WRITER’S EXT. NO. 289 

E-MAIL MCD@jdsw.com

August 4, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

Re: Petition of 360 Tour Designs & Marketing, LLC, for an Exemption Pursuant to 

Section 333 of the FAA Modernization and Reform Act of 2012 

Dear Gentlemen: 

Pursuant to § 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14 

C.P.R. Parts 21 and 36, 360 Tour Designs & Marketing, LLC (“360 Tour Designs”), hereby applies 

for an exemption from the Federal Aviation Regulations (“FARs”) identified below, to allow 

commercial operation of DJI Phantom 2 Vision+ and the DJI Phantom 3 Professional quad-copter 

unmanned aerial vehicles (i.e. “small unmanned aircraft” or “UAS” or “Phantoms”). 

For your convenience, the petition is organized as follows: 

I. Description of Petitioner 

II. Types of Operations 

A. Use of UAS by 360 Tour Designs for Aerial Data Collection, Including 

Photography and Videography 

B. Use of UAS by 360 Tour Designs for Site Inspections, Surveys, and Liability 

Risk Management

III. Relevant Statutory Authority 360 Tour Designs' Proposed UAS Operations Meet the 

Requirements of § 333 of the Reform Act

IV. Regulations From Which Exemption is Requested 

A. 14 C.F.R. Part 21: Airworthiness Certificates

B. 14 C.F.R. Part 67: Medical Certificates and Conditions

C. 14 C.F.R. §§ 61.101(e)(4) and (5), § 61.113, and 315(a): Privileges and 

Limitations of Recreational Pilots, Private Pilots, and Sport Pilots

D. 14 C.F.R. §§ 91.9, 42.23(b), and 45.27(a): Flight Manual, Aircraft Marking, and 

Placard Requirements

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

F. 14 C.F.R. § 91.119: Minimum Safe Altitudes
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G. 14 C.F.R. § 91.121: Altimeter Settings

H. 14 C.F.R. § 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions

I. 14 C.F.R. §§ 91.405(a), 91.409(a), 91.417(a) and (b): Maintenance Inspections

J. 4 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

K. 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b): 

Maintenance Inspections and Operation After Maintenance

V. Drug and Alcohol Program 

VI. Public Interest 

VII. Privacy 

VIII. Federal Register Summary 

IX. Conclusion

I. DESCRIPTION OF PETITIONER 

360 Tour Designs provides real estate companies and professionals, as well as other 

commercial businesses, the highest quality service solutions available to help market realtors 

increase their exposure and capture leads, and to survey and inspect real estate and structures 

thereon. Founded in 2010, 360 Tour Designs has established itself as the leader within the multiple 

markets areas it has entered by providing professional photography, videography, Internet, and 

social media postings, resulting in increased views and sales of real estate and surveying and 

inspecting of real estate and structures erected thereon. It is in this spirit that 360 Tour Designs 

seeks an exemption on behalf of all of its offices and sales territories to utilize UASs to provide 

unique aerial photo and video services. 360 Tour Designs has assembled a UAS team covering all 

of the skill sets necessary to offer safe and effective UAS services, including an array of experienced 

aviation system professionals. 

Petitioner is as follows: 

360 Tour Designs & Marketing, LLC

Attn: Greg Drake 

507 North York Street, Suite 3A 

Mechanicsburg, Pennsylvania 17055 

Tel (717) 877-4434 

Email greg@360tourdesigns.com 

II. TYPES OF OPERATIONS 

A. Use of UAS by 360 Tour Designs for Aerial Data Collection, Including 

Photography and Videography 

360 Tour Designs is requesting exemptions pursuant § 333 to perform aerial photography 

and videography of real estate to enhance and augment residential and commercial real estate 

listings. Images acquired can also be utilized to promote tourism and marketing campaigns. 
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August 4, 2015 

B. Use of UAS by 360 Tour Designs for Site Inspections, Surveys, and Liability 

Risk Management 

360 Tour Designs also seeks exemption pursuant to § 333 to conduct inspections, surveys, 

and to assess, manage, and mitigate liability risks. The use of UASs will be an extremely valuable 

tool in places where it is impossible, unsafe, unfeasible, or unreasonable to conduct inspections, 

surveys, and assessments through physical inspection, survey, or assessment. This is particularly 

relevant when the structural integrity or environmental conditions pose especially high risks to 

human inspection. The alternative use of conventional aircraft or helicopters necessitates increased 

expense, operational difficulties, and added risks. 

III. RELEVANT STATUTORY AUTHORITY 

This petition for exemption is submitted in accordance with § 333(a) - (c) of the FAA 

Modernization and Reform Act of 2012. Congress has directed the FAA “to safely accelerate the 

integration of civil unmanned aircraft systems into the national airspace system.” Section 333 of the 

Reform Act permits the FAA Administrator to authorize the use of unmanned aircraft systems to 

operate in the National Airspace (“NAS”) where it is safe to do so based on the following 

considerations: 

 The UAS's size, weight, speed, and operational capability; 

 Operation of the UAS in close proximity to airports and populated areas; and 

 Operation of the UAS within the visual line of sight of the operator.1

Additionally, the FAA Administrator has general authority to grant exemptions from the 

agency's safety regulations and minimum standards when the FAA Administrator decides a 

requested exemption is in the public interest. See 49 U.S.C. § 106(f) (defining the authority of the 

Administrator); 49 U.S.C. § 44701(f) (permitting exemptions from §§ 44701(a), (b) and §§ 44702 - 

44716, et seq.). A party requesting an exemption must explain the reasons why the exemption: (1) 

would benefit the public as a whole; and (2) would not adversely affect safety (or how it would 

provide a level of safety at least equal to the existing rules). See 14 C.F .R. § 11.81 (petitions for 

exemption). 

IV. 360 TOUR DESIGNS' PROPOSED OPERATIONS MEET THE REQUIREMENTS OF § 333 

OF THE REFORM ACT 

The proposed operations in this Petition for Exemption qualify for expedited approval under 

§ 333 of the Reform Act. Each of the statutory criteria and other relevant factors are satisfied.

A. Approval is Warranted Based on the UASs Size, Weight, and Operational 

Capability

360 Tour Designs will employ the Phantoms. The Phantoms will be limited to a maximum 

flight speed of 30 m.p.h., and vertical ascent speed will be limited to 15 m.p.h., and weighs less than 

1 Id. at 333(b)(l).
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25 pounds, including their maximum payloads. Furthermore, the Phantoms have an integrated GPS 

system to calculate position and height and to relay that information via secure connection to the 

operator. In addition, the Phantoms contain a failsafe mode if its connection to the remote control is 

lost, directing the vehicle to return to a predetermined location and land to prevent injury or damage. 

B. Approval is Warranted Based on the Operational Restrictions Set Forth in the 

Operations Manual 

The flight operations manuals prepared by DJI for the Phantoms, together with other 

requirements adopted by 360 Tour Designs (collectively, the “Operations Manual”), contain all of the 

procedures and limitations necessary to successfully perform the types of operations proposed by 

360 Tour Designs. To assist the FAA in its safety assessment of 360 Tour Designs' operations, 

below is a summary of operational limitations and conditions which will ensure a level of safety equal 

to or exceeding the level of safety for operations conducted under current regulatory guidelines: 

1. The UASs employed by 360 Tour Designs will weigh 25 pounds or less. 

2. Flights will be operated within line of sight of the pilot in command. Visual observers 

may be used to augment the line of sight of the pilot in command. 

3. Maximum total flight time for each operational flight will be limited to the amount of 

time the UASs can be flown and still maintain a reserve battery power of no less than 

25%. 

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

verified prior to operation that the operation will not be conducted in any restricted 

location and will comply with other requirements, if any, that are in effect at the 

location of the operation. When necessary, all operations will be coordinated with the 

local FSDO prior to conducting the operation. 

5. Flights will be limited to a speed of 30 m.p.h., and vertical ascent will be limited to 15 

m.p.h.

6. The crew for each operation will consist, at a minimum, of the UAS pilot in command. 

One or more visual observers may also be utilized as necessary to safely conduct the 

mission.

7. The pilot in command will have sufficient experience and recurrent training to safely 

conduct the flight in accordance with the standards set forth in the Operations 

Manual.

8. When utilized, the visual observer designated for an operation will be in constant 

voice contact with the pilot in command.

9. The Phantoms will operate in accordance with the safety and operational 

requirements contained in their respective User Manuals.

10. When necessary, prior to the operation a Mission Plan will be created setting forth the 

limitations for the flight as well as contact and hazard information.

11. A Certificate of Authorization will be obtained prior to a flight outside of the blanket 

COA issued under the Section 333 “blanket” authorization.
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12. All required permissions and permits will be obtained from territorial, state, county, or 

city jurisdictions, including local law enforcement, fire, or other appropriate 

governmental agencies.

13. If the UAS loses communications or loses its GPS, it has the capability to return to a 

pre-determined location within the operational area and land.

14. The UAS has the capability to abort a flight in case of unpredicted obstacles or 

emergencies. 

15. The Phantoms will remain clear and give way to all manned aviation operations and 

activities at all times. 

V. REGULATIONS FROM WHICH EXEMPTION IS REQUESTED 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This 

statutory authority, by its terms, includes exempting civil aircraft, as that term is defined under 

§ 40101 of the Act, including UASs, from its safety regulations and minimum standards when the 

Administrator decides a requested exemption is in the public interest.2

360 Tour Designs seeks an exemption from several interrelated provisions of 14 C.F.R. Parts 

21, 45, 61 and 91 for purposes of conducting the operations outlined in Section II herein using a 

UAS. Listed below are (1) the specific sections of 14 C.F.R. for which exemption is sought, and (2) 

the operating procedures and safeguards that Petitioner has established which will ensure a level of 

safety better than or equal to the rules from which exemption is sought.3

A. 14 C.F.R. Part 21: Airworthiness Certificates 

The FAA has stated that no exemption is needed from this section if a finding is made under 

the Reform Act that the selected UAS provides an equivalent level of safety when compared to 

aircraft normally used for the same application. These criteria are met, and therefore no exemption 

is needed. See Grant of Exemption to Cayalazac Enterprises, LLC, Docket No. FAA-2015-1076. If 

however, the FAA determines that there are some characteristics of the Phantoms that fail to meet 

the requirements of the Reform Act, an exemption is requested. 

Equivalent Level of Safety

The Phantoms are safe when taking into account their size, weight, speed, and 

operational capability. The Phantoms weigh less than 25 pounds and will be flown at less 

than 30 miles per hour and completely outside controlled airspace. Additionally, the 

 

2 See 49 U.S.C. § 44701(f) (authorizing the grant of exemptions from requirements of regulations prescribed 

pursuant to Sections 44701(a) and (b) and Sections 44702- 44716). 

3 See 14 C.F.R. § 11.81(e), which requires a petition for exemption to include: 

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 you seek 

exemption. 
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Phantoms carry neither pilots nor passengers, carry no explosive materials or flammable 

liquid fuels, and operate exclusively within the parameters stated in their User Manuals. 

Operations under this exemption will be closely controlled and monitored by the pilot 

and will be conducted in compliance with local public safety requirements, to provide security 

for the area of operation. In all cases, the Phantoms operated under the proposed conditions 

will be at least as safe as, or safer than conventional rotorcraft operating with an 

airworthiness certificate without the restrictions and conditions of the proposed UAS 

operations. 

 

The aircraft themselves do not need a means to communicate with other aircraft or 

ATC, because those capabilities will be possessed by the pilot and observer, who are not 

onboard. See Grant of Exemption, Docket FAA-2014-0352. In addition, no sense and avoid 

technology is necessary on the UAS because it will be operated at all times by visual line-ofsight. Id.

B. 14 C.F.R. Part 67: Medical Certificates and Conditions 

On April 9, 2015, the FAA announced that a third class medical certificate is no longer 

required provided the UAS operator holds a valid driver’s license. The FAA determined that the 

change was consistent with the agency’s approach for sport pilot certificates, which only required a 

valid driver’s license and no FAA medical certificate. 

C. 14 C.F.R. §§ 61.101(e)(4) and (5), 61.113, 315(a): Privileges and Limitations of 

Recreational Pilots, Private Pilots, and Sport Pilots 

Petition seeks an exemptions from 14 C.F.R. § 61.101(e)(4) and (5) as well as 14 C.F.R. 

§ 61.113 and 14 C.F.R. § 61.3159a), which restricts recreational pilots, private pilots, and sport pilot 

license holders from flying for compensation or for hire, while also requiring a second class medical 

certificate for private pilots. The purpose of these sections is to ensure that the skill and competency 

of any pilot in command matches the airspace in which the pilot in command will be operating, as 

well as requiring certifications if the pilot is carrying passengers or cargo for hire. In this case, 

Petition will operate the UAS as part of a commercial operation but will not be carrying passengers 

or cargo. The FAA determined in Grant of Exemption docketed at FAA-2014-0352 that the unique 

characteristics of UAS operation outside of controlled airspace did not warrant the additional cost 

and restrictions requiring the pilot in command to hold a commercial pilot certificate and attendant 

class II medical certificate. 

Equivalent Level of Safety

Safe operation of the UAS is of paramount importance to 360 Tour Designs. To 

ensure safe operation of the Phantoms, 360 Tour Designs will require that any pilot in 

command be thoroughly versed in airspace and communication issues pertaining to all 

aircraft operators, including issues unique to UASs. Pilots will also be required to complete 

training by DJI, the manufacturer of the Phantoms, to obtain sufficient flight experience with 

the Phantoms as well as comply with the Operations Manual. 360 Tour Designs believes that 

this system will provide a higher level of competency and proficiency for its pilots. 
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D. 14 C.F.R. §§ 91.9, 42.23(b), and 45.27(a): Flight Manual, Aircraft Marking, and 

Placard Requirements 

Petitioner seeks an exemption from the aircraft marking and identification requirements 

contained in 14 C.F.R. §§ 91.9(c), 45.23(b) and 45.27(a). 

 14 C.F.R. § 91.9(c), Civil Aircraft Flight Manual, Marking, and Placard requirements, 

provides that: 

No person may operate a U.S.-registered civil aircraft unless that aircraft is identified 

in accordance with Part 45 of this chapter. 

 14 C.F.R. § 45.23(b), Markings of the Aircraft, states: 

When marks include only the Roman capital letter “N” and the registration number is 

displayed on limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on that aircraft near 

each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches 

nor more than 6 inches high, the words “limited,” “restricted,” “light-sport, 

“experimental,” or “provisional,” as applicable. 

 14 C.F.R. § 45.27(a), Rotorcraft, states: 

Each operator of a rotorcraft must display on that rotorcraft horizontally on both 

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23. 

360 Tour Designs does not request an exemption from this section but instead notifies the 

FAA that, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS 

flight manual, registration certificate, and other documentation will be kept at the control station with 

the pilot in command during flight. The Chief Counsel's Office has opined that for all UAS operations, 

this alternate method constitutes full compliance with the regulations. 

Equivalent Level of Safety

360 Tour Designs will mark all aircraft with their N-Number in a prominent spot on the 

fuselage with markings that are as large as practicable. 

E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness 

Petitioner seeks an exemption from 14 C.F.R. § 91.7(a), which requires that a civil aircraft be 

in airworthy condition to be operated. The FAA has stated that no exemption is required to the extent 

that the requirements of Part 21 are waived or found inapplicable. Accordingly, Petitioner requests 

that the requirements for Section 91.7 be treated in accordance with Section V(A), supra. 

F. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

Petitioner seeks an exemption from 14 C.F.R. § 91.119, which prohibits a civil aircraft 

operating below certain altitudes and away from any person, vessel, vehicle, or structure in noncongested areas. 
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Equivalent Level of Safety

Compared to flight operations with rotocraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel, any risk associated with 

operating the Phantoms below the minimum altitudes is far less than those that presently 

exist with conventional aircraft. An equivalent level of safety will be achieved given the size, 

weight, and speed of the Phantoms, as well as the location where operated. In order to avoid 

any risk to aircraft, flight operations will be restricted to 400 feet AGL or below. 

G. 14 C.F.R. § 91.121: Altimeter Settings 

This petition seeks an exemption from 14 C.F .R. § 91.121, which requires a person 

operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set 

to the elevation of the departure airport or barometric pressure. An exemption is required to the 

extent that the Phantoms do not have a barometric altimeter, but rather a GPS altitude read out. 

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety can be achieved if the UASs will 

be operated at 400' AGL or below and within visual line-of-sight in addition to GPS based 

altitude information relayed in real time to the operator. See Grant of Exemption to Astraeus 

Aerial, Docket No. F AA-2014-0352. As the attached User Manuals indicate, the Phantoms 

meet these requirements, and a zero altitude initiation point will be obtained prior to flight. 

H. 14 C.F.R. § 91.151(a)(1): Fuel Requirements for Flight in VFR Conditions 

Petitioner requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

§ 91.119. Section 91.119 prescribes the minimum safe altitudes under which aircraft may not 

operate, including 500 feet above the surface and away from any person, vessel, vehicle, or 

structure in non-congested areas. See 14 C.F.R. § 91.119(c). Section 91.119(d) allows for a 

helicopter to operate at less than those minimum altitudes when it can be operated “without hazard 

to persons or property on the surface,” provided that “each person operating the helicopter complies 

with any routes or altitudes specifically prescribed for helicopters by the FAA.” 

Equivalent Level of Safety

Compared to flight operations with rotorcraft weighing far more than the maximum 

weights proposed herein, and given the lack of flammable fuel, any risk associated with 

these operations is far less than those that presently exist with conventional aircraft. An 

equivalent level of safety will be achieved given the size, weight, and speed of the UASs, as 

well as the location where it is operated. In order to avoid any risk to aircraft, flight 

operations will be restricted to below 400 feet AGL . As set forth in the User Manuals, the 

Phantoms will be operated in a restricted area, away from persons or structures not involved 

in the operation. 
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I. 14 C.F.R. §§ 91.405(a), 91.409(a), 91.417(a) and (b): Maintenance Inspections 

Petitioner seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(2); 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.P.R. Part 43. See, e.g., 14 C.F.R. 

§ 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections ... have discrepancies 

repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed 

because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the 

Phantoms will not have. 

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the UAS Manufacturer's Manual. As provided in the 

Operations Manual, flights will not be conducted unless a flight operations checklist is 

performed that includes all of the aircraft's components. The Operations Manual also sets 

requirements for maintenance log books and record keeping as well as routine and postflight maintenance and inspections. 

J. 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

Petitioner requests an exemption from 14 C.P.R.§ 91.151(a)'s fuel requirements for flight in 

VFR conditions. Section 91.151 states: 

(a) No person may begin a flight in an airplane 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 - 

(1) During the day, to fly after that for at least 30 minutes; or 

(2) At night, to fly after that for at least 45 minutes. 

Here, the technological limitations on UAS battery power means that no meaningful flight operations 

can be conducted while still maintaining a 30 minute reserve. 360 Tour Designs proposes that all 

flights comply with this requirement by mandating that the aircraft be safely landed with no less than 

25% of battery life remaining. 

Equivalent Level of Safety

The FAA has stated that an equivalent level of safety is provided if the UAS flight is 

terminated with at least 25% reserve battery power still available. See Grant of Exemption to 

Astraeus Aerial, Docket No. FAA-2014-0352. The User Manuals conform to this limit, 

providing an equivalent level of safety. 
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K. 14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b): Maintenance 

Inspections and Operation After Maintenance 

Petitioner seeks an exemption from the maintenance inspection requirements contained in 

14 C.F.R. §§ 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b). These regulations specify 

maintenance and inspection standards in reference to 14 C.F.R. Part 43. An exemption from these 

regulations is needed because Part 43 and these sections only apply to aircraft with an 

airworthiness certificate, which the UAS will not have. 

Equivalent Level of Safety

An equivalent level of safety will be achieved because maintenance and inspections 

will be performed in accordance with the User Manual. As provided in the user Manual, 

flights will not be conducted unless a flight operations checklist is performed that includes all 

of the aircraft’s components. The User Manual also sets requirements for maintenance log 

books for both annual maintenance and preventative maintenance based on hours of flight. 

VI. DRUG AND ALCOHOL PROGRAM 

360 Tour Designs has policies in place to ensure that no person may act as a pilot in 

command, observer, or sensor operator if they are under the influence of alcohol or any drug. 

VII. PUBLIC INTEREST 

Granting 360 Tour Designs' exemption request furthers the public interest. National policy set 

by Congress favors early integration of UAS into the NAS in controlled, safe working environments 

such as those proposed in this petition. In addition, the public also has an interest in reducing the 

hazards and emissions associated with alternate use of helicopters to conduct similar inspection 

operations. The UAS in question is very light and does not carry any flammable fuel, further reducing 

the risk from any potential accident. 

Additionally, 360 Tour Designs' intended uses for the UASs have real-world benefits for 

Petitioner’s clients and the public at large. 360 Tour Designs will be able to augment real estate 

listings for clients as well as inspect and survey real property for site inspection, surveys, and liability 

risks and mitigation. 

VIII. PRIVACY 

All flights will be conducted in accordance with any federal, state or local laws regarding 

privacy. 

IX. FEDERAL REGISTER SUMMARY 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the 

Federal Register, should it be determined that publication is needed: 

360 Tour Designs seeks an exemption from the following rules: 
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14 CFR Part 21; 14 CFR Part 67; 14 CFR § 61.101(e)(4) and (5) 14 C.F.R. § 61.113; 14 

C.F.R. § 315(a); 14 C.F.R. § 91.9; 14 C.F.R. § 42.23(b); 14 C.F.R. § 45.27(a); 14 C.F.R. § 91.7(a); 

14 C.F.R. § 91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a)(1); 14 C.F.R. § 91.405(a); 14 C.F.R. 

§ 91.409(a); 14 C.F.R. § 91.417(a) and (b); 14 C.F.R. § 91.151(a); 14 C.F.R. §91.405(a); 14 C.F.R. 

§91.407(a); 14 C.F.R. §91.409(a)(2); and 14 C.F.R. §91.417(a) and (b). 

The exemption will enhance safety by reducing risk to the general public and property 

owners from the substantial hazards associated with performing equivalent work with conventional 

aircraft and rotorcraft. 

X. CONCLUSION 

Satisfaction of the criteria provided in § 333 of the Reform Act of 2012 size, weight, speed, 

operating capabilities, proximity to airports and populated areas, operation within visual line of sight, 

and national security-provides more than adequate justification for the grant of the requested 

exemptions to permit 360 Tour Designs to operate the selected UAS.

Granting the requested exemption will benefit the public interest as a whole in ,many ways, 

including (1) significantly improving safety and reducing risk by alleviating human exposure to 

danger, and (2) improving the quality of services and decreasing operating costs compared with 

conventional flight operations. 

If you have any questions or require any additional information, please do not hesitate to call. 

 Respectfully Submitted, 

JOHNSON, DUFFIE, STEWART & WEIDNER 

 

Mark C. Duffie, Esq. 

Brian W. Carter, Esq. 

Attachments: 

1. Phantom 2 Vision+ User Manual 

2. Phantom 3 Professional User Manual 

3. 360 Tour Design Operations Manual (submitted as a Confidential Document under 14 C.F.R. § 11.35(b) and 

exempt from disclosure under the Freedom of Information Act, 5 U.S.C. § 552 et seq., and any other 

requirements established by the FAA pursuant to Section 333 of the Reform Act). 

BWC:708850v3