AIRHAWK, LLC

Christopher Thelan 

Manager 

AIRHAWK, LLC

19719 Dartmouth Ave

Bend, Oregon 97702 

Phone: (206) 669-7015

Email: christhelan@gmail.com 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

February 8th, 2016

RE: Exemption Request Under Section 333 of the FAA Reform Act of 2012 and Part 11 of 

the Federal Aviation Regulations 

Petition Summary

Pursuant to Section 333 of the Federal Aviation Administration (FAA) Modernization and 

Reform Act of 2012 (FMRA), AIRHAWK, LLC hereby petitions for expedited approval and 

exemption from FAA authorizing commercial operation of its small unmanned aircraft systems 

(UAS) for remote sensing, aerial surveys, data and imagery collection for the industries and 

functions listed in Table 1. 

Agriculture Insurance

Construction Law Enforcement Support

Emergency Response/Search and Rescue Planning & Asset Management

Engineering & Surveying Promotion & Marketing

Environmental Monitoring Real Estate & Land Development

Event Photography & Videography Training & Education

Inspections Transportation & Infrastructure

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Table 1: Industries served and functions performed
If granted, the exemption would permit AIRHAWK, LLC to conduct commercial operations of 

small unmanned aircraft systems (UAS) that meet or exceed operational and safety requirements 

set forth by Congress in Section 333. As an unmanned aircraft technology firm, AIRHAWK, 

LLC requests operations granted under like conditions and limitations set forth in previous, and 

similar, Section 333 summary exemptions granted by FAA. In the event that a grant is provided 

by the FAA, AIRHAWK, LLC is fully committed to abiding by the 31 conditions and limitations 

(attatched document appendix D “Conditions and Limitations) expressed in Exemption No.’s 

14661 (Mikon Haaksman dba Haaksman Media), 14644 (Richard N. Aarons Photography), 

11837 (Avant Unmanned Aerial Solutions LLC) and 11213 (Aeryon Labs, Inc.) and other grants 

made for similar requests.

Statutory Authority 

Section 333 (a) states that the FAA “shall determine if certain unmanned aircraft systems (UAS) 

may operate safety in the national airspace system before completion of the plan and rulemaking 

required by Section 332”. Section 333 (b) then lists several factors that should be considered in 

determining which UAS’ would be eligible for expedited integration into the National Airspace 

System (NAS). Specifically UAS’ that “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 the users of the national airspace system or the public, or pose a threat to 

national security.” If a UAS meets the criteria laid forth in Section 333 (b), Section 333 (c) FAA 

has the authority to decide if an airworthiness certification as specified by Title 49 United States 

Code, Section 44704 is required for operation. Section 333 (c) specifically states that the FAA 

can determine “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.” Thus, the FAA has the ability to allow a UAS that meets the criteria 

put forth in Section 333 (b) to operate within the NAS without an airworthiness certification as 

long as the UAS does not pose any hazard or threat to the NAS, public, and national security. 

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Request for Relief 

In meeting the aforementioned requirements, AIRHAWK, LLC requests relief and exemption 

from the regulations summarized in Table 2. 

Unmanned Aircraft Systems 

AIRHAWK, LLC is requesting an exemption to operate a DJI Phantom 2 Vision Plus, DJI 

Inspire, DJI Phantom 3, and Event 38 E384. 

AIRHAWK, LLC’s UAS proposed for operation through this request weigh less than 55 pounds, 

fly at speeds of no more than 100 miles per hour (MPH), carry neither a pilot nor passenger, 

carry no explosive materials or flammable liquid fuels, and will operate within approved flight 

areas and heights through coordination and communication with the Flight Standards District 

Office (FSDO), Air Traffic Organization (ATO), air traffic control facilities and personnel, and 

any other entities or persons to satisfy terms set forth by the FAA for this exemption request. 

Table 2: Relief and exemptions summary 

14 CFR 61.113(a) and (b) 

14 CFR 91.109 

14 C.F.R. 91.7 (a) and (b)

14 CFR 91.119 

14 CFR 91.9 (b) (2) 

14 CFR 91.121

14 CFR 91.103

14 CFR 91.151(a)

14 C.F.R. 91.401-91.417

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DJI Phantoms and Inspire 

The Phantoms and Inspire UAS are four-rotor, lithium polymer battery powered unmanned 

aircraft manufactured by DJI. DJI is a global leader in the UAS market with thousands of their 

products in use for professional and recreational purposes. 

Given their extensive use and reliability, AIRHAWK, LLC asserts both the Inspire and Phantom 

series platforms can operate safely in the National Airspace System (NAS) through their 

appropriate use and operations in accordance with AIRHAWK, LLC’s training and operating 

parameters. 

These vertical takeoff and land (VTOL) quad-copters have GPS, autonomous flight capabilities, 

with telemetry and manual ground control. These aircraft are equipped with gimbals and high 

definition cameras. Each of these platforms have the capability to limit flight height above 

ground level (AGL) and limit flights in controlled airspace. 

The Phantom’s dimensions are 8.1 x 17 x 12.5 inches. The Inspire is 22 in x 22 in x 8 in. Both 

weight under 10 pounds. The following is representative of failsafe emergency procedures 

available between the Phantom and Inspire. 

- Loss of Communication: If the communication link with the PIC/operators ground 

control station is lost, the platform will initiative a return to home mode after three 

seconds of transmission loss. 

- Low Battery: Initiated automatically based on remaining battery life, altitude, and 

distance from home point - when the battery level is too a warnings is alerted to the PIC/

operator and the aircraft can automatically begin a return to home procedure. 

- Loss of GPS: Losing a GPS signal while flying autonomously will trigger the aircraft to 

hover using onboard altitude sensing. The PIC can then land the aircraft as soon as 

possible. 

Event 38 E384 

The E384 UAS is manufactured by Event 38. This lightweight fixed-wing platform is powered 

by a lithium polymer battery operated by a ground control station, and associated data link 

equipment. The E384 is made of a foam airframe, weighs less than 10 pounds, has approximately 

a 6 foot wingspan, and is 4.5 feet in length. The cruising operational speed of is approximately 

27 mph (23.5 knots). This small, lightweight unmanned aircraft operating at relatively slow 

AIRHAWK, LLC 4 of 20
speeds will pose little to no threat or hazard to people or structures on the ground, thus making it 

an exponentially safer alternative to manned, fixed-wing aircraft operating for similar 

applications. 

The E384 functions primarily to provide aerial imagery and remote sensing capabilities using 

one of a selection of interchangeable cameras. High resolution imagery enable data collection, 

extraction, and analysis from imagery produced by these cameras with application to numerous 

industries such as surveying, architecture, engineering, agriculture, insurance, planning, and 

transportation just to name few. Information gleaned from the imagery will help in countless 

ways like maximizing crop yields, improving response times and coordination following natural 

disasters, expediting insurance adjustment claims, and enhanced decision making and overall 

efficiencies amongst several industries ranging from real estate, planning, asset management, and 

more by having access to higher quality data. All providing a great benefit to the economy and 

the overall public interest. 

The E384 is a hand launched platform that requires no runway for take-off and landing. Once 

launched, the E384 will operate at an altitude of 400 ft. AGL or less over a designated and 

authorized flight area. 

Prior to each flight, the Pilot in Command (PIC) will set dimensions of a designated flight area 

and relevant flight parameters to ensure the E384 operates within the lateral, not to exceed visual 

line- of-sight (VLOS), and vertical, not to exceed 400 feet AGL, geographic limits of an 

approved site for operation. In the event a critical issue is detected e.g. a low battery state or loss 

of datalink, the E384 will immediately initiate a return-to-launch/home sequence. 

The E384 has extensive flight experience and a history of operational success overseas, including 

flights by over one hundred professional operators on 6 continents. The items below overview 

examples of its successful use provided from the manufacturer:

— Used to survey potential land for hydroelectric power plant construction in Uganda. 

— The National Technical University of Athens in Greece used it for studying open-pit 

mining. 

— The Belize Fishery Department began routine flights with the E384 to track illegal fishing in protected waters. 

— Recently the E384 was flown over three days at the Cleveland Airshow in the United States in a demonstration of its ability to safely integrate and operate in the NAS. 

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Each of the UAS platforms described above are equipped with advanced sensors and high 

definition cameras. They also have built-in capabilities to limit flight altitude above ground level 

(AGL) and the radius distance flown from the pilot/operator. Safety parameters to prevent, if 

needed, operations in controlled airspace through a no fly zone feature is also possible with the 

DJI platforms. 

Each of the AIRHAWK, LLC’s UAS have integrated safety features designed to help ensure the 

safety of persons and property within and surrounding an active operation area. For instance, as 

described above, if one of the aircraft lose communication with its ground control station or 

geographic positioning system (GPS) signal the aircraft can autonomously return to a predetermined location or hover in place until the manually landed safely, respectively. 

The Petitioner has supplied the following additional information as appendices for consideration 

of this request: 

- DJI Phantom Series Operation, Maintenance Materials (Appendix A) 

- DJI Inspire Operation, Maintenance Materials (Appendix B) 

- Event38 E384 Operation, Maintenance, and Training Materials (Appendix C) 

Aircraft Marking

Each of AIRHAWK, LLC’s UAS will be identified by serial number, registered in accordance 

with 14 C.F.R. Part 47, and have an identification (N-Number) markings displayed as large as 

practicable in accordance with 14 C.F.R. Part 45. 

Pre-flight Inspection, Maintenance 

Before each flight an AIRHAWK, LLC PIC will perform a series of pre-flight and takeoff checks 

as defined by the manufacturer noted in the Appendices provided. 

Routine inspection of all aircraft components, including, but not limited to the items listed below 

will take place: 

- Motors, wiring and connectors 

- Propellers, smooth, no chips or defects

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- Batteries, wiring and connectors 

- Remote command and control 

- Ground control station 

UAS Operating Parameters 

AIRHAWK, LLC PICs and visual observers, present during any and all flights, will ensure all 

operation remain within VLOS. Flights will be limited to 400 feet AGL – which is accurately 

measured by GPS. AIRHAWK, LLC’s UAS operator and PIC are well equipped and trained for 

operations sought in this exemption. 

Communication and coordination with the appropriate FSDO will take place prior to operations, 

as needed. Further coordination will take place, as required, with the Air Traffic Organization to 

obtain a Certificate of Authorization (COA) prior to any operations granted in this requested 

exemption. AIRHAWK, LLC’s UAS will not operate within 5 nautical miles of an airport 

reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for 

airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA 

published aeronautical chart, unless a letter of agreement with that airport’s management is 

obtained or otherwise permitted by a COA issued to the exemption holder. The letter of 

agreement with the airport management must be made available to the Administrator or any law 

enforcement official upon request. 

AIRHAWK, LLC’s UAS operations will remain clear and yield to the right of way of all manned 

aircraft operations and activities (including, but not limited to, ultralight vehicles, parachute 

activities, parasailing activities, and hangliders). 

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PILOT IN COMMAND AND OBSERVER OPERATIONS & 

QUALIFICATIONS

The Pilot in Command (PIC) and Visual Observer (VO) will operate all Unmanned Aircraft 

(UAS) while adhering to the following: 

— The UAS will not be operated at a speed exceeding 87 knots (100 miles per hour) nor 

will the UAS be operated at airspeeds greater than the maximum UAS operating airspeed 

recommended by the aircraft manufacturer. 

— The UAS will be operated at an altitude of no more than 400 feet above ground level. 

— The UAS will be operated within Visual Line of Sight (VLOS) of the PIC at all times. 

— All operations will utilize a VO. The UAS will be operated within the VLOS of the PIC 

and VO at all times. The PIC will be designated before the flight and will not transfer his 

or her designation for the duration of the flight. The PIC will ensure that the VO can 

perform the duties required of the VO. 

— All operating documents attached to this application will be accessible during UAS 

operations and made available to an administrator upon request. 

— Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics will undergo a functional test flight prior to conducting further 

operations. Functional test flights will only be conducted by a PIC with a VO and will 

remain at least 500 feet from other people. The functional test flight will be conducted in 

such a manner so as to not pose an undue hazard to persons and property. 

— The operator will be responsible for maintain and inspecting the UAS to ensure that it is 

in a condition for safe operation. 

— Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

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

operation of the UAS, the aircraft will be prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for safe flight. 

— The operator will follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

— All UAS operations will comply with all manufacturer safety bulletins.

— The Pilot in Command (PIC) will maintain a private pilot license and current FAA 

airman medical certificate or a valid U.S. driver’s license issued by the federal 

government. In addition, the PIC will maintain 40 hours cumulative flying time for the 

UAS utilized in operations. In addition, two (2) hours flying time and three (3) takeoffs 

and landings within thirty (30) days of the type of UAS utilized in operations will also be 

maintained. 

— The operator will not permit any PIC to operate unless the PIC has demonstrated the 

ability to safely operate the UAS. 

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— UAS operations will not be conducted during night. 

— The UAS will not operate within 5 nautical miles of an Airport Reference Point (ARP). 

— The UAS will 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. 

— If the UAS loses communication or loses its GPS signal, the UA will return to a predetermined location within the private or controlled-access property. 

— The PIC will abort the flight in the event of unpredicted obstacles or emergencies. 

— The PIC will ensure at least a 5 minute reserve powered flight time when completing all 

flight operations. 

— All operations will be conducted in accordance with an Air Traffic Organization (ATO) 

Certificate of Waiver or Authorization (COA). 

— All UAS operated will be identifiable by serial number and/or equivalent marking 

— All documents used by the operator to ensure the safe operation and flight of the UAS 

will be available to the PIC (and administrator or any law enforcement upon request) any 

time the aircraft is operating. 

— The UAS will remain clear and give way to all manned aviation operations and activities 

at 

all times. 

— The UAS will not be operated by the PIC from any moving device or vehicle. 

— All flight operations will be conducted at least 500 feet from all non-participating 

persons, vessels, vehicles, and structures unless protective barriers or structures are in 

place to protect such persons or the owner/controller of any vessels, vehicles or structures 

has granted permission for operating closer to those objects and the PIC has made a 

safety assessment to determine that it does not present an undue hazard. 

— All operations will be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

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

boundaries of the operational area as defined by the applicable COA will be reported to 

the FAA’s UAS Integration Office within 24 hours. Accidents will also be reported to the 

National Transportation Safety Board (NTSB). 

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Radio Frequencies

Radio frequencies used will be those allotted by the Federal Communications Commission 

(FCC) for data transmission and vehicle control in unlicensed frequency bands. All devices used 

will comply with FCC usage and emissions regulations. 

Safety and Benefits of the UAS

AIRHAWK, LLC plans to operate their UAS in a variety of applications that generally would 

require flying expensive, full-size manned aircraft to successfully conduct a mission or project. 

Small, light, unmanned aircraft vehicles and their systems offer countless benefits over the use of 

full- sized manned aircraft to numerous industries by leveraging products from aerial surveys, 

remote sensing, data and imagery collection. Replacing significantly larger manned aircraft 

carrying flights crews and flammable fuel with UAS that do not carry people creates a much 

greater margin of safety for UAS operators and visual observers by contrast to a manned aircraft 

flight crew and passengers. The lower acquisition, operational, and personnel costs, in addition to 

reduced environmental impacts such as reduced noise and emissions, through the use of batteries 

for power – in lieu of fuel and combustion engines, are reasons why it is beneficial to the public 

interest for AIRHAWK, LLC to receive FAA authorization to operate its unmanned aircraft. 

Conclusion 

AIRHAWK, LLC (the petitioner) seeks an exemption pursuant to 14 C.F.R. and Section 333 of 

the FAA Modernization and Reform Act (FMRA) of 2012, which will permit the safe operation 

of our UASs for commercial and business use. By granting these exemptions, the FAA 

Administrator will be fulfilling the Congressional mandate of the FMRA while also providing a 

community critical UAS services and resources necessary for its future growth and development. 

The petitioner respectfully requests that the Administrator grants these exemptions under Section 

333. 

Respectfully,

AIRHAWK, LLC 10 of 20
Christopher Thelan

Manager

AIRHAWK, LLC

Specific Exemption Requests and Equivalent Level of Safety Showings 

14 C.F.R. § 91.7 (a) and (b): Civil aircraft airworthiness 

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is 

in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy 

mechanical, electrical, or structural conditions occur. 

Sections 91.7 (a) and (b) prohibit operation of a civil aircraft unless it is in airworthy condition. 

AIRHAWK, LLC requests an exemption from this regulation because their UAS would not 

operate with an airworthiness certificate under the proposal set forth in this filing. Given the size 

of the aircraft and requirements contained in the manuals for maintenance and use of safety 

check lists prior to each flight, as set forth in in the operators manual, an equivalent level of 

safety will be provided. 

The FAA has issued similar exemptions to this regulation, including to Tradecraft LLC, 

Exemption No. 11303. 

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 

Commercial pilot privileges and limitations. 

The regulation provides that no person that holds a Private Pilot certificate may act as pilot in 

Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act 

as pilot in command 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. 

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AIRHAWK, LLC’s proposed operations require that the unmanned aircraft PIC must hold at 

least a Sport Pilot Certificate issued by the FAA. Since the aircraft cannot carry passengers or 

property, it is believed that AIRHAWK, LLC meets the intent of 61.113 Subparagraph (b) even 

though the intent of this application is to conduct operations for compensation or hire. 

14 C.F.R. § 91.109(a): Flight Instruction 

Section 91.109 (a) provides that no person may operate a civil aircraft (except a manned free 

balloon) that is being used for flight instruction unless that aircraft has fully functioning dual 

controls. 

AIRHAWK, LLC’s UAS are remotely piloted aircraft, and, by design, do not have fully 

functional dual controls. Flight control is accomplished through the use of a remote control and 

transmitters that communicates with the aircraft via radio communications. Completing 

instruction through the AIRHAWK, LLC training program will ensure an equivalent level of 

safety. The FAA has approved exemptions for flight training without fully functional dual 

controls for a number of aircraft and for flight instruction in experimental aircraft. See 

Exemption Nos. 5778K and 9862A. 

14 C.F.R § 91.119 Minimum Safe Altitudes 

Except when necessary for takeoff or landing, no person may operate an aircraft below the 

following altitudes: 

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 

feet to any person, vessel, vehicle, or structure. 

As set forth herein by AIRHAWK, LLC, their UAS will never operate at an altitude higher than 

400 feet AGL. Due to the nature of work proposed for remote sensing, aerial surveys, data and 

imagery collection this work necessitates flights at relatively low altitudes, i.e. less than 500 feet 

AGL, and an exemption from Section 91.119(c) is needed. The equivalent level of safety will be 

achieved given the size, weight speed, and material with which AIRHAWK, LLC’s UAS are 

built. Additional consideration will be given prior to flights such as communication and 

permission with the land owner or the party controlling the land. With advance notice, all 

affected individuals will be aware of AIRHAWK, LLC’s remote sensing, aerial surveys, data and 

imagery collection. Compared to similar operations conducted with conventional aircraft or 

rotorcraft, which weigh thousands of pounds and carry flammable fuel, any risk associated with 

these operations will be far less than those currently allowed with such conventional aircraft 

AIRHAWK, LLC 12 of 20
operating at or below 500 feet AGL. The FAA has approved exemptions for minimum safe 

altitudes to Chustz Surveying – Exemption No. 11285. 

14 C.F.R § 91.121 – Altimeter Settings 

91.121 requires aircraft to maintain a cruising level or flight level in reference to a current 

reported altimeter setting. AIRHAWK, LLC’s UAS are not equipped with a programmable 

altimeter but rather determine location and altitude via an onboard GPS. Additionally, since the 

E384 will be operating at or below 400 ft. AGL, there is no need to maintain hemispherical 

cruising altitudes for de-confliction with manned aircraft. For these reasons AIRHAWK, LLC 

seeks exemption from this regulation. 

An equal level of safety will be achieved through the Phantom, Inspire and E384 GPS, which 

provides altitude and location data to the PIC via the ground control station. The UAS 

Operations Manual, provided as Appendices, specifically addresses monitoring altitude and GPS 

readings prior to commencing flight operations. Combined with the fact that the aircraft’s altitude 

will be visually monitored by the PIC and Visual Observer, an equal level of safety is attained in 

lieu of referencing an altimeter setting. 

The FAA has approved exemptions for minimum safe altitudes to Pravia – Exemption No. 

11166. 

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

Section 91.151 (b) prohibits an individual from beginning “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. 

The Phantom and Inspire series battery life provides at most 25 minutes of powered flight. 

Without an exemption from 14 C.F.R. §91.151, flights would be limited to 5 minutes or less. 

Given the limitations on AIRHAWK, LLC’s proposed operations, a lesser reserve for flight in 

VFR conditions is reasonable. AIRHAWK, LLC believes that an exemption from 14 C.F.R. § 

91.151 (a) is safe and consistent with the scope of a prior exemption. See Exemption 10673 

(allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). 

Operating the Phantom and Inspire UAS without 20 minutes of reserve fuel does not produce the 

type of risks Section 91.151 (a) intended to prevent. Given its weight and construction material, 

the risks are less then contemplated by the current regulation. AIRHAWK, LLC believes that an 

AIRHAWK, LLC 13 of 20
equivalent level of safety can be achieved by the fact that their UAS can safely utilize VTOL 

capability to quickly and safely land within 3 minutes of an area within VLOS once alerted of a 

low battery. 

Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, and 

10808. 

Part 91 Subpart E (91.401-91.417) – Maintenance, Preventative Maintenance, and 

Alterations 

These regulations provided the maintenance and inspections requirements in reference to Part 39 

and Part 43. 91.405 (a) specifically states that “no person may perform maintenance, preventive 

maintenance, and alterations on an aircraft other than as prescribed in this subpart and other 

applicable regulations, including part 43 of this chapter.” AIRHAWK, LLC seeks full exemption 

from these regulations due to the fact that these sections apply to an aircraft with an 

airworthiness certificate for which AIRHAWK, LLC is already seeking exemption. 

An equal level of safety will be achieved by using the Phantom, Inspire, and E384 Operations 

and Maintenance Manuals (see appendices provided with this exemption request) which provide 

instructions on regular and corrective maintenance. AIRHAWK, LLC’s will be responsible for 

conducting and logging maintenance in accordance with these procedures. AIRHAWK, LLC 

PICs test to confirm their UAS are suited for flight following any maintenance. Maintenance that 

AIRHAWK, LLC is not capable of performing, or covered in these procedures, will be 

performed by the manufacturers. 

Similar exemptions have been granted to others such as TradeCraft, Exemption 11303, Toledo 

Aerial Media, Exemption 11288, and Skyphilly, Exemption 11256. 

Appendix A - DJI Phantom Series Operation, Maintenance Materials 

- Phantom 2 Vision+ User Manual (EN) v1.8: http://download.dji- innovations.com/

downloads/phantom_2_vision_plus/en/Phantom_2_Vision_Plus_User_Manua 

l_v1.8_en.pdf. 

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- Phantom 2 Vision+ Pilot Training Guide (EN) v1.1: http://download.djiinnovations.com/downloads/phantom_2_vision_plus/en/

Phantom_2_Vision_Plus_Pilot_Trainin g_Guide_v1.1_en.pdf. 

— Phantom 3 Professional User Manual v1.6: https://dl.djicdn.com/downloads/

phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.pdf

— Smart Flight Battery Safety Guidelines: http://dl.djicdn.com/downloads/phantom_3/

en/Phantom_3_Intelligent_Flight_Battery_Safety_Guidelines__en.pdf

Appendix B - DJI Inspire Operation, Maintenance Materials 

- Inspire 1 User Manual v2.0: https://dl.djicdn.com/downloads/inspire_1/en/

Inspire_1_User_Manual_en_v2.0_1218.pdf

- Inspire 1 Safety Guidelines v1.0: http://download.dji- innovations.com/downloads/

inspire_1/en/Inspire_1_Safety_Guidelines_en.pdf. 

- Intelligent Flight Battery Safety Guidelines v1.4: http://dl.djicdn.com/downloads/

inspire_1/en/Inspire_1_Intelligent_Flight_Battery_Safety_Guidelines_1.4.pdf

- Inspire 1 Maintenance Manual v1.0: http://download.dji- innovations.com/downloads/

inspire_1/en/Inspire_1_Maintenance_ManualV1.0_en.pdf. 

Appendix C - Event38 E384 Operation, Maintenance Materials

— Event38 E384 Manuals: http://droneyard.com/e384opsman.pdf

Appendix D - Conditions and Limitations Example

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption. 

AIRHAWK, LLC 15 of 20

Note: Due to many materials linked above exceeding the maximum allowable upload file size on FAA’s 

exemption portal, this information is being provided in the form of direct links on the manufacturers 

website. Please contact AIRHAWK, LLC if this information needs to be supplied by another means. 
1. Operations authorized by this grant of exemption are limited to the DJI Phantom 2 Vision 

Plus, DJI Inspire and DJI Phantom 3 when weighing less than 55 pounds including 

payload. Proposed operations of any other aircraft will require a new petition or a petition 

to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the aircraft 

manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL. 

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

requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. 

driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the 

visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to 

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

VO 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 VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations 

in accordance with the conditions and limitations stated in this grant of exemption, are 

hereinafter referred to as the operating documents. The operating documents must be 

accessible during UAS operations and made available to the Administrator upon request. 

If a discrepancy exists between the conditions and limitations in this exemption and the 

procedures outlined in the operating documents, the conditions and limitations herein 

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 or any law enforcement official upon 

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

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

update or revision would affect the basis upon which the FAA granted this exemption, 

then the operator must petition for an amendment to its grant of exemption. The FAA’s 

AIRHAWK, LLC 16 of 20
UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates 

or revisions to the operating documents. 

8. 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 prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such a 

manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in 

a condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS 

is in a condition for safe flight. The pre-flight inspection must account for all potential 

discrepancies, e.g., inoperable components, items, or equipment. 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. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA 

airman medical certificate or a valid U.S. driver’s license issued by a state, the District of 

Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC 

must also meet the flight review requirements specified in

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability 

to safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption, including evasive and emergency maneuvers and maintaining 

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

flight hours and currency must be logged in a manner consistent with

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to 

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

this exemption are permitted under the terms of this 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 

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are considered nonparticipants, and the PIC must operate the UA with appropriate 

distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted 

with an ARP, the center of the airport symbol as denoted on the current FAA-published 

aeronautical chart, unless a letter of agreement with that airport’s management is obtained 

or otherwise permitted by a COA issued to the exemption holder. The letter of agreement 

with the airport management must be made available to the Administrator or any law 

enforcement official upon request. 

17. 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. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the intended 

operation and to operate after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The exemption 

holder may apply for a new or amended COA if it intends to conduct operations that 

cannot be conducted under the terms of the attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification (N

−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as 

large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at 

the Ground Control Station of the UAS any time the aircraft is operating.

These documents must be made available to the Administrator or any law enforcement 

official upon request. 

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24. The UA must remain clear and give way to all manned aviation operations and activities 

at all times. 

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

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

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 in a manner ensuring the safety of nonparticipating 

persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for 

operating closer to those objects 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. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons 

under this exemption. 

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

permission from the property owner/controller or authorized representative. Permission 

from property owner/controller or authorized representative will be obtained for each 

flight to be conducted. 

28. 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. 

If this exemption permits operations for the purpose of closed-set motion picture and television 

filming and production, the following additional conditions and limitations apply. 

29. The operator must have a motion picture and television operations manual (MPTOM) as 

documented in this grant of exemption. 

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption 

must submit a written Plan of Activities to the local Flight Standards District Office 

(FSDO) with jurisdiction over the area of proposed filming. The 3-day notification may 

be waived with the concurrence of the FSDO. The plan of activities must include at least 

the following: 

a. Dates and times for all flights; 

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b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption; 

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS; 

d. Make, model, and serial or N−Number of UAS to be used; 

e. Name and certificate number of UAS PICs involved in the aerial filming; 

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request; 

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation. 

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 

45, 47, 61, and 91.

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