. Australia,

too, requires only passage of a UA-specific ground school program in lieu of a private pilot

license.7 Finally, more than a dozen countries, including Germany, Italy, France, Spain and

the Netherlands, have adopted the National UAS Certificate for Small Unmanned Aircraft

(BNUCMS) Standard for UA pilot certification.7 This standard results in a type-specific UA

certificate and does not require the operator to have a pilot's license. The process involves

taking a short ground school course, passing a ground school test and then passing a practical 

test on commercial operation of the specific UAS per the UAS manufacturer's operations

manual.

All of this experience and evidence indicates that the proposed exemption will

provide a greater level of safety than operations under 14 C.F.R. §61.113. In this instance,

the PIC has years of UA experience. He has focused his training and education on UAs

generally, and in particular on the aircraft to be operated, rather than taking on the cost,

additional time and risk to train on a manned aircraft, weighing several thousand pounds and

carrying highly flammable fuel.

The FAA has concluded in the NPRM that such DA-specific training is more than

sufficient to provide an equivalent level of safety for UA operations. Sometime in the next

18 to 24 months, that position will be enshrined in a valid regulation. However, in the

meantime, the FAA claims it lacks the authority to relax the requirement to possess a pilot

certificate. As described infra, that position is both incorrect and contradicted by the FAA's

recent decisions.

3.THE FAA HAS ALREADY EXERCISED THE AUTHORITY TO 

EXEMPT APPLICANTS FROM THE AIRMAN CERTIFICATE 

REQUIREMENT

5 Civil Aviation Authority, Safety Regulation Group, Unmanned Aircraft System Operations

in UK Airspace - Guidance, Section 2, Chapter 5, Page 2 (Aug. 10, 2012), available at

https://www.caa.eo.uk/docs/33/CAP722. pdf.

6 Civil Aviation Authority, Unmanned Aircraft and Aircraft Systems,

available at http://www.caa.co.uk/default.aspx?catid= 1995&pagetype=90

7 Australian Government Civil Aviation Safety Authority, available at

http://www.casa.gov.au/scripts /nc.dll?WCMS: STAND ARD: :pc=PC 1003

74.

7 See EuroUSC International, "Pilot Qualification, “available at

http://eurousc.com/services/pilot-qualifications/.
CHAD BROWN Petition for Exemption Page 10

The FAA claims that it lacks authority to exempt UA operators from the requirement

of 49 U.S. §44711 to hold an airman certificate authorizing the airman "to serve in the

capacity for which the certificate was issued." See, e.g., Exemption No. 11110 at 14. This

claim is inconsistent with both (i) the statutory language of that section and Section 333, and

(ii) numerous recent FAA decisions.

The operative part of 49 USC §44711 provides that a "person may not . . . serve in

any capacity as an airman with respect to a civil aircraft, . . . used, or intended for use, in air

commerce - (A) without an airman certificate authorizing the airman to serve in the

capacity for which the certificate was issued . . . " If the FAA's interpretation were 

correct, this language would require that any person wishing to operate a UA for 

commercial operations have an airman certificate authorizing the person to serve as 

an airman in commercial operations.

However, in all of its recent grants of Section 333 petitions, the FAA has -without

explicitly acknowledging the fact - exempted commercial UA operators from the §4471 l(A)

requirement that they hold an airman certificate authorizing them "to serve in the capacity

for which the certificate was issued." It has done so by allowing them to operate a UA so

long as they hold a private pilot’s orsport pilot's authorization, even though such a certificate

does not permit commercial operations. Exemption No. 11062 at 15-18; Exemption No.

11110 at 14-16; Exemption No. 11191 at 3-5; and Exemption No. 11229 at 3 and 8.

The FAA argues that it cannot exempt applicants from the requirements of §44711

because, while the specific language of Section 333 grants it limited statutory flexibility

relative to 49 U.S.C. §44704 for the purposes of airworthiness certification, Section 333 does

not provide flexibility relative to §44711 and other sections of Title 49. Exemption No.

11110 at 14. This argument ignores the plain language of the statute. The relevant language of 

Section 333 is:

(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
CHAD BROWN Petition for Exemption Page 11

(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.

The language of Section 333(b) is permissive: it requires that the Secretary

"determine, at a minimum . . . 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)." Nothing in

(b) precludes the Secretary from determining whether or not a pilot's license is required for

operation of a UA identified under paragraph (b)(1).

Indeed, the FAA has implicitly conceded the point by granting exemptions from the

requirement that commercial UA operators hold a commercial pilot certificate. From an

analytical standpoint, there is no difference between granting an exemption from the

commercial pilot's license requirement and granting an exemption from the private or sport

pilot's license requirement. Both are clearly exemptions from a specific statutory 

requirement in 49 U.S.C. §44711. If the FAA has the statutory authority under Section

333(b) to do the former, it has the same authority to do the latter.8

For the reasons set forth above, the FAA should reconsider its position and exercise

its full authority to grant an exemption from all the requirements of 49 use §44711, so that

CHAD BROWN serving as a commercial UA operator need not have a 

pilot's license. Alternatively:

1.CHAD BROWN 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:

8 The FAA has not specifically identified the statutory provision that underpins its authority

to grant the exemptions from the commercial pilot's license requirement. Whether the

statutory basis is Section 333 or some other provision makes no difference. Ifthere is a basis

for a partial exemption from in 49 U.S.C. § 44711, that basis also justifies an exemption

from the entire provision.
CHAD BROWN Petition for Exemption Page 12

(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. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENT 

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.CHAD BROWN 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)(l)(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.CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS 

OF SECTION 91.lSl(b).

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

(b), states the following:
CHAD BROWN Petition for Exemption Page 13

(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. CHAD BROWN 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. CHAD BROWN SEEKS EXEMPTION FROM THE 

REQUIREMENTS OF SECTION 91.407(a)(l)

Section 91.407, entitled Operation after maintenance, preventive maintenance,

rebuilding, or alteration, subsection (a)(l), 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. CHAD BROWN SEEKS EXEMPTION FROM THE REQUIREMENTS 

OF SECTIONS 91.409(a)(l) 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.CHAD BROWN 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:
CHAD BROWN Petition for Exemption Page 14

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

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

specified in paragraph (b) of this section:

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

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

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

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

include--

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

work performed; and

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

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

for return to service.

(2) Records containing the following information:

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

each rotor.

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

propeller, rotor, and appliance.

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

are required to be overhauled on a specified time basis.

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

last inspection required by the inspection program under which the

aircraft and its appliances are maintained.

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

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

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

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

required.

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

alteration to the airframe and currently installed engines, rotors,

propellers, and appliances.

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

prescribed:
CHAD BROWN Petition for Exemption Page 15

(1) The records specified in paragraph (a)(l) 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 CHAD BROWN SEEKS AND THE REASON 

CHAD BROWN SEEKS THE RELIEF

1.EXTENT OF RELIEF CHAD BROWN SEEKS AND THE 

REASON CHAD BROWN 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

FAA airman certificate or in the alternative an unmanned aircraft operator certificate with a

small UAS rating (like existing pilot airman certificates) 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, CHAD BROWN submits that an equivalent level of 

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

Vision+ UAS or DJI Inspire 1 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+ or DJI Inspire 1 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, CHAD BROWN submits that all flights of the DJI Phantom 2 Vision+ and 

DH Inspire 1 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to CHAD BROWN’S business; and (2) will not carry passengers or property for 

compensation or hire.

2. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE 

REASON CHAD BROWN SEEKS RELIEF FROM SECTION 

91.7(a).
CHAD BROWN Petition for Exemption Page 24

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the

extent required to allow CHAD BROWN to determine that the DJI Phantom 2 Vision+ 

and DJI Inspire 1 UASs are in airworthy condition prior to every flight by ensuring 

that the UAS is in compliance with the operating documents (i.e. the CHAD BROWN

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

Inspire 1 Instruction Manual).

CHAD BROWN seeks the requested relief because the DJI Phantom 2 Vision+ and 

DJI Inspire 1 UASs do not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. Therefore, CHAD BROWN will ensure that the DJI Phantom 

2 Vision+ and DJI Inspire 1 UASs are in airworthy condition based upon its compliance 

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

and DJI Inspire 1 Instruction Manual) prior to every flight, and further, determine that the 

aircraft are in condition for safe flight, as stated in the conditions and limitations below.

3. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE 

REASON CHAD BROWN 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+ and DJI Inspire I UASs, 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), CHAD BROWN

seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Inspire 1 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+ and DJI Inspire I UAs are equipped with a

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

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

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

4. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE 

REASON CHAD BROWN SEEKS RELIEF FROM SECTION 

91.lSl(b).

Relief from Section 91.l Sl(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+ and DJI Inspire 1 UAs during daylight hours in visual meteorological

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

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

at least 4.5 minutes. CHAD BROWN 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+ and DJI Inspire 1 UAs will severely constrain the practicality of any 
Page 23 CHAD BROWN Petition for Exemption

aerial video or still photo flight operations that CHAD BROWN proposes to conduct 

pursuant to this Petition.

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

Vision+ and DJI Inspire 1 UASs, the DJI Phantom 2 Vision+ and DJI Inspire 1 operating

documents, and CHAD BROWN’S proposed operating limitations, ensure that CHAD 

BROWN will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Inspire 1 

UAs during daylight hours in visual meteorological conditions (VMC), under visual 

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

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

at least 4.5 minutes.

5. EXTENT OF RELIEF CHAD BROWN SEEKS AND THE 

REASON CHAD BROWN SEEKS RELIEF FROM SECTIONS 

91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(l), 91.409(a)(l ) & (a)(2), and 91.417(a) & (b) only

apply to aircraft with an airworthiness certificate, CHAD BROWN requests relief from 

these Sections because the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs do not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ and 

DJI Inspire 1 UASs meet the conditions of FMRA Section 333 for operation without an 

airworthiness certificate. Accordingly, CHAD BROWN 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 CHAD BROWN Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, CHAD 

BROWN will document and maintain all maintenance records for the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs.

D. REASONS WHY GRANTING CHAD BROWN’S REQUEST WOULD BE 

IN THE PUBLIC INTEREST.

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

BROWN 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+ and DJI Inspire 1 UASs will

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

economy. Notably, the benefits of CHAD BROWN’S proposed operation of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs will be realized without implicating any 

privacy issues.

1. THE PUBLIC WILL BENEFIT FROM DECREASED CONGESTION 

OF THE NAS.

The DJI Phantom 2 Vision+ and DJI Inspire 1 UAs are battery powered and serve as

a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to

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

acquisitions, an exemption allowing the use of a DJI Phantom 2 Vision+ or DJI Inspire 1
CHAD BROWN Petition for Exemption Page 24

UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution,

as well as increase the safety of life and property in the air and on the ground.

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

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

DJI Phantom 2 Vision+ and DJI Inspire 1 UAs do not require an airport to takeoff or land.

Likewise, a reduction of manned aircraft conducting aerial video and photography missions 

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

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

2. THE PUBLIC WILL BENEFIT FROM THE SAFETY AND 

EFFICIENCY OF THE DJI PHANTOM 2 VISION+ AND DJI 

INSPIRE 1UASS.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Inspire 1

UASs, 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+ and DJI Inspire 1 UASs 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+

and DJI Inspire 1 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 Vision+ and DJI Inspire 1 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 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+ and DJI Inspire 1 UAs (weighing

approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum 

gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches

and 17.7 inches respectively, and with no fuel on board), has less physical potential for 

collateral damage to life and property on the ground, and in the air, compared to the manned

aircraft that typically conduct similar operations (weighing approximately 6,000 pounds

with a wingspan of approximately 42 feet, a length of 34 feet, and a fuel capacity of 180

gallons).

3. PERFORMING AERIAL VIDEO AND PHOTOGRAPHY 

OPERATIONS WITH THE DJI PHANTOM 2 VISION+ AND DJI 

INSPIRE 1UASS WILL BENEFIT THE ECONOMY.

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

UASs are also an economical alternative to using manned aircraft to conduct similar aerial

operations. As such, operation of the DJI Phantom 2 Vision+ and OJI Inspire 1 UASs will

allow United States based companies, like OAP, to remain competitive and contribute to

growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the
Page 23 CHAD BROWN Petition for Exemption

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+ and 

DJI Inspire I 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 Vision+ and DJI Inspire 1 UASs, companies such

as CHAD BROWN, 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+ and DJI Inspire I 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, CHAD BROWN’S proposed operation of the DJI Phantom 2 Vision+ and 

DJI Inspire 1 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 

2 Vision+ and DJI Inspire 1 UASs will be operated only in compliance with operating 

documents (i.e., the CHAD BROWN Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Phantom 2 Vision+ and DJI Inspire 1 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. 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 WIDCH CHAD BROWN SEEKS 

EXEMPTION.

1.REASONS WHY THE DJI PHANTOM 2 VISION+ AND DJI 

INSPIRE 1 UAS MEET THE CONDITIONS OF THE FAA 

MODERNIZATION AND REFORM ACT OF 2012 (FMRA) 

SECTION 333.

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

the unmanned aircraft and its operation, CHAD BROWN’S operation of the DJI Phantom 

2 Vision+ and DJI Inspire 1 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
CHAD BROWN Petition for Exemption Page 24

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 (I).

(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 requirementsfor the safe operation 

of such aircraft systems in the national airspace system.

In seeking this exemption, CHAD BROWN submits that the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs can operate safely in the NAS pursuant to FMRA 

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

and DJI Inspire 1 UASs; (b) the pilot certification requirement; and (c) the specific 

operating limitations.

a.THE SPECIFICATIONS OF THE DJI PHANTOM 2 VISION+ AND 

DJI INSPIRE 1UASS DEMONSTRATE ITS SAFE 

CHARACTERISTICS.

The DJI Phantom 2 Vision+ and DJI Inspire 1 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 VISION+ AND DJI INSPIRE 1UASS.

The technical specifications of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs

are set forth by the DJI Phantom 2 Vision+ and DJI Inspire 1 Specifications and Data Sheet,

attached hereto as Exhibits A and B.

ii. THE DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1 

UASS AUTONOMOUS FLIGHT AND NAVIGATION MODES 

ENABLE THE UASS TO REMAIN WITHIN A DEFINED 

OPERATIONAL AREA.
Page 23 CHAD BROWN Petition for Exemption

The DJI Phantom 2 Vision+ and DJI Inspire 1 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 Vision+ and DJI Inspire 1 UASs is provided at pages 31-

34 of the DJI Phantom 2 Vision+ and pages 12-16 and 45-50 of the DJI Inspire 1 User 

Manuals, attached hereto as Exhibit C and D.

iii. THE DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1UASS 

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 DH Phantom 2 Vision+ and DJI Inspire 1 UAs

will remain stationary, in flight, for 3 seconds or more. If, after 3 seconds, the DJI Phantom 

2 Vision+ and DJI Inspire 1 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 (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 32 - 34 and for the DJI Inspire 1 at pages 13 through 15 of the DJI

Phantom 2 Vision+ and DH Inspire 1 User Manuals, attached hereto as Exhibit C and D.

iv. THE DJI PHANTOM 2 VISION+ AND DJI INSPIRE 1GCS 

AND ITS OPERATION.

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

Vision+ and DJI Inspire 1 GCS and flight control software is provided at pages 31 through 

41 of the DJI Phantom 2 Vision+ User Manual and pages 40 through 51 of the DJI Inspire I

User Manual. DJI Phantom 2 Vision+ and DJI Inspire 1 User Manuals are attached hereto 

as Exhibits C and D.

b.FLIGHT OPERATIONS OF DJI PHANTOM 2 VISION+ AND 

DJI INSPIRE 1 UASS ARE LIMITED TO THE LINE OF 

SIGHT OF A CERTIFICATED PILOT IN COMMAND WITH 

A SAFETY OBSERVER.

CHAD BROWN will only utilize certificated pilots to act as a pilot in command 

(PIC) of the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs. Additionally, a safety 

observer will assist all pilots during flight time.

c. FLIGHTS OF DJI PHANTOM 2 VISION+ AND DJI INSPIRE 

1UASS WILL BE CONDUCTED PURSUANT TO SPECIFIC 

OPERATING LIMITATIONS.

In seeking this exemption, CHAD BROWN proposes to commercially operate DJI 

Phantom 2 Vision+ and DJI Inspire 1 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
CHAD BROWN Petition for Exemption Page 24

55 pounds maximum gross weight: DJI Phantom 2 Vision+ and DJI Inspire 1 

Unmanned Aircraft Systems. Proposed operations of any other aircraft will require 

a new petition or a petition to amend this grant.

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

the purpose of aerial video and photography.

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

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

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

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

ATC must be in feet AGL.

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

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

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

certificate.

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

permitted.

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

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

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

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

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

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

prescribed in the operating documents.

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

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

not permitted to operate the camera or other instruments.

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

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

discrepancy exists between the conditions and limitations contained in the grant

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

conditions and limitations contained in the grant of exemption take precedence

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

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

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

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

The operator must also present updated and revised documents if it 

petitions for extension or amendment to the grant of exemption. If the operator 

determines that any update or revision would affect the basis upon which the 

FAA granted the exemption, and 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.
Page 23 CHAD BROWN Petition for Exemption

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

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

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

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

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

the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

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

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

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

flight must make an entry in the aircraft records.

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

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

sections of the operating documents.

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

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

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

requirements, in accordance with the operating documents. Maintenance,

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

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

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

to service.

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

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

17.The PIC must possess at least a private pilot certificate and at least a current thirdclass 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.Sl (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
CHAD BROWN Petition for Exemption Page 24

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. §

19.1. All operations must be conducted under visual meteorological 

conditions (VMC). If flight at night is required; a special request will be made 

at the FAA office closest to proposed area of operations. Flights under special 

visual flight rules (SVFR) are not authorized.

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

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

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

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

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

Administrator upon request.

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

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

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a 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
CHAD BROWN Petition for Exemption Page 25

Commission (FCC) or other appropriate government oversight agency

requirements.

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

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

operating. These documents must be made available to the Administrator or any

law enforcement official upon request.

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

operations and activities at all times.

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

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

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

vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating

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

operator must ensure that nonparticipating persons remain under such

protection. If a situation arises where nonparticipating persons leave 

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

cease immediately and/or;

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

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

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

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

undue hazard, and;

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

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

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

permission from the land owner/controller or authorized representative.

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

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

boundaries of the operational area as defined by the applicable COA must be

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

Accidents must be reported to the National Transportation Safety Board (NTSB)

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

2. REASONS WHY AN EXEMPTION FROM THE REQUIREMENTS 

OF SECTION 61.113(a) AND (b) WOULD NOT ADVERSELY AFFECT

SAFETY.
CHAD BROWN Petition for Exemption Page 26

CHAD BROWN 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+ and DJI Inspire 1 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 Vision+ or DJI Inspire 1 UAS in a manner consistent with the exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from 

people, vessels, vehicles and structures.

Considering CHAD BROWN’S proposed area of operations, and the airmanship 

skills necessary to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS, 

CHAD BROWN submits that the additional manned airmanship experience of a 

certificated pilot would not correlate to the airmanship skills necessary for CHAD 

BROWN’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, l 1065, 11066, 11067, 11080, 11109, 11110, 11112,

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

CHAD BROWN will not allow any PIC to operate the DJI Phantom 2 Vision+ or 

DJI Inspire 1 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 2 Vision+ or DJI Inspire 1 UAS training and currency 

requirements, that the PIC is able to safely operate the DJI Phantom 2 Vision+ or DJI Inspire 

1UAS 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 CHAD BROWN’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
CHAD BROWN Petition for Exemption Page 25

included in the 10 hours of multi-rotor time and the 10 hours may be included in the
CHAD BROWN Petition for Exemption Page 28

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 experiencebuilding 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, CHAD BROWN will ensure sate operations by not allowing any PIC 

to operate the DJI Phantom 2 Vision+ or DJI Inspire 1 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+ or DH Inspire 1 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, CHAD BROWN will ensure that the DJI Phantom 2 Vision+ or 

DJI Inspire 1 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+ and DJI Inspire 1 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 CHAD BROWN’S operation of the 

DJI Phantom 2 Vision+ and DJI Inspire 1 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.
CHAD BROWN Petition for Exemption Page 27

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 91.15l(b) as a result of (1) the technical specifications of the DJI Phantom

2 Vision+ and DJI Inspire 1 UASs; (2) the limitations on the proposed flight operations; and

(3) the location of the proposed flight operations. Accordingly, CHAD BROWN will 

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

Inspire 1 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 

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+ and DJI Inspire 1 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

Vision+ 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 Vision+ 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)(l), 91.409(a)(l) & (a)(2), And 

91.417(a) and (b) WOULD NOT ADVERSELY AFFECT SAFETY.

In seeking this exemption, CHAD BROWN 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){l),91.409(a)(l) & (a)(2), and 91.417(a) & (b) 

will be met because CHAD BROWN will use trained technicians to perform maintenance, 

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

practices prescribed in the operating documents (i.e., the CHAD BROWN Aerial 

Operations Manual, Monthly Maintenance Log, and DJI
CHAD BROWN Petition for Exemption Page 30 

Phantom 2 Vision+ and DJI Inspire 1 Instruction Manual). Furthermore, CHAD BROWN

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

DJI Inspire 1 UASs.

Since the DJI Phantom 2 Vision+ and DJI Inspire 1 UASs will be inspected as

prescribed by the operating documents, CHAD BROWN will maintain the equivalent 

level of safety established by Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). A copy 

of the DJI Phantom 2 Vision+ and DJ! Inspire 1 User Manuals are attached hereto as 

Exhibit C and D; a copy of the DJI Phantom 2 Vision+ and DJI Inspire 1 UAS Maintenance 

LOG is attached hereto as Exhibit E.

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

BROWN 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+ and DJI Inspire 1 UASs 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)(l), 91.409(a)(l) & (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.

Inconsideration of CHAD BROWN’S proposed operating limitations, the 

operating documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI 

Inspire 1 UASs, CHAD BROWN submits that safety will not be adversely affected by 

granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(l) 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, CHAD BROWN requests 

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

Vision+ and DJI Inspire 1 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)(l), 91.409(a)(l) & (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
CHAD BROWN Petition for Exemption Page 29

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+ and DJI Inspire 1 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 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 CHAD BROWN’S intended operation of the DJI 

Phantom 2 Vision+ and DJI Inspire 1 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.l5l(b), 91.405(a), 91.407(a)(l ), 91.409(a)(l ) & (a)(2), and 91.417(a) & (b).

F. A SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL 

REGISTER, STATING: THE RULES FROM WHICH CHAD BROWN 

SEEKS EXEMPTION:

CHAD BROWN seeks exemption from the requirements of 14 C.F.R Sections 

61.l 13(a)&(b), alternatively 14 C.F.R Section 61.113, and 91. 7(a), 91.121, 

91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).

A BRIEF DESCRIPTION OF THE NATURE OF THE EXEMPTION 

CHAD BROWN SEEKS:

This exemption will permit CHAD BROWN to commercially operate an 

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

photography over allowed areas of the United States.

G. ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

AVAILABLE TO SUPPORT CHAD BROWN’S REQUEST.
CHAD BROWN Petition for Exemption Page 30 

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, CHAD BROWN’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 poses a threat to national

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

certification.

As discussed in detail above, CHAD BROWN will operate the DJI Phantom 2 

Vision+ and DJI Inspire 1 UASs safely in the NAS, without creating a hazard to users of 

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

CONCLUSION

As set forth herein, CHAD BROWN seeks an exemption pursuant to 14 C.F.R. § 

11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which 

will permit safe operation of the DJI Phantom 2 Vision+ and DJI Inspire 1 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 CHAD BROWN to safely, efficiently, and economically operate the DJI 

Phantom 2 Vision+ and DJI Inspire 1 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, CHAD BROWN respectfully 

requests that the Administrator grant this Petition for an exemption from the 

requirements of 14 C.F.R Sections 61.l 13(a) & (b) or alternatively 14 C.F.R Sections 

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

91.417(a) & (b), and permit

OAP to operate the OJI Phantom 2 Vision+ and DJI Inspire 1 UASs commercially for the

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

Dated: July 10, 2015

Respectfully submitted by: 

 

CHAD BROWN

2354 Fairview Lane

Mound, MN 55364