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UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________ ______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Ahmed Jamal Khan

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 3 Professional

UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on May 8, 2015

Ahmed Jamal Khan

848 N Rainbow Blvd. Suite 3618

Las Vegas, Nevada, 89107

714-721-7393
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TABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS.....................................................................................3

SUMMARY.............................................................................................................................4

.

INTRODUCTION AND INTERESTS OF PETITIONER.....................................................4

BACKGROUND.....................................................................................................................4

BASIS FOR PETITION..........................................................................................................5

NAME AND ADDRESS OF PETITIONER...............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH Ahmed Jamal Khan 

SEEKS EXEMPTION.................................................................................................8

THE EXTENT OF RELIEFAhmed Jamal Khan SEEKS AND THE REASON 

Ahmed Jamal Khan SEEKS THE RELIEF.............................................................11

THE REASONS WHY GRANTING Ahmed Jamal Khan’s REQUEST

WOULD BE IN THE PUBLIC INTEREST ............................................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

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

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........34

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS

AVAILABLE TO SUPPORT Ahmed Jamal Khan’s REQUEST.............................34

CONCLUSION......................................................................................................................35

APPENDICES............................................................................................36
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GLOSSARY OFABBREVIATIONS

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

GLONASS Global Navigation Satellite 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 Take-Off and Landing 
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SUMMARY

Ahmed Jamal Khan 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 to 

operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting 

aerial video and photography of construction sites, real estate and landscape over certain 

areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

Ahmed Jamal Khan provides his clients with formal expertise and strong knowledge 

in advanced photography and video solutions to allow an increase of efficiency, productivity 

and effectiveness in converting leads, prospecting, and solution selling. Ahmed Jamal Khan 

has over 8 years of experience in Digital/Analog and Video Photography Technology. He 

has over 10 years recreational and hobby experience in all aspects of aerial video and 

photography. The objective of Ahmed Jamal Khan’s aerial video and photography 

operations is to provide high quality imaging for a variety of commercial, public, and 

residential uses, specifically targeting:

Aerial film photography and production

Construction sites before, after and surveillance

Real-estate Appraisals and Marketing

Aerial acquisitions

Increase public awareness and safety
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BACKGROUND

Unmanned Aircraft Systems: DJI Phantom 3 professional UAS

Ahmed Jamal Khan seeks an exemption to operate the DJI system for compensation or hire 

within the (NAS). The DJI Phantom 3 professional is a vertical takeoff and landing (VTOL) 

Unmanned Aircraft (UA) with Global Navigation Satellite System (GLONASS) and Ground 

Control Station (GCS) utilizing a 2.400 GHz Remote Control system with a computer tablet. The 

DJI Phantom 3 professional has a maximum gross weight of approximately 2 pounds 13.2 ounces, 

while having a width of 24 inches and a height of 9 inches, and a maximum speed of 

approximately 31 knots. The DJI Phantom 3 professional (UA) is equipped with four main rotors;

utilizing Lithium Polymer batteries to power the electric motors.

The DJI Phantom 3 professional (UA) that will be operated by Ahmed Jamal Khan 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, Ahmed Jamal Khan, 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 3 professional (UA) 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, Ahmed Jamal Khan’s operation of the DJI Phantom 3 
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professional (UA) 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, Ahmed Jamal Khan 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.

Ahmed Jamal Khan submits that the requested relief is proper since an equivalent level of 

safety will be ensured. Ahmed Jamal Khan will use experienced personnel or technicians to 

perform maintenance, alterations, or preventive maintenance on the UAS's using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance Log, 

and DJI Phantom 3 Professional UAS Instruction Manual). Furthermore, Ahmed Jamal Khan will

document and maintain all maintenance records for the DJI Phantom 3 Professional UAS.

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

privileges and limitations: Pilot in command, is requested by Ahmed Jamal Khan 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 flighthour and current requirements, that the PIC is able to safely operate the DJI Phantom 3 

Professional UAS in a manner consistent with this exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Ahmed Jamal Khan seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Phantom 3 Professional (UAS) do not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. As such, Ahmed Jamal Khan submits that he will

ensure that the DJI Phantom 3 Professional (UAS) are in an airworthy condition, prior to every 

flight, by determining that the UAS are in compliance with the operating documents (i.e., Monthly 
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Maintenance Log, and DJI Phantom 3 Professional Instruction Manual), and that the aircraft are in 

a condition for safe flight.

Ahmed Jamal Khan also seeks an exemption from the requirements of Section 91.121, 

entitled Altimeter Settings, as the DJI Phantom 3 Professional UAS’s will not have a typical

barometric altimeter onboard. However, altitude information of the DJI Phantom 3 Professional

UAS will be provided to the PIC via Global Positioning System (GPS) equipment and Global 

Navigation Satellite System (GLONASS) and radio communications telemetry data link, which 

downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude 

information, combined with Ahmed Jamal Khan operation of the DJI Phantom 3 Professional UAS 

within visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121.

Additionally, Ahmed Jamal Khan seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. Ahmed Jamal Khan submits 

that safety will not be affected by operation of the DJI Phantom 3 Professional 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 minutes for the intended photo 

shoot and, assuming normal cruising speed, to fly after that for at least 2.5 minutes for recovery 

and landing.

In accordance with 14 C.F.R. § 11.81, Ahmed Jamal Khan 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: 

Ahmed Jamal Khan 

848 Rainbow Blvd., Suite 3681

Las Vegas, Nevada 714-721-7393

Email: JK6101@aol.com
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B. The Specific Sections of 14 C.F.R. From Which Ahmed Jamal Khan seeks

Exemption

1. Ahmed Jamal Khan 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.

(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.Ahmed Jamal Khan 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. Ahmed Jamal Khan 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;
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(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. Ahmed Jamal Khan Seeks Exemption From The Requirements Of Section91.151(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.

5. Ahmed Jamal Khan Seeks Exemption From The Requirement Of Section91.405(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. Ahmed Jamal Khan 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.
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7. Ahmed Jamal Khan 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. Ahmed Jamal Khan 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 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.
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(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.
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(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 Ahmed Jamal Khan Seeks And The Reason Ahmed Jamal Khan

Seeks The Relief.

1. Extent Of Relief Ahmed Jamal Khan Seeks And The Reason Ahmed Jamal Khan 

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, Ahmed Jamal Khan submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Phantom 3 

Professional UAS unless that PIC has met certain flight-hour and current requirements, 

demonstrating that the PIC is able to safely operate either the DJI Phantom 3 Professional 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. 
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Further, Ahmed Jamal Khan submits that all flights of the DJI Phantom 3 Professional 

UAS conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to Ahmed 

Jamal Khan’s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent of Relief Ahm e d J a ma l Kh a n Seeks And The Reason Ahmed Jamal Khan 

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 Ahmed Jamal Khan to determine that the DJI Phantom 3 Professional UAS's are 

in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the 

operating documents (i.e., the Monthly Maintenance Log and DJI Phantom 3 Professional 

manuals)

Ahmed Jamal Khan seeks the requested relief because the DJI Phantom 3 Professional UAS 

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

Therefore, Ahmed Jamal Khan will ensure that the DJI Phantom 3 Professional UAS are in 

airworthy condition based upon its compliance with the operating documents (i.e., Monthly 

Maintenance Log, and DJI Phantom 3 Professional 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 Ahmed Jamal Khan Seeks And The Reason Ahmed Jamal Khan 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 3 Professional UAS's, which utilize a barometric pressure sensor, 

GPS equipment, and a radio communications telemetry data link to downlink altitude information 
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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), Ahmed Jamal Khan seeks the requested relief because the DJI 

Phantom 3 Professional UAS 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 3 Professional 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 Ahmed Jamal Khan Seeks And The Reason Ahmed Jamal Khan 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 3 Professional 

UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules 

(VFR), for a total duration of 13 minutes to the first point of intended landing and, assuming 

normal cruising speed, to fly after that for at least 2.5 minutes. Ahmed Jamal Khan seeks the 

requested relief because without an exemption from Section 91.151(b), the flight time duration of 

the battery powered DJI Phantom 3 Professional UAS will severely constrain the practicality of 

any aerial video or still photo flight operations that Ahmed Jamal Khan proposes to conduct 

pursuant to this Petition.
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Significantly, as set forth below, the technical specifications of the DJI Phantom 3 

Professional UAS, the DJI Phantom 3 Professional UAS operating documents and Ahmed 

Jamal Khan’s proposed operating limitations, ensure that Ahmed Jamal Khan will safely 

operate the battery powered DJI Phantom 3 Professional 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 10 minutes to the first 

point of intended landing and, assuming normal cruising speed, to fly after that for at least

2.5 minutes.

5.Extent Of Relief Ahmed Jamal Khan Seeks And The Reason Ahmed Jamal Khan 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, Ahmed Jamal Khan requests relief from

these Sections because the DJI Phantom 3 Professional UAS do not require airworthiness 

certificates. As set forth more fully below, the DJI Phantom 3 Professional UAS's meet the 

conditions of FMRA Section 333 for operation without an airworthiness certificate.

Accordingly, Ahmed Jamal Khan will use trained technicians to perform maintenance, 

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

practices prescribed in the UAS operating documents (i.e., the Aerial Operations Manual, 

Monthly Maintenance Log, and DJI Phantom 3 Professional UAS Instruction Manual). 

Furthermore, Ahmed Jamal Khan will document and maintain all maintenance records for the 

DJI Phantom 3 Professional UAS.
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D. The Reasons Why Granting Ahmed Jamal Khan Request Would Be In The Interest;

That Is How It Would Benefit The Public As A Whole

Granting the present Petition will further the public interest by allowing Ahmed Jamal 

Khan 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 3 Professional UAS will decrease congestion of 

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

benefits of Ahmed Jamal Khan’s proposed operation of the DJI Phantom 3 Professional UAS

will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 3 Professional 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 the DJI Phantom 3 Professional 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 3 Professional UAS do not require an airport to takeoff or land. Likewise, a reduction 

of manned aircraft conducting aerial video and photography missions would result in fewer 

aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, 

and landing phases of flight operations.
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2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 3 

Professional UAS.

Conducting aerial acquisitions with the DJI Phantom 3 Professional UAS 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 3 

Professional UAS 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 Phantom 3 Professional UAS, while reducing the carbon footprint

of aerial acquisitions, also eliminates noise pollution, as the UA's are propelled by battery 

powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 3 Professional UAS 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 3 Professional UAS (weighing approximately 2 pounds 12 ounces and respectively, at

their maximum gross weights with 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, and a fuel capacity of 180 gallons

3. Performing Aerial Video and Photography Operations With The DJI Phantom 

Professional UAS's Will Benefit The Economy.
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In addition to being safe and efficient, the DJI Phantom 3 Professional UAS are also an 

economical alternative to using manned aircraft to conduct similar aerial operations. As such, 

operation of the DJI Phantom 3 Professional UAS will allow United States based companies, 

like Ahmed Jamal Khan’s 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 3 Professional UAS is one such technology that

not only allows companies greater operational flexibility compared to manned aircraft, but

provides such flexibility without the high operational cost of a traditional manned aircraft.

By operating the DJI Phantom 3 Professional UAS, companies such as Ahmed Jamal 

Khan’s 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 3 Professional UAS, 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, Ahmed Jamal Khan’s proposed operation of the DJI Phantom 3 Professional UAS 

will not implicate any privacy issues. Specifically, the Phantom 3 Professional UAS will be 

operated only in compliance with operating documents (i.e.Aerial Operations Manual, 

Monthly Maintenance Log, and the DJI Phantom 3 Professional UAS Instruction Manual's) 

which requires property owner involvement as well as local law enforcement notification, and 
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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 Ahmed Jamal Khan Seeks Exemption.

1. Reasons Why The DJI Phantom 3 Professional 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, Ahmed Jamal Khan’s operation of the DJI Phantom 3 

Professional UAS 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

(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 

operations 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 
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system, the Secretary shall establish requirements for the safe operation of such aircraft

systems in the national airspace system.

In seeking this exemption, Ahmed Jamal Khan submits that the DJI Phantom 3 

Professional UAS UAS's can operate safely in the NAS pursuant to FMRA Section 333, as 

demonstrated by: (a) the characteristics of the DJI Phantom 3 Professional UAS; (b) the pilot

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

a. The Specifications Of The DJI Phantom 3 Professional UAS Demonstrate Its Safe 

Characteristics.

The Phantom 3 Professional UAS 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 3 Professional UAS.

The technical specifications of the DJI Phantom 3 Professional UAS are set forth by the 

DJI Phantom 3 Professional UAS Specifications and Data Sheet, attached hereto as 

Exhibit A and B.

ii. The DJI Phantom 3 Professional UAS Autonomous Flight And Navigation Modes 

Enable The UAS's To Remain Within A Defined Operational Area.

The Phantom 3 Professional UAS may be operated in both manual and fully 

autonomous flight modes. The DJI Phantom 3 Professional may be operated in manual

flight mode only. A complete description of the flight and navigational modes of the 

DJI Phantom 3 Professional UAS is provided at pages 23-32 of the DJI Phantom 3 

Professional UAS and pages 8 & 11.

Iii. The Phantom 3 Professional UAS are Designed For Automatic Return To Home Point 

Or Hover In The Event Of Loss Of The Control Link Or Navigation.
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When the Control Link is lost, the DJI Phantom 3 Professional UAS will remain 

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

Professional due not reacquire controls 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 3 Professional UAS are set

forth at pages 22 through 32 DJI Phantom 3 Professional UAS User Manuals, attached 

hereto as Exhibit C.

iv. The DJI Phantom 3 Professional UAS and Its Operation.

A complete description of the operation and specifications of the DJI Phantom 3 

Professional and flight control software is provided at pages 22 through 32 of the DJI

Phantom 3 Professional User Manual. The DJI Phantom 3 Professional UAS User 

Manuals are attached hereto as Exhibits D.

b. Flight Operations Of DJI Phantom 3 Professional UAS are Limited To The Line Of 

Sight Of A Certificated Pilot in Command With A Safety Observer.

Ahmed Jamal Khan 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 3 

Professional UAS. Additionally, a safety observer will assist all pilots during flight time.

c. Flights Of DJI Phantom 3 Professional UAS Will Be Conducted Pursuant To Specific 

Operating Limitations.

In seeking this exemption, Ahmed Jamal Khan proposes to commercially operate DJI 

Phantom 3 Professional UAS for the special purpose of conducting aerial video and 

photography over certain areas of United States, pursuant to the following specific operating 

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

aircraft described in the operating documents, rotorcraft UAS's weighing less than 55 

pounds maximum gross weight: DJI Phantom 3 Professional UAS Unmanned Aircraft

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

petition to amend this grant.

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

purpose of aerial video and photography.

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

4. The UA must be operated at an altitude of no more than 400 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 UA's 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 
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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 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 UAS's operated under this exemption must comply with all manufacturer

Safety Bulletins.

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

action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current thirdclass medical certificate.
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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 

PIC's 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.

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 UAS 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.
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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 (NNumber) 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 UAS must comply with the Federal Communications Commission (FCC) 

or other appropriate government oversight agency requirements.

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

the PIC at the Ground Control Station of the UAS any time the UAS is operating. These 

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

upon request.

29. The UAS 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 UAS 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).
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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.

Ahmed Jamal Khan 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 3 Professional 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 3 

Professional UAS in a manner consistent with the exemption, including evasive and emergency 

maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

Considering Ahmed Jamal Khan’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 3 Professional UAS, Ahmed 

Jamal Khan submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for Ahmed Jamal 

Khan’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 
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Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 

11150, 11153, 11156, 11158, 11159, 11160, 11161). Ahmed Jamal Khan will not allow any PIC 

to operate the DJI Phantom 3 Professional UAS unless that PIC has demonstrated, by meeting 

minimum flight hour requirements of the DJI Phantom 3 Professional UAS training and 

currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Professional 

UAS or 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 Ahmed Jamal Khan’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 
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rather than additive; i.e. 5 hours make and model time may be 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 experiencebuilding flights the PIC is required to operate the UA with appropriate distances in 

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

Accordingly, Ahmed Jamal Khan will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 3 Professional 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 3 Professional 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, Ahmed Jamal Khan will ensure that the DJI Phantom 3 
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Professional 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 3 Professional 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 Ahmed Jamal Khan’s operation of the DJI Phantom 3 Professional UAS within 

visual line of sight, at or below 400 feet AGL, will ensure a level of safety equivalent to 

Section 91.121. The altitude information will be generated by GPS equipment installed on 

board the aircraft. Prior to each flight, a zero altitude initiation point is automatically 

established by the UAS's 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.
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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 3 

Professional UAS; (2) the limitations on the proposed flight operations; and (3) the location of 

the proposed flight operations. Accordingly, Ahmed Jamal Khan will ensure that he will safely 

operate the battery powered DJI Phantom 3 Professional UAS during daylight hours in VFR 

conditions, with enough battery power to fly for a total duration of 10 minutes to the first point

of intended landing and, assuming normal cruising speed, to fly after that for at least 2.5 

minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 3 

Professional UAS the limitations on the proposed flight operations and the 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 3 Professional provide 

audible and visual warnings to the PIC at the GCS when the UA's 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 3 Professional UAS 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).
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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, Ahmed Jamal Khan 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 because Ahmed Jamal Khan will use trained technicians to perform maintenance, 

alterations, or preventive maintenance on the UAS's using the methods, techniques, and 

practices prescribed in the operating documents i.e., the Operations Manual, Monthly 

Maintenance Log, and DJI Phantom 3 Professional UAS Instruction Manual. Furthermore, 

Ahmed Jamal Khan will document and maintain all maintenance records for the DJI Phantom 

3 Professional UAS.

Since the DJI Phantom 3 Professional UAS will be inspected as prescribed by the 

operating documents,Ahmed Jamal Khan 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 3 Professional User Manuals are attached hereto as Exhibit C and D; a 

copy of the DJI Phantom 3 Professional UAS Maintenance LOG is attached hereto as Exhibit

E. Likewise, the exemption sought will not adversely affect safety because Ahmed Jamal Khan

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 3 Professional UAS will be performed by trained technicians. Maintenance will be 

documented and maintained utilizing the monthly maintenance log.
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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 Ahmed Jamal Khan’s proposed operating limitations, the operating 

documents, and the technical aspects of the DJI Phantom 3 Professional UAS, Ahmed Jamal 

Khan 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, Ahmed Jamal Khan requests that

the FAA prescribe special conditions for the intended operation of the DJI Phantom 3 

Professional UAS, which contain such safety standards that the
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administrator finds necessary to establish a level of safety equivalent to that established by 14 

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

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

conditions will permit safe operation of the UA's 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 3 Professional UAS, 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, it

may prescribe 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.
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Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may 

prescribe special conditions for Ahmed Jamal Khan’s intended operation of the DJI Phantom 3 

Professional UAS, 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 Ahmed Jamal Khan Seeks Exemption:

Ahmed Jamal Khan 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 Ahmed Jamal Khan Seeks:

This exemption will permit Ahmed Jamal Khan to commercially operate an Unmanned

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

certain areas of the United States.

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

Jamal Khan’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, Ahmed Jamal Khan 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.
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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, Ahmed Jamal Khan will operate the DJI Phantom 3 Professional UAS

safely in the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose 

a threat to national security.
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CONCLUSION

As set forth herein, Ahmed Jamal Khan 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 3 Professional UAS 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 FAAAdministrator 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 Ahmed Jamal Khan to safely, efficiently, and 

economically operate the DJI Phantom 3 Professional UAS commercially within the NAS.

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

Modernization and Reform Act of 2012, Section 333, Ahmed Jamal Khan 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 Ahmed Jamal Khan to operate the DJI 

Phantom 3 Professional UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: May 08, 2015

Respectfully submitted,

Ahmed Jamal Khan

848 N Rainbow Blvd. Suite 3618

Las Vegas, Nevada 89107

714-721-7393 

Email – JK6101@aol.com
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APPENDICES:

A – DJI Phantom 3 Professional Data Sheet

B – DJI Phantom 3 Professional User Manuel

C - Monthly Maintenance Log
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APPENDIX –A

DJI Phantom 3 Professional UAS Data Sheet

Ahmed Jamal Khan only utilizes safe and reliable UAS's. DJI is an industry leader in small UAS 

production. DJI UAS's 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 and Radio Control Transmitter. 

1.1 DJI Phantom 3 Professional UAS

1.1.1 Aircraft - DJI Phantom 3 Professional UAS

1.1.1.1 Batteries – DJI Power 4480 mAH LiPo Battery

1.1.1.2 Weight (Battery & Propellers Included) –2 lbs 12 oz (1280g)

1.1.1.3 Hover Accuracy–Vertical: +/- 10m; Horizontal: +/- 1m

1.1.1.4 Max Tilt Angel -35deg

1.1.1.5 Max Ascent/Descent Speed – 5m/s / 3 m/s

1.1.1.6 Max Flight Speed –16m/s (NOT RECOMMENDED)

1.1.2 Gimbal

1.1.2.1 DJI Phantom 3 Axis Gimbal

1.1.2.2 Control Accuracy - ±0.03deg

1.1.2.3 Controller – 3Axis (pitch, roll, yaw)

1.1.2.5 Pitch - Controllable -90deg to 0deg

1.1.2.6 Horizon – Automatic

1.1.3 Camera

1.1.3.1 Sony EXMOR 1/2.3”

1.1.3.2 FOV 94° 20 mm
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1.1.3.3 Effective pixels: 12.4 M

1.1.3.4 Operating Temperature Range - 0°C to 40°C

1.1.4 Transmitter

1.1.4.1 Lightbridge

1.1.4.2 Operating Frequency 2.400GHz – 2.4835GHz

1.1.4.3 Communication Distance (unobstructed) FCC Compliance 2000m

1.1.4.4 Transmitter Power FCC Compliance: 20dBm CE:16 dBm

1.1.4.5 Battery 6000mAh Li-lon 2S

1.1.5.6 Operating Temperature - 0°C- 40°C

1.1.5 Range Extender

1.1.5.1 Lightbridge

1.1.5.2 Operating Frequency 2.400GHz – 2.4835GHz

1.1.5.3 Communication Distance (unobstructed) FCC Compliance 2000m

1.1.5.4 Transmitter Power FCC Compliance: 20dBm CE:16 dBm

1.1.5.5 Battery 6000mAh Li-lon 2S

1.1.5.6 Operating Temperature - 0°C- 40°C
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APPENDIX –B

DJI Phantom 3 Professional User Manuel
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APPENDIX – C

Monthly Maintenance Log

Ahmed Jamal Khan

Monthly Maintenance and Repair Log

Aircraft: 

Hours:

Date:

Date Issue

Discovered

Date Issue

Resolved

Issue Description/Maintenance

Conducted

Repair/Maintenance

Performed By

Airframe

Motors

Propellers

Flight Control

Update

Gimbal

Misc.
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