UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

Narrate Studios LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF 

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

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

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

OPERATION OF DJI PHANTOM 2 VISION+ UNMANNED AIRCRAFT 

SYSTEMS

PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 

(PUBLIC LAW 112-95)

Submitted on March 31, 2015 

Andrew W. Fischer

Narrate Studios LLC

211 North 1st Street #240

Minneapolis, MN 55401

Tel: (320)491-7280

Email: awfisch@gmail.com
2

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 NARRATE STUDIOS 

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

THE EXTENT OF RELIEF NARRATE STUDIOS LLC SEEKS AND THE 

REASON NARRATE STUDIOS LLC SEEKS THE RELIEF.........................11 

THE REASONS WHY GRANTING NARRATE STUDIOS LLC’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 NARRATE STUDIOS LLC’S REQUEST.........34 

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

APPENDICES........................................................................................37
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation 

GCS Ground Control Station 

GPS Global Positioning System

LOL Loss of Link 

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

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

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing
4

SUMMARY

Andrew W. Fischer 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 

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

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

special events, film sets, and landscape over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER

Narrate Studios LLC provides its clients with the highest quality digital content for 

use in their commercial, personal, and non-profit multimedia projects. Narrate LLC has 

established itself as a technological innovator in experiential multimedia and is recognized 

as a leader in providing a quality product. Narrate LLC has over 2 years recreational/hobby 

experience in all aspects of aerial video and photography. The objective of Narrate Studios 

LLC aerial video and photography operations is to provide high quality imaging for a 

variety of commercial, public, and residential uses, specifically targeting:

• Aerial event photography

• Aerial event filming

• Film production

• Aerial location scouting and safety inspection

• Increase public knowledge of UAS and promote safe UAS operations.

BACKGROUND
5

Unmanned Aircraft Systems: DJI Phantom 2 Vision UAS

Narrate Studios LLC seeks an exemption to operate DJI systems for compensation 

or hire within the NAS. The DJI Phantom 2 Vision+ is a vertical takeoff and landing 

(VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing 

electronic tablet or smart phone systems. The DJI Phantom 2 Vision+ has a maximum 

gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches 

width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. 

The DJI Phantom 2 Vision+ UA is equipped with four main rotors; driven by Lithium 

Polymer battery powered electric motors. 

The DJI Phantom 2 Vision+ UA that will be operated by Narrate Studios LLC will 

be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 

C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, 

Identification and Registration Marking.

BASIS FOR PETITION

Petitioner, Narrate Studios LLC, pursuant to the provisions of the Federal Aviation 

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

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

petitions the Administrator to commercially operate the DJI Phantom 2 Vision UAS 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, Narrate Studios LLC operation of DJI 
6

Phantom 2 Vision+ UAS 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, Narrate Studios LLC requests relief from Sections 91.405(a), 

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

requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

Narrate Studios LLC submits that the requested relief is proper since an equivalent 

level of safety will be ensured. Narrate Studios LLC will use experienced personnel or 

technicians to perform maintenance, alterations, or preventive maintenance on the UASs 

using the methods, techniques, and practices prescribed in the operating documents (i.e., 

Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). Furthermore, 

Narrate Studios LLC will document and maintain all maintenance records for the DJI 

Phantom 2 Vision+ UAS. 

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

privileges and limitations: Pilot in command, is requested by Narrate Studios LLC to the 

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

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

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

DJI Phantom 2 Vision+ UAS in a manner consistent with this exemption, including 

evasive and emergency maneuvers and maintaining appropriate distances from people, 

vessels, vehicles and structures. 

Narrate Studios LLC seeks relief from Section 91.7(a), entitled Civil aircraft 

airworthiness, because the DJI Phantom 2 Vision+ UAS do not require an airworthiness 

certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Narrate Studios LLC
7

submits that it will ensure that the DJI Phantom 2 Vision+ UAS are in an airworthy 

condition, prior to every flight, by determining that the UASs are in compliance with the 

operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

Instruction Manual), and that the aircraft are in a condition for safe flight. 

Narrate Studios LLC also seeks an exemption from the requirements of Section 

91.121, entitled Altimeter Settings, as the DJI Phantom 2 Vision+ UA will not have a 

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

Vision+ UA will be provided to the PIC via Global Positioning System (GPS) equipment 

and radio communications telemetry data link, which downlinks from the UA to the GCS 

for active monitoring of the flight path. This altitude information, combined with Narrate 

Studios LLC’s operation of the DJI Phantom 2 Vision+ UAS within visual line of sight, at 

or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. 

Additionally, Narrate Studios LLC seeks an exemption from the requirements of 

Section 91.151(b), entitled Fuel requirements for flight in VFR conditions. Narrate Studios 

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

UA during daylight hours in visual meteorological conditions (VMC) under visual flight 

rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 

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

after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, Narrate Studios 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:
8

Andrew Fischer

Narrate Studios LLC

211 North 1st Street #240

Minneapolis, MN 55401

Tel: (320)491-7280

Email: awfisch@gmail.com

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

Exemption. 

1. Narrate Studios LLC Seeks Exemption From The Requirements Of Section 

61.113(a) And (b). 

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

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

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

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

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

(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. Narrate Studios LLC Seeks Exemption From The Requirements Of Section 

91.7(a).

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

following: 

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

3. Narrate Studios LLC Exemption From The Requirements Of Section 

91.121. 

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

part: 
9

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

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

when operating--

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

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

within 100 nautical miles of the aircraft; 

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

this section, the current reported altimeter setting of an appropriate 

available station; or 

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

departure airport or an appropriate altimeter setting available before 

departure. 

4. Narrate Studios LLC Exemption From The Requirements Of Section 

91.151(b).

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

(b), states the following: 

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

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

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

fly after that for at least 20 minutes. 

5. Narrate Studios LLC Exemption From The Requirement Of Section 

91.405(a).

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between required inspections, except as provided in paragraph (c) of this 

section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 

6. Narrate Studios LLC 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: 
10

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

maintenance, rebuilding, or alteration unless--

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

43.7 of this chapter[.] 

7. Narrate Studios LLC Seeks Exemption From The Requirements Of Sections 

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

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

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

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

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

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

chapter; or 

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

with part 21 of this chapter. 

8. Narrate Studios LLC 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. 
11

(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. 

(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 Narrate Studios LLC Seeks And The Reason Narrate Studios 

LLC Seeks The Relief. 

1. Extent Of Relief Narrate Studios LLC Seeks And The Reason Narrate 

Studios LLC Seeks Relief From Section 61.113(a) And (b). 
12

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, Narrate Studios LLC submits that an equivalent 

level of safety will be maintained because no PIC will be allowed to operate the DJI 

Phantom 2 Vision+ UAS UA unless that PIC has met certain flight-hour and currency 

requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 

Vision+ UAS in a manner consistent with the operations specifications as described in this 

exemption, including evasive and emergency maneuvers, as well as maintaining 

appropriate distances from people, vessels, vehicles and structures.

Further, Narrate Studios LLC submits that all flights of the DJI Phantom 2 Vision+ 

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

Narrate Studios LLC business; and (2) will not carry passengers or property for 

compensation or hire. 

2. Extent Of Relief Narrate Studios LLC Seeks And The Narrate Studios LLC

Seeks Relief From Section 91.7(a). 
13

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

extent required to allow Narrate Studios LLC to determine that the DJI Phantom 2 Vision+ 

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

compliance with the operating documents (i.e., the Narrate Studios LLC Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). 

Narrate Studios LLC seeks the requested relief because the DJI Phantom 2 Vision+ 

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

Subpart H. Therefore, Narrate Studios LLC will ensure that the DJI Phantom 2 Vision+ 

UAS are in airworthy condition based upon its compliance with the operating documents 

(i.e., Monthly Maintenance Log, and DJI Phantom 2 Vision+ 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 Narrate Studios LLC Seeks And The Reason Narrate 

Studios LLC Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow 

flight operations of the DJI Phantom 2 Vision+ UAS, which utilize a barometric pressure 

sensor, GPS equipment, and a radio communications telemetry data link to downlink 

altitude information from the UA to the PIC at the ground control station (GCS). Since the 

FAA requires that any altitude information concerning UAS operations be reported to air 

traffic control (ATC) in feet above ground level (AGL), Narrate Studios LLC seeks the 

requested relief because the DJI Phantom 2 Vision+ UA’s altimeter may be set on the 

ground to zero feet AGL, rather than the local barometric pressure or field altitude, before 

each flight. 
14

Considering the limited altitude of the proposed operations, relief from 14 CFR 

91.121 is sought to the extent necessary to comply with the applicable conditions and 

limitations stated below. As more fully set forth herein, an equivalent level of safety will 

be maintained since the DJI Phantom 2 Vision+ 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 Narrate Studios LLC Seeks And The Narrate Studios LLC

Relief From Section 91.151(b). 

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

conditions, is requested to the extent required to allow flights of the battery powered DJI 

Phantom 2 Vision+ UAs during daylight hours in visual meteorological conditions (VMC), 

under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point of 

intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 

minutes. Narrate Studios LLC seeks the requested relief because without an exemption 

from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 

Vision+ UA will severely constrain the practicality of any aerial video or still photo flight 

operations that Narrate Studios proposes to conduct pursuant to this Petition. 

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

Vision+ UAS, the DJI Phantom 2 Vision+ operating documents, and Narrate Studios 

LLC’s proposed operating limitations, ensure that Narrate Studios LLC will safely operate 

the battery powered DJI Phantom 2 Vision+ UAs during daylight hours in visual 

meteorological conditions (VMC), under visual flight rules (VFR), with enough battery 
15

power to fly for a total duration of 13.5 minutes to the first point of intended landing and, 

assuming normal cruising speed, to fly after that for at least 4.5 minutes.

5. Extent Of Relief Narrate Studios LLC Seeks And The Reason Narrate 

Studios LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), And 91.417(a) & (b). 

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

only apply to aircraft with an airworthiness certificate, Narrate Studios LLC requests relief 

from these Sections because the DJI Phantom 2 Vision+ UAS does not require 

airworthiness certificates. As set forth more fully below, the DJI Phantom 2 Vision+ UAS

meets the conditions of FMRA Section 333 for operation without an airworthiness 

certificate. Accordingly, Narrate Studios LLC will use trained technicians to perform 

maintenance, alterations, or preventive maintenance on the UASs using the methods, 

techniques, and practices prescribed in the UAS operating documents (i.e., the Narrate 

Studios Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

Instruction Manual). Furthermore, Narrate Studios will document and maintain all 

maintenance records for the DJI Phantom 2 Vision+ UAS. 

D. The Reasons Why Granting Narrate Studios LLC Request Would Be In The 

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

Granting the present Petition will further the public interest by allowing Narrate 

Studios LLC to safely, efficiently, and economically perform aerial video and photography 

of special events, film sets, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 Vision+ UAS will decrease congestion of 

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

benefits of Narrate Studios LLC’s proposed operation of the DJI Phantom 2 Vision+ UAS 

will be realized without implicating any privacy issues. 
16

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

The DJI Phantom 2 Vision+ UA are battery powered and serve as a safe, efficient, 

and economical alternative to the manned aircraft traditionally utilized to obtain aerial 

imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, 

an exemption allowing the use of a DJI Phantom 2 Vision+ UAS would reduce the amount 

of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety 

of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, 

congestion around airports caused by arriving and departing aircraft will be reduced. The 

DJI Phantom 2 Vision+ UA 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.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI 

Phantom 2 Vision+ UAS. 

Conducting aerial acquisitions with the DJI Phantom 2 Vision+ 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 2 Vision+ 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 DJI Phantom 2 Vision+ UA, while reducing the carbon footprint 
17

of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery 

powered electric motors, rather than an internal combustion engine. 

By using the DJI Phantom 2 Vision+ 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 2 Vision+ UA (weighing approximately 2 pounds 11 ounces and 

6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 

inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and 

with no fuel on board), has less physical potential for collateral damage to life and property 

on the ground, and in the air, compared to the manned aircraft that typically conduct 

similar operations (weighing approximately 6,000 pounds with a wingspan of 

approximately 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI 

Phantom 2 Vision+ UAS Will Benefit The Economy. 

In addition to being safe and efficient, the DJI Phantom 2 Vision+ is also an 

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

such, operation of the DJI Phantom 2 Vision+ UAS will allow United States based 

companies, like Narrate Studios LLC, to remain competitive and contribute to growth of 

the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental 

Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. 

owned and operated companies must adopt new and alternative technology in order to 

remain competitive. Operating the battery powered DJI Phantom 2 Vision+ UAS is one 

such technology that not only allows companies greater operational flexibility compared to 
18

manned aircraft, but provides such flexibility without the high operational cost of a 

traditional manned aircraft. 

By operating the DJI Phantom 2 Vision+ UAS, companies such as Narrate Studios 

LLC, can remain competitive and profitable, and therefore, provide greater job stability to 

employees and contractors, which will ultimately contribute to growth of the U.S. 

economy. Improved financial performance of U.S. companies, through commercial use of 

the DJI Phantom 2 Vision+ 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, Narrate Studios LLC proposed operation of the DJI Phantom 2 Vision+ UAS will 

not implicate any privacy issues. Specifically, the DJI Phantom 2 Vision+ UAS will be 

operated only in compliance with operating documents (i.e., the Narrate Studios LLC

Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ 

Instruction Manual) which requires property owner involvement as well as local law 

enforcement notification, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119. 

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

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

Provided By The Rule From Which Narrate Studios LLC Seeks Exemption. 

1. Reasons Why The DJI Phantom 2 Vision+ UA Meet The Conditions Of The 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 
19

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

with the unmanned aircraft and its operation, Narrate Studios LLC operation of the DJI 

Phantom 2 Vision+ 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 operation within visual line of sight do not create 

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

threat to national security; and

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

airworthiness certification under section 44704 of title 49, United States 

Code, is required for the operation of unmanned aircraft systems 

identified under paragraph (1). 

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

section that certain unmanned aircraft systems may operate safely in the 

national airspace system, the Secretary shall establish requirements for the safe 

operation of such aircraft systems in the national airspace system. 

In seeking this exemption, Narrate Studios LLC submits that the DJI Phantom 2 

Vision+ UAS can operate safely in the NAS pursuant to FMRA Section 333, as 
20

demonstrated by: (a) the characteristics of the DJI Phantom 2 Vision+ UAS; (b) the pilot 

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

a. The Specifications Of The DJI Phantom 2 Vision+ UAS Demonstrate Its 

Safe Characteristics.

The DJI Phantom 2 Vision+ UAS does not create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security considering its size, weight, 

speed, and operational capability. 

i. Technical Specifications Of The DJI Phantom 2 Vision+ UAS. 

The technical specifications of the DJI Phantom 2 Vision+ UAS is set forth by the 

DJI Phantom 2 Vision+ Specifications and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Phantom 2 Vision+ UAS Autonomous Flight And

Navigation Modes Enable The UAS To Remain Within A Defined 

Operational Area. 

The DJI Phantom 2 Vision+ UAS may be operated in both manual and fully 

autonomous flight modes. A complete description of the flight and navigational modes of 

the DJI Phantom 2 Vision+ UAS is provided at pages 25-35 of the DJI Phantom 2 Vision+ 

User Manual, attached hereto as Exhibit B. 

iii. The DJI Phantom 2 Vision+ UAS Are Designed For Automatic 

Return To Home Point Or Hover In The Event Of Loss Of The 

Control Link Or Navigation. 

When the Control Link is lost, the DJI Phantom 2 Vision+ UA will remain 

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

UA does not reacquire control link data from the GCS, the UA will assume that the 

Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via 

GPS, and will descend to the takeoff position and shutdown. 
21

A complete description of the Failsafe Functions of the DJI Phantom 2 Vision+ 

UAS are set forth at pages 27 through 29 of the DJI Phantom 2 Vision+ User Manual, 

attached hereto as B.

iv. The DJI Phantom 2 Vision+ GCS And Its Operation.

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

Vision+ GCS and flight control software is provided at pages 32 through 43 of the DJI 

Phantom 2 Vision+ User Manual. DJI Phantom 2 Vision+ User Manual is attached hereto 

as Exhibit B.

b. Flight Operations Of DJI Phantom 2 Vision+ UAS Are Limited To The 

Line Of Sight Of A Certificated Pilot in Command With A Safety 

Observer. 

Narrate Studios LLC will only utilize certificated pilots who possess a current and 

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

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

c. Flights Of DJI Phantom 2 Vision+ UAS Will Be Conducted Pursuant To 

Specific Operating Limitations. 

In seeking this exemption, proposes to commercially operate DJI Phantom 2 

Vision+ UAS for the special purpose of conducting aerial video and photography over 

certain areas of United States, pursuant to the following specific operating limitations:

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

aircraft described in the operating documents, rotorcraft UASs weighing less 

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

Aircraft System. 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 UAs may not be flown at an indicated airspeed exceeding 20 knots.
22

4. The UA must be operated at an altitude of no more than 500 feet above ground 

level (AGL), as indicated by the procedures specified in the operating 

documents unless a special request is made and approved by ATC. All altitudes 

reported to ATC must be in feet AGL. 

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

times. This requires the PIC to be able to use human vision unaided by any 

device other than corrective lenses, as specified on the PIC’s FAA-issued airman 

medical certificate. 

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not 

permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy 

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

The SO and PIC must be able to communicate verbally at all times. Electronic 

messaging or texting is not permitted during flight operations. The PIC must be 

designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing 

and avoiding other air traffic and other ground based obstacles/obstructions and 

is not permitted to operate the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during 

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

discrepancy exists between the conditions and limitations contained in the grant 

of exemption and the procedures outlined in the operating documents, the 

conditions and limitations contained in the grant of exemption take precedence 

and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its 

operating documents. It is the operator’s responsibility to track such revisions 

and present updated and revised documents to the Administrator upon request. 

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

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

that any update or revision would affect the basis upon which the FAA granted 

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

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

questions arise regarding updates or revisions to the operating documents. 

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

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

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 
23

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records.

11. Any UAS that has undergone maintenance or alterations that affect the UAS 

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

component, must undergo a functional test flight. The PIC who conducts the 

functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment, not already covered in the 

relevant sections of the operating documents. 

13. The operator must follow the UAS manufacturer’s aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping 

requirements, in accordance with the operating documents. Maintenance, 

inspection, alterations, and status of replacement/overhaul component parts 

must be noted in the aircraft records, including total time in service, description 

of work accomplished, and the signature of the authorized person returning the 

UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer 

Safety Bulletins. 

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

corrective action taken against discrepancies discovered between inspections. 

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

third- class medical certificate. 

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

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

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

exemption, including evasive and emergency maneuvers and maintaining 

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

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

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

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

only be conducted during dedicated training sessions. During training, 

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

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

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

91.119. 

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 
24

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

rules (SVFR) are not authorized. 

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

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

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

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

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

the Administrator upon request. 

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

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

PIC. 

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

in accordance with the operating documents. 

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

emergencies in accordance with the operating documents. 

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

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

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

remaining. 

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

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

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

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

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

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

altitude level and potential transponder requirements. 

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

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

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

Subpart C. Markings must be as large as practicable. 

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

and control of the UA must comply with the Federal Communications 

Commission (FCC) or other appropriate government oversight agency 

requirements. 

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. 
25

29. The UA must remain clear and yield the right of way to all manned aviation 

operations and activities at all times. 

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

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

persons (persons other than the PIC, SO, operator trainees or essential persons), 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating 

persons from the UA and/or debris in the event of an accident. The 

operator must ensure that nonparticipating persons remain under such 

protection. If a situation arises where nonparticipating persons leave such 

protection and are within 500 feet of the UA, flight operations must cease 

immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted 

permission and the PIC has made a safety assessment of the risk of 

operating closer to those objects and determined that it does not present 

an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons 

do not present an undue hazard to those persons per § 91.119(a). 

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

with permission from the land owner/controller or authorized representative. 

Permission from land owner/controller or authorized representative will be 

obtained for each flight to be conducted.

33. Any incident, accident, or flight operation that transgresses the lateral or 

vertical boundaries of the operational area as defined by the applicable COA 

must be reported to the FAA's UAS Integration Office (AFS-80) within 24 

hours. Accidents must be reported to the National Transportation Safety Board 

(NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) 

And (b) Would Not Adversely Affect Safety.

Narrate Studios LLC submits that the equivalent level of safety established by 

Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the

DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting minimum 

flight-hour and currency requirements, that the PIC is able to safely operate the DJI 
26

Phantom 2 Vision+ UAS in a manner consistent with the exemption, including evasive and 

emergency maneuvers and maintaining appropriate distances from people, vessels, 

vehicles and structures. 

Considering Narrate Studios LLC proposed area of operations, and the operating 

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

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

the airmanship skills necessary to safely operate the DJI Phantom 2 Vision+ UAS, Narrate 

Studios LLC submits that the additional manned airmanship experience of a commercially 

certificated pilot would not correlate to the airmanship skills necessary for Narrate Studios 

LLC specific proposed flight operations. 

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

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

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

11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161). 

Narrate Studios LLC will not allow any PIC to operate the DJI Phantom 2 Vision+ 

UAS unless that PIC has demonstrated, by meeting minimum flight-hour requirements or 

the DJI Phantom 2 Vision+ UAS training and currency requirements, that the PIC is able 

to safely operate the DJI Phantom 2 Vision+ UAS in a manner consistent with this 

exemption, including evasive and emergency maneuvers and maintaining appropriate 

distances from people, vessels, vehicles and structures. 

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

with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a 

minimum of 5 hours of those hours as a UAS pilot operating the same make and model of 
27

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 Narrate Studios LLC proposed operations. The 

Administrator has held that prior documented flight experience that was obtained in 

compliance with applicable regulations would ensure safe operations, stating as follows: 

In Exemption No. 11062, the FAA required that prior to conducting operations for 

the purpose of motion picture filming (or similar operations), the PIC must have 

accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of 

total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS 

pilot with a multi-rotor UAS. Prior to operations under Exemption No. 11062, the 

PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot 

operating the same make and model of UAS to be used for operations under the 

exemption. For clarification, the FAA considers these minimum hour requirements 

to be inclusive rather than additive; i.e. 5 hours make and model time may be 

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

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

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

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

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

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

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

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

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

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

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

distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15. 

Accordingly, Narrate Studios will ensure safe operations by not allowing any PIC 

to operate the DJI Phantom 2 Vision+ UAS unless that PIC has demonstrated, by meeting 

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

DJI Phantom 2 Vision+ UAS in a manner consistent with the exemption, including evasive 
28

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, Narrate Studios LLC will ensure that the DJI Phantom 2 

Vision+ UAS is in an airworthy condition based upon the UAS’s compliance with its 

operating documents and as stated in the conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific 

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

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

11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

4. Reasons Why An Exemption From The Requirements Of Section 91.121 

Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained 

because the altitude information of the DJI Phantom 2 Vision+ UA 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 Narrate Studios LLC’s operation of the DJI Phantom 2 

Vision+ UA within visual line of sight, at or below 500 feet AGL, will ensure a level of 

safety equivalent to Section 91.121. The altitude information will be generated by GPS 

equipment installed onboard the aircraft. Prior to each flight, a zero altitude initiation point 

is automatically established by the UASs at ground level. 

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

circumstances similar, in all material respects, to those presented herein (e.g. Exemption 
29

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

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

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

Would Not Adversely Affect Safety.

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

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

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

location of the proposed flight operations. Accordingly, Narrate Studios will ensure that it 

will safely operate the battery powered DJI Phantom 2 Vision+ UA during daylight hours 

in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to 

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

at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Phantom 2 

Vision+ UAS; the limitations on the proposed flight operations; and the location of the 

proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 Vision+ UAS

provide audible and visual warnings to the PIC at the GCS when the UAs experiences low 

battery voltage, the first warning occurring at approximately 33% remaining battery power, 

and again at approximately 10% remaining battery power. At the critically low battery 

level, the DJI Phantom Vision+ 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 
30

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

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

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

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

11157, 11158, 11159, 11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections

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

Not Adversely Affect Safety. 

In seeking this exemption, Narrate Studios LLC submits that the equivalent level of 

safety with regard to the regulatory maintenance and alteration requirements established by 

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

because Narrate Studios LLC will use trained technicians to perform maintenance, 

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

practices prescribed in the operating documents (i.e., the Narrate Studios Aerial Operations 

Manual, Monthly Maintenance Log, and DJI Phantom 2 Vision+ Instruction Manual). 

Furthermore, Narrate Studios LLC will document and maintain all maintenance records for 

the DJI Phantom 2 Vision+ UAS. 

Since the DJI Phantom 2 Vision+ UAS will be inspected as prescribed by the 

operating documents, Narrate Studios LLC will maintain the equivalent level of safety 

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

Phantom 2 Vision+ User Manuals are attached hereto as Exhibit B; a copy of the DJI 

Phantom 2 Vision+ UAS Maintenance LOG is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because Narrate 

Studios LLC will use trained technicians to perform maintenance, alterations or preventive 
31

maintenance on the UAS using the methods, techniques, and practices prescribed by the 

operating documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety 

established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the 

DJI Phantom 2 Vision+ UAS will be performed by trained technicians. Maintenance will 

be documented and maintained utilizing the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is 

not adversely affected when the technical characteristics and operating limitations of the 

UAS are considered. 

In consideration of Narrate Studios LLC proposed operating limitations, the 

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

Narrate Studios LLC submits that safety will not be adversely affected by granting 

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

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

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

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

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

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

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

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

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

Vision+ UAS, which contain such safety standards that the Administrator finds necessary 
32

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 UAs for the limited purpose of conducting aerial video and photography 

over certain areas of the United States for compensation or hire. FMRA Section 333 sets 

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

NAS or the public, or otherwise pose a threat to national security; and further, provides the 

authority for such UAS to operate without airworthiness certification in accordance with 

any requirements that must be established for the safe operation of the UAS in the NAS. 

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

§ 21.16, for operation of the DJI Phantom 2 Vision+ 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, he prescribes special conditions and amendments thereto for the product. 

The special conditions are issued in accordance with Part 11 of this chapter and 

contain such safety standards for the aircraft, aircraft engine or propeller as the 

FAA finds necessary to establish a level of safety equivalent to that established in 

the regulations. 

See 14 C.F.R. § 21.16.

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

may prescribe special conditions for Leading Edge’s intended operation of the DJI 

Phantom 2 Vision+ 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, 
33

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 Narrate Studios LLC Seeks Exemption: 

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

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

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

A Brief Description Of The Nature Of The Exemption Narrate Studios LLC 

Seeks: 

This exemption will permit Narrate Studios LLC to commercially operate an 

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

photography over certain areas of the United States.

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

Studios LLC 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, Narrate Studios LLC request for exemption 

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

set forth above. 

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

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

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

certification. 

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

Vision+ UASs safely in the NAS, without creating a hazard to users of the NAS, or the 

public, or otherwise pose a threat to national security. 

CONCLUSION
34

As set forth herein, Narrate Studios LLC seeks an exemption pursuant to 14 C.F.R. 

§ 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), 

which will permit safe operation of the DJI Phantom 2 Vision+ 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 FAA 

Administrator will be fulfilling the Congressional mandate of the FAA Modernization and 

Reform Act of 2012, while also advancing the interests of the public, by allowing Narrate 

Studios LLC to safely, efficiently, and economically operate the DJI Phantom 2 Vision+ 

UAS commercially within the NAS. 

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

Modernization and Reform Act of 2012, Section 333, Narrate Studios LLC respectfully 

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

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

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

Phantom 2 Vision+ UAS commercially for the purpose of conducting aerial video and 

photography over certain areas of the United States.

Dated: March 31, 2015

Respectfully submitted,

Andrew Fischer

_________________________

Andrew W. Fischer

Narrate Studios LLC

211 North 1st Street #240

Minneapolis, MN 55401

Tel: (320)491-7280

Email: awfisch@gmail.com
35

Appendices:

A – DJI Phantom 2 Vision+ Specifications Data Sheet

B – DJI Phantom 2 Vision+ Manufacturer’s User Manual

C – Monthly Maintenance Log

APPENDIX – A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

Narrate Studios LLC only utilizes safe and reliable UASs. DJI is an industry leader in 

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

user to set parameters which will not allow flight into controlled airspace. Parameters can 

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

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

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

devices)

1.1 DJI Phantom 2 Vision+ 

1.1.1 Aircraft

1.1.1.1 Supported Battery – DJI 5200mAH LiPo Battery

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

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

1.1.1.4 Max Yaw Angular Velocity - 2000/s

1.1.1.5 Max Tilt Angel - 350

1.1.1.6 Max Ascent Speed – 6m/s

1.1.1.7 Max Descent Speed – 2m/s

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

1.1.2 Gimbal

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

1.1.2.2 Control Accuracy - ±0.030

1.1.2.3 Controllable Range – Pitch: -900 - 00

1.1.2.4 Maximum Angular Speed – Pitch: 900/s

1.1.3 Camera

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

1.1.3.2 Sensor Size – 1/2.3”

1.1.3.3 Effective Pixels – 14M

1.1.3.4 Resolution – 4384x3288

4.1.3.5 HD Video Recording – 1080p30 & 720p

4.1.3.6 Recording Field of View - 1100/850

1.1.4 Transmitter

1.1.4.1 Operating Frequency – 5.728GHz – 5.85GHz
36

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

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

1.1.4.4 Transmitter Power – FCC Compliance: 100mW

1.1.4.5 Working Voltage – 120mA@3.7V

1.1.5 Range Extender

1.1.5.1 Operating Frequency – 2412-2462MHz

1.1.5.2 Communication Distance (unobstructed) – 500-700m

1.1.5.3 Transmitter Power – 20dBm

1.1.5.4 Power Consumption – 2W
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APPENDIX – B

DJI Phantom 2 Vision+ Manufacturer’s User Manual
38

APPENDIX – C

Andrew W. Fischer

Narrate Studios LLC

211 North 1st Street #240

Minneapolis, MN 55401

Tel: (320)491-7280

Email: awfisch@gmail.com

month:_________(year:________

UAS$#:$___________ Date(Issue(

Discovered

Date(Issue(

Addressed

Software(Updates

Airframe(

Engines

Propellers

Camera(Gimbal

Landing(Gear

Vibration(Dampening

Other:

MONTHLY$MAINTENANCE$LOG

Issue(Description(&(Maintenance(Conducted Maintenance(Performed(By:(((

Print(&(Sign
39