UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: 

QuadCam LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 

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

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

OPERATION OF DJI PHANTOM 2 VISION+, DJI PHANTOM 3 UNMANNED

AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112-95)

Submitted on August 16, 2015

QuadCam LLC

Zachary David Marhafer

1331 Saddle Ct

Palm Harbor, FL 34683

727-510-0559

FAA Airman Certificate ATP3232267
! 2

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
! 3

SUMMARY

QuadCam LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

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

91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the

FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit 

QuadCam LLC to operate an Unmanned Aircraft System (UAS) for the commercial 

purpose of conducting aerial video and photography of construction sites, real estate, 

landscape, search and rescue, as well as perform over video certain areas of the United 

States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

QuadCam LLC provides its clients with expertise and knowledge in advanced 

technologies and solutions to increase efficiency, productivity and effectiveness.

QuadCam LLC has over 10 years of professional experience in aviation. He has over 

10 years recreational / hobby experience in all aspects of aerial video and photography. 

The objective of QuadCam LLC 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 event photography/videography 

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

• Search and Rescue operations

BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2 Vision+, DJI Phantom 3 UASs

QuadCam LLC seeks an exemption to operate DJI systems for compensation or hire 

within the NAS. The DJI Phantom 2 Vision+ and DJI Phantom 3 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	Phantom	3	has	a	maximum	gross	weight	of	2	pounds	13.1	ounces,	a	length	of																					

		16.2	inches,	width	of	16.6	inches,	height	of	10.5	inches,	and	a	maximum	speed	of		

		approximately	31.1	knots
! 4

The DJI Phantom 2 Vision+ and DJI Phantom 3 UAs that will be operated by QuadCam 

LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as 

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

Part 45, Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, QuadCam LLC, pursuant to the provisions of the Federal Aviation 

Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 

(FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby 

petitions the Administrator to commercially operate the DJI Phantom 2 Vision+, DJI 

Phantom 3 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, 91.151(b), 91.405(a),

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

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

unmanned aircraft and its operation, QuadCam LLC operation of DJI Phantom 2

Vision+ and DJI Phantom 3 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, QuadCam LLC requests relief from Sections 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for 

maintenance that only apply to aircraft with an airworthiness certificate.

QuadCam LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. QuadCam LLC 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 Phantom 3 Instruction Manual). 

Furthermore, QuadCam LLC will document and maintain all maintenance records for the 

DJI Phantom 2 Vision+ and DJI Phantom 3 UASs.

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

privileges and limitations: Pilot in command, is requested by QuadCam LLC to the extent 

necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level 

certificate, as well as an airman medical certificate, and who has demonstrated, by meeting 

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

DJI Phantom 2 Vision+ and DJI Phantom 3 UASs in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

QuadCam LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs do not require an 

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

QuadCam LLC submits that they will ensure that the DJI Phantom 2 Vision+ and DJI 

Phantom 3 UASs are in an airworthy condition, prior to every flight, by determining that 

the
! 5

UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, 

and DJI Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual), and that the aircraft 

are in a condition for safe flight.

QuadCam LLC also seeks an exemption from the requirements of Section 91.121, entitled 

Altimeter Settings, as the DJI Phantom 2 Vision+ and DJI Phantom 3 UAs will not have a 

typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 

Vision+ and DJI Phantom 3 UAs 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 QuadCam LLC operation of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs within visual line of sight, at or below 500 feet AGL, 

will ensure a level of safety equivalent to Section 91.121.

Additionally, QuadCam LLC seeks an exemption from the requirements of Section

91.151(b), entitled Fuel requirements for flight in VFR conditions. QuadCam LLC

submits that safety will not be affected by operation of the DJI Phantom 2 Vision+ and DJI 

Phantom 3 UAs during daylight hours in visual meteorological conditions (VMC) under 

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

approximately 13.5 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, QuadCam LLC provides the following 

information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

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

Zachary Marhafer

QuadCam LLC 

1331 Saddle ct

Palm Harbor, FL 34683

727-510-0559

Email:quadcamus@gmail.com

B. The Specific Sections Of 14 C.F.R. From Which QuadCam LLC Seeks

Exemption.

1. QuadCam LLC Seeks Exemption From The Requirements Of Section

61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, 

subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command

(PIC) of an aircraft that is carrying passengers or property for compensation or

hire; nor may that person, for compensation or hire, act as PIC of an aircraft.
! 6

(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. QuadCam LLC Seeks Exemption From The Requirements Of Section

91.7(a).

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the 

following:

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

3. QuadCam LLC Seeks Exemption From The Requirements Of Section

91.121.

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

part:

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

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

when operating--

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

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

within 100 nautical miles of the aircraft;

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

this section, the current reported altimeter setting of an appropriate 

available station; or

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

departure airport or an appropriate altimeter setting available before 

departure.

4. QuadCam LLC Seeks Exemption From The Requirements Of Section

91.151(b).

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

(b), states the following:

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

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

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

after that for at least 20 minutes.
! 7

5. QuadCam LLC 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. QuadCam LLC Seeks Exemption From The Requirements Of Section

91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

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

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

maintenance, rebuilding, or alteration unless--

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

of this chapter[.]

7. QuadCam LLC Seeks Exemption From The Requirements Of Sections

91.409(a)(1) And 91.409(a)(2).

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

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

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

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

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

chapter; or

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

with part 21 of this chapter.

8. QuadCam LLC Seeks Exemption From The Requirements Of Sections

91.417(a) And 91.417(b).

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

following:

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

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

specified in paragraph (b) of this section:

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

records of the 100-hour, annual, progressive, and other required or approved
! 8

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:

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

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

is performed.

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

transferred with the aircraft at the time the aircraft is sold.
! 9

(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 QuadCam LLC Seeks And The Reason QuadCam LLC Seeks 

The Relief.

1. Extent Of Relief QuadCam LLC Seeks And The Reason QuadCam LLC

Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: 

Pilot in command, is requested to the extent necessary to allow a PIC holding a private 

pilot or higher level certificate, as well as a current and valid airman medical certificate, 

and who has met certain flight-hour and currency requirements, to conduct the proposed 

UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that 

a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with 

any business or employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or property for compensation 

or hire.

As set forth more fully below, QuadCam LLC 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 Phantom 3 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 Phantom 3 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, QuadCam LLC submits that all flights of the DJI Phantom 2 Vision+ and DJI 

Phantom 3 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be 

incidental to QuadCam LLC business; and (2) will not carry passengers or property for 

compensation or hire.

2. Extent Of Relief QuadCam LLC Seeks And The Reason QuadCam LLC

Seeks Relief From Section 91.7(a).

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

required to allow QuadCam LLC to determine that the DJI Phantom 2 Vision+ and DJI 

Phantom 3 UASs are in airworthy condition prior to every flight by ensuring that the UAS 

is in compliance with the operating documents (i.e., DJI Phantom 2 Vision+ and DJI 

Phantom 3 Instruction Manual).

QuadCam LLC seeks the requested relief because the DJI Phantom 2 Vision+ and

DJI Phantom 3 UASs do not require an airworthiness certificate in accordance with 14
! 10

C.F.R. Part 21, Subpart H. Therefore, QuadCam LLC will ensure that the DJI Phantom 2 

Vision+ and DJI Phantom 3 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 Phantom 3 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 QuadCam LLC Seeks And The Reason QuadCam LLC

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 Phantom 3 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), QuadCam LLC

seeks the requested relief because the DJI Phantom 2 Vision+ and DJI Phantom 3

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 Phantom 3 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 QuadCam LLC Seeks And The Reason QuadCam LLC

Seeks Relief From Section 91.151(b).

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

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

Vision+ and DJI Phantom 3 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. QuadCam LLC 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 Phantom 3 UAs will severely constrain the practicality of any aerial 

video or still photo flight operations that QuadCam LLC proposes to conduct pursuant to

this Petition.

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

and DJI Phantom 3 UASs, the DJI Phantom 2 Vision+ and DJI Phantom 3 operating 

documents, and QuadCam LLC proposed operating limitations, ensure that QuadCam LLC

will safely operate the battery powered DJI Phantom 2 Vision+ and DJI Phantom 3 UAs 

during daylight hours in visual meteorological conditions (VMC), under
! 11

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 QuadCam LLC Seeks And The Reason QuadCam LLC

Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), 

And 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only 

apply to aircraft with an airworthiness certificate, QuadCam LLC requests relief from 

these Sections because the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs do not 

require airworthiness certificates. As set forth more fully below, the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs meet the conditions of FMRA Section 333 for operation 

without an airworthiness certificate. Accordingly, QuadCam LLC 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 QuadCam LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI 

Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual). Furthermore, QuadCam LLC

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

DJI Phantom 3 UASs.

D. The Reasons Why Granting QuadCam LLC Request Would Be In The

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

Granting the present Petition will further the public interest by allowing QuadCam LLC

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 Phantom 3 UASs will decrease 

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

Notably, the benefits of QuadCam LLC’s proposed operation of the DJI Phantom 2

Vision+ and DJI Phantom 3 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 Phantom 3 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 Phantom 3

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 Phantom 3 UAs do not require an airport to takeoff or land. Likewise, a

reduction of manned aircraft conducting aerial video and photography missions would
! 12

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 Phantom 3 UASs.

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ and DJI Phantom 3 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 Phantom 3 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 

Phantom 3 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 Phantom 3 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 Phantom 3 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 Phantom 3 UASs Will Benefit The 

Economy.

In addition to being safe and efficient, the DJI Phantom 2 Vision+ and DJI Phantom 3

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 DJI Phantom 3 UASs 

will allow United States based companies, like QuadCam LLC, to remain competitive

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

fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out 

leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered DJI Phantom 2

Vision+ and DJI Phantom 3 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.
! 13

By operating the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs, companies such as 

QuadCam LLC, 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 Phantom 3 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, QuadCam LLC’s proposed operation of the DJI Phantom 2 Vision+ and DJI 

Phantom 3 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs will be operated only in compliance with operating 

documents (i.e., the QuadCam LLC Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Phantom 2 Vision+ and DJI Phantom 3 Instruction Manual) which requires 

property owner involvement as well as local law enforcement notification, and in 

accordance with the Federal Aviation Regulations, including the minimum altitude 

requirements of 14 C.F.R. § 91.119.

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

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

Provided By The Rule From Which QuadCam LLC Seeks Exemption.

1. Reasons Why The DJI Phantom 2 Vision+ and DJI Phantom 3 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, QuadCam LLC’s operation of the DJI Phantom

2 Vision+ and DJI Phantom 3 UASs meet the conditions of FMRA Section 333, and will 

not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of 

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

Section 333 states the following, in part:

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

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

Transportation shall determine if certain unmanned aircraft systems may 

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

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

section 334 of this Act.
! 14

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

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

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

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

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

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

threat to national security; and

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

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1).

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

that certain unmanned aircraft systems may operate safely in the national 

airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system.

In seeking this exemption, QuadCam LLC submits that the DJI Phantom 2 Vision+ and 

DJI Phantom 3 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 Phantom 3

UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 Vision+ and DJI Phantom 3

UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 Vision+ and DJI Phantom 3 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 

Phantom 3 UASs.

The technical specifications of the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs are 

set forth by the DJI Phantom 2 Vision+ and DJI Phantom 3 Specifications and Data Sheet, 

attached hereto as Exhibit A and B.

ii. The DJI Phantom 2 Vision+ and DJI Phantom 3 UASs Autonomous 

Flight And Navigation Modes Enable The UASs To Remain Within 

A Defined Operational Area.

The DJI Phantom 2 Vision+ and DJI Phantom 3 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 Phantom 3 UASs is provided at pages 25-35 

of the DJI Phantom 2 Vision+ and pages 11-15 of the DJI Phantom 3 User Manuals, 

attached hereto as Exhibit C and D.
! 15

iii. The DJI Phantom 2 Vision+ and DJI Phantom 3 UASs Are 

Designed For Automatic Return To Home Point Or Hover In The 

Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 Vision+ and DJI Phantom 3 UAs will 

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

Vision+ and DJI Phantom 3 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 27 through 29 and for the DJI Phantom 3 at pages 11 through 15 of the 

DJI Phantom 2 Vision+ and DJI Phantom 3 User Manuals, attached hereto as Exhibit C 

and D.

iv. The DJI Phantom 2 Vision+ and DJI Phantom 3 GCS And 

Its Operation.

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

and DJI Phantom 3 GCS and flight control software is provided at pages 32 through 43 

of the DJI Phantom 2 Vision+ User Manual and pages 40 through 47 of the DJI Phantom 

3 User Manual. DJI Phantom 2 Vision+ and DJI Phantom 3 User Manuals are attached 

hereto as Exhibits C and D.

b. Flight Operations Of DJI Phantom 2 Vision+ and DJI Phantom 3 UASs

Are Limited To The Line Of Sight Of A Certificated Pilot in Command

With A Safety Observer.

QuadCam LLC will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs. Additionally, a safety observer will assist all pilots

during flight time.

c. Flights Of DJI Phantom 2 Vision+ and DJI Phantom 3 UASs Will Be

Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, QuadCam LLC proposes to commercially operate DJI 

Phantom 2 Vision+ and DJI Phantom 3 UASs for the special purpose of conducting 

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

following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less 

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

Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other 

aircraft will require a new petition or a petition to amend this grant.
! 16

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

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

questions arise regarding updates or revisions to the operating documents.

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

condition for safe flight. If the inspection reveals a condition that affects the
! 17

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 

third- class medical certificate.

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

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

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

exemption, including evasive and emergency maneuvers and maintaining 

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

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

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

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

only be conducted during dedicated training sessions. During training, 

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

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

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

91.119.
! 18

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

1.1. All operations must be conducted under visual meteorological conditions

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

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

rules (SVFR) are not authorized.

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

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

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

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

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

the Administrator upon request.

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

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

PIC.

22. If the UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or be recovered 

in accordance with the operating documents.

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

emergencies in accordance with the operating documents.

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

forecast weather conditions) there is enough power to fly at normal cruising 

speed to the intended landing point and land the UA with 25% battery power 

remaining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate 

of Waiver or Authorization (COA) prior to conducting any operations under the 

grant of exemption. This COA will also require the operator to request a Notice 

to Airman (NOTAM) not more than 72 hours in advance, but not less than 48

hours prior to the operation. All operations shall be conducted in accordance 

with airspace requirements in the ATO issued COA including class of airspace, 

altitude level and potential transponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by 

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

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

Subpart C. Markings must be as large as practicable.

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

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements.
! 19

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.

QuadCam LLC 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 Phantom 3 UASs unless that PIC has demonstrated, by 

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

operate the
! 20

DJI Phantom 2 Vision+ or DJI Phantom 3 UAS in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures.

Considering QuadCam LLC’s proposed area of operations, and the operating limitations 

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

those of commercial pilot requirements (See Exemption No. 11062); and the airmanship 

skills necessary to safely operate the DJI Phantom 2 Vision+ or Phantom 3 UAS, 

QuadCam LLC submits that the additional manned airmanship experience of a 

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

QuadCam LLC’s specific proposed flight operations.

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

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

Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

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

QuadCam LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ or DJI 

Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight-hour 

requirements or the DJI Phantom 2 Vision+ or DJI Phantom 3 UAS training and currency 

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

Phantom 3 UAS in a manner consistent with this exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures.

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14

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

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

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

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

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

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

safety during QuadCam LLC’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
! 21

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

the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the 

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

currency purposes). The FAA finds that at a minimum, the flight-hour requirements

in Exemption No. 11062 are appropriate to practice and build proficiency in the 

skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance 

with applicable regulations would satisfy this requirement. Training, proficiency, 

and experience-building flights can also be conducted under the grant of exemption 

to accomplish the required flight time. During training, proficiency, and

experience-building flights the PIC is required to operate the UA with appropriate 

distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15.

Accordingly, QuadCam LLC will ensure safe operations by not allowing any PIC to 

operate the DJI Phantom 2 Vision+ or DJI Phantom 3 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 DJI Phantom 3 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, QuadCam LLC will ensure that the DJI Phantom 2 Vision+ or DJI 

Phantom 3 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 Phantom 3 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 QuadCam LLC’s operation of the DJI 

Phantom 2 Vision+ and DJI Phantom 3 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
! 22

each flight, a zero altitude initiation point is automatically established by the UASs at 

ground level.

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

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

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

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

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

Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14

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

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

and (3) the location of the proposed flight operations. Accordingly, QuadCam LLC will 

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

Phantom 3 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 Phantom 3 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 Phantom 3 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 

Phantom 3 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 

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

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

aircraft to operate at less than the minimums prescribed in Section 91.151, including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to 

those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063,

11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156,

11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections

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

Not Adversely Affect Safety.

In seeking this exemption, QuadCam LLC submits that the equivalent level of safety with 

regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met
! 23

because QuadCam LLC 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 QuadCam LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ and DJI Phantom 3

Instruction Manual). Furthermore, QuadCam LLC will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs.

Since the DJI Phantom 2 Vision+ and DJI Phantom 3 UASs will be inspected as prescribed 

by the operating documents, QuadCam LLC will maintain the equivalent level of safety 

established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI 

Phantom 2 Vision+ and DJI Phantom 3 User Manuals are attached hereto as Exhibit C and

D; a copy of the DJI Phantom 2 Vision+ and DJI Phantom 3 UAS Maintenance LOG is

attached hereto as Exhibit E.

Likewise, the exemption sought will not adversely affect safety because QuadCam LLC

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 Phantom 3 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)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not

adversely affected when the technical characteristics and operating limitations of the UAS

are considered.

In consideration of QuadCam LLC’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 2 Vision+ and DJI Phantom 3

UASs, QuadCam LLC submits that safety will not be adversely affected by granting

exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and

91.417(a) and (b). The FAA has previously granted relief specific to UAS in circumstances

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062,

11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150,

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

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, QuadCam LLC requests that 

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

Vision+ and DJI Phantom 3 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,
! 24

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

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

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

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

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

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

without airworthiness certification in accordance with any requirements that must be 

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

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

§ 21.16, for operation of the DJI Phantom 2 Vision+ and DJI Phantom 3 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 Leading Edge’s intended operation of the DJI Phantom 2

Vision+ and DJI Phantom 3 UASs, which contain such safety standards that the

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

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

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

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

From Which QuadCam LLC Seeks Exemption:

QuadCam LLC seeks exemption from the requirements of 14 C.F.R Sections

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

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

A Brief Description Of The Nature Of The Exemption QuadCam LLC

Seeks:

This exemption will permit QuadCam LLC to commercially operate an 

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

photography over certain areas of the United States.
! 25

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

QuadCam LLC’s Request.

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

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

UAS may operate safely in the NAS. As such, QuadCam LLC’s request for exemption 

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

set forth above.

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

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

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

certification.

As discussed in detail above, QuadCam LLC will operate the DJI Phantom 2

Vision+ and DJI Phantom 3 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, QuadCam LLC 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 Phantom 3 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 QuadCam LLC to safely, efficiently, and economically operate the DJI 

Phantom 2 Vision+ and DJI Phantom 3 UASs commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, QuadCam LLC respectfully 

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

of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI 

Phantom 2 Vision+ and DJI Phantom 3 UASs commercially for the purpose of 

conducting aerial video and photography over certain areas of the United States.
! 26

Dated: August 16, 2015

Respectfully submitted,

QuadCam LLC

Zachary Marhafer

QuadCam LLC

Zachary Marhafer

1331 Saddle Ct

Palm Harbor, FL 34683

727-510-0559

Appendices:

A – DJI Phantom 2 Vision+ Specifications Data Sheet

B – DJI Phantom 3 Specifications Data Sheet

C – Link to DJI Phantom 2 Vision+ Manufacturer’s User Manual

D – Link to DJI Phantom 3 Manufacturer’s User Manual
! 27

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

QuadCam LLC only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user to 

set parameters which will not allow flight into controlled airspace. Parameters can also be 

set to limit flight to no higher than a predetermined and set altitude as well as limit flight 

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

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

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

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

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

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

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

1.1.2 Gimbal

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

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V
! 28

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W
! 29

APPENDIX – B

DJI PHANTOM 3 TECHNICAL 

SPECIFICATIONS

QuadCam LLC only utilizes safe and reliable UASs. DJI is an industry leader in small 

UAS production. DJI UASs are loaded with ground breaking software enabling the user to 

set parameters which will not allow flight into controlled airspace. Parameters can also be 

set to limit flight to no higher than a predetermined and set altitude as well as limit flight 

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

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

Aircraft

WEIGHT	(INCLUDING	BATTERY	AND	PROPELLERS)

1280	g

DIAGONAL	SIZE	(INCLUDING	PROPELLERS)

590	mm

MAX	ASCENT	SPEED

5	m/s

MAX	DESCENT	SPEED

3	m/s

HOVER	ACCURACY

·	Vertical:	+/-	0.1	m	(when	Vision	Positioning	is	active)	or	+/-	0.5	m

											·	Horizontal:	+/-	1.5	m

MAX	SPEED

16	m/s	(ATTI	mode,	no	wind)

MAX	ALTITUDE	ABOVE	SEA	LEVEL

6000	m

OPERATING	TEMPERATURE

0°C	to	40°C

GPS	MODE

GPS/GLONASS

Camera

SENSOR

Sony	EXMOR	1/2.3”	Effective	pixels:	12.4	M	(total	pixels:	12.76	M)

LENS

FOV	94°	20	mm	(35	mm	format	equivalent)	f/2.8,	focus	at	∞

ISO	RANGE

100-3200	(video)	100-1600	(photo)

SHUTTER	SPEED

8s	-1/8000s

IMAGE	MAX	SIZE

4000	x	3000

STILL	PHOTOGRAPHY	MODES

·	Single	Shot

·	Burst	Shooting:	3/5/7	shots

·	Auto	Exposure	Bracketing	(AEB):	3/5

·	Bracketed	Frames	at	0.7EV	Bias

·	Time-lapse
! 30

VIDEO	RECORDING	MODES

Phantom	3	Professional

·	UHD:	4096x2160p	24/25,	3840x2160p	24/25/30

·	FHD:	1920x1080p	24/25/30/48/50/60

·	HD:	1280x720p	24/25/30/48/50/60

Phantom	3	Advanced

·	FHD:	1920x1080p	24/25/30/48/50/60

·	HD:	1280x720p	24/25/30/48/50/60

SUPPORTED	SD	CARD	TYPES

Micro	SD

Max	capacity:	64	GB.	Class	10	or	UHS-1	rating	required

MAX	BITRATE	OF	VIDEO	STORAGE

Phantom	3	Professional

60	Mbps

Phantom	3	Advanced

40	Mbps

SUPPORTED	FILE	FORMATS

·	FAT32/exFAT

·	Photo:	JPEG,	DNG

·	Video:	MP4,	MOV	(MPEG-4	AVC/H.264)

OPERATING	TEMPERATURE

0°C	to	40°C

Gimbal

CONTROLLABLE	RANGE

Pitch	-90°	to	+30°

STABILIZATION

3-axis	(pitch,	roll,	yaw)

Vision

Positioning

MAX	VELOCITY

Less	than	8	m/s	(when	2	m	above	ground)

ALTITUDE	RANGE

30	cm-300	cm

OPERATING	RANGE

30	cm-300	cm

OPERATING	ENVIRONMENT

Surface	with	clear	pattern	and	adequate	lighting	(Lux	>	15)

Remote

Controller

OPERATING	FREQUENCY

2.400	GHz-2.483	GHz

MAX	DISTANCE

2000m	(outdoors	and	unobstructed)

VIDEO	OUTPUT	PORT

USB

OPERATING	TEMPERATURE

0°C-	40°C

BATTERY

6000	mAh	LiPo	2S

MOBILE	DEVICE	HOLDER

For	tablet	or	phone

RECEIVER	SENSITIVITY	(1%PER)

-101	dBm	±2	dBm
! 31

TRANSMITTER	POWER	(EIRP)

·	FCC:	20	dBm

·	CE:	16	dBm

WORKING	VOLTAGE

1.2	A	@7.4	V

Battery

Charger

VOLTAGE

17.4	V

RATED	POWER

Phantom	3	Professional

·	100	W

Phantom	3	Advanced

·	57	W

CAPACITY

4480	mAh

VOLTAGE

15.2	V

BATTERY	TYPE

LiPo	4S

ENERGY

68	Wh

NET	WEIGHT

365	g

MAX	FLIGHT	TIME

Approximately	23	minutes

OPERATING	TEMPERATURE

-10°C	to	40°C

MAX	CHARGING	POWER

100	W

App	/	Live

View

MOBILE	APP

DJI	Pilot

EIRP

100mW

LIVE	VIEW	WORKING	FREQUENCY

2.4GHz	ISM

LIVE	VIEW	QUALITY

720P	@	30fps	(depending	on	conditions	and	mobile	device)

LATENCY

220ms	(depending	on	conditions	and	mobile	device)

REQUIRED	OPERATING	SYSTEMS

·	iOS	8.0	or	later

·	Android	4.1.2	or	later

RECOMMENDED	DEVICES

·	iOS:	iPhone	5s,	iPhone	6,	iPhone	6	Plus,	iPad	Air,	iPad	Air	Wi-Fi	+	Cellular,	iPad

mini	2,	iPad	mini	2	Wi-Fi	+	Cellular,	iPad	Air	2,	iPad	Air	2	Wi-Fi	+	Cellular,	iPad

mini	3,	and	iPad	mini	3	Wi-Fi	+	Cellular.	This	app	is	optimized	for	iPhone	5s,

iPhone	6,	and	iPhone	6	Plus

·	Android:	Samsung	S5,	Note	3,	Sony	Xperia	Z3,	Google	Nexus	7	II,	Google	Nexus

9,	Mi	3,	Nubia	Z7	mini

·	*Support	for	additional	Android	devices	available	as	testing	and	development	continues
! 32

!

!

APPENDIX – C

DJI Phantom 2 Vision+ Manufacturer’s User Manual

http://download.djiinnovations.com/downloads/phant

om_2/en/PHANTOM2_User_Manual_v1.4_en.pdf
! 33

APPENDIX – D

 DJI Phantom 3 Manufacturer’s User Manual 

http://download.djiinnovations.com/downloads/phantom_3/en/Pha

ntom_3_Advanced_User_Manual_v1.2_en.pdf

!