August 21, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and 

Reform Act of 2012, 49 U.S.C. § 44701(f), and Part 11 of the Federal Aviation 

Regulations

Dear Sir or Madam:

On behalf of Pilot Training System (“PTS”), pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (the “Reform Act”) (“Section 333”), Subsection (f) of 49 U.S.C. § 

44701, and 14 C.F.R. Part 11, we request an exemption from the Federal Aviation 

Administration regulations listed below and discussed in Appendix A to allow PTS to conduct 

commercial operations with the DJI Phantom 2 Vision+ and Phantom 3 (these are old and new 

models of the same sUAS and will be referred to collectively as “Phantom”)1and the DJI Inspire 

1 (“Inspire”)2small unmanned aircraft systems (“sUAS”) for aerial photography and 

videography in connection with homeowner and private-property inspections,

3

and to conduct 

research and development operations to explore the use of sUAS to improve catastrophe 

response.

4

 

Conducting the requested sUAS operations — building and private property inspection and 

research and development — can be done safely in the National Airspace System (“NAS”) and is 

in the public interest for several reasons, which are detailed further herein and include: (1) 

removing safety risks associated with requiring people to access and inspect potentially

dangerous areas, including slippery or unstable roofs, (2) reducing the risks associated with 

performing inspections with manned aircraft, (3) reducing time required to complete inspections,

(4) improving the efficiency of PTS’s business operations.

 

1

The Phantom already has been approved for commercial use in similar contexts. See Exemption Nos. 11138, 

11153, 11189, 11191, 11195.

2

The Inspire is similar in form and function to the DJI Phantom but is equipped with more sophisticated safety 

features (explained below).

3

The FAA has granted similar exemptions. See Exemption 11175, 11293. 

4

The FAA has granted similar exemptions. See Exemption 11188, 11309.

Pilot Training System, LLC

4620 Frey St #318 | Madison, WI 53705 | tel 608.620.4315

Chris Johnson, PhD

ChrisJohnson@PilotTrainingSystem.com

 
August 21, 2015

Page 2

Applicant Information:

The name of the applicant: Pilot Training System, LLC

The primary contact for this application and company legal address is:

Chris Johnson Pilot Training System, LLC

Founder & CEO 4620 Frey St. #318

4620 Frey St. #318 Madison, WI 53705

Madison, WI 53705

Phone: (608) 620-4315

Exemptions Requested

PTS requests exemptions from the following regulations:

14 C.F.R. Part 21, Subpart H;

14 C.F.R. 61.23(a) and (c);

14 C.F.R. 61.101(e)(4) and (5);

14 C.F.R. 61.113(a) and (b);

14 C.F.R. 61.315(a);

14 C.F.R. 91.7(a);

14 C.F.R. 91.119(c);

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);

14 C.F.R. 91.409(a)(1) and (2);

14 C.F.R. 91.417(a) and (b).
August 21, 2015

Page 3

Airworthiness of the sUAS

Both the Phantom and Inspire are quadcopters with gimbal-mounted cameras manufactured by 

DJI, a market leader in sUAS. The Phantom has been authorized to conduct commercial 

operations, including property inspections, under several Section 333 exemptions.5 The Inspire 

is DJI’s more advanced model with enhanced features.

Technical specifications for the Phantom and the Inspire are summarized in the table below. 

DJI Phantom DJI Inspire 

Size ~1 foot x 1 foot ~1 foot x 1 foot

Total Weight 1280 g (2.74 lbs) 2935 g (6.47 lbs)

Max Ascent Speed 6 m/s (12 knots) 5 m/s (10 knots)

Max Descent Speed 3 m/s (4 knots) 4 m/s (8 knots)

Max Flight Speed 16 m/s (29 knots) 22 m/s (43 knots)

Hover Accuracy:

Vertical / Horizontal 

.8 m (2.6’) / 2.5 m (8.2’) .5 m (1.6’) / 2.5 m (8.2’)

Controller Frequency

(Main Channel)

5.725-5.825 GHz

(FCC Compliant)

5.725-5.825 GHz

(FCC Compliant)

Controller Range 2000 m (.5 mi) 2 km (1.24 mi)

Communications 

(Second Channel)

2.4 GHz Wi-Fi 

(No Interference)

2.4 GHz Wi-Fi 

(No Interference)

DJI provides a comprehensive suite of training manuals, maintenance procedures and user’s 

guides for the Phantom and Inspire.6 Collectively, these documents will be referred to as 

“Operating Documents” for each sUAS model. Each pilot in command (PIC) will be required to 

comply with all maintenance and inspection procedures outlined in the Operating Documents. 

Operating Conditions

PTS requests an exemption subject to the conditions listed in Appendix B, which are similar to 

the operating conditions required for the FAA’s previous grants of exemptions under Section 

333.

 

5

See Exemption Nos. 11138, 11153, 11189, 11191, 11195.

6

The Phantom Operating Documents are available at http://www.dji.com/product/phantom-2-vision/download and 

http://www.dji.com/product/phantom-3/download and the Inspire Operating Documents are available at 

http://www.dji.com/product/inspire-1/download. 
August 21, 2015

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In accordance with the conditions approved in previous exemption grants, PTS is requesting 

authority to operate the Phantom and Inspire within visual line of sight and below 400 feet AGL,

except as provided by FAA Air Traffic Control via COA. These operating conditions, along 

with those listed in Appendix B, and the sUAS safety features listed below provide an equivalent 

level of safety. 

The following safety features are incorporated into both the Phantom and Inspire to ensure public 

safety and safe integration into the NAS:

 Stability Control with Auto-Takeoff and Auto-Land: The automated flight-control system 

can take off and land automatically, and the system autocorrects the aircraft’s position to 

adjust for environment disturbances such as wind. 

 Intelligent Orientation Control (IOC) and Inertial Measurement Unit (IMU): The built-in 

inertial sensor and barometric altimeter measures orientation and altitude, respectively, 

and communicates this data back to the controller.

 Live Map and Radar with Failsafe & Battery Warnings: The controller displays a live 

map and radar to show the aircraft’s recent flight path, heading, bearing and distance 

from “home” (a predetermined start location within the boundaries of the privately owned 

property) for complete situation awareness. It also illustrates battery status and lowbattery warnings with estimated time to return “home” to alert the PIC and ensure that the 

aircraft does not power down unexpectedly during use. 

 LED Flight Indicators: LED lights are mounted to the four rotor arms of each model to 

visually indicate aircraft orientation (attitude) and status of the flight control system, 

alerting the PIC of possible issues.

 Maximum Height and Radius Limits: Before beginning flight, the PIC may set a 

maximum altitude and distance that prevent the sUAS from exceeding altitude limits and 

distance from “home.” 

 Flight-limited Safety Zones: The sUAS flight software comes loaded with a list of 

restricted areas that are divided into one of three categories: category A, category B, or 

no fly. Category A areas include major international airports; Category B is comprised of 

smaller airports; and the no-fly zones are sensitive national security areas such as the 

White House. Each restricted area is comprised of a no-fly zone in which the sUAS

cannot be operated and a warning zone surrounding the no-fly zone in which the PIC is 

alerted to the sUAS’ proximity to a restricted area. Category A areas also include larger 

restricted-altitude zones in which the sUAS will only fly below a certain altitude. 
August 21, 2015

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Additional details regarding the safety zones can be found in the Phantom and Inspire 

manuals, attached as Appendices C and D. 

 Loss of link. The built-in GPS system that aids in stability control will automatically 

return the sUAS to “home” if communication between the controller and aircraft is lost. 

The sUAS will enter failsafe mode when connection with the controller is lost and will 

wait 3 seconds before either landing or returning to a home point to land, depending on 

whether the sUAS is operating in GPS mode. When in non-GPS mode, the sUAS

automatically lands after 3 seconds. In GPS mode, the aircraft automatically returns to 

home and lands. When flying back to home, the aircraft first will ascend to pre-set 

altitude to avoid obstacles. If the aircraft is above the pre-set altitude when loss of link 

occurs, it will fly directly back to the home point. 

 Loss of GPS. If a loss of GPS occurs, the PIC maintains positive control of the aircraft

and can either land the sUAS, hover in place until GPS is reacquired, or continue the 

flight. Additionally, the sUAS have the ability to abort a flight in the event of unpredicted

obstacles or emergencies. 

 Sense-and-Avoid. An aftermarket, sense-and-avoid system such as the eBumper4 (see 

http://www.panoptesuav.com/ebumper/) will be incorporated with the Phantom and the 

Inspire to allow the sUAS to maintain a safe standoff distance from obstacles, preventing 

inadvertent collision and greatly enhancing the safety of operations. 

Operator Requirements

As a condition to the grant of the exemptions, PTS will require that the PIC hold either an airline 

transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a 

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

District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC 

will 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.

At the conclusion of the training, the PIC will be able to safely operate the sUAS 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. This training will include the following, to the extent necessary for the operations:

1) Perform an appropriate number of flights with the specific sUAS to be operated to obtain 

proficiency.
August 21, 2015

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2) Successfully learn and demonstrate all relevant flight maneuvers in the Phantom 2 Vision 

Pilot Training Guide.

7

3) Study and be knowledgeable of all relevant sections of the model-specific User’s Manual, 

Safety Guidelines, Battery Safety Guidelines, and other relevant applicable manuals, 

updates, alerts, warnings and safety bulletins provided by DJI for the specific sUAS to be 

operated.

4) Study and be knowledgeable of all relevant sections of the Inspire 1 Maintenance Manual 

and the Guide to the Phantom 2 Vision & Vision+.8

5) Understand and demonstrate relevant evasive maneuvers outlined in the “Always be 

Prepared for the Worst” scenarios outlined in the Guide to the Phantom 2 Vision & 

Vision+ (applicable for operators of both the Phantom and the Inspire 1).

Training flights will be conducted over private or controlled-access property. Training flights 

will be logged for each PIC in training in a manner consistent with 14 CFR § 61.51(b). 

PTS respectfully submits that the operator qualifications take into account the operating 

conditions and characteristics of the sUAS. 

Public Interest

PTS respectfully submits that using sUAS to inspect roof tops in lieu of requiring its employees 

to visually inspect roofs and to conduct research and development into catastrophe support 

operations offers a net safety benefit and will achieve an enhanced level of safety, as mandated 

under Section 333(c) of the Reform Act. Approval of this application also will benefit the public 

interest by providing faster and more cost-efficient insurance claim processing and insurance 

underwriting.

Inspection operations over private property and catastrophe areas with conventional manned 

aircraft involve very heavy aircraft, transiting to the operational location, carrying significant 

 

7

Since the maneuvers are universal, the Phantom Training Guide will be used for training PICs on both the Inspire 

1 and the Phantom.

8

The Guide to the Phantom 2 Vision & Vision+ contains maintenance information and technical and safety-related 

guidelines. The Guide to the Phantom 2 Vision & Vision+ is available at 

https://www.dropbox.com/s/mv8d1hohc3mceym/DJI%20Phantom%20Vision%20Summary%20Guide.pdf?dl=0.
August 21, 2015

Page 7

quantities of combustible fuels, and a multi-person crew in piloting and observation roles. By 

contrast, the sUAS weigh less than seven pounds, use a battery for power, are carried to and from 

the area of activity, remove the need for airborne pilots and observers, and pose less risk to 

people and infrastructure on the ground, as well as other aircraft.

Additionally, no national security issue is raised by the grant of the requested exemption due to 

the sUAS’ small size and load-carrying capacity, as well as their operational limitations and lack

of flammable fuel. All PICs will have been screened by the Department of Homeland Security. 

The grant of the requested exemption is in the public interest based on the clear direction in 

Section 333 and 49 U.S.C. § 44701(f),

9

the equivalent and enhanced level of safety of the 

proposed operations, and the significant public benefit, and cost savings to be realized as a result 

of the use of sUAS for aerial inspections. Accordingly, the applicant respectfully requests that 

the FAA grant the requested exemption without delay.

Privacy Concerns

The proposed operations will take place only over private or controlled-access property and only 

after obtaining written or verbal consent from the individual who owns or controls the property 

or is the property owner’s authorized representative before each flight. No privacy issues are 

raised by this application.

Federal Register Summary

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the 

Federal Register, should the FAA determine that publication is needed:

Docket No.: No. FAA-2015-____

Petitioner: Pilot Training System, LLC

Section of 14 CFR: Part 21, Subpart H, § 61.23(a) and (c), § 61.101(e)(4) and (5), 

§ 61.113(a) and (b), § 61.315(a), § 91.7(a), § 91.119(c), § 91.121, § 91.151(a), 

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

 

9

Pursuant to 49 U.S.C. § 44701(f), the “Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of this title if the Administrator 

finds the exemption is in the public interest.”
August 21, 2015

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Description of Relief Sought: PTS seeks an exemption to conduct commercial 

building and private property inspection operations using a small unmanned aircraft (55 

pounds or less).

Sincerely,

Chris Johnson
August 21, 2015

Page 9

APPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY

SHOWINGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION

PTS requests an exemption from the following regulations as well as any additional regulations 

that the FAA deems necessary to the operation of the DJI Phantom Vision 2+ and DJI Inspire 1

sUAS:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

Tile 14, Part 21, Subpart H of the Code of Federal Regulations establishes the procedural 

requirements for the issuance of airworthiness certificates as required by § 91.203(a)(1). Given 

the size and weight of the aircraft, the operating conditions, design safety features, and the 

proposed conditions and limitations, it is unnecessary to go through the certificate of 

airworthiness process under Part 21 Subpart H to achieve or exceed current safety levels. Such

an exemption meets the requirements of an equivalent level of safety under Part 11 and Section 

333. Section 333 authorizes the FAA to exempt aircraft from the requirement for an 

airworthiness certificate, upon consideration of the size, weight, speed, operational capability, 

and proximity to airports and populated areas of the sUAS involved.

In this case, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, 

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 

Phantom and Inspire weigh 2.74 and 6.47 pounds, respectively. They will not carry a pilot, 

passenger or flammable fuel. They will operate exclusively within a controlled area predisclosed and in compliance with the conditions set forth herein. Unlike other civil manned

aircraft operations, operations under this exemption will be tightly controlled and monitored by 

the PIC and visual observer, pursuant to the conditions set forth in Appendix B, the Operating 

Documents, and local public safety requirements. The FAA will have advance notice of all 

operations, to the extent required, through the filing of NOTAMs. The lack of flammable fuel

and the fact that the aircraft are carried to the location and not flown there all establish an

equivalent level of safety. The sUAS provide at least an equivalent level of safety to that of such 

operations being conducted with conventional aircraft that would be orders-of-magnitude larger 

and would be carrying passengers, cargo, and flammable fuel. 

14 C.F.R. § 61.23 (a) & (c)

Section 61.23(a) requires a person exercising the privileges of a transport pilot certificate to hold 

a first-class medical certificate, the privileges of a commercial pilot certificate to hold a secondclass medical certificate, and the privileges of a private or recreational pilot certificate to hold a 
August 21, 2015

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third-class medical certificate. Section 61.23(c) requires a person to hold a medical certificate or 

U.S. driver’s license when exercising the privileges of a sport pilot certificate in a light-sport 

aircraft other than a glider or balloon.

The operations proposed herein will provide an equivalent level of safety by complying with the 

conditions and limitations of this exemption. The FAA has found that these conditions and 

limitations provide an equivalent level of safety in numerous previous exemptions, including but 

not limited to Exemptions 11213, 11252, 11275, 11277, and 11278.

14 C.F.R. § 61.101 (e)(4) & (5): Recreation Pilot Privilege and Limitations; 14 C.F.R. 

§ 61.315(a): What are the privileges and limits of my sport pilot certificate

Section 61.101(e)(4) prohibits a recreational pilot from acting as pilot in command of an aircraft 

for compensation or hire. Section 61.101(e)(5) prohibits a recreational pilot from acting as pilot 

in command of an aircraft in furtherance of a business. Section 61.315(a) authorizes persons 

holding a sport pilot certificate to act as pilot in command of a light-sport aircraft. 

As with previous Section 333 exemptions,10 an equivalent level of safety is established because 

(1) the aeronautical knowledge requirements that would be applicable to UAS operations for a 

recreational pilot and sport pilot certificate were substantially similar as those for a private pilot 

certificate; (2) holders of recreational and sport pilot certificates are subject to security screening 

by the Department of Homeland Security; and (3) risk was mitigated through conditions and 

limitations regarding PIC training. 

14 C.F.R. §§ 61.113(a) & (b): Commercial Pilot Privileges

Sections 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers, and cargo, the UAS are remotely controlled 

with no passengers or property of others on board. The area of operation is controlled and 

restricted, and all flights are planned and coordinated in advance as set forth in the Operating 

Documents. In conjunction with the PIC’s required training, the level of safety provided by the 

requirements included in the Operating Documents meets or exceeds that provided by a single 

individual holding a commercial pilot certificate operating a conventional aircraft. The proposed 

operations will achieve at least an equivalent level of safety.

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

 

10 See, e.g., Exemption Nos. 11310, 11311, 11312, 11313, 11315.
August 21, 2015

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Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an airworthy 

condition. No FAA standard exists for determining an aircraft’s airworthiness when an 

airworthiness certificate is not issued. As the FAA has done with previous exemption grants,11

airworthiness will be ensured and an equivalent level of safety will be achieved by compliance 

with the Operating Documents prior to every flight.

14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 

91.119(c) limits aircraft flying over areas other than congested areas to 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. 

Because the aerial photography and videography work must be accomplished at altitudes less 

than 500 feet AGL an exemption is required. 

The equivalent level of safety will be achieved given the sUAS’ size, weight, speed, and 

proposed operating conditions. sUAS operations will be conducted over private or controlledaccess property with consent granted by the property owner/controller or authorized 

representative prior to each operation. 

14 C.F.R. § 91.121: Altimeter Setting

Section 91.121 requires each person operating an aircraft to maintain cruising altitude by 

reference to an altimeter that is set “to the elevation of the departure airport or an appropriate 

altimeter setting available before departure.” The Phantom’s and Inspires’ Inertial Measurement 

Units have barometric altimeters, but they cannot be set to the elevation of the departure 

location. Rather, upon initialization, the sUAS calibrate their positions without user input and 

transmit a single altitude measurement to the ground station. Thus, an exemption is required. 

An equivalent level of safety will be achieved by the operator, pursuant to the Operating 

Documents, confirming the altitude of the launch site shown on the altitude indicator before 

flight.

 

11 Exemption Nos. 11156, 11158, 11159.
August 21, 2015

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

This regulation prohibits an individual from beginning “a flight in an airplane under VFR 

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

to the first point of intended landing and, assuming normal cruising speed – (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The Phantom and Inspire batteries provide approximately 25 and 18 minutes of powered flight, 

respectively. Without an exemption from 14 C.F.R. § 91.151, the sUAS flights would not be 

allowed. Given the limitations on its proposed operations, allowing the sUAS to operate without 

the required reserve fuel is reasonable and is consistent with prior exemptions.12 An equivalent 

level of safety will be achieved because operating the sUAS without 30 minutes of reserve fuel 

does not engender the type of risks that Section 91.151(a) was meant to prevent given the size 

and speed at which the sUAS operate. In the unlikely event that a sUAS should run out of 

battery power, it would simply land. Given the sUAS’s weight and construction material, the 

risks are less than contemplated by the current regulation. PTS will require the UAS to return 

home and land when the battery reaches 30% capacity. 

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

Inspections 

Section 91.405(a) requires that an aircraft operator or owner “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.” Section 91.407 similarly makes reference to requirements in Part 43. Section 

91.409(a)(2) requires an annual inspection for the issuance of an air worthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and 

records of approval of the aircraft for return to service. 

An equivalent level of safety will be achieved by complying with the Operating Documents 

maintenance and inspection requirements because the sUAS will carry no external payload, will

operate only in restricted predetermined areas. In addition, the PIC will ensure that the sUAS is 

in working order prior to initiating flight, perform required maintenance, and keep a log of any 

 

12 Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)); see 

also Exemptions 2689F, 5745, 10673 and 10808.
August 21, 2015

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maintenance that is performed. Moreover, the PIC is the person most familiar with the aircraft 

and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent 

level of safety. 
August 21, 2015

Page 14

APPENDIX B

PTS OPERATING LIMITATIONS

1) Operations authorized by the grant of exemption are limited to the following aircraft:

DJI Phantom 2 Vision+, Phantom 3 and DJI Inspire 1, which weigh 2.74, 2.74 and 

6.47 pounds, respectively.

2) The DJI Phantom 2 Vision+ and Phantom 3 shall not be flown at a speed exceeding 16

m/s. The DJJI Inspire 1 shall not be at flown at a speed exceeding 22 m/s.

3) The sUAS will not be operated at an altitude more than 400 feet above. All altitudes 

reported to ATC shall be in feet AGL.

4) The sUAS 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.

5) All PICs have the option to use a visual observer (VO), but VOs are not required. The 

sUAS will be equipped with sense-and-avoid technology to mitigate collisions, and 

the PIC will maintain VLOS at all times. Furthermore, standard operating procedures 

will dictate that the PIC remains heads up, maintain continuous eye contact with the 

sUAS while the sUAS is in transit, looking down at the controller ONLY while the 

sUAS is stationary. Given these technological and procedural enhancements, PTS has 

concluded from a formal safety assessment that full collision avoidance responsibility 

should reside solely with the PIC who will have the option of including a VO if 

necessary. The PIC will physically follow the sUAS from the ground level throughout 

the flight process, maintaining close, lateral quarters without creating a safety hazard 

or obstructing VLOS. The PIC will have positional priority over a VO at all times, and 

the responsibility for maintaining the most effective VLOS vantage point resides with 

the PIC to ensure safety and efficiency of operations, rendering a VO useless in most 

cases. Therefore, in the unlikely event that VLOS is lost by the PIC, it will likely also 

be lost for the VO, so PTS opines that including a VO is unnecessary and costly 

because the PIC is capable of maintaining VLOS at all times. Furthermore, in the 

unlikely event that the PIC inadvertently loses VLOS with the sUAS at any point 

during the operation, the PIC can utilize the auto-flight features that allow the sUAS to 

auto-hover, auto-land or return “home” automatically depending on the most suitable 

method required for regaining VLOS. 

6) The operating documents and this grant of exemption must be accessible during UAS 

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

between the conditions and limitations in the exemption and the procedures outlined in 
August 21, 2015

Page 15

the operating documents, the conditions and limitations in the exemption take 

precedence and must be followed. Otherwise, PTS must follow the procedures as 

outlined in its operating documents. PTS may update or revise its operating 

documents. It is PTS’s responsibility to track such revisions and present updated and 

revised documents to the Administrator upon request. PTS must also present updated 

and revised documents if it petitions for extension or amendment to this grant of 

exemption. 

7) Prior to each flight the PIC must inspect the sUAS to ensure that it is in a condition for 

safe flight. The PIC shall not operate the aircraft if the inspection reveals a condition 

that affects the safe operation of the sUAS until the necessary maintenance has been 

performed and the sUAS is found to be in a condition for safe flight. The Ground 

Control Station, if utilized, must be included in the preflight inspection. All 

maintenance and alternations must be properly documented in the aircraft records.

8) Any sUAS that has undergone maintenance or alterations that affect the sUAS 

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

must undergo a functional test flight in accordance with the Operator’s Manual. The 

PIC who conducts the functional test flight must make an entry in the aircraft records 

of the flight. The requirements and procedures for a functional test flight and aircraft 

record entry shall be included in the Operator’s Manual.

9) The pre-flight inspection must account for all discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the 

operating documents.

10) PTS must follow DJI’s aircraft/component, maintenance, overhaul, replacement, 

inspection, and life limit requirements.

11) PTS 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 person authorized to return the sUAS to service.

12) Each sUAS operated under this exemption must comply with all manufacturer Safety 

Bulletins.

13) The 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 Colombia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also 
August 21, 2015

Page 16

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) PTS may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the sUAS in a 

manner consistent with how the sUAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances 

from persons, vessels, vehicles and structures.13 PIC qualification flight hours and 

currency must be logged in a manner consistent with 14 C.F.R. § 61.51(b). The PIC 

must ensure that the VO is trained appropriately in order to fulfill his or her duties. A 

record of training and qualification must be documented and made available upon 

request by the Administrator. Flights for the purposes of training the operator’s PICs 

and VOs (training, proficiency, and experience-building), 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 are considered nonparticipants, 

and the PIC must operate the UA with appropriate distance from nonparticipants in 

accordance with these operating conditions.

15) 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”). 

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

16) The sUAS 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 PTS’s COA. The letter of agreement with 

the airport management must be made available to the Administrator upon request.

17) The sUAS 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 sUAS loses communications or loses its GPS signal, the sUAS must return to a 

pre-determined location within the private or controlled-access property.

 

13 Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy 

this requirement.
August 21, 2015

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

accordance with the Operator’s Manual.

20) The PIC will be 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 30% battery power remaining in 

accordance with the operating documents.

21) 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 the requested 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 

shall be as large as practicable.

23) The radio frequency spectrum used for operation and control of the sUAS must 

comply with Federal Communication (FCC) or other appropriate government 

oversight agency requirements.

24) The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the sUAS any time the aircraft is operating. 

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

official upon request.

25) The sUAS must remain clear and yield the right of way to all other manned operations 

and activities at all times. 

26) The sUAS may not be operated from any moving device or vehicle.

27) The sUAS may not be operated over congested or densely populated areas. 

28) Flight operations must be conducted at a safe distance from all nonparticipating 

persons, vessels, vehicles, structures, and public access roads. The metrics involved 

with calculating a safe distance will vary from operation to operation given the state of 

the environment (e.g., wind direction and strength) and the task requirements (e.g., the 

dimensions of the property being analyzed). Therefore, the responsibility for 

determining a safe distance from all nonparticipating persons, vessels, vehicles, 

structures, and public access roads will reside with the PIC.

Following review of previous summary grants in which the FAA has required a 500-

foot distance from nonparticipating persons, vessels, vehicles, structures, and public 
August 21, 2015

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access roads, PTS opines that a 500-foot stand-off distance is too restrictive for the 

type of sUAS to be flown. Most operations will be below 50 feet, so maintaining a 

500-foot horizontal distance from all other people or property is unreasonable and far 

too restrictive to be maintained. Our PICs are trained to detect conflict situations in 

which a potential collision could occur, and they will cease operations immediately. 

Furthermore, given the sense-and-avoid technology, the stabilization technology and 

the standard operating procedures detailed in #5 above, PTS opines that is it perfectly 

reasonable to place this judgement on a licensed pilot who has a vested interest in the 

safety of by standers and their personal property. 

29) Operations nearer than 500 feet to the PIC, VO, operator trainees or essential persons 

as defined in the operating documents are permitted if those operations do not present 

an undue hazard to those persons per § 91.119(a) as determined by the PIC.

30) All operations must be conducted over private or controlled-access property.

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

boundaries of the operational area as defined by the applicable COA shall 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. 
August 21, 2015

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